IR 05000352/1978011
| ML19261C224 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/23/1979 |
| From: | Todd Jackson, Shanabaky M, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19261C218 | List: |
| References | |
| 50-352-78-11, NUDOCS 7903200214 | |
| Download: ML19261C224 (9) | |
Text
.
.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-352/78-11 Report No. Rn 157/7A_n7 50-352 Docket No. gn 1g, CPPR-106 A2 License No. CPPR-107 Priority Category A2
--
Licensee:
Philadelohia Electric Company 2301 Market Street Philadelohia. Pennsylvania 19101 Facility Name:
Limerick Generating Station (LGS)
Inspection at:
Limerick Generating Station and PEco Corporate Offices Inspection conducted:
December 11-14, 1978 Inspectors:
- .
/ 23 /9 70 M. M.
h nbak, Radiatieti Speciaiist
' datd si'gn'ed AC
$09t-03f79 T.(f.UJackson, Radiation Specialist (Intern)
date signed
'
n_ M.
n1ncH (rn-nni date signed m,
!
//23 79 Approved by:
D. -y dj. P. 'Stohr, Chief, Environmental and date signed 5pecial Projects Section, FF&MS Branch Inspection Summary:
Inspection on December 11-14, 1978 (Combined Reoort Nos. 50-352/78-11 and 50-353/78-07 Areas Inspected:
Routine, unannounced inspection of environmental protection program (construction phase), including: observations made by the inspector of the existing environmental conditions at the construction site and the surrounding environment; determination of the implementation status of the Construction Permit requirements; verifying the implementation of the Construction Permit requirements; management controls and procedures for implementing the environmental protection program during site preparation and construction. The inspec. tion involved 88 inspector-hours onsite by 2 NRC inspectors.
Results: Of the three areas inspected, no items of noncompliance were found in two areas; one apparent item of noncompliance was found in one area (Deficiency-failure to control an untreated wastewater discharge from the site - Paragraph 5.b).
(352/78-11-01 and 353/78-07-01)
Region I Form 12 (Rev. April 77)
.
.
DETAILS 1.
Persons Contacted
- W. Tate, Civil Staff, Bechtel
- H. D. Foster, PFQCE, Bechtel
- A. Arch, LSME, Bechtel
- J. Givin, Project Supt., Bechtel
- V. Johnson, Sub Contract Engr., Bechtel
- R. Sheibley, Constr. Eng., PECo
- R. Sevo, LSQAE, Bechtel
- W. King, Const. Engr., PECo
- J. Nelson, Pollution Control Engr., RMC
- B. Dragon, QAE, Bechtel
- J. Blevins, QAE, Bechtel
- E. R. Klassing, PQAE, Bechtel
- D. T. Clohecy, PEQAE, PECo
- A. Graham, Job Manager, J. E. Brenneman Co.
- H. R. Walters, QA, PECo
- C. H. Rush, Supervising Engr., Environmental Branch, PECo
- A. J. Marie, Group Leader, Radiation & Meteorology,.PECo
- J. W. Cratic, Engineer, Environmental Branch, PEco
- E. J. Purdy, Environmental Branch, PECo A. J. Pizzola, Engineer, Environmental Branch, PECo R. F. Costello, Engineer, Environmental Branch, PECo J. M. Bechtel, Shift Supervisor, PEco R. K. Young, Plant Operator, PECo
-
E. Pelly, First Class Operator, PECo
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (352/77-09-01 and 353/77-09-01):
Failure to prevent wastewater from reaching the natural water bodies in the area. The inspector examined the facilities constructed at the cement batch plant and found them to be as described in the licensee's letter dated October 17, 1977. The inspector had no further questions in this are.
.
(Closed) Unresolved (352/77-09-02 and 353/77-09-02):
Spoil Area Reclamation. The inspector determined that action was initiated by the licensee to grade and reseed the spoil areas both east a-d west of Longview Road. The inspector noted that parts of the spoil areas are still in use and that corrective action in this area was not fully completed (Details 5.c).
3.
General The inspection consisted of a review of the licensee's environmental protection program including measures taken to protect the environ-ment during site preparation and construction. The licensee's cur-rent requirements in this area are listed in Sections 3.C and 3.E of the Construction Permits, (CPPR-106 and CPPR-107), and described in the application and hearing records. The environmental protection requirements are sumarized in Section 4.5 of the Final Environmental Statement (FES). The inspection included a review of the licensee's records, procedures and audits, interviews with licensee personnel and observations made by the inspector.
4.
Determination of Implementation Status of the Construction Permit Requirements The inspector discussed with the licensee the implementation status of the Construction Permit requirements.
The licensee stated that the environmental protection program conducted during the construc-tion phase of LGS is in conformance with the NRC and other Federal and State requirements. The inspector noted that the environmental protection program was implemented through site instructions, pro-cedures and a checklist. The licensee stated that in addition to the documented measures taken to protect the environment and to minimize the environmental impact of the construction operations, all the construction operations are under constant observations and management supervision. The inspector also noted that two internal audits, C-130 (7/24/78) and C-106 (12/27-29/77), had been performed by the licensee during the past year.
ihe inspector noted that clearing operations for construction of the Schuylkill River facilities (intake structure and cooling tower blowdown diffuser) had begun in late 1977 and construction itself began in early 197.
.
5.
Verification of the Construction Permit Requirements a.
Site Tour Upon arrival at the Limerick Generating Station (LGS) construc-tion site, the inspector toured the area and examined the pre-vailing environmental conditions at the site and the surround-ing environment. The inspector observed the environmental conditions at the Schuylkill River waterfront, the temporary spoil area, soil condition and vegetation at the site, dusting level at the site roads and liquid effluent treatment and discharges.
One item of noncompliance discussed in Paragraph 5.b and one unresolved item discussed in Paragraph 5.c were identified.
b.
Effluent Treatment and Discharges The inspector noted that, other than effluent discharges at the construction areas for the Schuylkill River facilities, all the wastewater resulting from the construction operation was collected and treated prior to discharge. The water was channeled through the site storm drain system to a settling basin where it was treated and analyzed for the required water quality parameters. The inspector reviewed the settling basin operation records and noted that the settling basin was operated in accordance with Procedure No. 8031-FSC-38 and the water quality of discharges was in conformance to the NPDES Permit No. Pa 0023314 requirements.
The inspector examined the environmental conditions around the construction activities associated with the Schuylkill River facilities. On the morning of December 12, 1978, the inspector noted that turbid water was being discharged directly into the Schuylkill river from within the cofferdam surrounding the intake structure construction. Later on the same day, a sample was taken of the water being pumped out of the cofferdam and turbidity was found by the licensee to be 225 JTU.
It was also determined by the licensee that the pump being used for this discharge was operating at approximately 300 gpm.
The inspector also found that turbid water was being pumped out of the trench being dug for placement of the cooling tower blowdown
.
.
.
diffuser pipe and directly into Possum Hollow Run.
The in-spector stated that failure to prevent untreated we.stewater from reaching the natural water bodies in the area was in noncompliance with Sections 3.E.1 and 3.E.9 of the Construc-tion Permits, which reference the Commonwealth of Pennsylvania Water Quality Management Permit No. 4671202 and the Final Environmental Statement. The inspector also noted that the subcontractor responsible for construction of the Schuylkill River facilities had received several notifications from the licensee that the subcontractor was operating in violation of existing regulations regarding wastewater discharge.
The licensee's Audit Report C-130 (7/24/78) first identified the problem of this subcontractor's improper discharges to the Schuylkill River. The licensee's Corrective Action Report (CAR) No. 232 (7/27/78) was issued because of "high turbidity water (being) pumped into the Schuylkill", followed by CAR No.
246(October 26, 1978) which described concrete wastewater being pumped into the Schuylkill River from the Schuylkill River facilities' construction area. The licensee stated that the subcontractor had on several occasions been advised to stop such discharges and use a temporary settling basin con-structed along the cofferdam for treatment of wastewater.
The inspector examined this settling basin and it appeared to have never been used.
Also on the morning of December 12, 1978, the inspector noted that turbid water was being pumped out of the trench being dug for placement of the cooling tower blowdown water diffuser and into the Possum Hollow Run. This stream flows directly into the Schuylkill River.
The inspector stated that turbid water discharges to the Schuylkill River and Possum Hollow Run were in noncompliance with the NRC regulatory requirements.
(352/78-11-01 and 353/78-07-01)
c.
Spoil Areas and Solid Waste Disposal The inspector noted through site observations and records review, that solid wastes, including lunch type debris and construction scrap materials, were collected in specially marked containers and transported offsite by a private con-tractor to a licensed disposal area.
Scrap metal was sold to a private contractor.
No excessive refuse was observed at the site or at the site boundarie.
.
_
T e inspector noted that e.xcavated material from the trench b,ang dug for placement of the cooling tower blowdown pipes was being placed on the bar.k of Possum Hollow Run.
Most ex-cavated material was placed on the side of the trench away from Possum Hollow Run but enough was placed on the bank it-self to increase the stream's turbidity and for material to wash down the bank and into the stream. The licensee stated that as corrective action, bales of hay would be placed on the bank of Possum Hollow Run to prevent erosion and to minimize run off turbidity in the affected area. The licensee also stated that no more material would be placed on the bank of Possum Hollow Run and that the material now there would be removed within one month and used as backfill in the diffuser trench.
The inspector stated that until the material is removed from the bank of Possum Hollow Run as stated, this item is considered unresolved.
(352/78-11-02 and 353/78-07-02)
The inspector noted that all other excavated material was re-moved from the site and dispcsed of at two designated spoil areas. The inspector toured the spoil areas and examined the soil condition at the spoil areas and the surrounding environ-ment.
The spoil areas east and west of Long View Road were both ex-amined and it was noted that both areas had been partially graded and seeded in accordance with Section a.5.1.a of the FES, with the exception of those areas curren:ty in o;.tive use.
This item was left as unresolved follov.ing the 1977 inspection (352/77-09-02 and 353/77-09-02) and is now closed.
Because appropriate soil reclamation was incomplete at the time of this inspection, the spoil areas reclamation will be re-examined during a subsequent inspection as an inspector followup item.
(352/78-11-03 and 353/78-07-03)
d.
Base-Line Studies The inspector reviewed with the licensee the meteorological and radiological environmental surveillance studies.
The in-spector noted that the meteorological instrumentation was cal-ibrated according to written approved procedures and in con-formance with Regulatory Guide 1.2.
The inspector examined both the ensite and offsite meteoro-logical towers.
The single remaining remote monitoring station at Limerick airport was also examined. The licensee stated that as of yet there had been no further determination whether or not collection of meteorological data would be stopped because of the delayed construction schedule.
The licensee stated that the environmental radiological moni-toring program had been suspended due to the delayed construction schedule.
No samples are presently being taken. The licensee expects to resume the environmental radiological sampling and analysis program again in advance of two years prior to the anticipated date for plant start-up.
This will ensure at least 2 years of pre-operational data in addition to the data already collected. The licensee also stated that as of January 1979, the biological data collection program is also expected to be suspended and to be resumed again along with the radiological program at least 2 years prior to the plant start-up date.
6.
Management Controls and Program Implementation Procedures The inspector reviewed the licensee management controls as related to the environmental protection program - construction phase.
The inspector noted that the program was implemented through approved procedures and checklists.
The inspector reviewed the licensee program records and noted that the results of the site observations were documented and reported to management.
Areas reviewed included the following:
a.
Noise Level Measurements b.
Erosion and Sedimentation Control c.
Dust Control d.
Sanitary Waste Removal e.
Accidential Spill Control f.
Weed Control and Reseeding g.
Holding Pond Operations
h.
Yard Lighting 1.
Sanitary Facility Alarm j.
Dewatering k.
Oil Separator Inspections 1.
Trash Removal and Assurance of No Onsite Burning m.
Construction Pollut'on Control Schedule Review The licensee's system of Corrective Action Reports (CAR) was dis-cussed. The licensee stated that a CAR is issued whenever the Pollution Control Engineer determines that corrective action is necessary. The inspector noted that for some CAR's, specifically CAR Nos. 144, 165, 191, 195, 196, it took up to 4 months for correc-tive action to be completed. The licensee stated that new CAR's which reference the originals are issued if there is a backlog of CAR's which have not been closed out. The inspector also noted that some closed CAR's stated " Corrective Action taken" but pro-vided no details about the action.
The licensee stated that this area would be checked to see if there was a reason for slow response to some CAR's and that future corrective actions will be described in detail.
The inspector noted that CAR No. 214, classified as significant by the licensee, was issued because a " spill of untreated waste entered the holding pond; samples taken".
No results of these samples were reported by the licensee.
Determination of further action regarding this spill required that the results of the samples be evaluated before any discharges from the holding pond can be made to Possum Hollow Run. The inspector stated that the results of the above samples will be examined in a subsequent inspection as an inspector followup item.
(352/78-11-04 and 353/78-07-04)
7.
Unresolved Items Unresolved items are matters about which more information is re-quired in order to ascertain whether they are acceptable items, items of noncompliance or deviations.
One unresolved item was disclosed during this inspection.
This item is discussed in Para-graph.
8.
Exit Interviews The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on December 13, 1978, at the Limerick construction site and on December 14,1978, at the PECo corporate offices in Philadelphia. The inspector sumarized the purpose and the scope of the inspection findings.
.
J