IR 05000352/1980009
| ML19332A939 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/07/1980 |
| From: | Bores R, Todd Jackson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19332A932 | List: |
| References | |
| 50-352-80-09, 50-352-80-9, 50-353-80-08, 50-353-80-8, NUDOCS 8009190056 | |
| Download: ML19332A939 (9) | |
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V U. S. NUCLEAR REGULATORY COMISSION 0FFICE OF INSPECTION AND ENFORCEMENT j
REGION I
50-352/80-09 Report No.
50-353/80-08 50-352
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Docket No.
50-353
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CPPR-106 A2 License No.
CPPR-107 Priority Category A2 i
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Licensee:
Philadelphia Electric Company (PECO)
2301 thrket Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generating Station (LGS)
Inspection At:
Limerick, Pennsylvania Inspection Conducted:
May 22-27,- 1980 Inspectors:
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, Radiation Specialist (intern)
' date date Approved by:
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[d R-"I BoMs, Chief, Environmental & Special date ProjectsSection,FF&MSBranch Inspection Summary:
Inspection on May 22-27, 1980 (Combined Report Nos. 50-352/80-09; 50-353/80-08)
Areas inspected:
Routine, unannounced inspection of environmental protection program (constructionphase), 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; verification of the implementation of the Construction Permit require-ments; management controls and procedures for implementing the environmental pro-tection program during site preparation and construction.
The inspection involved 24 inspector-hours onsite by one regionally based inspector.
Results:
Of the three areas inspected, no items of noncompliance were found in two areas; one item of noncompliance (Deficiency - failure to control an untreated wastewater discharge from the. site - Paragraph 5.b(2)) was found iri one area.
B009190 @
Region I' Form 167 (August 1979).
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DETAILS 1.
Individuals contacted
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J. M. Corcoran, Field QA Branch Head, LGS, PEC0
- D. A. DiPaolo, QAE, PECO
- D. T. Clohecy, QAE, PECO
- M. S. Haninond, Construction Engineer, PECO
- J. Doering, Staff Engineer, PECO E. Purdy, Group' Leader, Biological and Thermal Monitoring, PECO A.' Marie, Group Leader, Radiological and Meteorological Programs, PECO H. Hansell, Engineer, PECO J. M. Bechtel, Shift Supervisor, PECO C. Hartman, Plant Operator, PEC0 J. Helaugh, Tester, PECO.
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G. C. Blinebury, Tester, PECO
- R. Leingang, APFE, Bechtel
- E. R. Klossin, PQAE, Bechtel
- J. Fallon, APFQCE, Bechtel
- J. J. Curci, QAE, Bechtel
- R. Stockholm, Assistant Field Engineer, Bechtel
- M. G. Tokolies, QAE, Bechtel
- B. A. Dragon, QAE, Bechtel
- P. R. Dunn, QAE, Bechtel
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (0 pen) Inspector Followup Item (352/78-11-03 and 353/78-07-03) Spoils Area Reclamation: The inspector examined the spoils areas east and west of Longview Road and noted that some areas were graded.
The licensee stated that they planned to seed these areas before June 13,1980 (Details 5.c).
This item will be re-examined at a subsequent inspection.
(Closed) Inspector Followup Item (352/78-11-04 and 353/78-07-04) Spill of Untreated Waste:
Followup of the licensee's Corrective Action Report (CAR)
- 214 showed that the " spill of untreated waste" was a spill of raw sewage, some of wnich entered Possum Hollow Run, which flows into the-Schuylkill River. The inspector stated that this was in noncompliance with regulatory requirements (352/80-09-01; 353/80-08-01) (Details 5.b(2).
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General The inspection consisted of a review of the licensee's environmental pro-tection program including measures taken to protect the environment during
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site. preparation and construction.
The licensee's current requirements in this area are listed in Sections 3.C and 3.E of the Construction Permits, (CPPR-106 and CPPR-107), and & cribed in the application and hearing m
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1 records.
The environmental protection requirements are summarized in i
Section 4.5 of the Final Environmental Statement (FES).
The inspection
included a review of the licensee's records, procedures and audits, inter-views with licensee personnel and observations made by the inspector.
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4.
Determination of Implementation Status of the Construction Permit
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Requirements 4-The inspector discussed with the licensee the implementation status of the Construction Permit requirements.
The inspector noted that the environmen-
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tal protection program was implemented through site instructions, procedures and checklists.
The licensee stated that in addition to the documented i '
measures taken to protect the environment and to minimize the environmental impact of the construction operations, all the construction operations are under constant' observation and management supervision.
The inspector i
reviewed Bechtel QA audits of the site Pollution Control Program Nos.
PFA-243 (5/3 6/1/79) and PFA-279 (4/24 - 4/25/78) and a Bechtel Audit
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i dated 10/1 - 10/15/79, and noted that no' program deficiencies were iden-l tified.
The licensee stated that the radiological and biological / ecological moni-
toring programs are currently suspended with the exception of water chemis-
try studies including the measurements of 24 parameters sampled monthly at five locations on the Schuylkill River, Perkiomen Creek, and the Delaware
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River. 'The licensee stated that they currently planned to re-start the pre-operational radiological monitoring program by the middle of 1980.
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5.
Verification of the Construction Permit Requirements
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a.
Site Tour Upon arrival at the Limerick Generating Station-(LGS) construction
site, the inspector toured the area'and examined the prevailing envi-
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ronmental conditions at the site and the surrounding environment.
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The inspector observed the environmental conditions at the Schuylkill River waterfront, the temporary spoils area, the site perimeter, the holding pond, sewage treatment facilities, concrete batch plant, con-struction and laydown areas, and meteorological instrumentation.
One unresolved item discussed in Paragraph 5.b(3) and or.e unresolved itemdiscussedinParagraph5.b(4)wereidentified.
b.
Effluent Treatment and Discharges The inspector discussed with the licensee the treatment of site waste-
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water, including operation of the permanent holding basin, the sewage
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treatment plant, the temporary holding pond, the concrete batch plant, and the site storm drain system.
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(1) Holding Basin
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The licensee stated that untreated wastewater is pumped to..the site permanent holding basin, which is operated in a batch mode, for appropriate treatment and released to Possum Hollow Run when
- the required effluent specifications are met. The inspector noted that current NRC requirements for holding basin discharge are contained in Pennsylvania Department of Environmental Resources (PaDER) Water Quality Management Permit No. 4671202. The inspec-tor reviewed the holding-pond discharge records completed since January,1978.
The licensee. stated that the temporary holding
' basin on site received dewatering' water and that this basin has never had'to be discharged due to r,aporation and limited volume of influent.
The -licensee stated that it is intended that the site storm drain system which co?lects rainwater and runoff will drain directly into Possum Hollow Run when it is completed.
Parts of the storm drain system presently discharge into the permanent holding basin.
(2) Sanitary Waste The inspector discussed with the licensee the operation of the site sewage treatment plant.
The inspector reviewed the circum-stances' of two discharges from the site of raw sewage into Possum Hollow Run which flows into the Schuylkill River.
The licensee stated that on February 8,1978, sewage had overflowed from the construction site sewage holding' tanks located near the sewage treatment plant at a rate of 2-5 gpm for 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, and that this spill had entered the storm drain system across the road from the holding tanks and flowed into Possum Hollow Run. This
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spill had resulted in the initiation of Corrective Action Report (CAR) #214 as noted in the last NRC inspection of this area (352/78-11-04; 353/78-07-04), as an item to be re-examined.
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The inspector noted that a CAR had also been issued for a spill of raw sewage from the construction site sewage holding tanks on July 3, 1979 which had also entered Possum Hollow Run.
The licensee. stated that this spill resulted when a blockage in the pipe carrying sewage to the holding tanks was cleared, causing an unusually high flow to reach the holding tanks.
The licensee stated that sewage had been released through a vent pipe which had been capped after the spill to prevent future such occurrences.
The-inspector observed no cap on the sewage holding _ tank vent at the time of the inspection..The licensee then stated that a recent modification in operation of the. holding tanks had required an air' hose to enter the tank through the vent and therefore the cap had been removed.
The inspector stated that 'the above failures to prevent untreated wastewater from reaching the natural water
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! bodiesfin the1 area was in noncompliance with ' Sections' 3.E.1 jand
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- 3.E.9 of. the _ Construction Permits,' which reference the Common-
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4671202-and-the Final Environmental Statement (362/80-09-01; 353/80-08-01).
.The licensee stated that the final design of the sewage treatment plant specified that; sewage would. flow'directly into the sewage.
treatment plant and-not normally enter the sewage holding tanks.
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The _ inspector reviewed the ' drawings describing a valve to be.
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placed in-the' sewage _ treatment p1 ant ' influent line which would allow sewage to flow directly to the treatment plant without
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. first entering the holding; tank (through which sewage currently
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The -licensee stated that.after the described modifica-tion.is-completed-the' sewage - holding tanks would ~ only be used -if-needed, not on a regular basis, and that this modification should reduce the potential for spills through the holding tank vent.
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The licensee stated that the sewage treatment plant modific.ation would be completed.in the near future but could not provide the inspector with a' specific date.'
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The licensee sthted that the.two other sewage holding tanks on site._(at the pipe shopfand at the concrete batch plant) wer'e
= equipped with level. alarms, and were pumped out by a contractor as needed. The-licensee stated that portable toilets onsite
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-were also pumped out and that all. sanitary waste removed from the site was disposed'of at a licensed treatment facility.
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(3) Oil Separator
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The inspector discussed with the licensee the operation and cur-t rent design of the oil separator system at the OE Shop area.
The inspector observed evidence of small' auanitites of oil on p
the'. slope where the oil separator system discharges and in the
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drainage ditch at the base of the slope.
The-licensee stated
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that current problems which could allow oil to escape from the U
oil separator ~ system include inadequate piping and oil back-up from thel associated waste oil' tank during times of high influent p'"
volume, such as when it rains.
The licensee stated that modifi-
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eliminate thecbackup from the waste oil. tank and alter the. pip-ing to enable adequate flow in the system,' and-that these modi-S fications would~ reduce the probability of oil being discharged
from the: system.' The-inspector reviewed a work-request for.the F
described modifications 'and noted that the' work had been approved.
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although a~ completion-date for the work was not available at the
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" time of the1 inspection. _..The licensee stated that oil ~ reaching t.
the drainage; ditch atithe ~ bottom'of the slope beneath the oil
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separator discharge flows to; the-holding basin where it is col-H lected before-discharge to Possum Hollow Run.
The licensee also sta_ted that:when there is a large volume'of site runoff, such as
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F when it rains, water flowing through the drainage ditch at the
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' base of.the slope where the oil separator discharges is diverted c
away.from the holding basin and directly into Possum Hollow Run.
The inspector stated that until the proposed modifications are 4:
made on the oil separator system there exists the potential for
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oil being-discharged.to Possum Hollow Run, and therefore this-item is considered unresolved pending completion of the system modifications-(352/80-09-02;353/80-08-02).
(4) ~ Construction Area Drainage
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During the site tour on_May 22, 1980,- the inspector examined the
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drainage patterns of the site and noted that where the site road n
(from the Schuylkill River area to the Longview Road spoils arec)
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crosses Possum Hollow Run there is a natural depression which acted as a settling basin and accumulated sediment.
The inspector observed a line of old hay bales at the area which the licensee stated had been placed there in an effort to help control runoff water turbidity and prevent suspended solids material in the run-
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off water from reaching Possum Hollow Run.
The inspector observed that the elevation of the depression area had been raised by depos-ited silt and sediment to approximately that of the surrounding
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woodland.
The licensee stated that actions would be taken as
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needed at this location to assure that the. settling area conti-nued to prevent turbid runoff-water from~ reaching the natural
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water bodies-in the area.
The inspector stated that this area
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would be re-examined in a subsequent inspection (352/80-09-03;
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The inspector also examined the construction near the Schuylkill
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River water intake structure on May 22, 1980, and observed a depression area near the intake building, the slopes.of which had all covering vegetation removed.
In addition, the inspector observed a pile of crushed stone and fine material stored at the edge of the depression and a drainage culvert at'the bottom of the depression which ended through the intake structure wall
several feet above river water level.
The inspector stated that there was potential for turbid runoff water from the depression
area to flow through the drainage culvert and into the Schuylkill River, thereby violating the requirements of the licensee's waste-
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water discharge permit.
The licensee stated that action necessary to prevent untreated wastewater from the depression from entering
the river would be accomplished.
The inspector stated that this item is considered unresolved pending completion of corrective actions necessary to p(352/80-09-04; 353/80-08-04).revent untreated the Schuylkill River
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The inspector examined;the spray pond construction area and noted
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that a trench had been dug at approximately the middle of the
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north side of the spray pond excavation.
The licensee stated
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Lthat this trench had been made to drain water from the spray pond excavation.
The inspector followed the drainage path of water from the excavation via this trench northward through a laydown area and to the fence at-the site boundary on Sanatoga Road near the intersection with Evergreen Road.
The inspector observed no
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oneite at the site boundary.
The inspector noted that continua-f.
tion of water. drainage out of the spray pond excavation through this trench could allow turbid runoff water to reach Sanatoga Road. -The licensee. stated that drainage through the trench from-the spray pond would be discontinued..The inspector stated that this. area would be re-examined in a subseouent inspection (352/80-09-05;535/80-08-05).
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c.
-Spoils Areas and Solid Waste Disposal The inspector examined the spoils areas east and west of Longview Road.
The licensee stated that only a small part of the spoils area
west of Longview Road is still being actively used.
The licensee
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stated that those spoils areas not in use will be seeded by June 13, 1980.. The licensee stated that the followin are to be included in this seeding program. g additional onsite' areas-(1) Permanent Storm System Outfall at Possum Hollow Run (2) West Bank of the Cooling Tower Area (3) Northwest Bank of the Cable Reel Storage Area
The inspector noted that these areas had been graded in anticipation
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of seeding.
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The inspector observed the active portion of the spoils area west of Longview Road du~ ring site tours on May 22 and 23, 1980, and noted that-assorted solid waste material other than excavation spoils (including
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waste concrete, metal, plastic, and foam rubber) had been deposited in the area.
The licensee stated that it was not normal procedure to
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place these materials in the~3poils area.
The inspector verified prior to the completion of the inspection that the licensee had issued CAR.
No. 284-on May 27, 1980 requesting that these materials be removed from-the spoils area and be disposed of properly.
The inspector noted that other solid wastes are collected in specifically marked containers, and the licensee stated that solid wastes are disposed of offsite by
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contractor arrangement at a licensed landfill.
The inspector had no
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6.
-Management Controls and Program-Implementation Procedures I-The inspector reviewed the licensee management controls as related to the environmental protection program - construction phase.
The inspector noted
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-The inspector. reviewed:the licensee ~ program records 'and noted that the results of the. site observations were documented.. Areas reviewed included the1following:
Category; Review-Frequency a. -
Erosion Control-Monthly b.-
Dust Control Weekly c.-
Dewatering.
Monthly
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d, Sanitary Facilities - waste disposal.
Monthly Bi-weekly
. e.- ; Trash Removal
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l Monthly during growing
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- Weed Control'and; Reseeding-
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- Yard Lighting -
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Semi-annually
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Holding Pond.0perations Bi-monthly i
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! Sound SurveyL Semi-annually
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Sanitary Facilities --holding tanks Monthly
'j.-~ Accidental-Spills
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-Each spill
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Pollution Control Program & Schedule Review Guarterly
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011 Spill Prevent 1on Monthly The inspector reviewed the licensee's periodic inspection reports in the above categories completed since the last NRC inspection in th.is area.
Thel licensee's system of Corrective Action Reports (CAR) was discussed.
- The licensee stated that a CAR is-issued whenever the Pollution Control Engineer determines that corrective action is necessary in an area. The inspector _ reviewed the licensee's CAR's Nos. 253-283' covering the period-
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December 14,1978 - May 2,1980.
The-inspector had no further questions in this area at this time.
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Meteorological ' Instrumentation The inspector; reviewed 1the licensee's meteorological instrumentation at F
the. tower onsite,. thel.second tower locate'd across the Schuylkill River
l from the plant ~ site, and the satellite-tower near the discharge diffuser d
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.s tructure.
Sie licensee stated.that wind speed, wind direction, air. tem-
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perature, humidity, precipitation and solar radiation ~were measured at q
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The licensee-stated that data was collected on chart-i paper and cent to a' meteorological ' contractor, Meteorological Evaluation
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Services,Lin Amityville,'.New-York, for evaluation.
Calibration of.meteoro-logical instrumentation was~ discussed. 'The inspector noted that the mete-t
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orological instrumentatien appeared-to be functioning with the exception
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of the-304 elevation wind direction instrument on Tower No. 2, which was
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L Japproximately 1800 'out:af phase.
The licensee stated that this instrument i.
would-be repaired.during the-calibration scheduled to be completed by the end.offJune,'1980.
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No items of noncompliance were identified.
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Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether-they are acceptable items, ittms of noncompli-ance, or deviations.- Two unresolved items were disclosed during this inspection.
These items are discussed in Paragraphs 5.b(3) and 5.b(4).
9.
Exit Interview The inspector met with the licensee representative (denoted in Paragraph
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1) at the conclusion of the inspection on May 27, 1980, at the Limerick Construction site.
The inspector summarized the purpose and the scope of the inspection and the inspection findings, including each of the unresolved items and item of noncompliance.
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