IR 05000498/1980032
| ML19351E987 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/12/1980 |
| From: | Brown G, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19351E986 | List: |
| References | |
| 50-498-80-32, 50-499-80-32, NUDOCS 8012190668 | |
| Download: ML19351E987 (7) | |
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.,U U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report Nos. 50-498/80-32 50-499/80-32
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Docket Nos. 50-498 50-499 Licensee:
Houston Lighting and Power Company (HLP)
Post Office Box 1700 Houston, Texas 77001 Facility Name:
South Texas Project, Units 1 and 2 Insoection at: South Texas Project, Matagorda County and HL? Offices, Houston, Texas Inspection conducted: October 21-23, 1980 Inspector:
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Lorenzoj ilborn, Radiation Specialist Date W
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Approved by:
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Glen IT. Brown, Chief, Fuel Facility and Material Date Safety Branch Summary Inscection on October 21-23, 1980 (Recort Nos. 50-498/80-32; 50 499/80-32)
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Areas Inscected:
Routine, unannounced inspection of construction pnase environmental protection programs, including organization and administration; i
site evironmental control program; audits; transmission line work; special studies and monitoring programs and tour of the site and surrounding area.
The inscection involved sixteen (16) inspector-hours by one (1) NRC inspector.
Resul ts: No items of noncompliance or deviations were disclosed.
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-2-DETAILS 1.
Persons Centacted Houston Lighting and Pcwer Comoany (HLP)
- R. W. Lawhn, Supervising Engineer E. P. Barganier, Lead Construction Supervisor
- G. J. Gibbs, Engineer
- H. P. Hardy, Engineering Technologist
- R. S. Hanna, Junior Engineer R. Gangluff, Chemical Technicians' Foreman Brown and Root, Inc. (B&R)
- A.
N. Costanza, Site Environmental Coordinator
- 0enotes those present at meeting at STP site on October 22, 1980.
- 0enotes those present at exit interview at HLP offices on October 23, 1980 2.
Licensee Action on Previous Inscection Findings (Closed) Unrcsolved item (50-498/79-07/1): This item is concerned with written precedr at had not been finalized and implemented to cover the scope of t
., assignment of responsibility, sampling procedures, acceptance criteria and analytical QC activities. The procedures are described in paragraph 6 of this report. This item is considered closed.
(Closed) Unresolved item (50-498/79-07/2): This item is concerned with burial of chemical and nonsalvageable waste at a designated location on-site.
Section 4.5.1 of the FES requires that nonsalvageable items be hauled from the site and disposed of in accordance with local regulations. The corrective action is described in paragraph 8 of this report. This item is considered closed.
3.
Organization and Administration The inspector reviewed the organizational structures of HLP and B&R as related to environmental matters at the site.
Changes were noted as follows:
l HLP 0. G. Barker, Manager, South Texas Project J. G. White, Licensing and Technical Coordinator W. F. McGuire, Manager, Environmental Protection Department R. W. Lawhn, Supervising Engineer, Nuclear Projects G. J. Gibbs, Licensing Engineer
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3&R J. L. Hawks, Engineering Project Manager Robert Withrow, Engineering Staff Manager.
A. N. Costanza, Site Environmental Coordinator l
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-3-The inspector had no further questions in this area at this time.
Internal Audits
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The inspector discussed audits and audit findings with HLP and B&R representatives.
The HLP Environmental Planning and Assessment Division
conducts cuarterly audits of the site Environmental Protection Control Program (EPCP) and an annual QA audit is conducted of HLP's Environmental Planning and Assessment Division.
The inspector reviewed these audits (purportedly conducted quartsrly on December 31,1979, March 18, July 3 and September 18, 1980 and annually on October 11,1979) as to scope and findings and determined that corrective action was completed for each
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identified discrepancy.
The inspector had no further questions in this area at this time.
5.
Site Environmental Protection Control Program The inspector noted that the EPCP is carried out by the Site Environmental Coordinator (B&R).
The inspector reviewed the changes to the program since the last inspection and had no further questions.
The inspector reviewed the daily log books and monthly reports which document activities of the EPCP. The inspector noted no open items at the time of this inspec-tion and previous open items had been satisfactorily closed out.
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6.
Saecial Studies and Monitoring Programs
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Studies and monitoring requirements during the construction phase are described in section 6.1 of the Environmental Report (ER) and section 6.1 of the Final Environmental Statement (FES). All of the construction phase studies and monitoring requirements are complete except entrainment and impingement studies which are be:ng conducted during periods of pumping of the intake structure. Telecyne Isotopes was. selected in September 1980 as the analytical contractor for the Preoperational Radiological Monitoring Program. The inspector notgd that written procedures have been implemented to cover the scope of the work, assignment of responsibility, samoling procedures, acceptance criteria and analytical QC activities.
The inspector noted those procedures as part of the STP Plant Procacures Manual PTP10.
This satisfactorily closes out an item that was unresolved during the most recent inspection (79-07).
The inspector had no further questions in this area at this time.
7.
Transmission Line Environmental Program The inspector discussed the imolementation of environmental protection for transmission line construction with HL&P representatives and reviewed documentation related to this program. The ownership and construction of
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each corridor by the various participating comoanies has been previously described (50-499/78-02).
Construction activity is now being conducted on the lines to the Velasco substation of HL&P and to the Hill Country substation of the City Public Service of San Antonio.
The inspector reviewed environmental status reports from the field which showed that environmental protection requirements are being met.
The inspector had no further questions in this area at this time.
8.
Site Tour A tour of the STP construction site and surrounding area was conducted on October 22, 1980. The inspector observed construction activity in progress and observed implementation of environmental protection measures related to the construction activities. No significant environmental concerns were observed other than those previously identified and documented by the S&R Site Enviornmental Coordinator.
During a site tour on May 7-8, 1979, the inspector noted burial of chemical and nonsalvageable waste at a designated location on site.
The inspector stated that section 4.5.1 of the FES requires that nonsalvageable items be hauled from the site and disposed of in accordance with local regulations.
He further stated that this item would remain unresolved (79-07/2) pending discussions with the NRC staff.
During the present inspection the inspector noted that by letter dated April 30, 1979 (ST-BR-HL 4115), B&R recommended on-site solid waste disposal due to reduced handling costs associated with en-site disposal of non-salvageable material and identified two potential areas available on the project site.
Proposed Site A is located just outside the embankment on the northwest corner of *he reser-voir embankment; proposed Site B is lccated on the east side of the site near tne Colorado River. HL&P evaluated the proposed disposal sites and eliminated Site B due to e.s proximity to Exotic Isle and its location in the flood plain.
Site A was evaluated and selected as the perferred site.
By letter dated May 18,1979, (ST-HL-BR-1514), HL&P notified B&R of the results of its evaluation and directed B&R to prepare the necessary infornation for registration of Site A.
HL&P elected to secure NRC accroval for on-site disposal once B&R obtained necessary TdQB approval.
B&R was further directed to coordinate registration informaticn with HL&P prior to submission to TWQB, and tn event such a solid waste disposal operation was deemed by I'dQB to be inadequate, B&R was to coordinate with HL&P any additional TdQB requirements for compliance with the Solid Waste Disposal Act, Section 4(f).
As required by the Solid Waste Disposal Act, Section 4(f), on June 11, 1979, B&R suomitted a report to the TdQB (ST-BR-XX-0348) describing prooosed on-site solid waste disposal operations. On June 24, 1979, B&R met with the TAQB Solid Waste Branch for the purpose of obtaining advance
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state approval of STP solid waste disposal operations.
B&R would receive approval to initiate solid waste disposal coerations, as described in the report, upon compliance with the deed recording reouirements required under TWOB Industrial Solid Waste Management Regulation Order No. 75-1125-1, Section 1.05.
On June 25, 1979, HL&P Enviornmental Protection Department gave approval for B&R to proceed with deed recording requirements.
On July 1, 1979, B&R submitted deed recordation information to the Matagorda County Clerk.
On August 16, 1979, B&R received official TOWR notice of registration of proposed on-site solid waste disposal operations.
On August 25, September 1, and September 3,1979, HL&P verbally notified the NRC (Telephone Minutes, Aufill to Luke, ST-HL-5025) of its plans to deviate from the STP Environmental Protection Control Plan (EPCP) and the FES Commitment for off-site solid waste discosal. HL&P and the NRC agreed that proper documentation should be included in the STP environmental records to explain these deviations and related corrective actions. The NRC stated that an official transmittal to them was not necessary. The revised commitment was incorporated in the EPCP and states that " solid waste generated during construction activities will be collected, stored, and sorted for salvageable items. Mercnantable waste is to be hauled from the Project and sold to scrap dealers.
Comoustible solid wastes (papers, wood) will be burned according to the State of Texas regulations.
The ashes from this burning operation along with non-merchantable wastes (concrete, polyvinyl chloride pipe, etc.) are to be land filled in a state approved disposal area on the Project site." This commitment is also reflected in the ER(OL).
On February 14, 1980, B&R provided information to the TDWR for amendment to registration to include excansion of the landfill and the addition of vehicle wash basins.
The TDWR issued notice of amended registration on March 28, 1980.
The proposed disposal area is located outside the northwest corner of the reservoir embankment, inside FM 521, and will utili:e approximately 116 acres. The proposed disposal area has previously been utili:ed as a spoil area. Surface run-off through the area is presently controlled by ditches and a sedimentation basin.
The area is near the waste sources and is accessible by existing private roads.
Collection, handling, storage, and operation of the disposal area will not interfere with private or public property rights off-site.
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6-The bulk of the material for disposal is composed of concrete and non-salvageable ferrous metal, which is inert, non-hazardous, Class I*I Waste.
The principal sources of this material are:
(1) from site preparation (such as the destruction of existing buildings and removal of small amounts of abandoned agricultural equipment), and (2) site restoration, after con-struction of STP has been completed (such as the destruction of temporary construction buildings).
The remaining portion of waste, less than 1",
by volume and weight, is small quantities of tin, PVC pipe and ash (from burning of wood and paper), which is also non-hazardous material.
The rate of deposition of material other than concrete is not expected to exceed an average of 50 tons / week over the life of construction activities.
The total volume of concrete waste during the life of construction is estimated to be between 10,000 to 25,000 cubic yards.
" Drive-in" trenches are excavated in strips within the disposal area, to a maximum depth of 5 feet on an as-needed basis.
Concrete, non-salvageable metals and ash are segregated into separate locations within the area.
Backfill of approximately 2 feet in death covers the waste to existing grade.
Concrete and non-salvageable metal are covered on a weekly basis, while ash is covered after each ceposition.
The mitigative measures taken to prevent ground and surface water con-tamination include the following:
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Materials disposed of are restricted to essentially inert, non-ha:ardous Class III Waste.
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No off-site material or hazardous substances are allowed in the disposal area.
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The entire disposal area is bermed to prohibit surface ficw through the area.
Excavation is limited to a maximum of 5 feet.
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Waste material is covered with approximately 2 feet of topsoil on a weekly basis, and in the case of ash, after each cesposition.
Upon completion of the construction phase, the disposal area will be restored to natural grade ano seeded.
The inspector reviewed the comitment for disposal, recomendation fer disposal and the proposea disposal and concluded that no significant adverse environmental. imoacts have occurred in use of the proposed dis-posal area; furthermore, due to the precautions taken during the discosal site selection and the nature of the waste to be disposed, no significant
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adverse anvironmental imoact is expected. The inspector had not further questions in this area at this time.
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Exit Interview l
The inspector met with a B&R representative at the STP site on October 22, 1980, and with HL&P representatives at the HL&P offices at the conclusion l
of the inspection on October 23, 1980 (see paragraph 1). The inspector i
sumarized the purpose and scope of the inspection, and discussed the
inspection findings.
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