IR 05000508/1980005
| ML19320C784 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 05/28/1980 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19320C782 | List: |
| References | |
| 50-508-80-05, 50-508-80-5, 50-509-80-05, 50-509-80-5, NUDOCS 8007180025 | |
| Download: ML19320C784 (9) | |
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U. S. !iUCLEAR REGUIATORY C0!ci1SSIO:3
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OFFICE OF INSPECTIo:i AND ENFORCEME!.~f
REGION V
50-508/80-05 Rsport No. 50-509/80-05 Docket No. 50-508 & 50-509 License No.
cPPo 154. 1gs Safeguards Group Licensee:
Washincton Public Power Sunoly System (WPPSSI
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P. O. Box 968 Richland. Washinaton 99352 Facility Nat:c:
Washington Nuclear Projects 3 & 5 (WNP-3/5)
Inspection at:
WPPSS, Richland and WNP 3/5 Site. Satsop. Washinaton Inspection conducted:May'13-15, 1980
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Inspectors: $ h O t M C 1"T h i '1 3 IMO G. P. Yuh Radiation Specialist dDate 'S igned
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Date Signed
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fd Approved by: F. A. Wen lawski, C ief
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Ddte Signed React
,ad{ation fety e,ction f
$I 80
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Approved By:
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H. E.13cok', Chief ~, Fuel Facilities and fiaterials Date Signed Safety Branch
S u==a ry
Inspection on May 13-15,1980 (Report flo. 50-508/80-05,50-509/80-05_)
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Areas Inspected: Routine unannounced inspection by a regional based inspector of the construction phase environmental protection program including, organization and administration; procedures; audits; construction pennit requirements; and a tour of the site.
The inspection involved 16 inspector-hours by one NRC Inspector.
Resul ts:
No items of noncompliance or deviations were identified.
RV For: 219 (2)
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DETAILS 1.
Persons Contacted a.
Washinoton Public Power Suoply System (WPPSS)
- C E. Love, Deputy Division Manager
- D. S. Lodmell, Construction Superintendent R. A. Chitwood, Manager, Environmental Programs
- D. J. Lagrov, Field Engineering Supervisor W. Davis III, Supervisor, Environmental Sciences
- L. L. Schinnel, Lead Environmental Engineer J. P. Chasse, Senior Environmental Engineer b.
Ebasco Services, Inc.
- A. M. Cutrona, Deputy Quality Assurance Manager D. A. Davis, Senior Project Quality Engineer c.
Washington State Energy Facility Site Evaluation Council, (EFSEC)
G. Hanson, Senior Project Engineer by telephone on ilay 14, 1980.
- Denotes those attending the exit interview.
2.
Action on Previous Inspection Findings (closed) Noncompliance (508/78-03, 509/78-03):
Failure to place concrete waste in a sanitary landfill. The inspector toured the area and observed that corrective action had been accomplished.
In addition the inspector reviewed procedural revisions intended to prevent future items of this nature (Paragraph 4).
3.
Organization and Administration The inspector discussed the organization and administration of environmental programs with WPPSS representatives.
In September of 1978 Ebasco and WPPSS integrated their staffs at the WNP 3/5 site. This integration resulted in a line of responsibility for onsite environmental coitrols as shown below:
Division Manaaer WNP.3/5 Deputy Divi,sion Manaaer
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l Pro _iect Enaineerina Manaaer I
l Lead Environmental Enoineer l I
i Associate Assistant Assistant Environmental Environmental Environmental Engineer Engineer Eng(ineer (Sewage Treatment (Environmental Inspectors)
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Plant)
(5)
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Each Environmental Engineer holds at least a Bachelor of Science degree in an environmentally related discipline. The onsite environment pro-gram is directed by the WPPSS Environment Programs Department. This group is located in Richland, Washington and reports to the Technical Division Manager. The corporate Environmental Programs Department is organized as shown below:
I Manaaer Environmental Programs l
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Administrative Suncort i
I Consulting Supervisor Environmental suoervisor Environmental Geoloaist Sciences Enaineerir a
! Administrative Sunoort I
I Associate Senior Environmsntal Socioeconomic Senior Environmental Geologist Scientist coordinator Engineer (2)
Environmental Senior State Scientist (Radiological)
Liaison Engineer l
l Environmental Scientist tnvironmental J
(2)
Engineer WNP 2, 1/4 l
l Environmental Scientist
' Lead Environmental 3 vacancies Engineer WNP 3/5 I
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' Environnental Techniciar lEnvironmental Engineer l vacant
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The licensee has developed an " Environmental Programs Department Planning Manual ". This manual constitutes a charter of operation for the Environ-mental Programs Department. All environmental commitments pertaining to the WNP 3/5 are contained in the "WPPSS Nuclear Projects Nos. 3 and 5, Environmental Commitments Book" dated April 2,1980. This book is revised quarterly to reflect current resolutions issued by the State of Washington Energy Facility Site Evaluation Council (EFSEC).
4.
Procedures The inspector reviewed written procedures that have been established and implemented to insure that the environmental commitments are met at the WNP 3/5 site.
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-3-WPPSS Environmental Program Department has issued a Technical Procedures Manual ". The inspector reviewed the following procedures that apply to the WNP 3/5 site at this phase of construction.
TEP 10-0, Environmental Documentation, Rev. O.
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TEP 10-1, Compliance with the State Environmental Policy Act (SEPA),
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TEP 10-2, Preparation, Review, and Approval of State site Application and Environmental Reports and Amendments, Rev.1.
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TEP 10-5, Originat,on, Approval and Distribution of Environmental
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Report Deviations, Rev. O.
TEP 10-6, i reparation, Review, and Sub.littal of Routine Environmental
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Construction Reports, Rev. O.
TEP 10-7, Review and Approval of Environmental Technical Specifications
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and Amendments, Rev. O.
TEP 11-0, Environmental Compliance and Monitoring, Rev. O.
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TEP 11-1, Environmental Commitment Identification, Rev. O.
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TEP 11-2, Environmental Coamitment Control During Construction, Rev. O.
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TEP 11-3, Environmental Review of Nuclear Plant Designs, Rev. O.
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TEP 11-4, Energy Facility Site Evaluation Council (EFSEC) Design
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Review, Rev. O.
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TEP 11-5, Environmental Technical Specification Compliance, Rev. O.
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TEP 11-6, Environmental Review of Plant Operating Procedures, Rev. O.
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EPI 11-2.1, Environmental Site Inspections During Construction, Rev. O.
During the last NRC inspection of the environmental program the inspector reviewed ELA:7.C Adain1strative Site Procedures ASP 11-10.1, ASP III-10.3 a6d ASP 1-6.
With the integratjon of WPPSS and EBAECO these procedures
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ine follow.ng procedures apply directly to the WNP 3/5 site.
PMP.8-115, Environmental Control During Construction, Rev. 3
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dated 3-10-8._.
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h ASP-PE-3-1, Environmental Protection Control Plan, Rev.1, dated 4-4-80.
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ASP-PE-3-2, Oil Spill Prevention and Countermeasure Plan, Rev.1,
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dated 5-25-79.
ASP-PE-3-3, Operation and Maintenance of the Chemical Treatment
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Facility, Rev. O, dated 5-25-79.
ASP-PE-3-4, Operation and Maintenance of the Sewage Treatment Facility,
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Rev. O, dated 5-25-79.
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ASP-PE-3-5, Operation and Maintenance of the Hypochlorination System, Rev. O, dated 5-25-79.
The inspector reviewed records maintainei pursuant to ASP-PE-3-1 for the period July 1978 thru May 1980. This review indicated the licensee is adhering to the procedural requirements.
Observations are being inade and documented by the Environmental Inspectors. These observations have be3, categorized according to their significance and corrective action has been taken within the prescribed time period.
No item of noncompliance was identified in this area.
5.
Audits Procedure EPI 11-2.3, Environmental Audit During Construction, Rev. O, dated 2-28-79, identifies the steps that WPPSS Environmental Engineers should follow during semi-annual environmental audits of project compliance with environmental commitments.
The inspector reviewed an audit of the WNP 3/5 project by the WPPSS Senior Environmental Engineer on October 22, 23, 25, November 1, 2 of 1979. The audit-report was issued November 6,1979. There we'e four findings of this audit which required a response. These findings involved improved filing, documentation of negative evaluations, minor procedural deficiencies, and revision of several procedures. The WNP 3/5 Lead Environmental Engineer responded in a letter dated November 28, 1979 to take corrective action by January 10, 1980.
The inspector ver'ified that corrective action had been completed January 11, 1980.
On March 15 thru 18,1980, Audit No.80-150 was performed by WPPSS Ouality Assurance Department of the WNP 3/5 environmental program. The inspector was informed that this audit met the requirement of EPI 11-2.3.
At the time of the inspection, the Lead Environmental Engineer had not received the audit repor.
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-5-The inspector reviewed the Audit Report 80-150, QAS-A-80-06 dated April 29, 1980. This audit identified one problem area involving the pH of the batch plant wash basin.
In accordance with ASP-PE-3-1 the Lead Environmental Engineer had already independently issued Environmental Infraction Report #333 to correct this problem. Corrective action is scheduled for corrpletion by June 18, 1980.
No item of noncompliance was identified in this area.
6.
Construction Pemit Requirements Construction Pemit Nos. CPPR-154, and 155 state in section 3.E.16 specific conditions for the protection of the environment. The inspector observed compliance with these conditions, several specific observa-tions are noted below.
a.
Condition 3.E.1. states:
"The applicants shall establish a control program which shall include written procedures and instructions to control all construction activities and shall provide for periodic management audits to deter-mine the adequacy of implementation of environmental conditions con-tained in this permit. The applicants shall maintain sufficient records to furnish evidence of compliance with all environmental conditions herein;"
i The licensee has established a control program as described in
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Paragraphs 3, 4 and 5 of this report.
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Condition 3.E.2 states:
"Before engaging in a construction activity not evaluated by the Commission, the applicants will prepare and record an environmental evaluation of such activity. When the evaluation indicates that such activity may result in a significant adverse environmental impact that was not evaluated in the Final Environmental Statement, the applicants shall provide a written evaluation of such activities and obtain prior approval of the Office of Nuclear Reactor Regulation for the activities;"
On May 14, 1980 the licensee began construction of an NSSS Haul
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Road along that area previously evaluated in the Final Environmh.al Statement for installation of a railroad spur.
The licensee per-formed an evaluation of the environmental consequences of this construction in lieu of the railroad spur and concluded that an adverse environmental impact will not result. WPPSS presented their findings to EFSEC in March and April 1980.
On April 28, 1980 EFSEC adopted Resolution No.171 which permitted construction of the'NSSS Haul Road, imposed specific controls, and acknowledged that construction of the NSSS Haul Road does not preclude construc-tion of an access railroad at some future dat.
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Condition 3.E.4 states:
" Construction plans and specification will contain specific erosion and sediment control measures governing the excavation of borrow pits, the disposal of surplus excavation, and the construction of earth fills.
State-of-the-art construction methods as discussed by the U.S. Environmental Protection Agency in the following two (2)
publications will be adhered to:
" Processes, Procedures, and Methods to Cor. trol Pollution Resulting from all Construction Activity," EPA-430/9-73-007, October 1973, and
" Comparative Costs of Erosion and Sediment Control, Construction Activities," EPA-430/9-73-018, July 1973."
The inspector viewed the licens;e's copies of EPA-430/9-73-007 and
/9-73-018 and determined from discussions with licensee representa-tives and by observation of erosion control measures that the reference guidance is being utilized.
d.
Condition 3.E.7 states:
"During clearing operations, stumps and other unsaleable timber will be disposed of by mulching or chipping.
If chipping cannot be utilized, the material will be burned in accordance with Washington State Department of Ecology Open Burning Regulation, Chapter 18-12 EAC.
During this burning operation, all necessary attendant fire control personnel and equipment will be on hand, and the burning operations will be deferred during air quality and fire hazard situations."
Records indicate that since July 1978 three burning permits have been issued for high stack burning associated with construction of the Cooley Laydown Area.
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Condition 3.E.16 states in part:
"Any discharge resulting from the construction of this facility will comply with the conditions contained in the National Pollutant Discharge Elimination System Permit (NPDES) issued for the facility, as presently approved or as later modified, except for those conditions regulating the discharge of radioactive effluents composed of byproduct material, source material, and special nuclear material..."
1.
On February 22, 1979, the suspended solids limit of 50 mg/l specified in NPDES Permit No. WA-002496-1 was exceeded at discharge number 009 by 3 mg/l for a period of up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
EFSEC was notified by telephone on February 23, 1978 and by letter G03-79-316 dated February 23, 1979.
This minor release was apparently due to operator error.
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During December 1979 hear, rainfall resulted in a slide down-stream of the C-1 pump installation and Cooley Laydown Area.
This slide, estimated at about 20,000 cubic yards, caused a washout of the Union Pacific Railroad tracks and release of turbid water to the Chehalis River.
EFSEC was notified by telephone on December 13, 1979 and by letters dated December 26, 1979 (G03-79-2368), and February 19, 1980 (G03-80-353).
The inspector discussed this matter with Mr. George Hansen, EFSEG Senior Projects Engineer. Mr. Hansen indicated EFSEC has been following this matter and expects that WPPSS will stabilize the affected area during the summer months.
Representatives of WPPSS indicate that based on geologic and
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hydrologic study of the Cooley Laydown Area it appears the slide may have been a natural occurence not caused by con-straction of the laydown area.
3.
On December 18, 1979 a diesel fuel tank being transported by truck developed a crack and spilled between 100 and 200 gallons of diesel fuel along the East Access Road. The Oil Spill Prevention and Countermeasure Plan was implemented.
A small amount of fuel may have reached the Chehalis River.
The estimated amount that reached the river was less than 5 gallons.
EFSEG and the U. S. Coast Guard were notified within three hours.
EFSEG was notified in writing by letter dated December 31, 1979 (G03-79-2403).
4.
On two occasions in February 1980 the pH limit of 8.5 specified in the flPDES Permit was exceeded at discharge number 009.
On February 18 discharge from the settling pond had a pH of 8.6 for six hours, and on February 26 the effluent discharge had a pH of 8.7 for up to 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.
These discharges were during a period of high rainfall. EFSEC was notified initially by telephone, followed by letters dated February 20, 1980 (G03-80-334) and February 28,1980 (G03-80-406).
The State of Washington's Energy Facility Site Evaluation Council (EFSEC) acts as the primary enforcer of the conditions contained in the NPDES permit which it issued, and it has taken measures that it considered appropriate in response to items 1-4 described above. The initial corrective measures and the long tenn preventative measures scheduled by the licensee appear adequate to prevent reoccurrence of these items.
No item of noncompliance was identified in this area.
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7.
Tour A general tour of the WNP 3/5 construction site and adjacent areas was performed on May 13 and 14,1980.
This tour included the Saginaw and Cooley laydown areas, Elizabeth Creek crossing, NSSS Haul Road and water intake system construction area.
The inspector observed conditions which indicate compliance with the requirements stipulated in the Construction Permit.
The areas inspected were clean, erosion control measures were in place and appear effective. Ground cover and seeding has been completed in many of the graded areas.
Permanent roads have been paved and dust control measures on unpaved roads were effective during the inspection period.
The inspector noted that the Environmental Inspectors were actively involved in monitoring the progress of field work.
No item of noncompliance was identified during the tour.
8.
Exit Interview The inspector met with the persons denoted in Paragraph 1 at the WNP 3/5 site, following the conclusion of the onsite inspection on May 14, 1980.
The inspector summarized the purpose and scope of the inspection and discussed the inspection findings.
The inspector complimented the licensee representatives en the physical appearance of the construction site and the effectiveness of their environmental protection program during the period since the last inspection.
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