IR 05000508/1981005
| ML20037D044 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 04/20/1981 |
| From: | Book H, Garcia E, Wenslawski F, Yuhas G, Yuras G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20037D043 | List: |
| References | |
| 50-508-81-05, 50-508-81-5, 50-509-81-05, 50-509-81-5, NUDOCS 8105210280 | |
| Download: ML20037D044 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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50-508/81-05 Report No.
50-509/81-05 Docket No.
50-508 and 50-509 License No.
CPPR-154/CPPR-155 Safeguards Group Washington Public Power Supply System (WPPSS)
Licensee:
P. O. Box 968
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Richland, Washington 99352 Washington Nuclear Project 3 and 5 (WNP-3/5)
Facility Name:
Inspection at: WNP-3/5 Site, Satsop, Washington Inspection conducted:
March 10-13, 1981 Inspectors:
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E. M. Garcia, Radiation Specialist Date Signed A
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' dj.go g l G. P.
u as, Radiation Specialist Date Signed h/
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F. A Wenslaw ki," Chief, Reactor Radiation Protection Date Signed
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Approved By:
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H. E. Book Chief, Radiological Safety Branch Date Signed Sum: nary :
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Inspection on March 10-13,1981 (Report No. 50-508/81-05, ~ 50-509/81 -05)
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Areas Inspected: Routine unannounced inspection by two regional based inspectors of the construction phase environmental protection program including, organization and administration, procedures, audits, construction permit requirements; a tour of the site; and processing of IE Circulars. The inspection involved 40 inspector-hours by two NRC Inspectors.
Results:
No items of noncompliance were identified.
RV Form 219 (2)
8105210.280 Q
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DETAILS
1.
Persons Contacted a.
Washington Public Power Supply System (WPPSS)
D. E. Dobson, Program Director
- N. C. Kaufman, Deputy Project Manager
- J. C. Lockhart, Project Q.A. Manager
- 0. E. Trapp, Project Engineering Manager
- L. Schinnell, Project Environmental Supervisor K. Cook, Project Licensing Manager
- J. Puzanskas, Q.A. Engineering Supervisor A. Christian, Environmental Engineer b.
Ebasco Services, Inc.
- A. M. Cutrona, Q.A. Manager
- Denotes those attending the exit interview.
2.
Organization and Administration The inspector discussed the organization and administration of environmental programs with Supply System representatives. A reorganization of the Supply System and Ebasco Site Project Adminis-tration took place on February 2,1981.
A major change since the pre-vious environmental inspection (Inspection Report 50-508/80-05) is the separation of the staffs for the Supply System and Ebasco and placing all the onsite environmental controls staff under WPPSS.
Under the current organization Ebasco will ensure compliance with environmental requirements by preparing designs, directing contractor's activities, and performing construction in accordance with permits.
Further Ebasco will perform initial environmental reviews and provide the Supply System with all the required information.
The Supply System current responsibilities in fulfilling envirnomental requirements include monitoring, overviewing and performance of measurements related to environmental. conditions. At the time of.
the inspection the environmetal group was also operating the Sewage Treatment Plant, the Central Site Chemical Treatment System, Batch Plant Acid Treatment System, and the Water / Wastewater Laboratory.
The existing line of responsibility for the Supply System onsite environmental controls is shown below:
WNP-3/5 IPROGRAM DIRECTORI I
IPROJECT MANAGERI I
IPROJECT ENGINEERING MANAGERI I
IPROJECT ENVIRONMENTAL SUPERVISORI I
EhVIRONMENTAL ENGINEERS (5)
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All environmental engineers possess at least.a bachelor's degree-in an environmentally related field. Two environmental ~ engineers.have licenses by the State of Washington to operate the sewage treatment plant and two others have operator-in-training permits.
The Supply System has a training program for all environmental personnel. This program is implemented by procedure PEI-ENV-2, Training and Certification of Environmental Personnel, Revision 0.
3.
Procedures The Supply System has a number of different procedure manuals. Technical Procedures (TEP) and Environmental Program Instructions (EPI) are system wide instructions. Administrative Site Procedures (ASP) and Project Site-Procedures (PSP) are for the WNP 3/5 site.
Project Engineering Instructions relate to the WNP-3/5 Project Engineering Department.. The WNP-3/5 Project Quality Assurance Department issues Quality Assurance Procedures (QAP).
The WPPSS Environmental Program Department's " Technical Procedures Manual" have received only minor revisions since the last inspection. The revisions consist mostly of changes in titles where the same function is being performed but, due to reorganization, a new title exists.
As a result of the WNP-3/5 site reorganization of February 2,1981 the applicant is in the process of issuing a new procedures manual under.
the title of Project Site Procedures (PSP).
Interviews with the
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applicant's representatives and reviews of inter-office memorandums of the Supply System and Ebasco indicate, that when the PSP are implemented they will be substantially tne same as the Administrative Site Procedures (ASP).
Changes will reflect the new titles and responsibilities.under the new separated site organizations for WPPSS and Ebasco.
Individual ASP remain in effect until a replacing PSP is implemented.
The inspector reviewed two ASP that were issued since the last environmental inspection; ASP-PE-3-ll entitled " Water / Wastewater Laboratory Analysis" and ASP-PE-3-13 entitled " Chloride and Fluoride Sampling".
l The inspector reviewed records maintained persuant to ASP-PE-3-1,
" Environmental Protection Control Plan", for the period January 21, 1980 i
through February 13, 1981. This review indicated the applicant is generally adhering to the procedural requirements. The applicant has separated from its Environmental Deficiency Log those deficiencies related to the Oil Spill Prevention and Countermeasure Plan due to their lower environmental significance and high numbers.
During the time period reviewed a total of 120 infractions were issued and only four had not been cleared by the time of the inspection.
In the inspector's judgement, observations are being nade, documented and categorized in accordance with their significance, and eventually resolved.
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The WNP-3/5 Project Engineering Department is issuing Project Engineering Instructions (PEI) which are coecifically' related to the Site Environmental Group. The inspector re" % cd the following Project Engineering Instructions:
PEI-GA-1, Preparation, Review, Approval and Control of Project Engineering Department Instructions, Revision 0.
PEI-ENV-1, Fuel /0il and Hazardous Material Inventory, Revision 0 PEI-ENV-2, Training and Certification of Environmental Pusonnel, Revision 0.
PEI-ENV-3, Environmental Inspection Shift Report, Revision 0.
PEI-LAB-1, Operation of the Water / Wastewater Laboratory, Interim 8-15-80 PEI-LAB-2, Analysis for Leachable Chlorides and Flourides from Swab Test, Interim 8-15-80 PEI-LAB-3, Flouride Analysis, Interim 8-15-80 PEI-LAB-4, Chloride (ION Electrode Method) Analysis, Interim 8-15-80 PEI-LAB-6, Environmental Personnel Oualifications for Working in Laboratory, Revision 0 PEI-LAB-8, Analysis of Water Sample for pH, Interim.1-29-81 The inspector found the instructions adequate for' environmental controls.
No items of noncompliance or deviations were identified.
4.
Audits Procedure EPI 11-2.3, Environmental Audit During Construction, Revision 1, dated 5/27/80, identifies the steps that Supply System Environmental Engineers should follow during semi-annual audits of project compliance with environmental commitments.
The inspector reviewed an audit report of the WNP-3/5 site and corporate environmental support conducted on November 17,18, December 15 and 30th by an environmental engineer based in the Supply System's Richland office.
The audit report noted that there were "no significant instances of noncompliance", but it raised some questions. All the issues raised by
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the audit had been resolved by the time of this inspection with the exception of the verification by the Supply System of the final disposition of hazardous waste used by contractors. The inspector was informed by the applicant's representative that the Supply System has verified that contractors properly dispose of hazardous waste, but
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fail to document it.
Documentation of proper disposal will be maintained in the future.
No items of noncompliance we.e identified.
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Construction Permit Requirements Construction Permit Nos. CPPR-154, and 155 state in section 3.E specific conditions-for the protection of the environment.
The inspector observed compliance with these conditions.
Several specific observations 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 determine the adequacy of implementation of environmental conditions contained in this permit. The applicants shall maintain sufficient records to furnish evidence of compliance with'all environmental conditions herein;"
The applicants control program is described in -sections 2, 3 and j
4 of this report.
b.
Condition 3.E.3 statts:
"If unexpected har.nful effects or evidence of irreversible damage are detected during facility construction, the applicants shall provide to the staff an acceptable analysis of the problem and a plan of action to eliminate or significantly reduce the ~ harmful effects or damage;"
The applicant's representative stated that.no written definitions of " harmful effects" or " irreversible damage" have been established, however, items such as the removal of a single tree are reviewed for their potential impact.
c.
Condition 3.E.4 states:
" Construction plans and specifications 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 Control 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."
According to the applicant's representative the specific errosion problems present at the WNP-3/5 site led to the development of come new approaches to errosion control. These new methods have been described in several professional papers presented by applicants or the Architect-Engineers' staff. Among the papers presented are:
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G. S. Jeane II, L. L. King, and K. R. Wise " Erosion Control at WPPSS Nuclear Projects Nos. 3 and 5", Proceedings of.
Conference X International Erosion Control Association March 1 and 2,1979, Seatle, Washington.
G. S. Jeane II, and L.' L. King " Erosion Control at Satsop, WNP-3 and WNP-5 August 1977 to March 1978" WPPSS-EP0-081, December 1978.
The applicant has copies of the EPA's papers mention'ed in the condition. The inspector was informed by the applicant's representative that periodically they contact EPA for updates on these publications, but have been informed that no revisions have been issued.
d.
Condition 3.E.5 states:
" Grading, groundcover, and seeding will be completed in each area of the site, providing its permanent configuration, as early as possible. Topsoil, having been stockpiled, will be returned to all disturbed areas and seeded. Topsoil compatible with ornamental planting and with native conifer. species will be obtained from local sources if site stockpiles become depleted or are found to be low in quality. Temporary plantings for erosion protection will continue throughout the construction period as required.
In areas where cutting and filling produce surplus excavation, earth sculpture techniques will be employed to return the site to complementary gradients and naturalistic land forms. Landscape plantings will be introduced in order to blend facilities into the landscape and complete the restoration process. Cleared areas will be stablized in order to prevent long-term erosion. Recommendations from the Soil Conservation Service will be considered in reseeding areas in natural vegetation.
Shrubs and ground covers, particularly frui.t and browse varieties,
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will be preserved wherever practicable."
The inspector noted during the tour of the site that areas thut had been disturbed early in construction but were not now in active construction use had been graded and seeded.
The applicant has met with Energy Facility Site Evaluation Council (EFSEC) and the State of Washington Department of Game for development of a revegation plan.
At the time of the inspection a revegation plan had not been finalized.
Landscaping in the immediate vicinity of the plant buildiags will not be done until late in the construction phas.
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Condition 3.E.6 states:
" Water flow from the immediate plant area Yill be controlled by early-installation of portions of the plant storm drain system.
Drainage from the plant northwest area and the construction lay-down area will be controlled by a system of catch basins, ditches, stilling basins, and settlement ponds. Drainage from the owner controlled storage area and the plant northwest will be controlled by ~a similar system of
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diversion ditches, drop inlets, stilling basins, and settlement ponds.
Drainage from the plant south will be controlled by a system of cut slopes with berm ditches and down drains."
The plant storm drain system is installed and catch basins ditches, stilling basins and settlement ponds are in the plant island and the Nuclear Steam Supply System (NSSS) Haul Road.
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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 contain'ed in the National
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Pollutant Discharge Elimination System Permit issued for the facility, as presently approved or as later modified, except for
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those conditions regulating the discharge of radioactive effluents composed of byproduct material, source material, and special-nuclear material."
To prevent inadvertent discharges, controls of conditions and.
locations in which potentially hazardous materials may be used and
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stored wei _ established.
ASP-PE-3-2, Oil Spill Prevention and Countermeasure Plan, describes the conditions and locations in which bulk oil, fuel, and hazardous material may be used and stored. This procedure has been incorporated in the EFSEC Resolution 149. Divergence from from ASP-PE-3-2 designated use and storage locations' would 'not only require a procedure revision but also a new EFSEC Resolution.
According to the applicant's. representative, the Architect-Engineer has twice informally inquired if the Supply System would seek a modification of EFSEC resolution 149 to permit the storage of oil (
products in the Cooley thydown Area. The Cooley Lay Down Area is not within the eriosion control ditch system and therefore not
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an approv ?d oil storage location.
The applicant's staff had informall,' discussed the possibility of modification of resolution 149 with 1FSEC staff. The applicant's representative stated that
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the EFSEC staff felt that the council would probably not agree to a modifici tion of resolution 149 to permit the storage of oil l
products. The Supply System informed Ebasco that they would not request a modification to resolution 149.
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On January 20, 1981 an Environmental Engineer noted that contractor 223 was storing a petroleum cleaning solvent in the Cooley Laydown Area.
Pursuant to procedure ASP-PE-3-1, Environmental Control Plan, a deficiency was issued by the Environmental Engineer. : 0n January 28, 1981 the Project Environmental Supervisor escalated the deficiency to an infraction. No written response to the infractions report detailing anticipated corrective action and providing a commitment date for completion was submitted within five working days of the issuance of the infraction report.-
Instead, according to the applicant's representative, an informal request to seek a final resolution that would permit storage and.use of
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the solvent at Cooley Laydown Area was made by the Architect-Engineer. The Project Environmental Supervisor reiterated the need for a response to the infraction report and requested that the solvent not be used.
On March 5,1981 the Projact Environmental Supervisor -learned that part of the solvent had been transferred from 55 gallon drums,
" essentially safety containers", to the large tank in which the solvent was to be used.
On March 11, 1981 while on tour of the construction site the inspector noticed a worker cleaning-parts using the solvent.
Just prior to the exit. interview the inspector received a copy of a memorandum dated March 12, 1981 responding to the infraction report. This memorandum does not detail anticipated corrective action 'nor does it provide a commitment.date for'.
completion of the corrective action.
Instead it describes why the Architect-Engineer feels that the use of the solvent should remain at the present location and requests a " resolution to allow them to remt 'n at the Cooley Area".
The State of Washington's Energy Facility Site Evaluation Council (EFSEC) acts as the enforcer of the conditions contained in the NPDES pennit which it issued. At the time of the inspection EFSEC had not reviewed this matter.
This matter was discussed at the exit interview.
On April 6,1981 the inspector was informed on the telephone by the applicant's representative that the Supply System had informed Ebasco that it did not intend to seek a modification to resolution 149; Also that the solvent had been removed from the Cooley Laydown
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area.
No items of noncompliance was identified in this area.
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Tour
' A general tour of. the WNP-3/5 ~ construction site and adjacent areas was performed on March 11 and_12, 1981.. The tour included the Saginaw and Cooley.Laydown Areas, NSSS Haul Road, Water.: Intake' System.
Construction Area and Barge Unloading Facility.
TFe inspector-observed conditions which indicate compliance with tne requirements stipulated in the-Construction Permit.-
The areas inspected were generally clean, erosion ~ control l measures -
were in' place and appeared effective. Grading and seeding.has been completed on many of the previously disturbed areas.
Permanent roads have been paved and dust control measures on unpaved roads were effective during the inspection period.
The area of tm slide identified in Section 6.e.2 of. the previous 1 environmental impection report was visited.' The slide area had-been; stablilized and the railroad tracks repaired. The applicant's representative stated that EFSEC had accepted the ' repairs.
No item of noncompliance was identified during the tour.
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7.
Followup on NRC Circulars
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The inspector reviewed procedures QAP-27, " Processing of NRC Inspection and Enforcement Bulletins / Circulars", and EDP-8.5, " Processing of-Regulatory Information and Requirements issued by NRC (During Project'
Design and Construction)". The inspector 'also reviewed records for IE Circulars No. 79-21, " Prevention of Unplanned Releases-of Radioactivity",
80-14 " Radioactive Contamination of Plant Demineralized Water -System 'and Resultant Internal Contamination of Personnel", and 80-18, "10 CFR 50.59 Safety Evaluations for Changes to Radioactive ~ Waste Treatment Systems".
The applicant had received copies of each circular listed above, and had reviewed each for applicability to the WNP-3/5 site. -It appears at
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this time that in reviewing circulars #79-21 and 80-18 the applicant may not have taken full advantage of the information provided. This-matter was discussed with the Project Licensing Manager ar d he agreed to look into it. The item was briefly discussed at the axit interview.-
8.
Exit Interview At the conclusion of.the inspection, the inspectors met with the persons denoted in Section 1.
The inspector summarized the purpose and scope of the inspection and discussed the inspection findings.
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