ML19225A806

Discusses Two Items of Concern in Connection w/780925 & 26 IE Insp of Station Environ Impact Control Procedures. Describes Method of Compliance Re Hydrological Monitoring Program & Transmission of Ecological Review

ML19225A806
Person / Time
Site:	Black Fox
Issue date:	07/11/1979
From:	Conrad V PUBLIC SERVICE CO. OF OKLAHOMA
To:	Regan W Office of Nuclear Reactor Regulation
References
6212.125.2000.3, NUDOCS 7907200274
Download: ML19225A806 (16)

Text

.= g 6212 DI N 8-016-626 PUBLIC SERVICE COMPANY OF OKLAHOMA A camaat ano scuts /,Esr ccvemy PO7%

P C 2CX 201 'UL3A O AL>cV A T C2 913 56' ?6* '

Public Service Comoany of Oklahoma July 11,1979 Black Fox Station File 6212.125.2000.32N Final Environmental Statement Methods of Compliance for Black Fox Station

. Environmental Projects Branch Division of Site Safety & Environmental Analysis Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Mr. W. H. Regan, Acting Assistant Director Gentlemen:

On July 26, 1978, Public Service Ccmpany of Oklahoma was issued a Limited Work Authorization for our Black Fox Station. The LWA issuance is c:bject to numerous environmental conditions set out crimarily in the Final Envionmental Statement for our station. In order to assure total compliance to these conditions, Public Service has developed a comprehensive Construction Environmental Imoact Control Prcgram which is implemented by project procedures and is aut 'able by management.

On September 25 and 26, 1978, an inspection team frcm NRC Region IV Inspection and Enforcement audited our station environnental impact control procedures and visited the station site. In their course of inspection, all areas of audit were in compliance--but two itens were identified for more study as to the in-terpretation for method of compliance (Attached NFC letter of audit findings dated October 17,1978). Since receipt of the nRC audit findings, this matter was discussed between the NRC staff and the NRC Region IV office and consequent-ly by both NRC offices wita PSO. These informal telephone communications served to keep the two NRC offices apprised of our cctivities and methcdologies of compliance over the cast few months. As a matter of ccmolete documentation, as opposed to any submittal of new information, two items are discussed herein along with a description of our method of compliance.

Hvurological Monitorina Program (FES _Sec. 6.1.3)

"The acclicant shall estaoiish a new samoling station, 2a, to be maintained and sampled contemcoraneously with Station 2 for the duration of construction of the barge slip, intake and discharge structures."

The hydrological monitoring system in reference was initiated by Public Service Ccmoany in en cuary 1974 and ccmoleted in January, 1975 (ER-Sec. 6.1.1) to orovida y

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,ELACK FOX STATION SERVICE LIST XC: L. Dow Davis , Esquire Joseph R. Farris, Esquire William D. Paten, Esquire John R. Woodard, III, Esquire Colleen Wcochear, Esquire Green, Feldman, Hall & Woodard Counsel for NRC Staf f 816 Enterprise Building U. S. Nuclear Regulatory Commission Tulsa, Oklahoma 74103 Washington, D. C. 20555 Andrew T. Dalton, Esquire Mr. Cecil Thomas 1437 South Main S treet, Suite 302 U. S. Nuclear Regulatory Commission Tulsa, Oklahoma 74119 Phillips Building 7920 Norfolk Avenue Mrs. Ilene H. Younghein Bethesda, Maryland 20014 3900 Cashion Place Oklahoma City, Oklahoma 73112 Mr. Jan A. Norris Environmental Preiects Branch 3 Mr. Lawrence Burrell U.S. Nuclear Regu.atory Ccmmission Route 1, Box 197 Phillips Building Fai rview, Oklahoma 73737 7920 Norfolk Avenue Bethesda, Maryland 20014 Mrs. Carrie Dickerson Citizens Action for Safe Energy, Inc.

Mr. William G. Hubacek P. O. Box 924 U.S. Nuclear Regulatory Commission Claremore, Oklahoma 74017 Office of Inspection and Enforcement Region IV Charles S. Rogers, Esc.

611 Ryan Plaza Drive, Suite 1000 Assistant Attorney General Arlington, Texas 76012 112 State Capitol Building Oklar.cma City, OK 73105 Mr. Gerald F. Diddle General Manager Associated Electric Cooperative, Inc.

P. O. Box 754 Springfield, Missouri 65501 Mr. faynard Human General Manager Western Farmers Electric Cooperative P. O. Box 429 Anadarko, Oklahoma 73005 Michael I. Miller, Esq.

Isham, Lincoln & Beale One 1st National Plaza Suite 4200 Chicago, Illinois 60603 Mr. Jcseph Gallo Isham, Lincoln & Seale 1050 17th Street N.W.

Washington, D. C. 20036 .

37 o79 366 265

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UNITED STATES NUCLE AR RE GULATORY CCMMISSION h

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REGiONiv I -* d ' j 611 RY AN PLAZA Or VE. SUITE 1000 1 f AR LINGTON. TE X AS 76011 Y

October 17, 1978 L2.12 DI N 8 - 013- 131 g g , g ,3e m Gast. 20. C5013L.

In R:: ply Refer To:

RIV Dacket Nos. STN 50-556 Rpt. 78-04 { gD AND FilJ.D STN 50-557 Rpt. 78-04 e

o q 2 ;,1978

• DI pgojtcT ME PgiicserviceCompanyofOklancma L g e s cosinot 7 q{ m id: Mr. i . h,. twing , Di rector Black Fox Station Nuclear Project 8-k1M - Pcs: Office Sox 201 rte Tulsa, Oklanoma 74102 T6P~_ entlemen:a ML c' g { inis refers to tne inspection conduced by Mr. R. J. Everett and Mr. H. C.

narrison curing the period Septemoer ?5-25,197S, of activities au:norized h ggS A G 4b'/NRC Limited Work Autnorication dated July 26, 1978, for tne ec. Units No. 1 and 2, and to tne discussion of our findincs with gg Messrs. M. E. Fate, I. N. Ewing, and other memoers of your staff at the

- conclusion of tne inspection.

Areas examined curing tne inspection and our findings are discussec in the enclosed inspection report. Witnin these areas, the inspection consisted of selective examination of procedures and representative records, interviews

-1:n personnel, and observations by the inspector.

Witnin :ne scope of the inspection, no items of noncompliance were identified.

Too unrt.olved items are identified in paragrapn 5 of :ne enclosed report.

n accorcance aitn Section 2.790 of :ne NRC's "R':les of Practice," Part 2, Title 10, Coce of Federal Regulaticns, a copy of this letter anc tne enclosed ins;ection report will be placed in the NRC's Public Document Room. If tne report contains anf information that you believe to be proprietary, it is ne:essary tnat y0u subriit a written application to tnis office, witnin 20 cajs of ne cate of tnis letter, requesting tna; sucn infor.a ion be witnneld frcm ;u:lic cisclosure. The application must include a full statement cf

ne reasons nnj it is claimed :na: :ne information is proprietary. Tne a; plication snouic Oe ;reparec so tna; any proprietary information identifiec is c0ntainec in an enclosure to :ne a;Dlication, since the a:piica: ion witnout

ne enclosure will also De placed in :ne Public Document Room :f we do not near froc jcc in :nis regarc witnin :ne spe:ified period, tne report will te h placec in :ne Public ccument Rocm.

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@ PuDlic Service Company October 17, 1975 of Oklancma Should you nave any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

/

/ g/ d .. ( (-

s W. C. Seidle, Chief Reactor Construction and Engineering Support Branch

Enclosures:

IE Inspection Report Nos. 50-556/78-04 50-557/78-04 O

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h U.S. NUCLEAR REGULATORY CO". MISSION OFFICE OF INSDECTION AND ENFORCEMENT REGION IV IE Inspection Report hos. STN 50-556/78-04 STN 50-557/78-04 Licensee: Public Service Ccmpany of Oklahoma (F50)

P: 0. Box 201 Tulsa, Oklanoma 74102 Focility: Black Fox Units 1 and 2 (SFS)

Inspection conducted: September 25-25, 1978 Inspectors: '[ b. w(l' / ' h 7 /7 .-

R. J. Everett, Raciat'o.1 Specialist Date g Accompanied by:  ! 5, b s_5, w .

H. C. diarrison , Raci a:1on Specialist

/ 6 - / 7 '7 9 Date Reviewed by:  ; // d 'M /d / 7/'X '

'Gleh D. Srcwn, Chief, Fuel Facility and '

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Date Material Safety Branch Ins:ection Su rary Inssection on Seatem:er 25-26,1978 (Recort Nos. STN 50-556/73-04 and STN 50-5T /7s-04)

Areas Inscected: Initial, announced inspection of construction pnase environmental protection programs, including organication and administration; plaas and procedures; implementation of environmental control program; envi-r::rrental monitoring; and a tour of the site and surrounding area. The inspection involved 28 inspector-hours by two NRC inspectors.

Results: Of tne five areas ins;ected, no items of noncomoliance wei e identi-flec.

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.h D ET A Ij._S_

l. Persons Contacted Public Service Comoany of Oklanoma

• M. E. Fate, Executive Vice President

• T. N. Ewing, Manager, SFS Nuclear Project

• V. L. Conrad, Manager, licensing and Ccmpliance J. L. Haynes, Site QC Supervisor H. H. Eller, Site QA Supervisor

• S. A. Bennett, Licensing Engineer R. D. Eyman, Environmental QC Specialist

• J. B. Perez, Manager, Quality Assurance

'Present at exit meeting en September 26, 1978

2. Orcanization and Acministration Tne inspector inquired as to the organi:ational structure that had been established to carry out tre environmental control programs during tne construction phase. The folicwing chart shows the present structure g and assigned individuals as indicated by BFS personnel.

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3-M. E. Fate, Exec. V.P.

1 T. N. Ewing, Manager BFS M. J. Lindberg, V.P.

Poveer Generation I

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Asst. to Manager l i K. Jones l

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G. W. Muenscn, Manager A. F. McGilbra, Manager Engineering & Construction Env. & Chemistry Control i

R. J. Kime, Manager V. L. Conrad, Manager i

Construction i Licensing & Ccmpliance I

I

h. H. Eller, Site J. C. Haynes, Site QA Supervisor QC Supervisor R. D. Eyman, Env. *S. A. Bennett QC Specialist Licensing Engineer

" Lead responsibility for t",e ECP.

O 366 270 w ee_. __. . w

3. Environmental Control Pro; ram (ECP) and Procedures The inspector reviewed the written program and procedures that relate to the Environmental Protectior Control Program. The documents are as follows:

Copy No. S " Construction Environmental Impact Control Program for Black Fox Station Construction" Pro.;ect Procedure Manual - Procedure No.15.Ct " Construction Environmental Impact Control Program Implementation" Field Project Procedure Manual - FPPM 4.9 " Site Construction Environmental Impact Control" After review of these documents and a discussion of tne program witn the acplicant, the inspector determined that the environmental control pec; ram was sufficiently documented and assignments of responsibility nave been made. Further, the program called for site inspection and audits by the corporate staff and procedures established to find and h correct items of potential environmental impact. The inspector had no further questions at that time.

4 Imolementation of the ECP ine inspector discussed tne implementation of the ECP and examined selected records. Monthly reports from the Site Environmental CC Engineer were reviewed for June, July, and August of 1973. The monthly report contained cnecklists for eacn legal requirement listed in the LWA to provide protection from environmental impacts during construction.

The reports also contained status information on each item of ncncom-pliance cited during the report period. The inspector had no further questions at that time.

Tne inspector reviewed the document M-1 "BFS Socioeconom1. Impact Assessment Program." The applicant described his preliminary contacts witn local governments and state planning agencies in order to implement tne program. The inspector stated that the program content and the initial contacts tnat have been made to inclement the program were sufficient to comply with section "f" of the LhA.

5. Envirormental Monitorinc ine applicant's environmental monit) ring programs are described in section 6.1 of the FES. Tne following gives the status of eacn Q monitoring program-366 271

__ - . =

a, Ther .al - tem;erature studies in the Verdigris River have been completed. No additional information is required.

b) Radiological - Baseline studies have been completed. Applicant will initiate Preoperational Program no later than two years prior to the operating license.

c) Hydrological - The applicant has developed a program to assess the physical, chemical and geological parameters of the site area surface waters. This program is discussed in detail in section 6.1.1 of the ER. Tne applicant considers the program completed with exception of two stations in the river which are sam 71ed for physical and chemical parameters. The inspector stated that the requirement in section 6.1.3 of the FES calls for an exoanded program to include the above two stations. This would imply that the applicant should continue the detailed program and add the two str. ons in question. The inspector stated that this issue wou k remain unresolved pending discussions with the NRC staff.

c) Meteorolocical - Site meteorological data was taken using the 330 foot tower in 1973-1974. The applicant plans to take no

@ otner meteorological measurements during the construction phase.

e) Ecolocical

1. Terrestrial - Baseline surveys have been completed. No construction or preoperational monitoring programs are required. Section 6.1.5.1 of the FES requires an inspect;on program for erosion in the draw between the central station complex and the wastewater holding pond. The applicant stated that this program would be implemented or the draw would be concreted on each side to prevent erosion.

2. Aquatic - The applicant's program was carried out according to taoie 6.1-1 of the ER. The program has been completed and no further preoperational monitoring is required.

Tne applicant stated that no monitoring programs or special studies are ceing conducted by contractors and PSO programs are essentially complete.

The applicant described One training provided by an ecology consultant on March 8-9, 1978. Constructicn personnel were given ecological training so tnat they can become aware of and avoid ecological i.cpacts during construction. Section 4.5.2.1 of the FES requires specifically trained personnel 366 272

to recognize and protect ecologically sensitive a.eas. Item 12.b of the LWA exempts right of way (ROW) monitoring for ecological impact which appears to conflict with the requirements stated in section 4.5.2.1.6. The latter reference calls for ecological inspectic s by a qualified individual of all completed areas.

The inspes ;or stated that this issue would be considered unre-solved pending discussions with the NRC staff.

6. Site Tour The inspector toured the site and surrounding area durirq the inspec-tion to observe the condition of the site with regard to environmen'.al impacts and to observe the implementation of the applicant's environ-mental control program. The inspector noted two areas needing attention and corrective action. A small oil spill was noted at the discharge structure cofferdam and fire damage wa's found in the protected cemetery plot south of the station complex. The cemetery is fenced but not locked. The fire consumed a few square meters of grass and brush.

The applicant stated that these incidents would be investigated and appropriate action taken to protect these areas.

The applicant stated that all known oil and gas wells have new been plugged. The inspector reviewed certificates of plugging prepared by a state agency.

The inspector inquired as to work on transmission line right of way (ROW). The applicant described the planned RCWs, which are described in section 3.9 of the ER, and stated that a separate environmental impact procedure would be written in the future to cover this activity.

No construction work on R0W is planned for at least two years. The inspector had no further questions at that time.

7. . Unresolved Items Unresolved items are matters which require additional infomation in order to detemine if they ard acceptable items, items of noncompliance, or deviations. Two unresolvet items were identified during the inspec-tien. These items are discussed in paragraph 5.

5. Management Meeting The inspector met wich P50 rep esentatives at the corporate offices in Tulsa on September 25, 1978 (See paragraph 1). The inspector discussed the NRC enviro . mental inspection program and the regulatory require-ments for environmer.tal protection in the LWA.

O 366 273 MWP iE M i i s N 'E W ""TW"

9. Exit Intersiew The inspector cet with P50 representatives at the corporate offices in Tulsa on Septecer 26, 1978 (See paragrapn 1). The inspector surr.arized the purpose and scope of the inspection, and discussed the findings.

O 366 274

_ . . . .. =. - =_ __ . - -- = - - - = -

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MWA C,N ME NT I

wb5 1 .I distcrbed?

g 2 A Not on the cost-bonefit, no.

3, Q Nou I'd liko to turn for a second to the answers 4 to Board Cucations 8 and 9. I 5 Turning first to Doard Question 3: It's a 6 fact, is it not, that grading as a mothed of removing access 7 roada prosentsa not unacceptable impact so far as the Staff 8 ic coneerned?

o A Yes, that's true. I did not say I would not 10 accopt grading as a mitigation sensure.

11 Q And that is what the appliennt proposes, is itw1 +#

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not?

AVW 13 A Yes, it is. 3;;;I rl

& g O Not1 turning to Board Question 9 for juce one GG 15 sccond, and if you might also turn to page 4-7 of the Final my CAW Enviren=cntal StaNet, in tho accond full paragraph on Ed 16 37 , page 4-7 of the Final Environmental Stato:cnt thero are foug h)=3 i

sections of the procosed right-of-way which the staff g*")*

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g originally preposed would requiro inspection by a qualified w 20 biologist; is that correct?

A Yes, that's corract, 21 n Q And $ cst reading taas into the record these are

,, n-D , n-E, nI-A and HI-B.

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, i Now, then, do you know whother o: not the con-struction of transmission lines in Sections n-D and n-B 25 :d i,

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~ I wb6 are still propcccd by the applicant as a part of -- or as .

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2h cazociaccd with th; ccastruction of the Black Fc:: Station? l

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31: A I beli:vo the applicant has indicat:d those  !

. k 40!i linas would 50 built whothor or not Blach Fox Station is t) 5 !! built.

5f I Q All right, sir.

7 !! Waro thoco two escrions the arcas of primurf ila 0 1; intarost to the Staff with respect to a qualified biologist?

t- .

0! A Thosearetheonesforwhichwohavodoce=oC(1

'O fi ovidenco for which a qualifted biologist -- en which to Q '

1; baso the requirc=ent.

12 j! -

Q All right, sir. E55) 12 - Uhat abcut those other two sections, XII-A an #

14

\ a. I-27 9~@

15 A The Staff roacocod that thosa soctions, basa #

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on all the infor=ation we had, could potentially contain 3 17 ', sinilar uniquo habitats.

ja[ C You have no present evidence that thay do in i l'

19 li fact?

20 A Thora is no concrrito ovidence. that thoro aro 1

2; any unique habitats in that region.

Q All right, sir.

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20 yce-bMim

• hat th re 2 is new any requiremont a

y, ,l as far as tha NRC Staff is concerned that the apolicant

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g-j We a quclified biologict when clearing those proposed i4 he i: I C

366 276

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'ac 7 8 cransmissicn routes?_ _

l A No, ua'ra willing to withdraw the requirement, j j _

3j I Q Dr. Ecng, c' urning to your prepared cactimony, f

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" i, sir, on the cocond pago tharc ic a statement in tho seconc ,

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i I 31 paragraph en that page that after the conclusien of the ,

4 3j construction of the Northoantern Station thout 140 operating 7 il crows will be employed. 5 11 3 Could you tall us, please, how many porcons D i, constitute a crow? Or did you =enn to say thera would bc

!G i;) 140 individuala? i 11 l A (Witnces Hong) Would you rescat tho qucation, 12 .

plecca? ~

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10 ij Q It's the sccond sentonca in the cocond para-I 14 lI I graph ca pago 2 of your prepared testimony. Thora's tho i

15 statoront tha'c about 140 oporating--

16 A Will you indicato the lines?

l 37j Q I'd ha gicd to do it, sir.

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It's the fifth line.

s 39 A The fifth line frcm the top cn the cecend pagc?

zo O The second paragraph on tho accend page.

A okay, 21 ld nl} Q Do ycu seo the reference to 140 cporating crews, I!

3i cir?

t 3h 11 A Right.

3 0 :17 qucation in: Do operating crevs - dce that l .'

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