ML19347B087

Responds to NRC 800711 Ltr Re Violations Noted in IE Insp Rept 50-483/80-17.Corrective Actions:Engineers Informed That Site Burning of Solid Waste Not Permitted.Required Monitoring Devices Installed,Calibr & Placed Into Svc

ML19347B087
Person / Time
Site:	Callaway
Issue date:	07/31/1980
From:	Bryan J UNION ELECTRIC CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19347B085	List: ML19347B087
References
ULNRC-372, NUDOCS 8010010503
Download: ML19347B087 (5)

Text

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O UNION ELECTRIC COMPANY g teos omarsov svarrv ST. Louis. Missoumi July 31, 1980 so ..u

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Mr. A. B. Davis, Chief Fuel Facility and Materials Safety Branch U.S. Nuclear Regulatcry Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Davis:

ULNRC- 372 ,

INSPECTION REPORT NO. 50-483/80-17 This is in response to your letter of July 11, 1980, reporting results of an inspection at Union Electric Company's Callaway Plant Site on June 26 and 27, 1980 and as detailed in inspection report number 50-403/80-17.

None of the material in the inspection report or in the response is considered proprietary by Union Electric Company.

The following is in response to the items listed in Appendix A, Notice of Violation, of the inspection report.

Deficiency (483/80-17-01)

Section 3.E.4 of Construction Permit CPPR-139 requires, in part, l that the' applicant shall establish a Control Program which shall include written procedures and instructions to control all con-struction activities as prescribed herein and shall provide for periodic management audits to determine the adequacy of the im-  !

plementation of environmental conditions. Section 1.2.3 of the  ;

applicanes Control Program requires, in part, that burning will )

be properly supervised and there will be no burning of solid waste containing garbage.

Contrary to these requirements, solid waste and garbage was ob-served burning in the "new" land fill trench area on June 27, 1980, with no one in attendance and the old land fill area con-tained evidence of frequent burning of trash containing garbage.

AUG 2 8 G5h 80100110 R325 l

Mr. A. B. Davis July 31, 1980 CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

A meeting was held on July 3, 1980 and all appropriate C.

struction Superintendents and outside Area Engineers were in-formed that burning is not permitted on site, without prior approval and control from Union Electric Nuclear Construction.

In addition, the initial coordinatien with the State of Missouri Department of Natural Resources has been established for the purpose of obtaining an approved burning permit for wood-type wastes.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

The Project Environmental Coordinator will continue to make frequent inspections of the landfill and will assure tPat all new construction and area engineering personnel are familiar with the burning regulations.

Any future burning performed after receipt of the authorizing permit will be monitored by the Environmental Coordinator and supervised by the appropriate Construction Superintendent.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Daniel is presently in full compliance. There will be no burning of solid waste until we are in possession of a burning permit issued by the Missouri State Department of Natural Resources.

DEFICIENCY (483/80-17-02)

Section 3.E.4 of Construction Permit CPPR-139 requires, in part, that the applicant shall establish a Control Program which shall include written procedures and instructions to control all con-struction activities as prescribed herein and shall provide for periodic management audits to determine the adequacy of the im-plementation of environmental conditions. Section 3.2.1 of the applicant's Control Program requires a Surface Water Quality Monitoring Program designed to identify those chemical effluents which if released during construction activities may inhibit aquatic organisms or, in some way, reduce the desirability of the water for recreational uses. Tables 3.2.-1, 3.2.-2, 3.2.-3 and 3.2.-4 list typical parameters which will be tested based on type, duration, and extent of construction activities. In ad-dition, discharge flow will be monitored from each of the site's settling ponds. Quarterly sampling locations are shown on Figure 3.2-1.

Mr. A. B. Davis July 31, 1980 t

a. Contrary to these reg '.remen ts , " Stream flow" a para-meter listed in Table 3.2.-1 was not measured December 20, 1979.

b. Contrary to these requirements, sample location A-2, listed in Figure 3.2.-1, has not been sampled since June, 1979.

CORRECTIVE ACTION TAKEN AND THE REbOLTS ACHIEVED:

a. Although stream flow at stations B-2, C-2, D, E-1 and E-2 were not listed on Table 1 of the December 20, 1979 i water quality report, they were indicated in the text of the letter dated February 5, 1980 from Envirodyne Engineers as follows:

B-2 & C-2 were 59,000 cfs D, E-1 and E-2 were < 1 cfs Thus, no corrective action was taken.

b. Wilcoxan's sum rank test was used in the statistical analysis of the 1973-1974 water quality data. Wilcoxan's test is a nonparametric test designed to evaluate two independent samples. The results indicated that Station A-1 and A-2 were statistica3'.y homogeneous. Thus, it was decided that sampling of Station A-1 would be suf-ficient to provide an upstream " control" sample for com-parison with other downstream samples. Therefore, Station A-2 was not monitored during the construction monitoring program. Station A-2 was inadvertently left on Figure 3.2.-l. The Environmental Protection Program-Construction Stage will be revised to remove this incon-sistency.

CORl!ECTIVE ACTION TO BE tai'EN TO AVOID FURTHER NONCOMPLIANCE:

a. No further action required.

b. Figure 3.2-1 of the Environmental Protection Program-Construction Stage will be revised to remove Station A-2.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

a. UE is presently in full compliance,

b. The Environmental ProtectiGn Program-Construction Stage revision will be issued by September 1, 1980.

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Mr. A. B. Davis July 31, 1980 DEFICIENCY (483/80-17-03)

Section 3.E.4 of Construction Permit CPPR-139 requires, in part, that the applicant shall establish a Control Program which shall include written procedures and instructions to control all construction activities as prescribed herein and shall provide for periodic management audits to determine the adequacy of the implementation of environmental conditions. Section 3.2.1 of the applicanthCbntrol 1 Program describes a Surfs 7e Water Quality Monitoring Program which, l in part, requires the monitoring of the discharge flow from each of the site's settling ponds.

Contrary to these requirements, discharge flows from the site's settling ponds are not being monitored.

CORRECTIVE ACTION TAKEN AND THE RESULTS ACHIEVED:

New steel angle frames have been fabricated and are awaiting installa- l tion at the settling pond locations. The monitoring devices will then be mounted to the new frame supports, be calibrated and placed into operation.

In addition to the equipment installation, as described above, the related work procedure " Surface Water Quality" (WP-7 02) will be re-vised to allow for either the visual recording of the discharge flow when no overflow is occurring or for estimating the flow on occasions when the equipment might be temporarily inoperable.

CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:

Installation of the monitoring equipment and revision of WP-702 is designed to avoid further noncompliance when discharge information is not available.

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THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Installation of monitoring equipment will be achieved by August 15, 1980. Full compliance will be achieved upon revision of WP-702 which will be issued by September 5, 1980.

Mr. A. B. Davis July 31, 1980 If you have any questions regarding this response or additional informattion is required, please let me know.

Very truly yours, 1

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h\ / W d.s (JohnK. Bryan (i NGS/mdj l cc: Mr. H. M. Wescott, NRC Region III i Mr. W. A. Hansen (NRC Resident Inspector, Callaway Plant)

Missouri Public Service Commission i.

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