IR 05000250/1978022

IE Inspec Rept 50-250/78-22 & 50-251/78-22 on 780912-15 During Which 1 Item of Noncompliance Was Noted:Review of Groundwater Monitoring Sched Not Done Quarterly But semi- Annually W/Out Benefit of Req Amend to Lic

ML17338A337
Person / Time
Site:	Turkey Point
Issue date:	10/12/1978
From:	Cunningham A, Hufham J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17338A333	List: IR 05000250/1978022 L-78-364, Ack Receipt of IE Inspec Rept 50-250/78-22 & 50-251/78-22 on 780912-15.Does Not Consider Any Info Therein to Be Proprietary ML17338A332 ML17338A335
References
50-250-78-22, 50-251-78-22, NUDOCS 7812050249
Download: ML17338A337 (9)

Text

gal% REGgg (4 P

O UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30303 Report Nos.:

50-250/78-22 and 50-251/78-22 Docket Nos.:

50-250 and 50-251 License Nos.:

DPR-31 and DPR-41 Licensee:

Florida Power and Light Company P. 0.

Box 529100 Miami, Florida 33152 Facility Name:

Turkey Point Plant Units 3 and

Inspection at:

Turkey Point Plant Homestead, Florida Florida Power and Light Company Miami, Florida Inspection conducted:

S ptember 12-15, 1978 Inspector:

A. L. Cunni ham Approved by J.

.

ufha En ronmenta F

Facilit e

Special Projects Section Materials Safety Branch Date Ins ection Sumna Ins ection on Se tember 12-15 1978 (Re ort Nos. 50-250/78-22 and 50-251/78"22 environmental protection program including management controls; environmental monitoring; environmental surveillance and assessment; plant reporting requirements; review of canal dilution test program; review and discussion plant intake coffer dam leakage; followup on previously identified enforcement items.

Inspection involved 30 inspector-hours on-site by one NRC inspector.

Results:

Of the seven areas inspected, no apparent items of noncompliance and deviations were identified in six areas.

One apparent item of non-coapliance was identified in one area (deficiency - periodic review of groundwater aonitoring schedule, Details I, paragraph 6.b).

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<<.'~)HS 4>>'

RII Rpt.

Nos. 50-250/78-22 and 50-251/78-22 DETAILS I Prepared by:

A. L. Cunningham, nvI ntal Scientist Environmental and Special Projects Section Fuel Facility and Materials Safety Branch Dates of Inspection:

S ptem r 12-15, 1978 Reviewed by J

W.

ufha e

Special Projects Safety Branch E

ironmental ection Fu 1 Facility and Materials ate 1.

Persons Contacted

• Y. M. Gaafer, Site Superintendent J. Hays, Plant Manager W. E. Abel, Assistant Supervisor, Monitoring and Research Ronald H. Hix, Senior Environmental Specialist-G. D. Whittier, Licensing Engineer

+J.

Pendland, Nuclear Licensing Engineer

• N. Ranek, Environmental Engineer

• Denotes those present at exit interview.

2.

Licensee Action on Previous Ins ection Findin s (Closed)

Noncompliance (77-09-01):

Reporting Requirements:

Licensee stated that records and analysis of the biological study identifying numbers and variety of fauna associated with the cooling canal banks as compared with the area surrounding the cooling canals which were neglected in previous semiannual reports, would be included in the report for the period ending June 30, 1977.

The licensee also stated that data prior to December 31, 1976, would be submitted separately by September 11, 1977.

The inspector reviewed semiannual and all interim reports for periods extending through June 30, 1978.

Inspection confirmed that faunistic studies were implemented and reported as required.

There were no questions regarding this item.

(Closed)

Noncompliance (77-9-02):

Baseline Terrestrial Ecological Reports.

The licensee stated that suamary reports of the baseline ecological studies, including the years 1975 and 1976 would be

RII Rpt. Nos. 50-250/78-22 and 50-251/78-22 I-2 completed by June 1,

1978.

The inspector reviewed the suamary report submitted.

There were no questions regarding this item.

3.

Unresolved Items No unresolved items were disclosed during this inspection.

4.

Mana ement Controls a

~

Section 5.0 of Appendix B Technical Specifications charges the licensee with responsibility for establishment, execution and review of programs to administer the Environmental Technical Specifications (ETS).

The specification further requires detailed written operating procedures and the establishment of organizational and administrative procedures that will provide for management review and independent audit functions to assure implementation of the ETS.

The inspector reviewed organizational responsibility for implementation of environmental monitoring, surveillance, and special studies programs defined in Appendix B

Technical Specifications.

Review of FPSL Corporate-Organization Environmental Affairs functions and detailed discussions with both licensee and licensee contractor representatives disclosed that program management and responsibilities appeared consistent with those requirements defined in the ETS.

b.

Section 5.1 of Appendix B Technical Specifications provides for periodic management review and independent audit of all requirements and conditions defined in the specifications.

The inspector reviewed the minutes and proceedings of meetings of the Company Environmental Review Group (CERG) for the period July, 1977 through August, 1978.

The inspector also reviewed and discussed with licensee representatives the Quality Assurance Report for Audit Nos.

QAA-LEP-77-1 (May 12 - June 28, 1977)

and QAA-LEP-78-1 (May 31 - August 8, 1978) which concerned the Environmental Engineering Department compliance with FPQ.

QA Manual QPs 4.4, 6.2, 17.1, and implementation of St. Lucie Unit

and Turkey Point Units 3 and 4 ETS.

Inspection disclosed that the licensee's review and audit programs appeared to meet all requirements of the above cited specification.

5.

Environmental Monitorin Appendix B Technical Specification 3.2 requires periodic monitoring of cooling water discharged from the licensed facility into Lake Warren for the following physicochemical parameters:

(1) daily: pH, DO, and salinity; (2) weekly:

NHg, BOD and COD; (3) monthly:

Cu, Zn, Co, hs, Hg.

The inspector reviewed monitoring proceduresy audited monitoring

RII Rpt.

Nos. 50-250/78-22 and 50-251/78-22 I-3 records for the period June, 1977 through August, 1978, and discussed the monitoring program with licensee representatives.

Inspection disclosed that all monitoring requirements were implemented as defined by the above cited specification.

6'.

Environmental Surveillance and Assessment Appendix B Technical Specification 4.0 requires implementation of an environmental surveillance and special study program to provide information for assessment of the impact of plant operation on the environment.

Section 4.A of the specification defines the conditions and requirements for aquatic surveillance.

Surveillance currently includes groundwater studies and biological monitoring of plankton, fish, benthos, and physicochemical characteristics of microbial activity in cooling canal soil sediments.

Section 4.B of the specification defines requirements for terrestrial surveillance which includes the following:

(1) baseline program; (2) impact studies; (3) revegetation of the cooling canal banks; (4) long-term monitoring.

b.

The inspector reviewed the licensee's aquatic surveillance program, including review of procedures, records, reports, and field data for the period June, 1977 through August, 1978.

The following specific areas were inspected:

(1) groundwater studies; (2) monthly plankton, fish and benthos monitoring; (3) semiannual monitoring of benthic organisms.

In the case of the groundwater study, defined in Appendix B Technical Specification 4.A.2.a, inspection disclosed that the licensee implemented a change in the review requirement without benefit of an approved amendment to the specification.

The specification required that the licensee review the groundwater monitoring schedule, on a quarterly basis, with the Central and Southern Florida Flood Control District (CSFFD) in consultation with the USGS.

The licensee changed the above cited review frequency to semiannual making it effective during the third quarter of calendar year 1977.

A licensee representative stated that a request for ETS revisions, including the change implemented above, was submitted to the NRC February 28, 1978; however, the request had not yet been acted upon by the NRC.

The inspector informed licensee representatives that failure to comply with the required review frequency, as stated in the subject specification, constituted an item of noncompliance (250/78-22-01, 251/78-22-01).

The inspector also informed licensee representatives that he would discuss the subject citation with his management upon return to, the Regional Office.

The inspector later contacted the licensee and informed them that NRC regional management concurred in the finding.

Since a change to the subject Technical Specification was requested by the licensee's

RII Rpt. Nos. 50-250/78-22 and 50-251/78-22 I

I-4 letter to the NRC Office of Nuclear Reactor Regulation dated February 28, 1978, no further response to this item is required.

It should be understood, however, that no revision is in accord with the Technical Soecification requirments unless and until it is specifically authorized by the NRC Office of Nuclear Reactor Regulation.

c

~

The inspector reviewed the licensee's terrestrial baseline program.

The program was designed to establish baseline conditions characteristic of the South Florida terrestrial ecosystem through a comprehensive three-year research effort to provide control information against which impact of the cooling canal system would be evaluated.

The study was initiated in March, 1973, and concluded in September, 1976.

The following requirements were included:

(1) definition of types and relative abundance of natural plant associations as a function of topography over a 10,000 acre tract of land which includes tidal, mangrove salt marshes, freshwater wetland, and dry land communities; (2)

kinds and abundance of native animals that live in association with the different plant communities; (3) experimental studies of selected parameters such as effects of soil physicochemical and I

microbial characteristics on occurrence of plant association groups.

Inspection disclosed that all elements of the program were implemented as required.

d.

The inspector reviewed the licensee's program on revegetation of the cooling canal banks, including review of procedures and records (period June, 1977 through August, 1978), discussions with personnel and observation of selected areas of the cooling canal system.

The following specific areas were inspected:

(1)

spoil bank erosion; (2) spoil bank vegetation; (3) physicochemical and nutrient analysis of spoil bank soils.

There were no questions regarding this item.

IP 7.

Plant Re ortin Re uirements Appendix B Technical Specification 5.4.a.

requires that the Semiannual Environmental Monitoring Report include records of monitoring require-ments surveys and samples, and an analysis of environmental data.

The inspector reviewed and audited the Semiannual Environmental Monitoring Report for the periods ending December 31, 1977 and June 30, 1978, to assess its compliance with the above cited specification.

Inspection disclosed that these reports were consistent with the requirements defined in subject specification.

Inspection also included a review of the report on the baseline ecological studies defined in Technical Specification 4.B.1.

There were no questions regarding these item RII Rpt.

Nos. 50-250/78-22 and 50-251/78-22 I-5 8.

S ecial Pro rams The inspector reviewed the status of the In-dilution Test Program.

This program was initiated on July 25, 1978, and involves infusion of water from Card Sound into the cooling canal system at an approximate rate of 300 cfs.

The program is designed to assess the effect of dilution on diminution of "scaling in the Units 1, 2, 3 and

condenser tubing.

At the time of inspection, effect of the test could not be assessed because of heavy rainfall during the test interval.

There were no questions regarding this item.

9.

Intake Canal Coffer Dam During the course of the inspection, the licensee reported that an opening was verified on September 12, 1978, in the intake dam structure separating the cooling canal system from the barge turning basin.

The opening resulted from a separation of the interlock between adjacent sections of barrier dam sheet piling.

Licensee representatives confirmed that some exchange of water was occurring.

through the opening under conditions of normal tidal fluctuations; e.g.,

under the low, low tidal cycle, maximum loss of water from the canal system to the basin was estimated at 68 cfs.

Minimal environ-mental impact was anticipated.

The licensee has initiated steps to repair the breach and submitted a nonroutine report to NRC Region II Director.

This incident and all mitigating actions will be reviewed during a subsequent inspe'ction.

10.

Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on September 15, 1978.

The inspector suamarized the, scope of the inspection and discussed the findings listed herein.