ML19344E281
| ML19344E281 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/09/1980 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19344E270 | List: |
| References | |
| SBN-126, NUDOCS 8008280308 | |
| Download: ML19344E281 (5) | |
Text
,
PUBLIC SERVICE h -.y of New Hampshre O
5 d
$EABROOK STATION Engineering Office:
20 Tunt#ke Road Westborough, MA 01581 July 9, 1980 SBN-126 T.F. B.4.2.7 United States Nuclear Regulatory Commission Rugion I 631 Park Avenue King of Prussia, Pennsylvania 19406 Gentlemen:
Inspection 50-443/80-05 and 50-444/80-05 Pursuant to receipt of your correspondence regarding 'h? results of the subject inspection, we of fer the following repl'y:
A.
NRC Notice of Violation Section 3.E.(8) of Construction Permit Nos. CPPR-135 r e CPPR-136 requires that, "A control program shall be established by the applicants to provide for a periodic review of all construction activities to assure that those activities conform to the environmental conditions as set forth in these permits."
Section 3.E.(7) of Construction Permit Nos. CPPR-135 and CPPR-136 requires that, "The applicants shall take the necessary mitigating actions, including those summarized in Section 4.5 of the Final Environmental Statement (FES) during construction cf the Station... to avoid unnecessary adverse environmental impacts from construction activities."
Commitment No. 13 of Section 4.5.1 of the FES requires that " Plans will be developed for measares to be used in mitigating undesirable effects of l
construction.
These measures will include erosion control, dust stabilization, landscape restoration, traffic control, restoration of animal habitat, and preservation of archeologica11y valuable artifacts."
i Contrary to these requirements, the licensee's environmental surveillance program, established pursuant to Section 3.E.(8) of the Construction l
Permits, was not adequate to assure rnat certain construction activities I
conformed to the environmental condi': ions as set forth in the above l
l 80 0 82 8 0 3CD16
. e U.S. Nucicar Regulatory Com=ission July 9, 1980 Region I Page 2 Construction Per=its.
Specifically, the following site conditions which existed on May 5-7, 1980 and were not identified by the environ = ental surveillance progra=, were in nonconfor=ance with co==it=ents =ade in Section 4.5.1 of the ETS.
(1) Haybales, used to control turbidity of run-off water at the site peri =eter, were not =aintained in an ef fective condition.
(2)
Waste concrete had been i= properly disposed of at one location.
(30 Erosion was not controlled on the slopes of the " South 40" area.
(4)
Te=porary settling basins were not of sufficient capaci:y nor adequately =aintained so as to effectively control turbidi:y and suspended solids of the effluents.
Response
Corrective Action Taken and Results Achieved This infraction generally deals with the adequacy of weekly environ = ental surveillance progra=.
Af ter the NRC inspection, the site environ = ental inspec:or perfor=ing the surveillance at : bat ti=e was reindoctrinated with the Seabrook Station Environ = ental Protection progra= and retrained for the weekly surveillance and the use of the check sheet.
That individual has recently been assigned to te=porary duty off-site. His replace =ent has also been indoctricated wi:h the Progra= and trained in the surveillance perfor=ance and use of the checklist. Addi:ionally, at the the Second Quar:er 1980 Enviroe= ental Review Board Meeting, it was agreed to initiate a bi-=cc:bly site audit of the weekly environ = ental surveillance by of f-site Review Board =e=bers or designees in addi: ion to the present review of the weekly surveillance reports. This will be i=ple=ented by July 15, 1980.
As to the individual ite=s:
(1) Haybales. where required to control turbid run-off water at the site peri =etec, have been placed or replaced.
Collected secii=ent, in areas where haybales were not in use or did not effectively =itigate run-of f, have been re=oved.
In areas of severe run-of f, additional filtering =easures consisting of TY?AR filter fabric plus crushed stone have been placed so as to direct run-off to points where turbidity can be effectively removed.
This work is now co=plete.
(2) The vaste concrete noted by the inspec:or was i= properly disposed of by an off-site concrete supplier whose driver was unfa=iliar with the project rules concerning correct concrete disposal =ethods.
This concrete is hardened and adhered to the rock face, thereby providing slope protection in itself.
Consequently, it will be left where it is.
In order to prevent re-occurrence by that supplier, he has been directed to have his drivers carry the unused portien of their deliveries back to his batch plant for disposal. Additionally, all
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4 A
U.S. Nuclear Reg matory Commission July 9, 1980 Region I Page 3 contractors using off-site suppliers will be notified of this requirement during their entrance interview beforc com=encing work at Seabrook.
(3) The material noted on side slope of the " South 40" area was improperly disposed of.
It has been and remains our intention to maintain the larger more stable shot rock as the slope face and as a berm at the top of the s. lope to preclude run-off.
The material noted as eroding is a much finer material intended to be disposed of on the top of the disposal area l inside the berm. We feel that the greatest part of the ercsion of this material that will take place has taken place and that efforts to remove it from the slope face will cause more objectionable environmental effects such as displacement of more material, further erosion of " freshly" exposed surfaces, and destabilization of the rock face, than just leaving this material where it is, which we will do.
To preclude any further effects of eroded sediments, fresh haybales have been placed at the foot of the affected slopes. Also, signs have been placed arcund the perimeter of the " South 40" area designating "No Dumping Over Side Slopes." Finally, administrative measures to preclude reoccurrence of the problem have been implemented, including informing all drivers and supervision of the correct disposal methods and areas, issuing a Project Notice explainiag same, and designating one person as responsible for this area and its operations.
Continuing emphasis will be placed on this area during the weekly environmental surveillance.
(4) Efforts to rebuild and enlarge the temporary settling basins were initiated during the May 5-7, 1980 inspection.
That work was completed several days later.
During the week of June 16-20, 1980, the dewatering of the pipe trench serviced by these basins ceased.
Subsequently, neither basin was used again and both are now removed along with that part of the sediment which escaped the basios which could be removed without causing proportionately greater damage to the original ground they were deposited on.
B.
NRC Notice of Violation Section 3.E.7 of Construction Permit Nos. CPPR-135 and CPPR-136 requires that, "The applicants shall take the necessary mitigating actions, including those summarized in Section 4.5 of the FES, during construction of the Station... to avoid unnecessary adverse environmental impacts from construction activities."
Commitment No. 4 of Section 4.5.1 of the FES requires that, " Settling basins will be utilized to control the turhidity of effluents from dewatering processes carried out during construction."
Contrary to these requirements, settling basins as used were not of suf ficient capacity nor adequately maintained to ef fectively control the turbidity of ef fluents from dewatering processes carried out during construction, as shown by silt and sedi=ent deposits from the basin effluents outside the basins on May 5, 6, and 7,1980.
1
'U.S. Nuclear R2gulatory Commission July 9, 1980 l
Region I Page 4 l
Response
l Corrective Action Taken and Results Achieved Please refer to A(4) above. Additionally, it is our intention to remove from use the only two other temporary holding basins now periodically used for discharge of run-off. We are doing this to avoid the difficulty of being aware of when they are in use and monitoring their discharges.
Alternate means will be found, implemented, and these basins removed from use by July 31, 1980.
C.
NRC Notice of Violation Section 3.E.(7) of Construction Permit Nos. CPPR-135 and CPPR-136 requires th a t, "The applicants shall take the necessary mitigating actions, including those summarized in Section 4.5 of the FES, during construction of the Station... to avoid unnecessary adverse environmental impacts from construction activities."
i 4
Commitment No. 14 of Section 4.5.1 of the FES requires that the turbidity l
of waters discharged from holding basins be limited to 25 JTU unless and until acceptable levels have been established.
Contrary to these requirements, the discharge from the permanent settling basin exceeded 25 JTU on numerous occasions including January 8, August 20, October 1, 19,79 and March 3, 10 and April 19, 21, 1980.
Response
Corrective Action Taken and Results Achieved It has been our practice to interpret the term " holding basins" in Section 4.5.1, Commitment No.14 of the Final Environmental Statement, as referring to temporary structures usually built from haybales, filter cloth, and crushed stone.
These " holding o. sins" are employed to filter dewatering effluents that cannot be directed to the permanent settling basin.
Discharge from these " holding basins" has a turbidity limit of 25 JTU or less.
We also interpret the discharge from the permanent settling basin to be l
controlled under the ef fluent limitations as specified in NPDES Permit No. 0020338 which for turbidity is 10 JTU. Against this criteria we have determined that for essentially the entire period from December, 1978 to the present, we have not been in compliance. As directed by permit requirements, we have notified the EPA and State of New Hampshire Water Supply and Pollution Control Commission of the non-compliance, its sustained nature, and our efforts to identify the source of the turbidity and reduce it to a complying level.
We originally suspected, and continue to feel, that the tunnel dewatering effluent is the major contributor of turbidity in the settling basin.
This has been strengthened somewhat by our observation that as the tunnel flow has increased, so has average turbidity of the ef fluent from the basin.
'. 'U.S. Nucicar R2gulatory Co==iscica July 9, 1980 Region I Page 5 To date, working on this pre =ise, we have tried a s=all =ulti-celled cascade settling basin to rective the tunnel discharge prior :o pu= ping to settling basin; introducei. a poly =eric flocculant, POLYFLUC II, to the tunnel discharge line; built, in the tunnel, a two-celled setriing basin with 90-120 =inu:e recentica ti=e; and have, most recently, relocated the POLYFLUC II =etering and pu= ping syste= to ground level so that this flocculant can be introduced after the tunnel discharge is pu= ped but prior to introduction to the settling basin so that the =echanical action of the pumps will not break the floc chains formed.
In Septe=ber, 1979 while washieg down the tunnel rock walls for geologic
=apping, iron bacteria was noted on the walls.
k'e evaluated whether this iron bacteria was contributing to the turbidity in addition to the rock fines resulting fro = the = ole operation.
The results of the evaluation were inconclusive but led us to consider that a ferrous to ferric reaction =ay be taking place in the settling basin after deposi: of the tunnel dewatering effluent.
Most recently we have perfor=ed bench tests on various oxidining agents that =ay be used to bring about oxidation, flocculation and settling of iron in the settling basin. However, before we initia:e such efforts, we are considering all ra=ifications so tha: a solution to :he turbidity proble= does not crea:e a larger problem, = ore environ =entally objectionable or har=ful than the original one.
Accordingly, we cannot offer a date when we will achieve co=pliance.
Ou r efforts are ongoing and will continue until we find the source and the solution of this deficiency.
3:cause of this turbidity nonco=pliance, we have given particular attention to biological =onitoring infor=ation fro = the Browns River sa=pling stations tha:
hcVe been =aintained since ce==ence=ent of construction activity.
Senthic co== unity data for 1979 shows no evidence of either qualitative or quantitative shifts frc= that of earlier years.
Please contact us if you require additional infor=ation.
l l
Very truly yours,
'yY John DeVincentis
(
J Project Manager l
JD/ncj i
i I