IR 05000003/1974014
| ML20050A277 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/27/1974 |
| From: | Bores R, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A272 | List: |
| References | |
| 50-003-74-14, 50-247-74-14, 50-286-74-19, 50-3-74-14, NUDOCS 8203310666 | |
| Download: ML20050A277 (19) | |
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RO I Form 12 (Oct 74) (Rev)
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U. S. ATO:!IC E::CRGY CO:2iISSIO:i DIRECT 05ITE OF REGULATORY OPE?aTIO::S
REGION I
50-3/74-14 50-3 - Unit 1 50-247/74-14 50-247-Unit 2 RO Inspection Report No:
50- 2M / 74-19 Docket No:
sn_9:r, " 3 - 3 DPR-5 Licensce: Consolidated Edisen Conranv of Nat. York. Inc. (Con Ed) License No: DPR-M CPPR-62 4 Irving Place Priority:
C - Unit 1 New York, New York 10003 Category:
c - U.,4e 2
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B - Unit 3 Safeguards Group-Location: Indian Point Nuclear Station, Units 1, 2, and 3
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Buchanan, New York Type of Licensee:
Unit 1:
PUR, 290 Infe (B&t1); Unit 2:
"t<R,
873 MWe (W); Unit 3:
Pl.~d, 905 MWe (W)
Type of Inspection:
Announced Enviroacental Routine Dates of Inspection:
October 21-24, 30-31, 1974 Dates of Previous Inspection: September 28-October 1, 1974 N A*.10.0 '
/.#d6)
it. 87. T S/
I Reporting Inspector:
lf' Robert J. Bo[s, Radiation Specialist DATE g
Accompanying Inspectors:
None DATE
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DATE DATE Other Accompanying Personnel:
None DATE sd' a
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Rsviewed By:
w.'..:M O.*c-_.s,u'--
sto r,1 7 /
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h J. P. Stohr, S!nior Environmental Scientist D.iTE 8203310666 741129
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PDR ADOCK 05000003 O
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SU?"t.iRY OP FI"DI!!CS Enforcenent !.ction (Envi$on ental bonitorina)
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The follo.f.ing two iter.s were found to be in violation of the radiologi-cal environmental conitoring progran specified in Section 4.2 of the Environnental Technical Specifications, Appendix B to the Operating-c License for Indian Point Units 1 and 2.
1.
Can=a spectral analvses were not perforced on each air particulate l
filter and on each airborne iodine sacple, as required.
(De tails,
Paragraph 4.a)
2.
Analysis of milk samples for I-131 were not carried out within
eight days of sampling, as reouired.
(Details, Paragraph 4.b)
One iten was found to be in violation of Section 4.1.2.a of the Environ-mental Technical Specifications, Appendix B to the Operating License for Indian Point Units 1 and 2.
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1.
The specified provisions for making changes in the surveillance and special studies programs vere not followed in naking changes to the impingement program.
(uctails, Paragraph 9.a)
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Licensee Action on Previousiv Identified Enforcement Items (Environmental Monitorinz)
Four'itets of nonconfor=ance vere identified in RO Inspection Report No. 50-286/73-05, 50-3/73-08 relating to the environnental nonitoring requirements, as follows:
1.
Failure to perform air particulate sampling using the mobile moni-tor af ter }brch 1973.
(Details, Paragraph 4.a)
2.
Failure to perforn H-3 analyses on rainfall samples from all of the
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required locations for each reauired sampling interval.
(De tails,
Paragraph 4.c)
3.
Failure to sannle well water from each required location during each required sampling interval.
(Details, Paragraph 4.d)
4.
Records were unavailable to confirm that H-3 analyses were performed on a number of required water samples during >by 1972.
(Details, Paragraph 4.d)
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All of the items of nonconfornance listed above have been corrected.
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Desien Chances None Other Sicnificant Findines (Environmental Monitorine)
A.
Current Findines (Unresolved Itces)
1.
Conpliance with Appendix B, Environmental Technical Specifica-tion 2.1.3, Maximum Ecat Rejection Rate (BTU /hr), could not be determined from the method used to calculat'e the heat rejection rate.
(Details, Paragraph 7)
2.
Compliance with Appendix B, Environmental Technical Specifica-tion 5.6.E.2.a, Reporting Recuirement for I-131 Concentrations in Air, could not be determined because the sensitivity of analysis was not sufficient to determine the report levels.
(Details, Paragraph 4.a)
'B.
Status of Previous 1v Renorted Unresolved Items Two unresolved itens were identified in RO Inspection Report No. 50-286/73-05, 50-3/73-08.
1.
The diking of transformers was reviewed during the inspection and is no longer considered to be an unresolved item.
(Details,
Paragraph 11)
2.
The quality control program and analytical procedures for the environmental progran were reviewed, and this item is no longer considered unresolved.
(Details, Paragraph 5)
Manacenent Interview Jon October 31, 1974, following the inspection, a meeting was held in the of fice of Mr. W. Stein, lbnager, Nuclear Pover Generation, at Indian Point Nucicar Generating Station. The following individuals
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were in attendance:
Mr. R. Bores, Radiation Specialist, USAEC, RO:I Mr. W. Stein, Manager, Nuclear Pouer Generation, Con Ed Mr. R. Van Wyck, Ibnager, Nuclear Services, Con Ed Mr. A. Cheifetz, Director, Radiation Safety, Con Ed Mr. J. Kelly, Plant Chemistry Director, con Ed Mr. P. Crinican, Nuclear Environmental Monitoring Supervisor, Con Ed Mr. M. Considine, Engineer, Of fice of Environmental Affairs, Con Ed Mr. G. Wasilenko, Quality Assurance, Con Ed
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During this meeting, the following items were discussed:
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A.
Air Samnlinz Pre ran The inspector stated that Table 4.2-1, Section 4.2.1.a of the Environmental Technical Specifications, Units 1 and 2, recuires that air particulate samples and air iodine samples each be analy-zed by gamma spectral analysis in additien to the gross beta analy-ses.
The inspector stated that, uith the exception of the time when the sanples were collected and analyzed according to the Program 2 reoisirements, the air particulate samples were compos-ited, as were the air iodine samples, and gamma spectral analyses were performed on the composite samples from each station on a monthly basis in violation of the requirements.
The inspector stated that the violation reported in RO Inspection Report No. 50-286/73-05, 50-3/73-08 in reference to the mobile air monitor had been corrected.
He also stated that Section 5.6.E.2.a of the Environmental Technical Specifications for Units 1 and 2, requires that if individual charcoal filters show I-131 airborne concentrations greater than 1.1 x 10-14 microcuries per em3 and the milk pathuay of population exposure is involved, that these results be reported to the AEC wi thin 74 hmirs.
The inspecter fur *ka-stated that his inspection revealed that the air iodine monitoring systems employed dig,not have sufficient sensitivity to determine the I-131 concentrations at the above level.
He stated that this area was considered unresolved at the present time.
(De tails,
Paragraph.4.a)
B.
Milk The inspector stated that Section 4.2.1.b of Appendix B, Environmen-tal Technical Specifications, recuire that analysis of milk samples for 1-131 be-carried out within eight days of sampling. The inspec-tor stated that this requirement was not met in most cases, in viola-tion of the above recuirement.
(Details, Paragraph 4.b)
C.
Inninnenent Procram i
The inspector stated that several changes had been made in the fish impingccent study program specified in Section 4.1.2.a(2)VI, Appen-dix B, Env.ronmental Technical Specifications for Units 1 and 2.
The inspector stated that channes could be made by the licensee in the Special Studies Proeram in accordance with Section 4.1.2.a(1)3(3)
of these Srecifications.
This sec tion.recuires tha t these changes
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be revieved by the Environmental Protection Committee (EPC) in
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accordance with the Adninistrative Controls specified in Section 5.13 of these Technical Specifications, prior to implementing the propcsed changes cad then dochnenting these chanpes in the next semi-annual report.
The inspector stated that the frequency of washing the traveling screens and the cethod of subsannling impinged fish had been changed from those specified in Section 4.1.2.aVI, prior to its review by the EPC.
These changes were not reported in the next seni-annual report (January to June 1974) in violation of the above requirements.
(Details, Paragraph 9.a)
D.
!!axinun Heat Reiection Race (BTU /hr)
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The inspector stated that Section
.l.3 of Appendix B, Environmental TechnicalSpecifications, Units 1)and2,requiresthat the maxinun heat rejected to the river from each unit not exceed specified values as calculated by the given formula.
The inspector stated that the given nethod of calculation as used by the licensee was not suffi-
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cient to show conpliance with the maximun heat rejection limits for each unit, as specified.
The inspector stated that this matter was considered unresolved.
(Details, Paragraph 7)
E.
Discharpe_V,elocity The inspector stated that as part of the inspection the regulation of the gates of the discharge structure was reviewed.
He further j
stated that at the time of inspection of the discharge structure the water level narkers were covered with a growth such that the water levels could not be accurately read.
(The inspector noted that no discharge port changes had been required during the previous two weeks.)
The licensee stated that since the inspector's visit to the structure, these markers had been cleaned and the procedures modified to require prenpt cleaning, as necessary.
(Details, Paragraph 8)
F.
Transforner Slac Pits The inspector inquired as to the adequacy of the transformer slag pits to contain the oil in the event of a major leak or transforner rupture. The licensee stated that this had not yet been evaluated but that this natter would receive pronpt attention.
(Details, Paragraph 11)
G.
Radiolocical Sannif ne and Annivtical '_rocedures The inspector discussed a number of other items involving the
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radiological envirennental saapling and analytical programs, including:
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The physical placement of thernoluminescent dosinctors (TLD's)
such that shieldir.g from their surroundings is mininized wherever practical.
(Details, Paragraph 4.g)
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The use of funnels or other devices to reduce the anount of evap-oration from precipitation samples.
(Details, Paragraph 4.c)
3.
The use of hcl in water samoles to prevent selective io.ns from plating out on container walls.
(Details, Paragragk 4.d)
4.
The assurance that representative samples of media, such as soil or vegetation, are actually used in the analyses.
(Details,
Paragraph 4.e)
5.
The need for the licensee to be familiar with analytical proce-dures, capabilities and limitations, including the comparison of split sample data from different contractors.
0 Details, Paragraph 5)
H.
Previous Enforcement I t en s_
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The inspector stated that he revieued the licensee's actions on cach of the items of nnnennforr?nce listed ir PP I., cr9r "ep-_ t No. 50-286/73-05, 50-3/73-08 and found that each iten had been cor-rected. The unresolved items listed in that report were now con-sidered resolved.
(Details, Paragraphs '4.a, 4.c, 4.d, 5, and 11)
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DETAILS 1.
Persons Centacted Consolidated Edisen Connany Mr. W. Stein, Manager, "uclear Pouer Generation Mr. R. Van Wyck, Ibnager, Nuclear Services Mr. A. Cheifets, Director, Radiation Safety J
Mr. J. Kelly, Plant Chemistry Director
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Mr. P. Crinigan, Nuclear Environmental Monitoring Supervisor Mr. M. Considine, Engineer, Office of Environmental Affairs Mr. G. Wasilenko, Quality Assurance Mr. S. Julias, General Supervisor, Performance Mr. J. Higgins, General Chemical Supervisor
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Mr. A. Ferraro, Engineer Mr. S. Cancone, Chief Operations Engineer
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Mr. S. Zulla, Acting Operations Engineer, Unit 3 Texas Instrunants Incorporated (Ecoloeical Services)
Mr. B. Smith, Assistant Technical Director Mr. P. CrrcSc, " :: C:..;_; S per elaue Mr. D. Mayercek, Task Lead,er, Impingement Mr. P. Muessig, Group Leader, Impingement Physiology Teledvne Isotopes Dr. D. Schuts, Vice President
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Dr. D. Martin, Manager, Applied Physics Mr. K. Roach, Project Coordinator
_ York Research Corcoration Mr. R. Kearton, Field Supervisor 2.
General The inspection consisted of a review of the environmental monitor-ing program at the Indian Point Nuclear Generating Station (IP)
site, Buchanan, New York, enco= passing both the radiological and nonradiological aspects of these programs.
The licensce's opera-tional environ =catal conitoring require =ents for Units 1 and 2 are specified in Appendix B to the Facility Operating License DPR-26, Environmental Technical Specification Requirenents for Units 1 and 2.
The licensee's preoperational conitoring requirements
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~7-for Unit 3 are described in Section 2.9.2 of the Unit 3 FFAR and are essentially censistent with the radiological environmental progran specified for Units 1 and 2.
Areas included in this inspection vere a selective examination of air sampling, precipit: tion collection and gan=a dosimetry (TLD)
stations, the impinge =ent and fisheries program, noteorologv, the chemical and thernal conitoring of discharges, sampling and analy-tical procedurcs, renresentative progran results, interv$ews with licensee and contractor personnel and observations by the inspec-tor.
As part of this inspection, the labcratory facilities of Texas Instrutents, Incorporated, who perforned the impingement and fisheries studies, and the laboratory facilities of Teledyne
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Isotopes, Westwood, Neu Jersey, who perforned some of the radiolog-ical analyses for the licensee, were visited.
3.
Organization and Administration All environmental sacples for radiological analyses are collected
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by' Con Ed personnel.
all of the recuired gross alpha, gross beta (and H-3 analyses of water sa=ples) are perforced by Con Ed under-the superv'ision of Mr. P. Crinigen, who reports to Mr. A. Cheifetz, Oirc;ior cf ?._Cla*ie.. E fu'j,
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Manager, Nuclear Services, con Ed.
The samples are then sent to Teledynn Isotopes, Uestuood, New Jersey for required gamma spectral analyses, I-131 analysis for milk, Sr-89 and 90 analyses and H-3 a nalys es.
Since January 1974 duplicate nilk samples were also sent to Eberline Instrument Corporation, Southeastern Facility, West Columbia, South Carolina for I-131 and gat =a spectral analyses.
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sults of these analyses are reviewed by Mr. Van Wyck, Mr. Cheifetz
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and Mr. Crinigan.
Chemical discharges are monitored by the plant chemistry staff under the direction of Mr. J. Kelly, and the therca,1 discharges and hydro-logical conditions are conitored by the plant operations personnel.
Site meteorological data is processed by Con Ed while the touer instrunentation is maintained and calibrated by York Research-
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Corporation, Stanford, Connecticut.
.The biological (acuatic) studies are funded and directed thr: ugh Mr. H. Woodbury, Vice President for Environmental Af fairs, Con Ed.
The studies along the Hudson River are conducted primarily under
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contract with Texas Instruments, Inc. O!r. J. Taylor,' Proj ect LManager) for the fisherles'and inpingement studies and New York University ("r. J. Lauer,-Project "anager) for entrainacnt studies.
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Mr. M. Considine,. Con Ed, oversecs and coordinates these s tudies a t the Indian Point site.
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Other studics being perforned for Con Ed include thernal conitoring 0)cncs and Moore), thernal codeling (ouirk, Lauler and natusky and Alden Labs) and radioccology (Neu York University).
The review and audit of the radiological nonitoring progran were carried out, as required, by the Nucicar Facilities Saf ety Co==ittee (NFSC) and that of the nonradiological conitoring and studies pro-gran by the Environ =catal Protection Cocaittee (EPC).
4.
Radiolocical Monitorfec Procran I
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Airborne Activity Section 4.2.1.a and Table 4.2-1 of the Environ = ental Technical Specifications for Units 1 and 2 and Section 2.9.2 of the FSAR of Unit 3 describe the air monitoring requirements for the site.
Table 4.2-1 requires that weekly air oarticulate and air iodine
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samples be taken at five locations and each be analyzed for gross beta-ganna and ganna spectral activity during the Pro-gram 1 nonitoring regime.
In addition, the Unit 3 FSAR re-quires that a nobile air conitor be used to ' sample air at one of four selected offsite stations.
In renard to the latter requirenent, the inspector noted that the mobile nonitoring progran had been reinstituted follouing the last inspection of this area. Termination of this prograc
had been identified as an item of nonconfornance in RO Inspec-tion Report No. 50-286/73-05, 50-3/73-08. The inspector stated that this item had been corrected.
The inspector's examination of several of the air sampling sta-tions revealed that all appeared to be functioning properly and were essentially the sacc as described in the above mentioned inspection report.
The inspector inquired as to the collection efficiencies of the charcoal ' impregnated filter paper currently
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used to conitor airborne iodine.
The inspector reviewed the licensee's documentation in this matter and found that these filters were reported to be approxicately 500 efficient for collecting elenental iodines, but less than 2% efficient for collecting organic iodines.
The licensee stated that a collec--
tion efficiency of approxicately 50% was used in calculating airborne iodine activities.
(The combined collection effi-ciency and the counting efficiency was taken as 0.25 for the counting systen.) The licensee stated that he was arare of the poor colicetion properties of this charcoal paper and uas in the process of evaluating a charcoal cartridge (Cartridge -
No. 4235-IC, manufactured by Scott, Acne Products Division) uith
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a parallel sanpline pror an.
The licensee's information indi-
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cated that this filter was greater than 99% efficient for col-Iceting elc= ental iodine and greater than 80% for the organic
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iodine species.
The licensee stated that the use of these filters would be implemented into the environmental monitoring progran within the next several nonths.
The licensee stated that the weekly filters, both the particulate and the charcoal impregnated paper, were counted for gross beta-ganma activity af ter 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> at Con Ed's environcental laboraf tory facility. The licensee stated that the $cckcan Wide Beta II
was used for these analyses, whenever possible.
Otherwise, the NMC internal proportional counters were used for this purpose.
i The inspector's examination of instrunent backgrounds and effi-ciency checks indicated that care was taken to assure instrument reliability.
The licensee stated and the data verified that the filters were analyzed by gatna spectral analyses by Teledyne Isotopes as monthly composites of particulate filters and iodine filters from each station.
The inspector stated that this was in viola-
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tion of the Technical Specifications which require that gamma spectral analyses be perfor=ed on each filtar, The inepcete-noted that unen the
sampling was done according to the Program 2 sampling frequency, the sanples were analyzed individually, as
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required.
I The inspector noted that the Mininum Detectable Level (20DL) for I-131 in air as measured by Con Ed on the basis of gross beta-gaena -activity on the charcoal filter was greater than 1.1 x 10~14
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microcuries/ca, while that given by Teledyne Isotopes was
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approxicately 6 x 10-15 microcuries/en3
(uCi/cm ).
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number did not take into account the iodin ~e collection effi-ciency nor. the decay of I-131 since sanpling. The inspector stated that Section' 5.6.E.2.a of the Environmental Technical
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Specifications required that if individual charcoal filters,
showed air I-131 concentrations of 1.1 x 10-14
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pCi/cm3 or greater (if the nilh pathway was involved) that the results be reported to the AEC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The inspector noted that since there were sone milk cows in the area that the milk
pathuay was involved.
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ter than the above report levels, the inspector stated that the licensee could not know whether a report was required, unless
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a filter showed lodine activity in excess of the MDL.
(Review of the air concentrations reported by Tcledyne Isotopes shoved no I-131 concentrations above the MDL.)
The inspector further
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The inspector stated that this natter
would be considered unresolved.
b.
Milk Section 4.2.1.a and Table 4.2-1 of the Environmental Technical Specifications for Units 1 and 2 require that nilk be sampled I monthly in Program 1 monitoring phase and be analyzed for I-131 within eight days of sa pling by radiochemical analyses.
They further require that ganna spectral analysis be cade of each sample and Sr-89, 90 be determined semi-annually.
The licensee stated that duplicate milk samples were collected
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monthly since Januar:* 1974 and that one sample vas sent to
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Teledyne.'sotopes and the second to Eberline Instrument Corpora-tion for analyses.
The inspector's revieu of the contractor's
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reports indicated that in cost cases the I-131 analyses vere not completed uithin eight days of sa:pling.
The inspector stated that this was in violation of the above requirements.
T:m data farthur 1-d*aatad that t!.c rc wi scu.JL.u. abauc ;
e to 8 pCi/l of I-131 for Teledyne Isotopes.
That of Eber'ine was < 1 pCi/1 according to the procedures exanined.
No I-131 above the MDL levels were reported by either contractor.
Re-view of the other analyses indicated no further violations in
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this area.
The inspector noted that several milk sample analv-l ses indicated the presence of Cs-137 in concentrations up to
30 pCi/1 as determined by Teledyne. The inspector stated that
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these levels were rather unusual and inquired as to the cause j
of these levels.
Neither the licensee nor contractor-personnel could explain these a typical levels. The gat =a spectral analy-ses performed by Eberline did not help in resolving this catter since the latter contractor had considerably higher MDL's for the ganma spectral analyses..The licensee stated that this matter uould be evaluated.
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Precipitation Section 4.2.1.a and Table 4.2-1 of the Environnental Technical Specifications require that precipitation be collected conthly two locations and be analy:cd for gross beta-gn==a activity at and H-3 if'" sufficient vet deposition occurs."
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The inspector examined the licensec's collection techniques and observed that large, open topped, stainless steel pots were used as collectors.
The inspector stated that the large, open surface area allowed tuch evaporation to occur.
The licensee
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stated that the gross beta-ganna activity was determined in terms of pCi/m' and that usually the nearby rain gauge contained enough water to suffice for the H-3 determination.
The inspec-tor noted that the large evaporation losses from the open-topped
collectors were pointed out in Inspection Report No. 50-286/73y05, 50-3/73-08.
The licensee stated that =cchods to reduce evapora-tive losses would be examined and appropriate action would be taken.
i The inspector's review of the licensee's records since the last inspection of this area indicated all of the required sampling and analyses were perforned.
The inspector stated that the violation listed in, the above report in regard to H-3 analysis of rainwater had been corrected.
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Other Water Sannline
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Section 4.2.1.a and Table 4.2-1 require that drinking water,
-- end uc1-oter ve saapled at conthly intervals from a specified number of locations and analyzed for E-3 and gross beta-ganma activity.
Hudson River water is also collected at the intake and discharge structures on a continuous basis and i
i analyzed weekly as above.
The inspector's review of the collection and analytical proce-dures indicated that they were the sace as described in RO Inspection Report No. 50-286/73-05, 50-3/73-08.
Gat =a spectral
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analysos, when required as in Progran 2 conitoring, were car-ried out by Teledyne Isotopes and/or Eberline.
H-3 analyses were perforne.' by Con Ed on each sample and by the contractors.
The inspector stated that he found no violations in these areas.
The licensec stated that vell water was sampled as required from the Verplanck location through arrangements with the property The inspector observed that the violation identified in-owner.
the above report relating to this sanpling location had been corrected.
The inspector examined the licensee's records re-
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lating to the H-3 analyses of lake, well, reservoir and Hudson River watcr in ?!ay 1972 and found then to be in accord with the requirc:ents.
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The inspector discussed with the licensee the need for mininiz-ing the plate-cut of selective ions fron water to container
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The licensee stated that na treatment was currently
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used but that he would evaluate the use of hcl and NaHSO3 in all water samples and take appropriate action to reduce the pla te-out tendency.
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Vecetatien and Soil The inspector reviewed the terrestrial vegetation sampling and
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soil sampling programs required by the FSAR and Section 4.2.1.a of ths Environmental Technical Specifications.
The sampling and analyses performed by the Con Ed personnel were essentially un-changed frcm that described in R0 Inspection Report No. 50-280/
73-05, 50-3/73-08. During the Program 2 requirement, gamma spectral analyses and Sr-89, 90 analyses were perforued by Teledyne Isotopes.
Discussions with the licensee and contrac-tor personnel indicated that some improvements were needed in
preparing the soi' and vegetation samples for analyses.
The need for selecting representative samples (soil and vegetation)
for analysis uas discussed. The licensee stated that this would be evaluated and appropriate action would be taken.
No viola-tions were found in these areas.
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Other "edig
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Other environmental nedia required by the FSAR Unit 3 or Section 4.2.1.a of the Environmental Technical Specifications
.I to be sampled for radiological analysis include aquatic vege-tation, Hudson River sediment and fish, and each principle food product grown within 10 miles of the site.
The licensee's records indicated that the food product sampling had been completed in October but the analytical results were not yet available.
As to the other media listed above, inspec-tion of the licensee's records and discussions uith the licensee indicated tha' the sampling and analytical reauirements were be-ing met.
With regard to the aquatic vegetation, the. inspector noted that I-131 concentrations in excess of 10 pCi/gn (uet)
were found in a number of recent samples.
Because of the short half-life of I-131 and the unlikelihood of such a build-up of I-131 in aquatic vegetation, the licensee was unabic to account for these findings.
The licensee stated that Teledyne had been notified of these results and these analyses would be re-examined.
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Exterr.a1 E.idiation Section 4.2.1.a and Table 4.2-1 recuire that direct gamma radia-tion be measured both on a spot check basis, annually, and con-tinuously, read on a monthly basis.
Revie.1 of the licensco's records and discussions with the li-censee revealed that a minimum of 2 5 locations (15 locations are required in Tabic 4.2-1) were nonitored monthly as required, using the harshaw TLD-100 LiF chips as described in RO Inspec-tion Report ::o. 50-286/73-05, 50-3/73-08. The licensee had established control monitoring stations for air monitoring and direct garma radiation monitoring since the last inspec-tion of these areas.
Individual TLD =casurements exhibited considerable variation and therefore at least 5 to 10 chips were used at each location. The licensee further stated that a dual program would be started within a month to compare the LiF measurenents with those of the Teledync Isotopes CaSO4 (Dy) TLD badges.
The licensee stated that if the latter badges proved satisfactory, they would be used in place of the LiF chips.
T'he inspector's examination of TLD incations and placenent of the devices indicated a number of instances in which the TLD was shielded on one or more sides, by a metal or wood structure.
The inspector discussed the placement of TLD's to minimize shiciding from nearby structures, and noted that this had been discussed at the previous inspection.
The licensee stated that this would be revieued and there the TLD could be placed in a less shielded position eithout making it a target for vandals, the TLD would be moved.
5.
Quality Control and Analvtical Procedures The inspector selected procedures and equipment used at Con Ed's environnental laboratory, methods of performing analyses and analyzing results. The inspector noted that the method of record-keeping for environnental data had been improved considerably since i.
the last inspection.
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The inspector revicued the available proceduren from the radioanaly-tical contractors and the quality control data available from each.
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The licensce participates in the EPA spike sample progran and sub-mits " spikes" to each of the contractors. The inspector stated that since routine milk and w.'tcr samples ucre split and sent to
Eberline and Tcledyne, these results should be reviewed more closely
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as a ceasure of contractor performanc'c.
The inspector discussed with the licensee the neet to revicu the contractors' facilitics and equip-nent, backgreunds, ef ficiencies, and analytical technic,ues on a pc-riodic basis in erder to determine the precision, sensitivities and capabilities or limitatiens of the contractors.
The licensee stated that these areas would be reviewed.
The inspector revicued the un-resolved item relating to the contractor's analytical and quality assurance procedures (identified in RO Inspection Report No. 50-286/
73-05, 50-3/73-08), and this item is no longer considered unresolved.
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6.
Chenical Discharpes The inspector examined the methods used by the licensee to assure that the requirements of Section 2.3 of the Environmental Te.chnical Specifications, Units 1 and 2, with regard to chemical concentra-tions in effluents were met.
The licensee stated that all of the samples taken and analyzed were in ac.ordance with approved stand-ard methods.
Selective procedures u tre examined, as well as, rep-resentative records of the results.
The inspector found no instance
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in which the frequency of analyses was not as reauired, nor of con-centrations in excess of the limits given in Tables 2-1 and 2-2 of Section 2.3.
Among the water quality parameters reviewed were cF1--3-
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':- nd, li.'.1.m '..,d...22m, s e.ifl;..nlac-y tance and dissolved oxygen.
The inspector also reviewed the circumstances surrounding an apparent oil spill in the Hudson River on October 27, 1974. The inspector had noted the oil sheen on the water in the vicinity of the discharge structure on October 30, 1974. The licensee's investigation indi-cated that the oil had been found on October 27 after a barge had transferred No. 6 diesel fuel to the IP storage tank for use in the Unit 1 superheaters.
The lic2nsce's investigation indicated that i
the spilled oil came from the barge and not fron IP.
The licensee stated that when the oil was discovered, clean-up procedures were
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i baplemented and the State of New York 'was notified.
The State and
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the Coast Guard investigated the spill and were apparently satis-fled with the corrective actions. The licensee's estinate of the
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oil lost to the river from the barge was less than 5 gallons.
No apparent adverse environmental effect was observed.
l 7.
Therral Discharces
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Section 2.1 of the Environmental Technical Specifications for Units 1 and 2 specify the Limiting Conditiens for Operation re-garding thermal dischar;;cs, including 11mits on the maximun tem-perature change across _ t he cooling water systnm, the maximun water
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f discharge temperature, the cax1=um heat discharge rate (BTU /hr) and i
the rate of.tcr.perature change.
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.The inspector reviewed precedures, conitoring nothods and represen-I tative records pertinent to the above areas and discussed them with i
i the licensee.
With regard to the naximun thermal discharge rate, L
j-Section 2.1.3 and the tonitoring requirements in Section 3.1.3 of
j the Environmental Technical Specifications,.the licensee had cal-
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culated the heat rejcetion rates by the specified for=ula in
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j Section 2.1.3 on a daily basis.
Review of the nethod of calcula-
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l tion, houever, revcaled that this calculation was not sufficient
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for each unit.
The calculation did give the average heat rejection
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rate fren both Units each day add also a " maximum rej ection rate" calculated by naximizins the AT and the circulating water flow for l
cach day.
This calculation sometimes appeared to exceed the maxi-
mum heat rejection.!imit on a daily basis, but was not representa-l tive of the actual heat rejection race.
The inspector stated that
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this area nas considered unresolved.
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i 8.
Uater Intake and Discharne Velocities Section 2.." of th'e Environnental Technical Specifications for j
Units 1 and 2 specify limits cn the approach,- intake and discharge
velocitics. The corresponding monitoring requirements are speci-
ficd in Section 3.2.
The inspector discussed the procedures and examined the equipment
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used by the licensee to meet these requirements.
The licensee used
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a Marsh-McBirney, Inc. instrument with an electromagnetic sensor to
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deternine the approach and intake velocitics.
Revicu of represen-l tative records indicated that the requirements of these sections
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With regard to the discharge velocity determinations, Section 2.2.3
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requires a minimum discharge velocity of 10 feet /second whenever l
Units 1 and 2 are above 50% power. The discharge velocity is cal-
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culated from the water height difference between the discharge canal
Icvels and the river level, requiring a 1.5 to 1.7 foot height dif-ference to satisfy. the discharge velocity requirement.
The adjust-ment of the discharge -port' gates to maintain the required water
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height dif ference is required within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following any change in flow rate of the circulating water pumps.
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O The licensee stated that the cater level differential was deternined by the shif t operator, who read the vater levels posts inside and outside the discL:rge' structure, on which level carkincs were painted.
The inspecter examined these posts on October 22 and again on October 30, 1974 and found that the tarhings were not readable due to biological growths on the carker posts.
The operator's log indicated readings could not be cade because of these grouths in several instances in October.
A review of the circulating punp operation logs shcred no change in pump opera-tion since the beginning of October.
The licensee stated at the management meeting of October 31, 1974 that these tarker posts had been cleaned on October 31 and the operating procedures had been chanFed so that prompt cleaning of the narkers was required, ebenever necessary to secure an accurate measurement.
9.
Biological Monitorine a.
Impinecment The licensee's rcquirements to monitor and determine the fish impingenent at the site's intake structures are specified in Section 4.1.2.a(2)V1 of the Environmental Technical Specifica-
+4a-c fn* n-ite 1
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Tne e s the r-yire ente e7neitted ir-clude the frequency of vashing the traveling screens (once per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift) and the nethod of subsampling the impinged fish.
The inspector observed the licensee's contractor, Texas Instrunents, Incorporated, cashing the fixed and traveling screens, collecting the impinged fish, counting and identify-ing then. Discussions with the contractor and licensee person-nel revealed that the frequency of washing the screens (both fixed and tra.. ling) cas usually once per day unless more fre-quent cashing vere required because of s build-up of debris on the fixed screens. The contractor also stated that 25% of the first hundred fish plus 1% of additional fish of any species
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or subgrou; uere subsanpled for weight and length neasurements.
The inspector stated that these subsa=pling procedures were not consistent with those in the Environnental Technical Specifica-
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tions, nor were the traveling screens washed as frequent as required.
The licensee stated that Section 4.1.2.a.B(3) of these specifi-cations alloued for changes in the special programs section and
shoved the inspector documentation that was sent to the EPC (Environmental Pretectica Committee) for their approval in
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accordance with the above'~ section.
The inspector stated that the approval of such changes cust be obtained from the EPC before the changes are inplemented.. The changes in the impingenent subsampling progren ucre nade in Decenber 1973,
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whereas, Jhey ucre brought to the attention of the EPC in
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hay 1974.
These, changes were also to be reported in the
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next semi-ennual report (Janu,ary-June 1974). 'These changes
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were not documented in the above report. The inspector stated that the changes were not made in accordance with the require--
ments of Section 4.1.2.a.B(3) above and were considered.a violation.
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The inspe'htor reviewed representative records and program rd '
sults from the impingement studies, us'c of the air bubbling system and fish physiological studies and found no other violations.
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Other Aquatic Studies s
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The inspcetor discussed the fisheries' studies with the contrac-c
- tor and licensee personnel, including types of studies conducted, methods of sampling, frequencies and comparisons of data with
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cther c ulica.
T.c.r.r ca u..tc ilv a scoults s,e r e teviewed along wicn contractor reports regarding the Hudson River studies.
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The inspector also reviewed with the licensee the entrainment n
studies conducted at the IP site by NYU.
Equipment, sampling locations, and methods were examined.
10.
!!cteorology The inspector reviewed the requircrents of Section 4.1.1.b of the Environmental Technical Specifications regarding meteorological monitoring at the IP-site.
The licensee was collecting the data as required from both the 100 foot and 400 foot meteorological tcwcrs.
The data from the 100 foot tower was fed to the Control-Room of Unit 1.- The licensec stated that within the next feu months the data'from the 400 foot tower would be directed to the control room. Data from both towers is currently analyzed and summarized by Con Ed personnel.
Tower and instrument naintenance
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is contracted ' to the York Research Corporation.
Records of data recovery and instrument calibration were reviewed.
No violations
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auxiliary transfe'rncrs were suf ficient to contain all the oil in j
the event of a tajor. transformer leak or rupture. The inspector
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noted that' this itc= was Icf t unrasolved in RO Inspection Report No. 50-286/73-05, 50-3/73-08.
The licensee stated that this item v
had been inadvertently missed and hed not yet been evaluated. The I
licensee stated that the adecuacy of these slag pits would be
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evaluated promptly to '..ssure that no nil would. reach the river in the event of. a spill.
The assurance that these. pits would not fill with water and thereby reduce the oil holding capacity would c
also be evaluated.
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