IR 05000220/1981002
| ML17053C744 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/29/1981 |
| From: | Bores R, Todd Jackson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053C745 | List: |
| References | |
| 50-220-81-02, 50-220-81-2, NUDOCS 8107210343 | |
| Download: ML17053C744 (26) | |
Text
I d
.S.
NUCLEAR REGULATORY COMMIS ON
~
OFFICE OF INSPECTION AND ENFORCEMENT g
Region I h
Re port No.
50-220/81-,02 Docket No.
50-220 License No. DPR-63 Priority Category Licens'ee:
Niagara Mohawk Power Corporation (NMPC)
300 Erie Boulevard West Syracuse, New'ork 13202.
Facility Name Nine Mile Point Nuclear Station, Unit 1 (NMP-1)
Inspection at:
Scriba, New York Inspection conducted:
Febr ry 9-13, 24-27, 1981 t
Inspectors:
'
T.J.
c n, Radiation Specialist date signed date signed Approved by:
R.J.
Bores, ief, Independent Measurement 8 Environmental Protection'ection, EPICS,PS Branch date signed
- Zl date signed Inspection Summar
Ins ection on Februar 9-13, 24-27, 1981 (Re ort No. 50-220/81-02)
~A""I d:R
.
Agf f
ffg programs for operations, including:
management controls for these programs; the licensee's program for quality control of analytical measurements; implementation of the environmental monitoring programs - radiological; implementation of the environmental monitoring programs - biological/ecological; nonradioactive effluent release rates and limits; and followup on licensee action on previous environmental inspection findings.
The inspection involved 34 direct inspection-hours by one regionally based NRC inspector.
Results:
Of the six.areas inspected, no items of noncompliance were found in five areas.
One item of noncompliance (Inadequate environmental airborne iodine sampling - Detail 5.a)
was identified in one area.
Qtupe 8J-f7&ip8fS Region I Form l2 (Pev. April 77)
DETAILS 1.
Individuals Contacted Nia ara Mohawk Power Cor oration NMPC
- M. Silliman, Acting General Superintendent
"T. Roman, Station Superintendent
"E. Leach, Superintendent Chemical/Radiation Management
- H. Flanagan, Environmental Protection Coordinator B. Taylor, Site IAC Supervisor R.
Coon, Unit I8C Supervisor D. Palmer, Supervisor, gC Operations G. Leskiw, Assistant Supervisor, qC Operations D. Regan,
"8" Technician N. Sereno,
"C" Technician J.
Coates,
"0" Technician Power Authorit of the State of New York PASNY R. Pasternak, Resident Manager V. Childs, Assistant to the Resident Manager RE Baker, Superintendent of Power R. Burns, Assistant to the Superintendent of Power M. Cosgrove-',
Site gA Engineer 0. Tall, Training Coordinator R. Converse, Operations Superintendent B. Gorman, Environmental Supervisor A. McKeen, Assistant to Radiological and Environmental Services (RES)
Superintendent K. Szeluga, RES "B" Technician R. Liseno, Shift Supervisor 0. Johnson, Control Room Shift Operator H. Keith, I 5 C Supervisor
"denotes those present at the exit interview
Licensee Action on Previous Ins ection Findin s
(Closed)
Unresolved Item (220/78-15-01):
Location of environmental TLDs.
The inspector reviewed selected TLD stations and noted that TLDs appeared to be appropriately located at the stations to minimize siting effects.
Those TLDs observed were mounted on the plant-side of support posts.
The inspector had no further questions regarding this item.
(Closed) Deficiency (ZZO/78-15-02):
Failure to calibrate environmental radiation monitor.
The inspector reviewed calibrations of the environmental mon'itors completed since NRC Inspection 50-220/78-15 and noted that calibrations were performed as requi red, in accordance with the licensee's corrective action described in the December 1,
1978 response letter.
The inspector had no further questions regarding this item.
(Closed)
Unresolved Item (220/78-15-04 and 220/77-16-02):
Environ-mental Analytical Laboratory.
The inspector reviewed the current laboratory facilities which are located in the Auxiliary Access Point Building on the J.
A. FitzPatrick site and noted that the necessary equipment was calibrated and operating at the time of the inspection, and that operations were conducted according to approved procedures.
The inspector had no further questions regarding this item.
(Closed)
Unresolved Item (220/78-15-05):
Biological data availability.
The licensee's biological contractor, as of January 1981, was Ecological Analysts, Inc.,
who replaces Texas Instruments, Inc.
Sampling and analytical records, the data in question, were maintained at the contractor's field office in Oswego.
The inspector had no further questions regarding this item.
(Closed) Infraction (220/78-15-06):
Exceeding 4T limit during flow reversal operations..
The licensee's December 1,
1978 response letter described, as corrective actions, procedure changes and an investigation into failures of Gate
"C" to function properly.
The inspector reviewed the appropriate procedure and selected thermal discharge records and identified no further items of noncompliance.
The inspector had no further questions regarding this item.
(Closed) Deficiency (220/78-15-07):
Exceeding bT limit during normal plant operations.
The inspector reviewed licensee operations and corrective actions taken as described in response letters dated December 1,
197 and February 7, 1979, and reviewed selected thermal discharge records completed since September 1978.
No further items of noncompliance were identified.
The inspector had no further questions regarding this ite (Closed) Deficiency (220/78-15-08):
Failure to report exceeding bT during normal plant operations.
The inspector reviewed selected thermal discharge records and licensee event reports (lERs) completed since the last inspection and noted that reporting requirements appeared to have been satisfied.
The inspector had no further questions regarding this item.
(Closed) Deficiency (220/78-15-09):
Exceeding the annual discharge limit for phosphorus.
The licensee stated that no chemical wastes, including phosphorus, have been discharged from the plant since the Spring of 1979, and therefore, this problem did not recur.
The inspector had no further questions regarding this item at this time.
3.
Mana ement Controls The inspector reviewed the licensee's management controls for the environmental monitoring programs.
Areas reviewed included:
Assign-ment of responsibility; program audits; corrective action for identified inadequacies and problem areas in the program; and the reporting, analysis, and evaluation of program data.
a.
Assi nment of Res onsibilit The inspector reviewed the organization and administration of the environmental monitoring programs.
The program is run by the site Environmental Protection Coordinator who reports to the site Supervisor of Chemistry/Radiation Management, who in turn reports to the General Superintendent, Nuclear Generation.
The licensee stated that as of January, 1981, the biological monitoring programs are no longer conducted by Texas Instruments, Inc., but are now contracted to Ecological Analysts, Inc.
b.
Pro ram Review and Audits The following licensee audits were reviewed as part of this in-spection.
Audit Dates Pro ram Area Covered June 5,
1978 October 10, 11, 12, 19 and November 17, 1978 Environmental Station In-spection and Sample Collection Safety Review and Audit Board (SRAB) Radiological Audit-covered radiological effluents and environmental monitoring
'0 October 10, ll, 12, and 19, SRAB Environmental Tech Spec 1978 (ETS) 'Audit-covered all nonradiological areas
October 16-17, l979 October 16-.18, 1979 December 11-13, 1979 December 18-19, 1979 Texas Instruments, Inc. (TI)
(biological programs)
SRAB ETS Audit SRAB Radiological Audit Radiation Management Corp.
(RMC)
(radiological contractor)
June 24-25, 1980 October 14, 1980 October 14-16, 1980 October 15-17, 1980 February 2-6, 1981
"Environmental Station Inspection and Sampling Collection" Surveillance Report SR-80-13 Texas Instruments, Inc. (TI)
SRAB ETS Audit SRAB Radiological Audit RMC The inspector noted that the audits of TI covered sample collection, processing, analyses, and data reduction and reporting.
Audits of RMC covered sample processing, analyses, and data reduction and reporting.
The inspector noted that the licensee, during the December 18-19, 1979 audit of RMC, had questioned the discrepancy between RMC results and EPA values for Cs-137 in EPA Crosscheck Program milk samples.
RMC's response to the licensee, dated January 10, 1980, stated that the discrepancy was due to the, methodology used in RMC's analysis of the milk and that an alternative method was under investigation which would better assure the preservation of any cesium in the sample.
The inspector discussed with the licensee the methodology still being used by the contractor and the possible effects of this methodology on radioactive cesium results reported for milk.
The licensee stated that the contractor would perform a complete evaluation of the methodology used for gamma spectral analysis of milk and its effect on cesium r'esults.
The inspector stated that the adequacy of gamma spectral cesium results would be considered unresol'ved pending completion of'his study and subsequent review by the NRC (220/81-02-01).
4.
Licensee Pro ram for Qualit Control of Radiolo ical Anal ses The inspector reviewed the licensee's program for quality control (QC)
of laboratory radiological measurements and noted that the analytical contractor (RMC) had its own QC program, and that the licensee conducted a
QC program which included the contractor and those analyses performed
D II by PASNY personnel.
The analytical contractor in this area and the licensee had both prepared detai,led written procedures for their respective QC programs.
Environmental samples were also split with the New York Stat'e Department of Environmental Conservation.
The licensee stated that the contractor.
QC data was reviewed and evaluated on a routine basis.
The licensee stated that the QC program was being upgraded and provided the inspector with a copy of the "Draft Environmental Surveillance Program QA/QC Program" description.
The inspector reviewed the draft program document and noted that there were clear provisions for:
Assignment of responsibility to manage and conduct the program; Number and types of samples to be included; Acceptance criteria; and Followup action on identified discrepancies.
The draft program also contained provisions for detailed periodic checks of environmental monitoring stations and equipment.
The licensee stated'hat this upgraded version of the QA/QC program would be implemented by May 1981.
The inspector stated that this program would be reviewed during the next inspection of the area.
No items of noncompliance were identified in this area.
Im lementation of the Environmental Monitorin Pro ram Radiolo ical a.
Direct Observation The inspector, toured the site environmental analytical laboratory and reviewed the associated procedures, logs, and instrument calibrations.
The inspector examined selected environmental air sampling and'irect radiation monitoring stations, and observed.the changing of the -air particulate and air iodine collection media, measurement of sample flow rates, the recording of the required information for each sample, and the checks made on each sampler as it was returned to service.
The inspector noted that at most air stations (with the exceptions of stations H, I, J, and K) the charcoal cartridge holder did not contain seals so that the cartridges were therefore loose in the holders.
This would allow some of the air from the sampling stream to bypass the cartridge.
The inspector stated that this sampling arrangement did not provide adequate sampling of airborne iodine because the air flow through the charcoal cartridge.was reduced by an indeterminate amoun The inspector stated that inadequate sampling of airborne iodine wa's
'an'tem of noncompliance with regulatory requirements.
The inspector noted that prior to the conclusion of the inspection the licensee had provided adequate seals at those sampler stations where they were lacking, thereby correcting the problem.
The inspector discussed with the licensee other aspects of environmental air sampling and noted that the air sampler inlet tubes each contained a
90 degree
.bend through which inlet air was deflected before reaching the particulate filter.
The inspector discussed with the licensee the advantages of having the inlet air first pass through the particul,ate filter, thereby eliminating the possibility of line effects on air particulate sampling.
The licensee stated that the elbow had been incorporated to keep precipitation from the reaching filter.
The licensee stated that the inlet design would be modified to eliminate any possible line effects and that precipitation protection would be provided by an alternate means.
This area will be re-examined during a subsequent inspection of the area (220/81-02-02).
b.
Review of Re orts (1)
Routine The inspector reviewed the following reports as part of this inspection.
Annual Environmental Operating Report, January 1-December 31, 1978 Annual Environmental Operating Report, January 1,-December 31, 1979 RMC Environmental TLD System:
Evaluation of Compliance with USNRC Regulatory Guide 4. 13-August, 1978 The inspector determined through discussions with the licensee, review of these reports, and review of data that the licensee had reported all required information.
(2)
Nonroutine The inspector reviewed the circumstances and licensee's evaluations of the following anomalous measurements reports.
LER No.
79-12 79-24 Date September 7,
1979 November 1, l979 Subject Area Nn-54, Co-60, Cs-137 in Cladophora Cs-137 in milk
The inspector noted that the levels of radioactivity re-ported in Cladophora represent a minimal environmental impact based on the low levels of activity measured and the dose consequences to man are insignificant based on the low level of radioactivity and the indirect dose pathways to man involved.
The inspector discussed with the licensee the Cs-137 in milk as measured on the one occasion noted above and reviewed a report prepared for the licensee by NUS Corp, titled "An Evaluation of the Cesium Concentrations in Environmental Milk Sample and their Significance at the Nine Mile Point-James A. Fitzpatrick Site".
This report was prepared in response to an elevated Cs-137 level reported for a September 1979 milk analysis at Station No. 25.
The inspector stated that based on the above report, it did not appear possible to rule out the Nine Mile Point-J.A. Fitzpatrick plants as a source of the Cs-137 in milk, although neither did it appear likely that the plants are the only source.
It is important to note that regardless of source, the reported
pCi/1 of Cs-137 in milk would produce a whole body exposure of 0. 10 mrem/month to an adult (critical individual) and 0.89 mrem/month to an infant liver (critical organ), calculated using methodology presented in Regulatory Guide 1. 109 for maximum exposed individuals.
The measured level of 53 pCi/l did not appear to persist for more than one month and was not identified at any other sampling stations.
These doses are a small fraction of the 25 mrem/year limit of 40 CFR 190 for members of the general public.
The inspector had no further questions with regard to this item at this time.
The inspector reviewed LER 80-30, dated January 5,
1981, concerning problems in meeting required analytical sensitivities for fish samples in 1980, as identified by licensee SRAB audit in October, 1980 and discussed licensee actions taken to achieve the sensitivities.
The licensee stated that possible improvements in sensitivites were still being pursued with the analytical contractor.
The inspector stated that the effectiveness of'icensee actions would be'eviewed during a subsequent inspection of the area (220/81-02"03).
The inspector conducted an independent evaluation of I-131 detected in milk in November, 1980 as described in LER 80-28 and reviewed all pertinent available data.
Based on peak I-
131 airborne release rates from both plants at the site just prior to and during the period in which I-131 was detected in milk, using the pathway models described in Regulatory Guides 1. 109 and 1. 111,, it was not possible to identify as the sole source either. plant releases or the October 16, 1980 Peoples Republic of China weapons test and resulting fallout.
The attachment to this report illustrates the airborne Iodine-131 releases from both the NMP and JAF sites during the interval September through November, 1980.
Also shown on the same plot are the date of the weapons test by the Peoples Republic of China on October 16, 1980, and the dates, locations and the I-131 results of all milk samples with positive values.
The maximum airborne release rate (from JAF) for I-131 occurred during the week in which the weapons test occurred.
Because
'of the near proximity to the JAF-NMP source to the sampled milk farms, any deposition from this source should have taken place within hours of the release.
Oeposition from the weapons test, on the other hand, would first be expected to occur approximately two weeks after the test because of the atomspheric diffusion and transport time.
The deposition from the latter would also be distributed in time over several weeks.
Review of the milk data (and as depicted in the Attachment)
has indicated that the first positive iodine measurements in milk occurred approximately two weeks following the weapons test at which time the iodine release rates from both NMP and JAF plants had decreased by a factor of about 10.
These positive milk I-131 samples were collected from several locations including the control farm.
Subsequent to this date (November 3, 1981) all sampled milk cattle in the area (with the exception of Sampling Station No. 25) were removed from pasture for the winter.
Sample Station No.
showed an increase in I-131 levels in milk to 10 pCi/l and remained at about that level (>> 8 pCi/1) until the end of November, while the NMP-JAF releases continued at about a factor of 20 below the peak release rate.
Consequently, while one cannot easily rule out that the NMP-JAF releases contributed to he I-131 activities measured in these milk samples, it appears at least highly unlikely that these releases were the sole source of the measured activity.'egardless of the source of the I-131 the expected dose consequences would be minor.
Only one cow was present at Station No.
25 where the elevated levels were detected, and consumption of this cow's milk with 10 pCi/1 of I-131 for the one month period involved would produce 3.8 mrem to an infant thyroid, although no infant consumed milk from this farm (an adult would receive a thyroid dose of 0.5 mrem).
legend JAF STACK JAF VEIIF'HP STACK iodine-.131 Airborne Release. Rates from Nine Mile Point/J.A.FitzPatrick Plants: September November 198 I'
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The inspector had no further questions regarding the above releases and their consequences at this time.
No items of noncompliance were identified.
C.
Other Records The inspector reviewed selected results of analyses of the radiological monitoring program, especially the 1980 data for which the annual report was issued subsequent to the inspection, and discussed with the licensee the methodologies used to calculate error and to calculate lower limits of detection (LLD).
The inspector determined that the required samples and analyses had been collected and analyzed in accord with the ETS.
No items of noncompliance were identified relative to this area.
d.
Meteorolo ical Monitorin The inspector examined the site meteorological instrumentation, including the meterological tower which is maintained by NMPC and the recorders in the Nine Mile Point, Unit 1 Control Room.
The licensee stated that the control room recorders amd the rest of the meteorological instruments are checked on a biweekly basis and calibrated semi-arinually.
The inspector reviewed the meteorological instrument calibration procedures and calibration records completed since the last inspection of this area (50-220/78-15).
Starting speeds for the wind speed sensors were discussed and the inspe'ctor noted that the semi-annual instrument calibrations did not include a recertification that these sensors could meet the starting speed specifications of Section 3.1. 1 and Table 3. 1-1 of the ETS.
The inspector noted that the type of instruments in use appeared capable of meeting the required specifications and stated that the issue of whether the installed instruments could in fact meet the starting speed specifications would remain unresolved pending licensee verification and subsequent NRC review (220/81-02-04).
The inspector reviewed the licensee's evaluation regarding the loss of data transmission from the met tower to the control rooms as described in LER 80-20, September 29, 1980 and examined the corrective actions taken to prevent recurrence.
.The licensee stated that a spare of the part which caused the problem is now maintained in case replacement is necessary.
No items of noncompliance were identified.
6.
Im lementation of the Environmental Monitorin Pro ram-Biol o ical/Ecolo ical The inspector examined the impingement sampling apparatus at the plant side of the intake tunnel and reviewed selected sampling and analytical procedures.
The following reports were reviewe ~Re ort 48-hour
~ga hnia gulex LC50'Test Using Nalsperse 7348 and 7388 a'ondenser Mater Treatment:
Oct. 26-29, 1979 Using Nalsperse 7348 and 7388 Date October 1,
1979 January 11, 1980 1979 Nine Mile Point Aquatic Ecology Studies March, 1980 Environmental Impact Assessment for Chemical Treatment of Main Condenser Cooling Mater January 12, 1981 The licensee stated that it was currently not planned to use biocides in the main.condenser cooling water.
The inspector also reviewed selected records and data completed since the last inspecti,on of this area in September, 1978.
The inspector reviewed the circumstances concerning a missed impingement sample as descr'ibed in LER 78-41 (December 28, 1978),
and noted that the associated'.
environmental impact was negligible.
No items of.- noncompliance were identified in this area.
Nonradioact'ive Effluent Release,.Rates and Limits a
~
Thermal The inspector reviewed selected records of the thermal monitoring system since the last inspection of this area, including thermal discharge records, calibration records and related procedures.
The inspector also reviewed the circumstances and licensee's evaluations regarding LERs 80-06 (2/2/80)
and 80-11 (7/22/80)
which described occurrences during which the ETS hT limit was exceeded.
The inspector reviewed the chart recorder repairs made subsequent to LER 80-06 and the current operation of the thermal.
monitoring system.
Calibration records pertinent in response to LER 80-02( l/16/80) concerning thermal sensors found out of tolerance
.
were reviewed.
The inspector had no further questions concerning this area and no items of noncompliance were identified.
b.
Chemical The inspector examined selected results of chemical use monitori'ng completed prior to Spring, 1979, and LER 78'-'6 (November 2, 1978)
describing Na and S04 releases.
-The licensee stated that no chemical wastes had been discharged fr'om the site since Spring 1979.
The inspector had no further questions in this are.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations..
Two unresolved items were disclosed during this inspection and are discussed in Details 3.b and 5.d.
9.
Exit Interview On February 27, 1981, at the conclusion of the inspection, the inspector met wi ih those individuals denoted in Detail 1.
During this meeting the purpose and scope of the inspection were summarized and the inspection findings, including the item of noncompliance and the unresolved items, were discussed.