IR 05000220/1988035
| ML17055E437 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point |
| Issue date: | 12/29/1988 |
| From: | Davidson B, Joseph Furia, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055E436 | List: |
| References | |
| 50-220-88-35, 50-410-88-33, IEB-79-19, NUDOCS 8901180081 | |
| Download: ML17055E437 (22) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220/88-35 50-410/88"33 Docket Nos.
50-220 50-410 License Nos.
OPR-63 NPF"33 Priority
- 'ategory C
Licensee:
Nia ara Mohawk Power Cor or ation 301 Plainfield Road S racuse New York 13212 Facility Name:
Nine Mile Point Units 1 and
Inspection At:
Scriba New York Inspection Conducted:
November 28 December
1988 Inspectors:
. Davidson, Radiation Specialist ate J.
T. Furia, Radiation S
cialist
/~ p./ Pd date Approved by:
Wg J.
scia
, Chief, Effluents Radiation Protection Section, FRSSB, ORSS da Ins ection Summar
Ins ection on November 28 - December
1988 Combined Ins ection Re ort Nos. 50-220/88-35 50-410/88-33)
Areas Ins ected:
Routine, unannounced inspection of the licensee's radioactive effluent controls, radioactive waste and transportation, and radiological en-vironmental monitoring programs.
Results:
No violations were found.
PDR AD<
9010'901180081
,9 CK Ob000220 F'DC
DETAILS 1.0 Individuals Contacted During the course of this routine inspection, the following personnel
. were either contacted or interviewed.
Princi al Licensee Personnel 1.2
"M. Dooley, Licensing
- N. Rademacher, Director, Nuclear Compliance
"H. Flanagan, Environmental Protection Coordinator
"P. Volza, Radiation Protection Manager
"0. Henderson, Supervisor Radwaste Operations, Unit Two
"C. Beckham, Manager, QA Operations - Nuclear
"A. Ross, Unit Two Chemistry
~J. Duell, Chemistry Superintendent
- M. Scholtens, Radiation Protection
"C. Gerber, Supervisor Radwaste Operations, Unit One
"J. Blasiak, Unit One Chemistry T. Wanek, Quality Assurance Engineer J. Burton, QA/QC D. Barcomb, Radiation Protection T. Mood, Training E.
Langi lie, Supervisor RP Instrumentation Other licensee employees were also contacted or interviewed during the inspection.
New York Public Service Commission
"D. Losurdo 1.3 Nuclear Re viator Commission
"R. Temps, Resident Inspector, Unit One R. Laura, Resident Inspector, Unit Two
"Indicates those individuals who attended the exit interview on December 2, 1988.
2.0.
~Pur use The purpose of this routine inspection was to review the licensee's program in the following areas:
~ The licensee's ability to control and quantify 'radioactive solids, liquids', gases and particulates during normal and emergency operation;
+The licensee's ability to implement its radiological environmental monitoring program during normal and emergency operations; and
~The licensee's ability to properly package low-level licensed radioactive material radwaste for disposal and transport.
3.0 Licensee Actions on Previous Ins ection Findin s
3.1 3.2 (Closed)
50-410/86-12-01 (Inspector Follow-Up Item).
Review Unit 2 Radwaste Shipping Program.
The licensee has implemented procedures for the preparation and shipment of radioactive waste as required.
These procedures are thorough and properly addresses all pertinent
.
issues.
This
-item is closed.
t (Closed)
50-220/87-08-01, 02, and 03 (Violations pertaining to the delivery of control rod cutting equipment to the Brunswick Station).
The licensee has completed the revisions to site procedures and has implemented the necessary changes in the areas of hot particle monitoring, transportation of radioactive material, and proper determination of isotopic content of radioactive material.
This item is closed.
'.3 (Closed)
50-410/88-13-01 (Inspector Fol low-Up Item),
Review licensee's actions and data'collection regarding use of, alternative sampling equipment.when the GEMS is inoperable.
The licensee's actions included 1) - Installation of a vacuum gauge to indicate negative pressure and provide a means for corrections to flow gauge readings; 2) - Inclusion of a step in Procedure N2-CSP-79,
"Gaseous Effluent Manual Sampling and Analyses "to prevent introduction of
"bleed air" into samples; and 3) - Provision 'of temporary jumper to separately energize the GEMS or the auxiliary sampling system so that anisokinetic sample flow rates would not occur.
This item is closed.
4.0 Li uid and Airborne Radioactive Effluents 4.1 Pro ram Chan es 4.2 Since the last inspection in this area, no changes were made.
The licensee's chemistry group is responsible for implementing the liquid and airborne radioactive effluent controls programs under the supervision of unit supervisors who report to the Superintendent of Chemistry and Radiochemistry.
This individual reports to the General Superintendent of Nuclear Generation.
Records and Re orts The inspector reviewed the licensee's latest Semi-Annual Effluent Release Report for the period January 1 - June 30, 1988.
No obvious mistakes, anomalous measurements, omission or trends were noted.
Current release data for the period July 1, 1988 to the present including gaseous and liquid discharges were reviewed.
In view of the fact that Unit One has been shut down for nearly one year and seldom releases liquids, a liquid waste permit for Unit Two and a
simulated gaseous release for Unit One sere evaluated against the
licensee's Offsite Dose Calculation Manual (ODCM).
The inspector performed hand calculations and compared the results to the licensee's.
The results were:
Unit One
~lsoto e
Gaseous Dischar e (mrem/year)
Release Rate Gamma Air Beta Air Licensee NRC Xe-133-0.492 uCi/sec 4.16E-4 4. 1E-4 l.24E"3 1.24E-3 Licensee NRC Kr-85m 0.392 uCi/sec 1.13E-3 1.16E-3 1.85E-3 1.85E"3 Licensee NRC Kr-88 0. 144 uCi/sec 5.27E-3 5.3E-3 1. OE-3 1. OE-3 For Unit Two, results for an actual liquid waste discharge were compared.
The results were:
Unit Two Dischar e
LWS - TK-SA 10/30/88 Total Dose (mrem)
~lsoto e
~Activit
~Total Bod Liver GI-LLI NRC Mn-54 ZN-65 Licensee Co-58 Co-60 88 uCi 100 uCi 82 uCi 123 uCi 1. 06E-4 2. 36E"4 1.87E-4
, 1.01E"4 2.27E-4 1.80E"4 These results indicated good agreement.
The inspector had no further questions in this area, No violations were identified.
4.3 Instrumentation The inspector reviewed the surveillance tests and calibrations for the Unit One and Two Main Steam Line and post-treatment offgas radiation monitors.
Specifically, the following procedures were reviewed:
N1-1SP-Q-PMG,
"Off-Gas Radiation Monitor Preventative Maintenance",
Nl-lSP-Q-PM7, "Main Steam Line Preventative Maintenance,"
N2-RSP-RMS-R104,
"Calibration Procedure Main Condensor Air Ejector",
N2-RSP-RMS-M104,"
Channel Functional Tests - Main Condensor Air Ejector," N2-1SP-MSS-M001,
"Monthly Functional Tests for Main Steam Line Radiation Monitor",
N2-1SP-MSS-R104,
"Channel Calibration for Main Steam Line Radiation Monitor".
Calibration records from January 1,
1988, to present for the offgas and main steam line radiation monitors were reviewed.
No concerns
were identified.
In addition, the inspector reviewed the initial transfer calibration data from the vendor for Unit Two's offgas radiation monitor.
No problems were noted.
The inspector toured Unit Two to observe and read out local monitors to compare values to those in the control room.
As Unit Two was also shut down, no signal was present.
The licensee's liquid waste radiation monitor was out of service due to recurrent problems with contamination affecting monitor sensitivity.
Consequently, the licensee performs independent redundant line up verification, sampling and analysis as required by Technical Specifications and will be reporting on the prolonged inoperability condition in the next semi annual effluent release report.
The inspector had no further questions in this area.
4.4 'ir Cleanin S stem The inspector reviewed records of tests of the Standby Gas Treatment Systems (SGTS), Control Room and Reactor Building Emergency Exhaust Ventilation Systems.
Testing was conducted on April 12-14, 1988 (Unit One)
and Nov. 22-23, 1988 (Unit Two).
Both in-place tests of HEPA filters and iodine absorbers and laboratory tests of iodine absorbers were made.
The licensee was found meeting Technical Specification requirements in this area.
4.5 Audits The inspector reviewed Audit No. 87028-RG/IN which was performed from November 30 - December 11, 1987.
This audit included gaseous and liquid effluents, sampling and calibration/surveillances.
The
'audit appeared to be of adequate depth to evaluate programmatic weaknesses.
Technical specialists were included in the audit team.
No major issues 'were found in the effluents area.
No violations were identified.
5.0 Radiolo ical Environmental Monitorin Pro ram 5.1 Pro ram Chan es Since the last inspection in this area, no changes have occurred within the organization.
However, the inspector noted that the licensee uses the New York Power Authority's James A. FitzPatrick Environmental Laboratory to analyze samples.
The JAF Environmental Laboratory recently increased its workload twofold by now being used to analyze samples for another NYPA facility.
The program appears to be effectively run.
No backlog of samples or analyses was noted.
The Niagara Mohawk Environmental Coordinator is responsible for implementing the REMP.
This individual reports to the Superintendent of Nuclear Generatio.2 Records and Re orts The inspector reviewed the licensee's latest submittal of the Annual Environmental Monitoring Report for the period January 1-December 31, 1987.
The review was conducted against Technical Specifications and ODCM requirements for sampling locations, measurement and monitoring frequencies, land use census, interpretation and evaluation of data.
No obvious mistakes, anomalous measurements or biases were observed.
The inspector also reviewed the results of the environmental monitoring program conducted by the State of New York around the Nine Mile Point/FitzPatrick site under a cooperative agreement with the NRC.
This program consists of co-located sampling stations for some media, such as air sampling and split or independent sampling for other media such as milk or fish, The data reviewed indicated generally good agreement between New York and the licensee data.
Additional data reviewed 1988 to date was air flow calibration data and quarterly TLD data.
The TLD data was compared to NRC TI.D data.
The data indicates agreement within 55 which is excellent.
The data is presented in Table 1.
No violations were identified in this area'.
5.3 Meteorolo ical Monitorin Pro ram 5.4 The inspector verified the operation of the licensee's meteorological instrumentation by observing the readout of wind speed; direction and 30, 100 and 200 foot temperature data from the primary meteorological monitoring tower.
In addition, the inspector reviewed results of two procedures, S-lCP-AS-WS-2,
"Teledyne Geotech Wind Direction and Velocity Instrument Calibration,"
Rev.
10 and S-1CP-SA-WS-1,
"Teledyne Geotech Temperature and Delta Temperature Instrument Calibration," Rev.
10.
Review of the requirements of these two procedures indicated compliance with semi-annual calibration requirements.
REMP A Pro ram 5.5 The inspector reviewed the licensee's REMP gA program to verify that the gA program included control of sampling, processing and analysis, and data evaluation.
The licensee participates in the EPA Inter-laboratory Comparison Program.
Results are promptly compared and disagreements are followed up on in a timely manner.
Audits The inspector reviewed SRAB Audit "D" conducted in 1986 and 1987 of the Niagara Mohawk Power Corporation/JA Fitzpatrick Environmental
Nonitoring Program.
The audit teams included a technical specialist and checklists were used to cover the objectives of the audit effort.
Within the scope of this review, no concerns were identified.
6.0 Trans ortation and Radioactive Waste S stems 6.1 Solid Radioactive Waste 6.1.1 Unit 1 Solid radioactive waste, including dry active waste (DAW),
spent resins, evaporator bottoms and oils, are collected and processed by Radwaste Operations.
The licensee has formalized its Process Control Program (PCP) for ensuring appropriate waste form and determination of waste classification in Procedure AP-3.7,
This procedure is then supplemented by the procedures listed below, reviewed during this inspection, which present specific instructions for various components of the PCP.
Nl-WHP-l,
"Required Documentation Concerning Packaging and Shipping of Radioactive Wastes" Nl-WHP-3,
"Cask Handling Procedure" N1-WHP-4,
"Cask Loading Procedure" Nl-WHP-9,
"Cement Solidification Procedure" Nl-WHP-9A,
"Cement/Oil Solidification Procedure" Nl-WHP-llA, "Process Control DAW" Nl-WHP-11B, "Process Control Procedure for Oil/Cement Solidification" N1-WHP-11E, "Process Control CNSI Cement Solidification" N1-CSP-14Y, "Collection and Analysis of Waste Samples" Solidification and stabilization of waste is accomplished by using a
CNSI cement process.
This system will be augmented in the future with a Stock Equipment Cement Solidification system.
During this inspection, records of four waste shipments from 1988 were selected at random for review.
Results of this review indicated an error in calculating waste classification for shipment number 1088-159.
Specifically, the concentration of Strontium-90, used in determining waste classification in
8.
accordance with 10 CFR 61.55, was in error by four orders of magnitude.
This error originated in a calculational error made by a Radiation Protection technician, and was not detected during a review conducted by the Site Radioactive Material Section.
This error did not result in the improper classifi-cation of the waste shipment.
This error was discussed with the Supervisor, Site Radioactive Material Shipping and the Supervisor, Unit 1 Radwaste Operations.
Both indicated'that the licensee is in the process of converting to a computer program for calculating waste and transport classification, but that at the present time this program was not operational.
During 1988, Unit 1 has made 21 shipments of radwaste for burial, with a total volume of approximately 7200 cubic feet.
Scaling factors for the various waste streams are determined annually by the Chemistry Section.
Composite waste samples are submitted to a vendor laboratory for total isotopic analysis, with the results used to determine the appropriate scaling factors for each waste stream.
Individual shipments of radwaste, except for DAW, are sampled by Chemistry to determine
'amma isotopic content of critical nuclides, and gross alpha determinations.
DAW is surveyed by Radiation Protection and a
licensee developed computer program is used to calculate isotopic activity.
Within the scope of this inspection, no violations were noted.
6.1.2 Unit 2 The Unit 2 PCP is contained in Procedure AP-3.7. 1, "Process Control Plan", which is supplemented by the procedures listed below, reviewed during this inspection, which address specific areas in the processing of radwaste in order to conform with the waste classification and form requirements of 10 CFR 61.
"Asphalt Solidification Operating Procedure" N2-CSP-14,
"Solid Radwaste Surveillance" N2-WHP"4,
"Cask Loading Procedure" N2-WHP-10B, "Operating Procedure Oil Solidification" N2-WHP-ll,
"Process Control DAW" N2"WHP-12,
"Solid Dry Waste Collection and Composition"
The Unit 2 Radwaste Operations section currently solidifies waste through the use of a LN Technologies'ement process.
Unit 2 is in the process of testing an asphalt solidification system to augment the existingcement processing, A provision of the PCP requires that guality Assurance conduct reviews of each batch of radwaste prior to processing to a
solidified form.
Oiscussions with licensee personnel indicate that the intention of this requirement was for all batches of asphalt solidification to be inspected by gA, not all solidified radwaste batches.
The inspector explained the importance of correcting this error.
The licensee currently conducts unannounced guality Control Survei llances of 10% of the PCP batches, which is the same as is conducted at Unit 1, but does not perform survei llances on all batches.
This item is open pending licensee changes to Procedure AP-3.7. 1 (50-410/88-33-01).
The inspector reviewed the records of five radwaste shipments from 1988, selected at random.
Records were found to be complete, calculations accurate, and shipments made in a professional manner.
Ouring 1988, Unit 2 has made 41 shipments of radwaste, with a total volume of approximately 10,500 cubic feet.
Scaling factors for the various waste streams are determined on an annual basis.
Oetermination of radwaste container content is conducted using the same methodology as Unit 1, and the Chemistry'aboratory equipment used for isotopic analysis is the same for both units.
Within the scope of this inspection, no violations were noted.
6.2 Shi in and Trans ot tation Shipping of radioactive materials from the Nine Mile Point site is coordinated through the Site Radioactive Material Shipping section.
Surveys of shipping containers and transport vehicles both before and after loading is conducted by Radiation Protection, who also perform the calculations to determine waste and transport classification.
Plant Chemistry determine isotopic concentrations on material through the analysis of radioactive material samples and the use of scaling factors.
guality Control conducts independent inspections of shipping activities including the acceptance of shipping casks and radwaste liners and High Integrity Containers.
Results of these inspections
10.
are documented and kept on file with other pertinent shipping documents.
The licensee conducts an ongoing training program for technicians in Radwaste Operations as part of its upward mobility program.
Additionally, technicians from the Chemistry and Radiation Protection Division who are involved. in the preparation or transportation of radioactive material are also given training in processes specific to the licensee as well as regulatory awareness training.
Courses in regulatory awareness and site specific procedures are also given'egularly to supervisory personnel involved in the preparation and transportation of radioactive material.
Examination of the training records, course manuals and examination results indicates that this training program meets the provisions of NRC IE Bulletin 79-19.
6.3 Audits The licensee's corporate guality Assurance Department conducts periodic audits of the Process Control Programs at both units.
The most recent audit, number 88006-RG/IN, was conducted during the period March 14-24, 1988, and was reviewed by the inspector for completeness.
This audit identified four problem areas, addressed by Corrective Action Requests (CAR).
Upon issuance of the audit report, both units were required to respond to the CARs in writing.
Responses to the CARs have not been finalized by the Radwaste Operation sections as of December 1,
1988.
CARs are tracked by guality Assurance until final resolution, and the next audit of the Process Control Program will include follow-up review of actions taken to correct these identified deficiencies.
In addition to the four CARs, the audit report also identified seven items which were referred to the Safety Review and Audit Board for further action at the board's discretion.
The audit also included review of responses to previous audit report CARs and to issues raised in previous NRC inspection reports.
7.0 Exit Interview The inspectors met with licensee representatives denoted in Section 1 at the conclusion of the inspection on December 2,
1988.
The inspector summarized the purpose, scope and findings of the inspectio Location
~
NRC Lic Com Table
fl-1 d
1987
TLD Results 1988
25
10
16.1-0.8 14.2-0.5 14.9<0.7 15.4+0.2 14. 2-0. 7 15.%0.2 14.9>0.7 15.2a0.4 15.1+0
15.2-0.8 16.4"-0.6 16.5-'0.8 14.6-0.5 14 3~1.4
1+0
14.5-'l.4 12.9+0.5 13.3-0.4 14.9-0.5 13.6-0.5 15.5'-0.6 17.6-0.7 15.2~0.6 17.2+0.6 14.7-0.5 15.5'-0.5 16. 5 io. 6 17.0~0.4 15.4-0.6 17.4-0.6 15.0~0.7 17.0-'0.8 14.5~0.7 15.4-0.6 14. 3'- 0. 7 15. 1-0. 5 13.1~0.7 15.5+0.6 mi ssing 15.0-0.6 14.400.8 17.8-0.5 13.6=0.7 15.3-0.6 13.9+0.8 14.9+0.3 13.%0.7 14.4<0.3 13. 7~0. 7 14.5+0.3 15.7>0.6 16.2-'0.7 14.2-0.6 13.7~0.6 14.5+0.6 12.9+0.6 13.0-0.5 12.4+-0.5 12.9-"0.5 13.3~0.9
51 15.8+0.8 17.3+0.4 13.8~0.5 14.0+0.4 14.5'-0.5 16.0-0.4 13.%0.7 17.5~0.8 14.0~0.8 15.8-'0.4 13.9+0.5 13.8-0.3
52 15.%0.7 16.6~0.5 15.6+0.6 14.4-0.4 16.4+0.6 16.6-0.4 14.9-0.7 15.8~0.6 14.1-0.8 14.4-0.6 16.2~0.8 14.8+0.3
17
16.00.8 18.2~0.8 14.8'-0.7 15.5~0.4 16.6-0.8 16.6-'0.4 15.510.6 17.4~0.6 15.3+0.5 15. 6~0.3 15.640.6 13.2-0.4 16.9i0.6 18 4'-0
16.6-0.6 16.8-0.6 15. (Lo.s 17.4 0.4 15.3i0.7 16.1~0.6 12.4-0.6 15.4-0.4 14.6~0.7 16.4-0.6 18.0+0.9 16.6-0.4 13.7~0.7 15.%0.3 13.9-0.8 15.2~0.3 15.1+0.6 17.6<0.8 14.%0.5 13.6-0.6 14. 60. 6 14.8-0.5
82
7
92 15.8-0.8 16.2-'0.4 15.640.7 17. 2i0. 4 15 4co
16.6<0.6 15.4<0.7 16.4'-0.4 15.1-0.5 13.0-0.3 14 9io
16.0~0.4 15.240.5 14.3~0.4 15 Oio
15.04.5 15.1-0.5 14.8+0.4 15.7>0.6 18.2+0
16.0-0.6 16 4vo 6 15.6+A.6 18.2~0.6 16.4-0.7 16.2i0.6 13.5+0.7 15.2-0.2 14.8+0.7 15.0+0.5 15.1-0.7 16.8-0.4 13.3~0.7 15.0-0.4 15 1-0.8 16.3-0.4 15.5-0.7 14.240.8 15.8-0.6 16.840.6 14.%0.6 13.2+0.4 14.%0.6 14.210.5 15.1>0.6 13.4*0.5 14.%0.6 14.6<0.6
93 15 3-0
13.5-0.7 15.2%.5 15.7+0.6 14.6-0.5 17.1+0.8 15.0>0.7 15.2+0.4 12.9~0.7 i6.8.O.6 14.6<0.6 12.8-0.3 Notes:
2.
3.
Results are in mR/quarter.
The NRC uncertainty is the random uncertainty at one standard deviation.
The licensee's uncertainty is the standard deviation of the mean resul