IR 05000245/1979006
| ML19259D253 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/17/1979 |
| From: | Shanbaky M, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19259D244 | List: |
| References | |
| 50-245-79-06, 50-245-79-6, 50-336-79-06, 50-336-79-6, NUDOCS 7910170488 | |
| Download: ML19259D253 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
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50-245/79-06 Report Nos.
50-336/79-06 DPR-21 Docket Nos.
DPR-65 DPR-21
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C License Nos.DPR-65 Priority Category C
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Licensee:
Northeast Nuclear Energy Company (NNECO)
P. O. Box 270 Hartford, Connecticut 06101
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Facility Name:
Millstone Nu' clear Power Station Units 1 and 2 (MNP5)
Inspection at: Millstone Site and NUSCO Corporate Office in Berlin, Connecticut Inspection conducted:
March 12-16, 1979 Inspectors:
W.,
e[M d!2./!N79 M. M. Shanbaky, Radiat40n Specialist date signed ~
f date signed Approved by:
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J. P.
tot (r, Chief, Environmental and Special ddte sit ned '
J Pr ects Section, FF&MS Branch Inspection Summary:
Inspection on March 12-16, 1979 (Combined Report Nos. 50-245/79-06 and 50-336/79-06 Areas Inspected:
Routine, unannounced inspection of erivironmental monitoring programs for operations at MNPS Units 1 and 2, including:
the 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 a followup on the licensee's action on previous environmental inspection findings.
The inspection involved 42 inspector-hours cnsite by one regional based NRC inspector.
Results:
Of the five areas inspected no items of noncompliance were found in two areas.
Four apparent items of noncompliance (Deficiency -failure to
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collect and analyze oyster samples, Detail 5.e; Deficiency -inadequate sampling of required fish impingement monitoring, Detail 6; Deficiency - exceeding the discharge temperature rate of change, Detail 7.a; and Deficiency - simultaneous chlorination during inappropriate intake temperatures, Details 7.b) were identified in three areas.
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DETAILS 1.
Persons Contacted
"J. E. Opeka, Station Superintendent
- E. Farrell, Unit 2 Superintendent
- E. Mroczka, Station Service Superintendent
- J. McHugh, Chemistry Supervisor
- W. Rombely, Operations - Unit 1
- R. Ayala, Station Service Engineer D. Clark, Shift Supervisor, Unit 2 R. W. Johnson, Operations Assistant R. Alleng, I&C - Unit 1 V. Jones, Chemistry Foreman, Unit 1 W. C. Renfro, Chief, Environmental Programs Branch, NUSCO
- B. R. Johnson, Supervisor of Life Science, NUSCO R. C. Rodgers, Environmental Programs Cranch, NUSCO
- D. W. Lenth, Environmental Services, NUSCO
- J. W. Doreski, Environmental Programs Branen, NUSCO
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- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (0 pen) Unresolved Item (245/77 27-01; 336/77-27-01):
Environmental thermoluminescent dosimeters (TLDs) performance evaluation.
The inspector noted that the environmental TLDs performance evaluation was completed for all of the TDL performance paramcters with the exception of energy dependence studies.
The inspector stated that this item will remain unresolved pending completion cf these studies (Details 5.c).
3.
Management Controls a.
Assignment of Responsibility The inspector reviewed the organization and administration of the environmental monitoring programs with respect to changes made since the last inspection of this area.
The inspector determined that these areas remained esse'itially as described in NRC:IE Report Nos.
245/77-27 and 336/77-27.
b.
Audits The inspector rc/iewed the program audits and noted that documented audits were performed by NUSCO staff during 1977 and 1978.
During this period the audits were performed on a semi-annual basis by the Env' 'nmental Review Board (ERB).
The audits were performed in l l 6.f
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accordance with procedures No. MPER-1, which have established criteria to identify, report, correct, and followup on inadequacies in the program.
The inspector reviewed the semi-annual ERB audit conducted in May 1978.
The inspector noted that for each identified item requiring corrective action, the item was brought to the attention of appro-priate management and that corrective action was either completed or in progress.
The second semi-annual audit required by Section 5.3 of the ETS was performed in December 1978, however, the audit results were still being documented.
The inspector stated that this item will be examined during a subsequent inspection (245/79-06-01; 336/79-06-01).
The licensee stated that in addition to the required semi-annual ERB audits, frequent visits to the analytical contractor laboratory were made during 1977-1978.
These visits constituted a continuous program followup and evaluation.
The " :spector noted that frequent meetings of the ERE vere conducted during 1977-1978.
During these meetings, program problem areas, progress and evaluation were discussed.
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c.
Drocedures
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The inspector examined selected administrative procedures and environ-mental monitoring procedures and their respective revisions.
The inspector determined that the examined procedures were reviewed and approved as required.
The inspector discussed with the licensee certain of the program operating procedures including the fish impingement monitoring, chemical useaje inventory and thermal efflue.:t monitoring procedures.
The licensee stated that these procedures would be revised and upgraded (Details 7).
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No items of noncompliance were Mentified in this area.
4.
Licensee Program for Quality Control of Analytical Measurements The inspector discussed with the licensee the quality control (QC) of analytical measurements as related to the radiological analyses of environmental media.
All environmental media anclyses were performed during 1978 by an analytical contractor laboratory, (Interex, Inc.), with the exception of the tritium analysis which w&? performed by Teledyne Inc.
Tha licensee stated that another analytical laboratory (Radiation Management Corporation -RMC) was und as a QC laboratory.
The licensee stated that the program includes QC measures for instrumentation control, QC charts, laboratory personnel qualification and the U.S. Environmental Protection Agency (EPA) crosscheck program.
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The inspector examined the contractor analytical results for EPA spiked I-131 milk samples.
The licensee stated that the r. ilk QC samples were analyze a by Ge(Li)-since chemical processing of dry milk would cause a difficult analytical problem.
The inspector noted that the contractor analytical results were... general agreement with the EPA known spikes al the 50 to 100 pCi/1 concentration.
With regard to Cs-137, Sr-89, 90 and gamma spectroscopic analyses in water, samples were provided by the EPA and analyzed by the contractor on quarterly basis.
The inspector noted that the contractor laboratory analytical results were in general cgree-ment with the EPA known spikes for Cs-137, Cs-134, Co-60 and Sr-89, 90.
Only one Sr-89, 90 spiked water sample (No. 30510) analytical results were in disagreement with the EPA known values.
This was investigated by the license and the analytical contractor, and as a result, an erroneous chemical yield determination was suspected.
The sample sas reanalyzed and better analytical results were obtained.
The licensee spiked H-3 water samples were analyzed by the analytical
laboratory during 197E.
The analytical results were in disagreement with the known spikes et the 10,000 to 20,000 pCi/l levels.
The analytical results of the 10,000 and 20,000 pCi/l H-3 spiked water samples were 5670 and 11400 pCi/1, respectively.
The licensee stated that this area will be investigated to determine the cause of these discrepancies.
The inspector stated that this item will be considered unresolved (245/79-06-02; 336/79-06-02) pending reexamination of the H-3 QC analysis.
5.
Implementation of the Environme.ntal Monitoring Program - Radiological a.
Routine Reports The inspector reviewed the licensee's annual environmental radio-logical monitoring report for the period from January 1 to December 31, 1977.
The inspector verified that the report was submitted to the NRC at the required time and included the required environmental radiation monitoring program results.
The required annual environ-mental radiological monitoring report for the period from January 1 to December 31, 1978 was in a draft form.
The licensee stated that the report will be submitted to the NRC as required by the end of March 1978.
b.
Direct Observations The inspector examined a number of the air sampling and direct radiation monitoring stations.
The inspector examined the operability and the location of the monitoring stations and noted that all the examined stations were in an operable condition and located at the required locations.
The inspector noted that spare charcoal cartridges for iodine sampling were kept in plastic bags at the sampling station.
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inspector discussed with the licensee the possibility of any changes in the cart idges collection effeciency due to environmental factors.
The licensee stated that the stored cartridges are only to be used for offsite sampling during emergency, they are not used for the routine environmental samples collection, however, this area would be evaluated.
The inspector stated that this item will be examined during a subsequent inspection (245/79-06-03; 336/79-06-03).
c.
Environmental Direct Radiation Environmental direct radiation is measured with thermoluminescent dosimeters (TLDs). The inspector examined the environmental direct radiation monitoring station and noted that all the examined stations were provided with TLDs and located as required.
The inspector reviewed the licensee's TLD direct radiation measure-ments data for 1977-1978.
During 1977 the State of Connecticut TLD direct radiation measurements data at four of the near site locations, (Pleasure Beaci, New London Country Club, Ledyard and Old Lyme),
showed an ase? age exposure rate of 11.81 uR/hr whereas the licensee measured average exposure rate during the same period and locations was 7.8 uR/hr.
The inspector discussed with the licensee this apparent discrepancy.
The licensee stated that this area was investi-gated and a TLD-ionization chamber comparison study was initiated.
The licensee stated that the calculated exposure rate values obtained from his TLDs were in agreement with those obtained from the ionization e
chamber measurements within an acceptable statistical error.
The licensee's records showed that the average exposure rates measured with the TLD and ionization chamber were 11.37 and 11.82 uR/hr, respectively during the study period.
The inspector examined the TLD direct radiation measurement for 1978 and noted locations 2, 5, 6, 7, and 8 showed higher than background exposure rate (4.5 uR/hr above the general background radiation),
during the first half of 1978.
All of these TLD stations were located at about 0.5-mile of the plaht. The inspector noted a signifi-cant reduction in the general exposure rates during the second half of 1978.
The licensee stated that the reduction in the exposure rate was attributed to the operation of the new off gas system in May 1978.
The inspector discussed with the licensee the current performance criteria for environmental TLD (NRC Regulatory Guide 4.13 and ANSI N-545-1975).
The licensee stated that the R d performance studies were conducted during 1978.
The inspect'- c'anined the study results including:
(1) Calibratior and laboratory tm *ing 1162
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(2) Field.qposure and dependency on length of exposure period
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(3) Unifor.nity
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(4) Reproducibility (5) Energy dependence (6) Directional dependence (7) Light dependence (8) Foisture dependence
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The study results showed that the TLD would meet the acceptable performance criteria as defined ir, ANSI N-545 and Regulatory Guide 4.13 with the exception of energy dependence.
The ANSI standard specified that the response of the TLD to photons shall be deter-mined for several energies between 30 kev and 3 MeV.
The inspector noted that the TLDs were tested at photon energies between 100 kev and 1 MeV.
The licensee stated that this area will be further investigated.
The inspector stated that this item will remain unresolved pending the completion of energy dependence study (245/77-27-01; 336/77-27-01).
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d.
Milk Sampling and Analyses The inspector reviewed the milk sampling and analyses program results for 1978.
The milk sampling records showed that three of the required sampling stations were relocated during the 1977-1978 sampling seasons.
The control sampling location (No. 22) was changed from 11.0 miles West Northwest to 15.0 miles North Northwest of the plant.
Milk sampling station 20 was relocated from S.0 miles North Northwest to 7.0 miles West and location 24 from 11.0 n.;1es North Northeast to 15.0 miles Northeast.
The licensee stated that these sampling stations were relocated to more suitable locations and the control station was moved to a lower background location.
The inspector noted that, although it appeared that these changes would not result in a significant change in the environmental monitoring requirements, this matter was not previously reviewed and approved by the NRC prior to implementation (ETS, Section 5.6.3).
The licensee stated that all the changes were submitted to the NRC in the proposed new Technical Specifications (Appendix I, TS).
The inspector stated that until these changes are reviewed by the NRC-NRR and incorporated in the new TS, this matter is considered unresolved (245/79-06-04; 336/79-06-04).
The inspector examined a sample of the raw analytical data for cow and goat milk samples for 1977-1978.
The licensee's records showed that the milk samples were collected within the required frequency
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and analyzed with the required Lower Limit of Detectability (LLD, HASL-300).
One milk sample showed 0.5 + 0.3 pCi/l of I-131 with an
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error exceeding the ETS maximum overall error (+ 25% - one sigma).
The licensee stated that this sample was investigated and reanalyzed, but due to the samil sample size (2 liters) that LLD was not met.
The inspector noted that, although the sample volume could have been one factor which lead to this analytical problem, the relatively high counter background was the critical coutributing factor to the observed analytical error.
The licensee stated that as of August 1978 h new p gated anti-coincendent counting system was used for counting the milk samples.
The new system background count rate was significantly lower (0.048 CPM) than that of the old system.
The inspector noted that with the new counting system all the samples were analyzed with analytical sensitivities meeting the required LLD.
Iodine-131 concentrations in the 1978 cow milk samples were below
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the LLD exqept during the nuclear weapons testing fallout period during March and April when the maximum I-131 concentration was 19 pCi/1.
By the end of June 1978, the observed I-131 concentrations were at or oelow the LLD.
Plant related I-131 was detected only in goats milk (* 2 pCi/1).
(This would result in a thyroid dose which represents only a small fraction of the ETS annual design dose objective of 15 mrem /y.)
The 1978 average concentrations of Sr-90 in the collected cow milk samples were 10.8 and 9.3 pCi/l for the indicator and control sampling stations, respectively.
The 1978 average concentration of Cs-137 were 16.0 and 18.4 pCi/l for the indicator and control sapling stations, respectively.
The average Sr-90 and Cs-137 co.1 centration in the collected cow milk samples at the indicator stations were similar to those ambient levels which were observed at the control station.
The 1978 average concentrations of Sr-90 in goats' milk samples were 36.4 and 16.5 pCi/1 for the indicator and control sampling stations, respectively.
Cesium-137 concentrations were 79 and 25.5 pCi/1 for the indicator and control sampling stations, respectively.
Neither Sr-89 nor Cs-134 were observed in goats' milk during 1978 except during the nuclear weapons testing fallout period in March and April.
The inspector noted during this period that the Sr-89 con-centration was at a maximum of 27 pCi/1.
This concentration steadily declined, within the following few months, to 5 pCi/1.
(The absence of Sr-89 and Cs-134 would suggest that the observed Sr-90 and Cs-137 concentrations were not plant related.) The licensee stated that the relatively elevated concentrations of Sr-90 and Cs-137 in milk were investigated and it was concluded, based on the low activity release from the plant and the historically high background of Sr-90 and Cs-137 from fallout in the area, that these concentrations were not plant related.
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The inspector noted, through records review and discussion with the licensee, that the milk animals census was conducted as required (ETS, Section 3.2.3).
e.
Aquatic Sampling and Analyses The inspector reviewed the licensee analytical results of the aquatic samples which were collected during 1978 including oyster samples.
The inspector noted that Ag-110m was observed in oyster samples collected from the quarry (1310 pCi/Kp).
The inspector examined the plant liquid effluent and noted that A9 110m was discharged to the quarry during 1978.
The inspector determined, through review of discharge records and discussion with the licensee that the observed Ag-110m levels in oyster were related to the plant operation.
The inspector reviewed the licensee dose caluclations and verified by independentcalculationsthatthedosetoinqvidualsconsuyngthe oysters from this location would be 8.0 x 10 and 1.2 x 10 mrem to the GI and whole body, respectively.
This represents a small fraction of the 10 CFR, Part 50, Appendix I design criteria which are based on an annual projected dose of 3 mrem / unit.
The licensee stated that the quarry location is not one of the required sampling stations and its samples are not representative of actual environ-mental levels and in addition, no actual dose consequence was antici-pated from these levels since that oysters in the quarry were within the confinement of the restricted area.
The licensee stated that oysters are not native in the plant environ-ment and they have to be seeded on trays to acquire the samples.
The inspector noted that one of the required oyster sampling locations was not sampled for oysters during 1978 (Location 3, Table 3.2.2, ETS).
The licensee stated that oyster trays were originally located at Location 3, however, due to repected loss of the trays at this location during the previous years, oysters were not seeded or sampled from location No. 3 during 1978.
The inspector stated that failure to collect and analyze the oyster samples as required was an item of noncompliance (245/79-06-05; 336/79-06-05).
f.
Meteorology The inspector examined the onsite meteorological instrumentation and readout systen at the control room (Unit 1).
The examined meteoro-logical instruments appeared in an operable condition at the time of inspection.
The inspector discussed with the licensee the meteoro-logical data recovery.
The licensee records showed that the overall recovery of meterological data during 1978 was better than 90% for each of the required parameters.
The inspector reviewed the system calibration results and noted that the meteorological monitoring system was calibrated as required durir.g 1978.
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g.
Site EvacGation Alarm The inspector noted that the site evacuation alarm was not audible at the Unit 1 control room offices.
The inspector discussed this matter with the licensee who stated that the site evacuation alarm was announced on the site page system and because of possible noise interference with the operators in the control room the speaker volume for the page system was lowered in the control room.
The licensee stated that this item will be evaluated and corrective action will be taken.
The inspector stated that until adequate action is completed, this item will be considered unresolved (245/79-06-06; 336/79-06-06).
6.
Implement'ation of the Environmental Monitoring Program - Bio logical / Ecological The inspector reviewed by discussion with the licensee and examination of reported biological data (1977 report), the implementation status of the biological / ecological monitoring program.
The licensee stated that the 1978 biological studies were completed as required by the ETS.
The inspector reviewed portions of a draft of the 1978 annual biological monitoring report.
The inspector noted that the biological studies were completed as required during 1978.
The inspector observed the fish impingement sampling at MNPS-1.
The inspector noted that the required fish impingement sample for March 14, 1979 was dumped into the " trash trough" which contained old debris and fish from previous screen washing.
The inspector reviewed the licensee's impingement sampling procedures (EP8-ll-1-10, Revision 7) which states that "as organisms are sorted, the debris will be placed into the trash trough for disp 2 sal."
The inspector stated that inadequate fish impinge-ment sampling on March 14, 1979 was an item of noncompliance (245/79-06-07; 336/79-06-07).
7.
Nonradioactive Effluent Release Rates and Limits a.
Thermal Releases The inspector determined, through review of the plant thermal dis-charge records and examination of the thermal monitoring equipment and the associated readout systems, that the plant thermal discharges were in compliance with the current NRC regulatory limits during 1978 and up to the time of this inspection with the following excep-tion.
The rate of change of discharge termperature Limiting Condition for Operation, LC0 (ETS, Section 2.1.2), was exceeded for short periods of time on two occasions on July 14, 1978 and March 10, 1979.
These events were reported to the NRC as required.
The inspector noted that tne licensee implementation of corrective action was timely and adequate to prevent recurrence.
The inspector stated that since the reported events resulted in actual release
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from the site exceeding the ETS regulatory limit, this would be cited as an item of noncompliance (245/79-06-08; 336/79-06-08).
The inspector stated that since corrective actions were completed, no further reply to this item was required.
The inspector examined the temperature monitoring procedures for both Units 1 and 2.
The inspector noted that MNPS-1 procedures (OP 323) included corrective actions to be taken when the ETS thermal limits are approached or exceeded.
Such a corrective action state-
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ment was not included in MNPS-2 procedures.
The licensee stated that MNPS-2 procedures will be reviewed and an action statement would be included.
The inspector stated that until the MNPS-2 thermal discharge monitoring procedures are reviewed and modified, this item is considered unresolved (336/79-06-09).
b.
Chlorination and Chlorine Monitoring The inspector reviewed the licensee chlorination and chlorine effluent analyses records for 1978.
The inspector noted that the LC0 for chlorine concentration in the discharge (ETS, 2.3.1.1) was not exceeded.
Section 2.3.1.2, ETS, requires that simultaneous continuous chlori-nation at Unit 1 and Unit 2 occur only when the intake water tempera-ture is between 45 F and 55 F.
The inspector noted that simultaneous continuous chlorination at Unit 1 and Unit 2 was performed on December 10 and 11,1977, when the maximum daily. intake temperatures were 43.7 F and 43.0, respectively.
The inspector stated that this was in noncompliance with Section 2.3.1.2 of the ETS (245/79-06-09; 336/79-06-10).
c.
Chemical Inventory The inspector examined the results of the required chemical inventory for 1977 and 1978.
The inspector noted discrepancies in the reported values for chemical useage and discharges for 1977.
Similar errors were found in the 1978 draft annual report.
The licensee stated that some of these discrepancies are typographical errors and all the noted discrepancies will be corrected and included in the 1978 annual environmental report.
The inspector stated that until the corrected chemical useage and discharge values are reported for 1977 and 1978, this item is considered unresolved (245/79-06-10; and 336/
79-06-11).
d.
Examination of Discharge Quarry on Waterfront The inspector examined the discharge quarry and noted no unusual water quality changes (color, turbidity, odor, etc.).
The inspector noted that excavated material was placed near the meteorological tower at the waterfront.
The inspector discussed with the licensee
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the potential runoff to the Sound from the area which could contain suspended material.
The licensee stated that the excavated material was placed at this location temporarily to improve the waterfront grade at this location.
The licensee stated that the area will be graded and stabilized by the end of April 1979.
The inspector
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stated that until this is completed this item is considered unresolved (245/79-06-11; 336/79-06-12).
8.
Unresolved Items Jnresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, item of noncompliance or deviations.
Seven unresolved items were disclosed during this inspection as described in Details 4.0, 5.c, 5.d, 5.g, 7.a, 7.c. and 7.d.
9.
Exit Interview
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On March 14 and 16, 1979, the inspector met at the MNPS and at the corporate offices of NUSCO, respectively, with the individuals noted in Detail.1. On March 20, 1979, the inspector contacted Mr. B. Johnson and Dr. R. Rodgers of NUSCO by telephone.
During these meetings / contacts, the inspector discussed with the licensee the scope and findings of this iorrection, including each of the noncompliance and unresolved items.
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