IR 05000250/1981004
| ML17340B186 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/03/1981 |
| From: | Cunningham A, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17340B185 | List: |
| References | |
| 50-250-81-04, 50-250-81-4, 50-251-81-04, 50-251-81-4, NUDOCS 8105120600 | |
| Download: ML17340B186 (11) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION REGION I I 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Repor t Nos. 50-250/81-04 and 50-251/81-04 Licensee:
Florida Power and Light Company P. 0.
Box 529100 Miami, Florida 33152 Facility Name:
Turkey Point 3 and
Docket Nos.
50-250 and 50-251 License Nos.
DPR-31 and DPR-41 Inspection at Mia F
id and Homeste
, Florida Inspector:
A.
.
unn1ngha Approved by:
D.
MD Montgom y, A ng Section Chief, EPPS Branch te igned D te Signed Inspection at March 2-6, 1981 Areas Inspected This routine unannounced inspection involved 36 inspector-hours on site in the areas of environmental radiation monitoring including:
management controls; quality control of analytical measurements; implementation of the environmental monitoring program; status review of the onsite meteorological measurements program; review of previous inspection findings.
Results Of the five areas inspected, no violations or deviations were identified in five area Cl
DETAILS Persons Contacted Licensee Employees
- R. J.
Spooner, guality Assurance Engineer S. A. Kingsbury, Radiological Environm'ental Plant Administrator
"J. J. Maisler, Environmental Planning Engineer J. Gaafer, Superintendent Land Management Program
"H.
F ~ Story, Corporate Health Physicist
- F. M. Gavila, Assistant Manager, Environmental Services
- R.
G ~ Fisher, Meteorologist
"A. T. Hall, Environmental Specialist J.
Hays, Plant Superintendent H.
E. Yaeger, Plant Manager H. N. Paduano, Manager Power Resource Nuclear Services
- A. Benedict, Technical Specialist
"H. D. Johnson, Environmental Planning Specialist J.
S.
Wade, Jr.,
Chemistry Supervisor Other Organization J. Pelchat, Public Health Physicist, State of Florida Department of Human and Rehabilitative Services
"Attended exit interview Exit Interview The inspection scope and findings were summarized on March 6, 1981 with those persons indicated in Paragraph 1 above.
Licensee Action on Previous Inspection Findings (Cl osed)
Unresolved Item (50-250/79-16-01, 50-251/78-16-01)
Inadequate Semiannual Survey of Milk Producing Animals.
The inspector revi.ewed the findings of a detailed aerial. survey of milk producing animals conducted by the licensee within a fifteen mile radius of the plant site.
The aerial survey was conducted in November 1978, in response to the subject item.
Inspection disclosed that the survey appeared adequate.
There were no further questions regarding the adequacy of the subject survey.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions.
The new unresolved item identified during this inspection are discussed in paragraph S.
Management Controls
'a
~
b.
c
~
Management and administrative controls defined in Section 6.0 of the Technical Specifications were reviewed by the inspector with respect to the following items:
(1) organizational and management responsi-bility for the radiological environmental montioring program; (2)
environmental monitoring procedures; (3) quality assurance including periodic audits and anlytical quality control.
The inspector conducted a detailed review including discussions with cognizant licensee representatives of recent corporate organizational changes to determine the adequacy of specific management responsi-bility for assuring implementation of the radiological environmental monitoring program.
Inspection disclosed that organizational structure and specific management assignments should assure continued implementa-tion of the program in accordance with license requirements.
There were no questions regarding this item.
Technical Specification 6.8. 1 requires, in part, that written proce-dures shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections 5. 1 and 5.3 of ANSI N18.7-1972, and Appendix A of NRC Regulatory Guide 1.33 (guality Assurance Requirements (Operations)).
Inspection included a compre-hensive review of the licensee's vendor procedures developed to assure implementation of the radiological environmental monitoring program defined in Table 4. 12-1 of Technical Specification 4. 12.
Inspection also included review of the licensee's procedures developed for implementation of the onsite meteorological measurements program in accordance with Section 7.f of Appendix A, NRC Regulatory Guide 1.33.
The radiological environmental monitoring program is implemented by the State of Florida Department of Health and Rehabilitative Services (DHRS).
The inspector reviewed the DHRS procedures listed below.
(1)
A"0 (2)
B-3 (3)
SP-1-3 (4)
SP" 11-1 (5)
SP-III-2 (6)
SP-IV-2 (7)
SP-V-0 (8)
SP"VI"0
"Collection guality Control Samples"
"Analysis guality Control Samples"
"Air Samplers"
~~Biotan
"Gamma Background"
."Water and Precipitation"
"Vegetation"
"Food Crops"
(9)
SP-VII-2 (10)
SP-VIII-0 (11)
SP" IX"0 (12)
SP-X-3 (13)
SP"XI"2 (14)
SP-XII-0 (15)
SP-XIII-0 (16)
1-3 (17)
2-0 (18)
3"0 (19)
4"0 (20)
7"4 (21)
8-0 (22)
9-1 (23)
(24)
Sol l
"Algae"
"Milk"
"Quality Control"
"Annual Garden Census:
"Semiannual Dairy Census"
"Thermoluminescent Dosimeter"
"Nuclear Chicago Gas Flow Proportional Counter" (Laboratory. Calibration)
"Hewlett Packard 54068 Gamma Spectrometer" (Laboratory Calibration)
"Packard Liquid Scintillation Spectrometer" (Laboratory Calibration)
"Gas Meter" (Field Calibration)
"Ionization Chambers, Stray Radiation" (Field Calibration)
"Air Pumps, Gast" (Field Calibration)
Environmental Procedure A-10 Rev.
3 (South Dade Meteorological Tower)
Control Room Procedure 103.2 (Procedure Addressing Maintenance or Winds Speed and Wind Direction Recorders (Plant site water tower meteorological Facility)
Inspection disclosed that both the licensee and licensee vendor main-tained updated procedures including all revisions thereof.
Inspection also disclosed that the subject procedures and all revisions thereof were reviewed and approved by DHRS; however, the procedures were not formally approved by licensee management.
The inspector expressed concern regarding the licensee's failure to formally document their detailed review, approval, and acceptance of their vendors proce-dures.
The inspector reminded licensee representatives that DHRS (the licensee's vendor)
implements a condition of their (i.e.,
the
d.i licensee)
license as defined in Technical Specification 4.12, Table 4. 12-1.
In accordance therewith, the licensee assumes full responsi-bilityy for the adequacy of the licensee condition as implemented, including the adequacy of all procedures employed in required sampling, radiochemical analyses, and quality control programs assuring the accuracy and validity of sampling and analyses.
The inspector informed licensee representatives that their failure to formally approve the subject procedures would.be considered an unresolved item pending a
more detailed review of regulatory procedural requirements (50"250/ 81"04"01; 50"251/81-04-01).
Technical Specification 6.5.2.8.a provides for audit of the licensee's conformance to all provisions contained within the Technical Specifi-cations and applicable license conditions at least once per year.
Inspection included a detailed review of audits and respective audit checklists of radiological environmental surveillance Technical Specification requirements, and The DHRS implementation of environ-mental sampling and respective radiochemical analyses defined by Technical Specification 4. 12, Table 4. 12-1 during the period May 1978, through December 1980.
The scope of vendor audits included the following items:
(1) quality assurance program and procedures; (2)
compliance of sampling and chemical analytical programs with technical specification requirements; (3) verification of radiological environ-mental survey implementation.
Criteria for vendor and Technical Specification. audits included all applicable Technical Specifications defined in Sections 4.0 and 6.0 of that document, Appendix B of 10CFR50, OHRS QA procedures, DHRS sampling and analytical procedures.
Licensee audits conducted during the period May 1978, through December 1980, and reviewed by the inspector are listed below.
(1)
Audit No. 08-03. FLS.78-1 (Vendor)
(2)
Audit No. 08-03.FLS.79-1 (Vendor)
(3)
Audit No. 08.-06.FLS.79-1 (Vendor)
(4)
AUdit No. 08-03.FLS.80-1 (Vendor)
(5)
Audit No. QAE-ENV-80-1 (6)
Audit No. QAS"ENV-80"2 (7)
Audit No. QAS-ENV-79-1 (8)
Audit No. QAA-LEP"78"1 Review of the above audits, their respective findings and required closeouts of such findings, disclosed that the licensee's audits appeared consistent with those requirements defined by Technical Specification 6.,5.2.8.a. 'here were no quesions regarding this item.
6.
Implementation of the Radiological Environmental Survey Program Technical Specification 4. 12 defines the requirements for the licensees radiological environmental survey program.
Inspection included review and discussion of the following items with cognizant licensee and licensee vendor representatives:
(1) semiannual radiological effluent release and environmental monitoring reports for the period January 1,
~(
1979 through December 31, 1980; (2) licensee vendor implementation of environmental sample collections and radiochemical analysis of same as defined in Technical Specification Table 4.12-1; (3) vendor analytical qual ity control program.
Inspecti on di scl osed that al 1 sampl ing including air, water, soil aquatic biota, sediment, and terrestrial excluding milk, was implemented as defined in Table 4.12-1.
Radio-chemical analysis and assessment of samples
'were implemented as required.
Inspection also disclosed however that milk samples were not collected during the entire existence of the sampling program.
A licensee representative stated that such samples were not available because of the following reasons:
(1) the absence of dairy herds within the assigned sampling radius of the plant; (2)
where milk producing animals (cows and goats)
were found, owners refused to sell or give milk as samples; (3) isolated milk producing animals located during semiannual surveys found to be dry.
The inspector reviewed results of the 1978 DHRS aerial survey of milk producing animals within a
15 mile radius of the plant.
The DHRS memorandum (dated December 8,. 1978), which summarized the results of the subject survey, identified at Location 8 an experimental station approximately eleven miles northwest of the plant which raises goats (a herd of approx-imately 70 at time of survey),
some sheep and horses.
The station provides animal blood to hospitals and others for research purposes.
Milk produced by the goat herd is used solely to feed young animals at the experimental station.
In discussions with licensee representa-tives, the inspector was informed that milk sampling was to be confined to commercial dairy herds only and the potential availability of milk samples from the above cited experimental station was not considered.
The intent: of the survey is establishment of an adequate sampling program assuring cognizance of changes in radioactivity in the environs.
Limiting milk sampling to commercial diary herds within the assigned sampling radius where no such herds are resident therein, while failing to attempt sampling of smaller groups of milk producing animal.s within the assigned radius, is consistent neither with the intent nor objective of the program.
The inspector informed licensee representativ'es that an effort should be made to sample milk producing animals within the assigned radius of the plant.
A licensee repre-sentative later stated (telephone conversation with inspector on April 6, 1981)
that the feasibility of such sampling would be immediately reviewed; further, that sampling would be implemented if candidate animals're available and required access.
to same is allowed.
The inspector informed the licensee representative that this finding would be carried as an inspector follow-up item (50-250/81-04-02 and 50-251/81-04-02)
.
The inspector accompanied the OHRS public health physicist during routine sampling/recovery of all air particulate monitoring stations with associated TLOs, and selected surface water sampling stations to verify'mplementation of selected parameters of the environmental
radiation survey program.
Inspection including the following:
(1)
detailed review of sampling and sample recovery procedures employed during actual surveillance; (2) inspection of gas meter calibration records at each air particulate monitoring station; (3) verification of availability of spare air particulate monitoring systems and related spare items including charcoal cartridges, filter media, TLDs.
Inspection disclosed that all particulate monitoring stations and maintenance thereof were consistent with Technical Specificat'ion 4. 12 and those requirements imposed by licensee operations, calibration, and maintenance procedures.
7.
Meteorological Measurements Program Inspection included a detailed review of the status of the onsite meteorolo-gical measurements program and facilities.
The following items were inspected:
(1)
operating, calibration and maintenance procedures and records for plant site (within the restricted area) water tower meteorolo-gical facility, South Dade meteorological tower, and the ranger shack
meter wind speed/wind direction facility; (2) inspection of Units 3 and
control room wind speed/wind direction (232 foot elevation water tower facility) recorders and discussion with control room shift supervisor regarding maintenance of such recorders; (3) inspection of South Dade meteorological facility including discussions with land management personnel regarding operation and maintenance of the facility.
Inspection disclosed that operation and maintenance of the site meteorological facilities network were consistent with licensee procedure and accepted industry practices.