IR 05000271/1978025
| ML19276D985 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/11/1978 |
| From: | Shanbaky M, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19276D975 | List: |
| References | |
| 50-271-78-25, NUDOCS 7903020067 | |
| Download: ML19276D985 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-271/78-25 Docket No.
50-271 License No.
DPR-28 Priority Category C
Licensee:
Vermont Yankee Nuclear Power Corporation 20 Turnpike Road Westborough, Massachusetts 01581 Facility Name:
Vennont Yankee Nuclear Power Station (VY)
Inspection at: Vermont Yankee Nuclear Power Station, Vernon, Vermont Inspection conducted: November 13-16, 1978 Inspectors:
As97
,, bkV
/2 M7W M. M. Snanoaky, Rad 1& tion 5pecialist
/da te' s i gned date signed date si ned Approved by:
/1 // 28 J.
p'. S'tchr, Chief, Environmental and date signed Special Projects Section, FF&MS Branch Inspection Summary:
Inspection on November 13-15, 1978 (Report No. 50-271/78-25)
Areas Inspected:
Routine unannounced inspection of environmental monitoring programs for operations, including: management controls for these programs; the licensee 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 actions on previous environmental inspection findings.
The inspection involved 28 inspector-hours onsite by one NRC regional based inspector.
Results: Of the five areas iaspected, no items of noncompliance were found in four areas.
Two apparent items of noncompliance were identified in one area (Deficiency - exceeding the chlorine limit in the plant discharge - Paragraph 7.b; Deficiency - exceeding the pH limit in the plant discharge - Paragraph 7.c).
Region I Form 12
'/ 9 03 0 2 0M (Rev. April 77)
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DETAILS 1.
Persons Contacted
- W. F. Conway, Plant Superintendent, VY
- E.
P. Gaines, Jr., VY-Rutland
- D. J. Marx, Chief Biologist, VY-Rutland
- G. D. Weyman, Chemistry and Health Physics Supervisor, VY
- B. M. Ball, Technical Assistant - Radiological and Environmental, VY
- D. C. Girroir, Engineering Assistant, VY
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (77-14-01): Failure to collect some of the required air particulate samples.
The licensee records showed that corrective actions in this area were completed as described in the licensee letter to the NRC dated September 27, 1977.
(Closed) Unresolved (77-14-02): Exceeding the plant thermal release limits during closed cooling cycle operations.
No thermal release limits were established for closed cooling cycle operations in the new Non-Radiological Technical Specifications (Amendment No. 48 NRTS).
(Closed) Unresolved (77-14-03): Evaluation of exceeding the plant thermal release limits during closed cooling cycle operations.
Based on the NRR staff and the licensee evaluations, the plant thermal release limit requirements for closed cooling cycle opera-tions were eliminated from the NRTS.
(Closed) Unresolved (77-14-04): Chlorination system modes of operation.
Based on the NRR staff evaluation, it is acceptable for the chlorination system to be operated in a manual mode providing the NRTS chlorine limits in the plant discharge are not exceeded.
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 site environ-mental radiation monitoring program is supervised by Mr..
Ball, Technical Assistant-Radiological Environmental, who reports through Mr. D. Weyman, Chemistry and Health Physics Supervisor, to Mr. W. Conway, Plant Superintendent.
Environ-mental radiation monitoring data evaluation and report writing were assigned to Mr. J. Jow, Engineer, who reports through Mr.
P. Littelfied, Radiological Engineering Manager, to Mr. J.
Robinson, Environmental Engineering Manager.
The environmental radiological sample analyses are still performed at the Yankee Organization Environmental Laboratory.
The plant nonradio-logical effluent monitoring programs are supervised by Mr. D.
Weyman, Chemistry and Health Physics Supervisor.
No changes were observed in the administration of the biological monitoring programs.
b.
Program Review and Audits The inspector reviewed the program audits and noted that docu-mented audits were performed by the Vermont Yankee Nuclear Power Corporation staff during 1977-1978.
The inspector reviewed the results of an audit performed on June 7,1978 of the Yankee Organization Environmental Laboratory.
The audit included several of the laboratory activities including labora-tory Quality Assurance.
As a result of the audit it was decided that no sample analyses other than environmental samples will be performed at the laboratory.
The inspector discussed with the licensee this practice and the licensee stated that this action was taken to avoid relatively the high background in the laboratory and possible sample cross con-tamination.
The inspector had no further questions in this area at this time.
No items of noncompliance were identified in this area.
4.
Licensee Program for Quality Control of Analytical Measurements a.
Radiological The inspector reviewed the licensee's program for quality control (QC) of analytical mexurements as related to the radiological analyses of environmental media.
All the en-vironmental media analyses were performed during 1978 at the Yankee Organization Environmental Laboratory.
The inspector reviewed a sample of the laboratory QC procedures including:
Instrumentation Control (Procedure No. 71), Preparation of
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Quality Control Charts (Procedure No. 715); Preparation of Calibration Sources and Process Check Samples (Procedure No.
720); Standardization of Carrier and Standard Solutions (Pro-cedure No. 730); U,S. Environmental Protection Agency (EPA)
Cross Check Program (Procedure No. 740); Yearly Qualification of Laboratory Personnel (Procedure No. 750); and Chemical Reagent Control (Procedure No. 760).
The inspector determined that following these procedures would provide for an adequate QC of analytical measurements.
The inspector discussed with the licensee the apparent lack of background radiation control charts in the procedures.
The licensee stated that this area will be discussed with the laboratory management and will be clarified in the near future.
The inspector examined a sample of the laboratory QC records for 1978 including the results of the EPA intercomparison program. The inspector reviewed the QC data in light of the licensee monitoring requirements, the licensee's acceptance criteria (+15%) and the state-of-the-art for low level radio-logical measurements.
The laboratcry analytical results for the EPA-spiked environmental media (Milk and Water) showed a general agreement for I-131 in milk, gross B and a in water and Co-60, Cs-134, Cs-137, Sr-89, Sr-90 and H-3 in water.
The licensee stated that the environmental themoluminescent dosimeters (TLDs) QC program has continued during 1977 and participation in the 1978-1979 QC program is anticipated.
b.
Biological The inspector discussed with the licensee the QC measures taken to assure validity of biological sampling, sample identi-fication, analytical measurements and data processing, analyses and evaluation.
The licensee stated that the biological programs are under constant review and evaluation by the VY staff and biological contractor management (Aquatic Inc.).
The licensee stated all biological samples identification was performed by qualified biologists.
Each calendar quarter, two phytoplankton, zooplankton and benthos samples were split and then counted and identified by the biologists and the senior biologist.
The analytical results of these split samples were usually in close agreement.
The licensee stated when disagree-ments between the analytical results of the biologist and the
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senior biologist or the external sample examiners were en-countered, the cause of the discrepancy was investigated and additional training was provided.
With regard to the water quality parameters including metals, monthly EPA spiked samples or laboratory prepared unknowns were analyzed as blind samples and the analytical results were evaluated.
The inspector had no further questions in this area at this time.
No items of noncompliance were identified in this area.
5.
Implementation of the Environmental Monitoring Program - Radiological a.
Routine and Nonroutine Reports The inspector reviewed the licensee's annual environmental radiological monitoring report for the period from January 1 to December 31, 1977.
The inspector noted that the report submittal was delayed until June 1, 1978. The licensee notified the NRC of this delay in a letter dated March 23, 1978.
The inspector noted that the delay in reporting resulted from program changes including the startup of the new analytical laboratory and the time consumed to resolve the encountered analytical and nuclear instrumentation problems during the last quarter of 1977.
The inspector verified that the report included the required environmental radiation monitoring program results.
The inspector also reviewed the licensee's nonroutine report (LER-78-1/3L) including the circumstances surrounding this reportable occurrence and the licensee's corrective actions which were taken to prevent recurrence.
The inspector noted that the LER was submitted to the NRC as required.
b.
Environmental Direct Radiation Environmental direct radiation is measured with thermolumine-scent dosimeters (TLDs).
The inspector examined the environ-mental direct radiation monitoring stations and noted that all the examined stations were provided with TLDs and located as required.
The inspector reviewed the licensee's TLD system with respect to system calibration and performance evaluation.
The inspector noted that each TLD was calibrated and assigned a calibration factor.
The licensee stated that VY is still participating in the Department of Energy sponsored TLD inter-comparison program.
The inspector reviewed the 1977 program
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results and noted a general agreement between Oak Ridge National Laboratory (0RNL) and VY results.
The ORNL field measurement showed 34.9+2.4 mR (ionization chamber) whereas the VY TLD reading showiid an average of 29.417.4 mR.
The ORNL laboratory exposure was 91.7+7.3 mR whereas VY TLD readings
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showed an average of 93.4114 mR.
The inspector discussed with the licensee the current performance criteria for environ-mental TLDs (NRC Regulatory Guide 4.13 and ANSI N-545-1975).
Areas discussed included uniformity, reproductibility, depend-ence of exposure interpretation on the length of the field cycle, energy dependence, directional dependence, light dependence, moisture dependence, fading and self dosing.
The licensee stated that the performance of these studies will be evaluated.
The inspected stated that this area will be reexamined during a subsequent inspection. (78-25-01)
The inspectorsreviewed the direct gamma radiation monitoring data for the period from January 1977 to September 1978.
The inspector noted that the direct radiation levels at the monitoring station located near the Vernon School were reduced by a factor of 6-10% as a result of turbine shielding installation during 1976.
The direct radiation exposure rate at the Vernon School including contributions from both the natural background radiation and the VY plant operation during 1977-1978 was 9.98 pR/hr. The inspector noted that the background radiation at the control stations during 1977 was 9.3-10.7 pR/hr.
The inspector had no further questions in this area at this time.
c.
Air Samolina and Analyses The inspector examined several of the offsite environmental air sampling stations.
The inspector noted that the monitoring stations were in an operable condition and located at the required locations at the time of the inspection.
Station No.
1.1 was inoperable during November 5-13, 1978.
The inspector noted that a Licensee Event Report (LER) was prepared by the licensee to be submitted to the NRC describing the noted inadequacy.
The inspector reviewed the environmental air sampling records for the period from September 1977 to November 15, 1978 and noted that, with the above exception, all the air particulate and air iodine samples were collected as require.
The inspector verified, through records review and examination of the air monitoring stations, that the air sampling system
flow rate was 1 ft / minute.
Based on this flow rate the
collected weekly total air volume should be 10080 ft.
The inspector noted that the collected total air volumes, which were recorded on the sampling and analytical sheets, were about 7000 ft3 for each of the sampling stations.
The inspector also noted a wide variability in the volumes of air samples collected at different stations.
The inspector stated that these apparent discrepancies could lead to a conservatism in calculating radionuclide concentrations, nevertheless the results could be erroneous.
The licensee stated that it appears that the calibration factors obtained from the gas meter wet test were inaccurate.
The licensee stated that this area will be evaluated and corrective action will be taken.
The inspector stated that this area would be re-examined during a subsequent inspection.
(78-25-02)
d.
Other Environmental Media The inspector reviewed the 1977-1978 sampling and analytical data for other environmental media including milk, river water, river sediment, ground water, fish, vegetables and aquatic plants.
The inspector noted that the environmental media were collected and analyzed as required.
e.
Meteorology The inspector examined the meteorological instrumentation during the inspection and noted that the required instrumen-tation appeared to be functioning properly at the time of the inspection.
The inspector also determined from the examination of the last system calibration records that the meteorological instruments had been calibrated on a routine basis.
At the time of the inspection the system semi-annual calibration was due, and the licensee stated that the required calibration will be performed within the next few weeks.
The inspector noted that the meteorology readout systems in the control room were operational at the time of the inspection.
The inspector discussed with the licensee the system performance.
The licensee records showed that the meteorological data recovery during 1977 has exceeded 90% for the required monitoring parameters.
No items of noncompliance were identified in this are.
6.
Implementation of the Environmental Monitoring Program - Biological /
Ecological The inspector reviewed by discussion with ths licensee selective program procedures and results.
The inspector discussed with the licensee the biological and ecological data for the 1977 program which was reported to the NRC in report no. 7.
The inspector noted, through discussion with the licensee and review of data, that the biological studies included impingement, entrainment, fisheries, phytoplankton, zooplankton, benthos and water quality studies.
During the open cooling cycle testing the fish impingement experi-ence at VY showed that a relatively small number of spottail shiner, pumpkinseed, white perch and yellow perch *were impinged on the traveling screens. The licensee stated that the fish impingement sampling regime at VY varies with the seasonal variability in the fish populations in the river. The inspector discussed with the licensee the daily impingement monitoring requirements listed in Table 2.2-3 of the NRTS.
The licensea stated the NRTS fish impinge-ment monitoring requirements are only applicable to Phase No. 5 study. The inspector noted that Phase No. 5 study was completed and the results were reported to the NRC as required.
The inspector reviewed the 1977 benthic fauna studies.
Relatively high population densities were observed at sampling stations No. I and 2 during February and at station No. 3 during September.
The inspector discussed with the licensee the benthic organisms sampling procedures and the apparent large numbers of organisms collected from these locations. The licensee stated that the observed high densities were due to the nature of the bottom substrate at these locations which favors tubificids and caddis flies.
The inspector reviewed the summary of the benthic organisms sampling data for 1975 and 1976 and noted similar densities of tubificids, caddis flies and chironomids.
The inspector had no further questions in this area at this time.
No items of noncompliance were identified in this area.
7.
Nonradioactive Effluent Release Rates and Limits a.
Thermal The licensee's current requirements in this area are listed in Amendment No. 48 to the NRTS, effective October 13, 1978.
The inspector determined through review of the plant thermal
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discharge 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.
The inspector had no further questions in this area at this time.
b.
Chlorination and Chlorine Monitoring The inspector reviewed the circulating water chlorination pro-cedures " Sampling and Treatment of Circulating Water - 0.P.
4627." No chlorine addition rate or duration were specified in the procedures.
The licensee stated that the sodium hypochlorite injection rate and duration varies depending on the chlorine demand.
The inspector noted that the chlorination operation did not exceed two hours per day during open cooling cycle and fifteen minutes during closed cooling cycle operations.
The inspector noted that, on several occasions, the condenser discharge continucus chlorine analyzer showed above 0.5 ppm of free residual chlorine.
The licensee stated that most of the free residual chlorine observed at the condenser discharge would be depleted by the time the water reaches the plant aerating structure. The inspector discussed with the licensee measures taken to insure compliance with the NRTS total chlorine limit at the plant aerating structure.
The licensee stated that, with the new chlorination regime, grab samples are taken at the aerating structure and analyzed for total chlorine when relatively high free chlorine levels are detected at the con-denser discharge.
The licensee stated that the chlorination system settings are established based on the previous chlorina-tion experience including the free chlorine at the condenser discharge and the total chlorine concentration at the aerating structure.
The inspector reviewed a sample of the 1977-1978 chlorine monitoring records and noted that the NRTS total chlorine limit at the plant discharge was exceeded on October 20, 1978, for a 15 minute period.
The circulating water system chlorina-tion was in progress during open cooling cycle operation and the free chlorine recorder at the condenser discharge showed about 0.8 ppm of free chlorine.
During the same period, a
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grab sample was taken at the plant aerating structure and analyzed for total residual chlorine.
The sample analytical results showed a 1.1 ppm of total residual chlorine.
The licensee stated that the observed chlorine concentrations were due to a malfunctioning valve in the sodium hypochlorite injection system.
The licensee stated that the chlorination system was shut off and the valve problem was repaired.
The inspector stated that exceeding the total Chlorine Discharge Limiting Condition for Operation (LCO) was an item of non-compliance (78-25-03).
c.
Neutralization Tank pH The inspector reviewed a sample of the condenser cooling water pH monitoring records for the period from August, 1977 to October,1978.
Section 1.B.3 of the NRTS requires that the pH of the plant discharges be controlled within pH limits of 6.5-8.5 except when due to natural causes.
The inspector noted that on April 29,1978, the LC0 for condenser discharge pH was exceeded. The discharge pH value was 8.8 and the continuous pH recorder at the river showed a pH of 7.2 - 7.4 during April 29, 1978. The inspector stated that exceeding the plant discharge pH LC0 was an item of noncompliance (78-25-04).
8.
Exit Interview On November 16, 1978, at the conclusion of the inspection, the in-spector met with the licensee representatives denoted in Paragraph 1.
The scope and findings of this inspection, including each item of noncompliance were discussed.
The licensee acknowledged the findings.