IR 05000277/1988033
| ML20207L568 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/04/1988 |
| From: | Davidson B, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207L544 | List: |
| References | |
| 50-277-88-33, 50-278-88-33, NUDOCS 8810170352 | |
| Download: ML20207L568 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-277/88-33 Report No.
50-278/88-33 50-277 Docket No.
50-278 DPR-44 License No.
DPR-56 Priority Category _C
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Licensee:
Philadelphia Electric Company 2301 Market Street Fhiladelphia, PA 19101 Facility Name:
Peach Bottom Units 2 and_3 Inspection At:
Delta, PA Inspection Conducted:
September 6-9, 1988
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[d J, /fM Inspectors: _.
j,g y _ David' sin, Radfation Specialist
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/,//jf9g Approved by:
_ Chief, Ef fluents Radiation da/e j
W ter cias,
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Protection ection, FRSSB, ORSS Inspection Summary:
Inspection on September 6-9, 1988 (Report No. 50-277/88-33; and 50-278/68-33)
Areas Inspected:
Routine unannounced inspection of the licensee's radioactive eff fuent cont 7ols program including effluent releases, radiation monitoring system calibration and surveillances, air cleaning systems testing, manacement controls.
Results: No violations were identified.
One unresolved item was identified pertaining to the offsite dose calculation manual.
Details, Section 3.
0010170352 881004 PDR ADOCK 05000277
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DETAILS 1.0 Personnel Contacted During the course of this routine inspection, the following personnel were contacted or interviewed.
1.1 Licensee Personnel
- G. Hanson, Regulatory Engineer
- D. LeQuia, Supt. Plant Services
- T. Cribbe, Regulatory Engineer
- 0. Odell, Support Chemist
- D. Oltmans, Senior Cnemist
- G. Dawson, Senior Engineer, I&C
- J. Pratt, Manager, Quality Other licensee personnel were contacted or interviewed during this inspection.
1.2 NRC Personnel
- L. Myers, Resident Inspector
- Attended the exit interview on September 9, 1933.
2.0 Management Controls The inspector reviewed the 11censee's management oversight for the control of liquid and gaseous effluents, including assignment of responsibility and progran audits.
2.1 Assignment of Responsibility The Chemistry Department has primary responsibility for control of liquid and gaseous effluents, reltase permits, off site dose calculations, effluent monitor calibrations and preparation of Semiannual Radioactive Ef fluent Release Reports.
A plant chemist is responsible for the day to day operations and program implementation.
This individual reports to a senior chemist who reports to the
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Superintendent of Plant Services.
A separate Quality Assurance i
Division cunducts audits of selected activities.
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2.2 Audits The inspector reviewed the following audit:
+AP87-13[HPC, "PBAPS Liquid and Gase~:s Effluent Releases /Off site Oose Calculation Manual (00CM)"
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This audit was quite comprehensive and included acceptable and unacceptable findings. The inspector noted that within the context
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of unacceptable findings, several immediate changes resulted such as:
- Revision 19 to HP0/CO-18, "Processing Liquid Radioactive Waste"
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included an additional step to ensure that valves HV-2-20-144,
146 are properly aligned es a means to prevent inadvertent l
releases.
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'Several inconsistencies between the licensee's ODCM and USNRC i
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Regulatory Guide 1.109 were clarified and incorporated into revision 2 of the ODCM.
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i 3.0 Effluent Releaso Records i
The inspector reviewed the licensee's effluent release data from i
j January 1, 1987, to September 9, 1988. During the first three months of
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i this time period both gaseous and liquid releases occurred from unit i
operation.
Since then both units have been in outage conditions and no
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continuous fission gas releases have been made.
The inspector reviewed gaseous releases for the first quarter cf 1987 and performed spot checks l
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on liquid release data throughout the twenty-one month period.
In this j
review, two discrepancies were noted.
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1)
The licensee's Offsite Oose Calculation Manual, Revision 2, only
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requires the licensee to calculate the dose from liquid effluents, to the total body and bone to a member of the public at and beyond
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the site beundary rather than to the total body and any organ of a
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member of the public as required by Technical Specification
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3/4.8.B.2, and as a result, Revision 2 of the 00061 does not fully l
implement the Technical Specification requirements.
Normally,
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at a BWR on a fresh water site, radioactive liquid effluent dose pathways to the liver of a teen-age member of the public predominate due to the isotopes of cesium and zine-65.
The licensee should i
revise the 00CM to be consistent with Technical Specification Requirements and verify that Technical Specification requirements have been conformed to for any organ exposure.
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Prior to the issuance of the licensee's Technical Specifications in j
the current form, lable 4.8.1, "Radioactive Liquid Waste Sampling and Analysis" included the requirement to analyze proportional
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composites of batches for P-32 along with other radionuclides.
The P-32 analysis requirement was deleted from Table 4.8.1 but the
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licensee retained the sampling and analysis requirement in their j
surveillance procedures (ST 7.5.1.d).
Accordingly, whenever P-20 is i
measured in liquid effluents,,,he bone does become the maximally I
exposed organ.
In the absence of P-32 the maximum dose is i
calculated to the liver of a teen age individual.
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2)
The inspector calculated the infant thyroid doses from.first quarter 1987 radiciodine releases using the models and equations of tFS licensee's 00CM.
Licensee and NRC values were identical.
The licensee's Semiannual Radioactive Effluent Release Reports for 1987, which include quarterly dose summaries, were found to disagree with the values contained in the licensee's Annual Dose Assessment Report for 1987, viz: the Seni Annual Report Table 1A line B-3 critical organ dose total of 0.0683 mrem disagreed with the Annual Duso Assessment Table VI-5 Annual Doses to All Organs by Pathway at location of Highest Organ Dose (Thyroid), which gives c value of 0.134 mrem for an infant thyroid from the cow-milk pathway.
The licensee stated that they would review their liquid effluent data back to 1985 and calculate teen liver doses to determine whether they were in compliance with the requirement to calculate cumulative organ doses to the maximum exposed organ in T/S 3.8.B.2.
This information and necessary changes to the 00CM will be provided to the NRC within the reporting period for the next semi annual radioactive effluents release report.
The inspector stated that this determination of compliance with T/S 3.8.8.2 and evaluation of apparent discrepancies between the 00CM calculated thyroid doses and those reported in the Annual Dose Assessment Report would be considered an unresolved item (50-277/88-33-01; 50-278/88-33-01).
4.0 Radiation Monitoring Instrumentation Technical Specification 4.8.B.3.9 requires, in part, the liquid radwaste effluent radiation monitor to be calibrated every 12 months; 4.8 B.3.b requires, in part, flow calibrations every 12 months.
Specification 4.8.C.4 requires, in part, radiation monitor calibrations on reactor building exhausts and main stack raofation mcnitors, flow rate monitors and sample flow rate monitors every 12 months.
The main stack sample flow line Hi/Lo pressure switches are functional tested every six months and calibrated every 18 months (paragraph 4.8.C.4.d.)
The inspector reviewed the performance of the following surveillance tests (ST's) for compliance with these Technical Specifications:
oST 2.5.3.A, B, "Calibration of Vent Stack Flow Loops";
- ST 2.5.4. A, B, "Calibration of Of f Gas Stack Flow Loop";
- ST 2.5.18, "Calibration of Vent Stack Sample Flow Loop";
- ST 2.5.19, "Calibration of Radwaste Building Vent Exhaust";
- ST 2.5.37, "Calibration of FIT-422, FS-493, FR-441";
- ST 2.5.38, "Calibration and Setpoints of Discharge Flow Monitor";
- ST 2.5.39, "Calibration of Main Stack Sample Flow Instrumentation";
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- ST 2.10.10 "Calibration of FT 3979A, B Main Stack Rad. Monitor";
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In addition, the following surveillance test results were also reviewed:
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- ST 4.6.1, "Main Steam Line Source Calibration" (T/S 3/4.2);
- ST 4.7.2-2A/3A, "Vent Stack Radiation Monitor Calibration"; (T/S 3/4.8.C.4a) and
- ST 4.7.3.8, "Control Room Radiation Monitor Calibration (T/S 3/4.11).
Spot checks on surveillances performed from 1987-1988 indicated that they were performed on schedule as required.
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Within the scope of this review, no violations were noted.
5.0 Air Cleaning System Testing
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Technical Specifications 3/4.7 and 3/4.11 require, in part, that the
Standby-Gas Treatment System (SGTS) and Control Room Emergency I
i Ventilation Systems be periodically tested for removal efficiencies to challenge gases and particulates.
The inspector reviewed records of
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tests and surveillances as follows:
- ST 7.4.4 and 7.4.6, "In Place 00P Leak Test, Halide Test and Carbon Sample Lab Analysis".
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and 'B' train SGTS systems 12/87 and 2/88;
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- ST 7.7.1, "Control Room Emergency Ventilation Filter Efficiency Test", 11/86 and 10/87; and
- ST 13.7A, "SGTS Filter Diffs ential and Heater Capacity Tests",
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12/85, 6/87, 11/87, 2/88, i
These tests are performed by a vendor who works under PBAPS procedures.
No violations were noted.
6.0 Unresolved Item
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Unresolved items are items about which more information is required in l
order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed.during this
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inspection is discussed in paragraph 3.
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7.0 Exit Interview
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The inspector met with licensee representatives identified in Section 1.0 t
at the conclusion of the inspection on September 9,1988.
The inspector summarized the scope of the inspection and the inspection findings. At
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no time during this inspection was written material provided to the licensee by the inspector.
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