IR 05000289/1975021

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IE Insp Repts 50-289/75-21 & 50-320/75-12 on 750917-19. Noncompliance Noted:Failure to Notify NRC by Telephone & Telegraph within 24-h on Two Occasions Re Violation of Limiting Conditions for Operation
ML19210B669
Person / Time
Site: Crane  Constellation icon.png
Issue date: 10/16/1975
From: Bores R, Stohr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19210B666 List:
References
TASK-TF, TASK-TMR 50-289-75-21, 50-320-75-12, NUDOCS 7911110137
Download: ML19210B669 (16)


Text

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- ' . (, , ' U. S. NUCLEAR REGUIATOPY COMMISSION OFFICE OF INSPECT *0N AND ENFORCEMar , - ~

REGION I

. . - - -- , 50-289 Inspection Report No: 50-289/7'5-21 and 50-320/75-12 Docket No: 50-320 ~ = DPR-50 censee: Metropolitan Edison Cotipany License No: CPPR-66 n P. O. Box 542 Priority- .. C Reading, Pennsylvania 19603 Category: A ~ Safeguards Three FLile Island :;uclear Station - Units 1 and 2, Group: cation: (TMI-1, D!I-2) Middletown, Pennsylvania I " ,

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Unit 1 - PiiR (36 J), 2535 1.?(t) . ' pc of Licensee: Un it 2 - Ph'R (Em. 2 7 72 m e) ,

Unannounced Environnental Monitoring =- 4 , Unit 1, Special - Unit 2, Routine ='_ of Inscettion:

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. ,. , te jInspection: September 17-19, 1975 j - i . tes of Previous Inspection: August 27-29, 1975 - , .i porting Inspector: e,*M/ /0 -/o - 70 _ , .R.'J. Bores, Radiation Specialist DATE "~ g ' \\ tonpanying Inspe.ctors: NONE ' . ... _. . - .

_ _ -. DATE m .

-

DATE - her Acconpanying Personnel: NONE ~ - - _ _, D ~E /[,[ J vicued By:

. J.PMtchr,SeniorEnvironmentalScientist / DATE 1E b 05' ' '

. . 791111o[3 7 ..

. . . . . . V SU1DfARY OF FINDINGS '~

.

Enforcement Action (Environmental Monitoring) ..... A.

Items of Noncompliance "" - ' ' ' 1.

Violations n None - 2.

Infractions ' , None - 3.

Deficiencies Contrary to Section 5.6.c of the Appendix B, Technical Specifi- =- cations (T.S.) for TMI-1, telephone and, telegraph notifications were not made to the NRC within 24 hours on two occasions in f.

which a Limiting Condition for Operation was exceeded, and the required written reports were not submitted within 7 days of the events.

(Details, Paragraph 7) i . =.. . .; . B.

Deviations ,, - - None -

f ' , ! Licensee Action on Previously Identified Enforcement Action (Environmental Monitoring) ? ! . The licensee's corrective actions as submitted in a. letter dated January 20, 1975, to the USh7C, Region I, in response to items of noncompliance identified in the AEC-RO:I letter of December 20, 1974 and in the AEC-RO Inspection Report No. 50-289/74-34 were reviewed during this inspection.

ip The inspector had no further questions in these matters.

(Details, E Paragraph 4.a) ~ Design Changes $ None Unusual Occurrences 1.

Total. residual chlorine in the plant river discharge in excess of the limits specified by Section 2.2.1.a of the Appendix B, T.S. for 1536 0u0 ' - . _ _. _ - -,. - _ _ . _ _. _

. ?:.4 . I V THI-l was reported to the Co= mission by the licensee on the follow-ing occasions as Environmental Incidents: EI 50-289/75-01 January 24', 1975' letter dated January 31, 1975 = EI 50-289/75-02 April 13,1975 April 18, 1975 = .

::

(Details, Paragraph 6.a.)

{ . . 2.

Total residual chlorine at the plant river discharge in excess of 0.01 ppm for more than two hours on April 17, 1975, in noncompliance with Section 2.2.1.c of the Appendix B, T.S. for TMI-1 was reported ,g by the licensee in a letter as EI 50-289/75-03, dated April 24, %= b4 1975.

(Details, Paragraph 6.a.)

, 3.

Suspended solids in the plant river yater discharge on June 6, .... 1975, in excess of the Section 2.2.2 of the Appendix B, T.S. for TMI-l limits durihg the release of a vaste neutralizing tank was . _ _. reported in a letter to the NRC as EI 50-289/75-04.

(Details, . Paragraph 6.b.)

) , - i

4.

Failure to monitor effluents prior!to discharge as require'd by the Appendix B. T.S. TMI-l Environmental Monitoring Requirements to-ensure compliance with Sections 2.2.2 and 2.2.3 on August 2, 19'75 ~~_ _ _ _. was reported by letter to the NRC as EI 50-289/75-05 on August 9,

. [ s 1975.

(Details, Paragraph 6.b.)

' ,. - 5.

Dissolved solids in the plant water; discharge on August 4, 1975 in excess of the Section 2.2.2 Appendix B, T.S. TMI-l limits was reported by letter to the NRC as EI150-289/75-06 on August 9, " "" 1975.

(Details, Paragraph 6.b.)

i ... _ , .=

6.

Plant river water discharge temperatures in excess of the 3 F Section 2.1.9. (1) Appendix B, T.S. IMI-l limit below the inlet water temperature was reported by letter to the NRC on the fol2owing occasions as Environmental Incidents: . . , EI 50-289/75-07 August 3, 1975 letter dated August 22, 1975 EI-50-289/75-08 August 26, 1975 September 3, 1975 _ (Details, Paragraph 6.c.)

The inspector examined the circumstances surrounding each o.f the , above reported Environmental Incidents and reviewed the licensce's " . 1586 QM a]

  • ' " ~ ' *

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. -3- . . actions to correct the noncompliance and prevent its recurrence.

s_,- The inspector had no further questions in these matters.

(See - . Infractions and Deficiencies Identified by the Licensee, Deficien-cies - Itecs 1-6).

7.

Tritium concentrations in surf ace water samp'les collected down- ..m stream from the TMI-l discharge in excess of four times or ten times the control station values were reported to the !!RC by ~

== letter as required by Section 5.6.2.b of the Appendix B T.S.

TMI-l on the following occasions: - Nonroutine 30-Day Environmental Report 74-02 dated December 24, 1974 Nonroutine 30-Day Environmental Report 75-01 dated April 18, 1975 Nonroutine 7.-Day Environ = ental Report 75-01 dated May 23, 1975 Nouroutine 30-Day Environmental Report 75-02 dated August 18, 1975 The inspector reviewed the licensee's sampling and analytical pro-gram as related to the above reports and also reviewed the liquid ___ discharges f rom TMI-l in conjunction with the sampling program.

""

The inspector' stated that he had no further questions w'ith respect to the reported tritium levels at this time.

(Details, Pa.ragraph 4.b.)

/ ._ Other Significant Findings (Environmental Monitoring) , _.. . ! . A.

Current Findines .- , 1.

Unresolved Items ,- . None 2.

Infractions and Deficiencies Identified by Licensee a.

Infractions " ' None - - , b.

Deficiencies , (1) Total residual chlorine in discharge in excess of Section 2.2.1.a Appendix B, T.S. limits.

(Item 1, Unusual Occurrences) ewas (2) Total residual chlorine greater than 0.01 ppa in - discharge for more than two hours per day as limited .., \\ - 1586 002 - - - - - - - - - - - __ __ .

. ..... -4- , _.

s,/ by Section 2.2.1.c, Appendix B, T.S. (Item 2, Unusual' Occurrences) ,, _,. . (3) Suspended solids in discharge in excess of the Sec- _. - -._ ' tion 2.2.2 of Appendix B, T.S. limits.

(Item 3, "~l- , , Unusual Occurrences)

(4) Failure to monitor effluents prior to discharge as ..i required to ensure compliance with Sections 2.2.2 and 2.2.3 of the Appendix B, T.S.

(Item 4 Unusual Occurrences) _. _ - (5) Diss,olved solids in discharge in excess of the ... Section 2.2.2 Appendix B, T.S. limits.

(Item 5, - Unusual Occurrences) (6) Plant river discharge temperature in excess of the ! 30F, section 2.1.a. (1), Appendix B, T.S. licit below "~^

  • . plant intake water temperature.

(Item 6, Unusual 55[ Occurrences)

5 ~.~"

t ' B.

Status of Previousiv Reported Unresolved Items ... None Reported.

~... . /] Hanagement l , , j Interview

. On September 19, 1975, following the inspection, a meeting was' held at Three Mile Island Nuclear Station.

The following individuals attended: R. J. Bores, Radiation Specialist, USNRC, Region I' ~ ' J. G. Herbein, Manager, Generation Operations - Nuclear, Met-Ed (TMI),

J. J. Colitz, Station Superintendent - Unit 1, Met-Ed (TMI) J. E. Romanski, Supervisor - Radiation Protection & Chemistry, Met-Ed (TMI) T. A. Jenckes, Radiation Safety and Environmental Engineer (RS&EE), Met-Ed ,

(TMI) - M. R. Buring, RS&EE, Met-Ed (Reading) . " During this meeting the following items were discussed: A.

Gene ral ' The inspector stated that this was a special environmental inspec-tion for TMI-l to review the previously identified items of non-compliance and the reported Environmental Incidents since the last i 5C6 0u,a , e

<. - _.=~ss~~.. ~. _ m..w -. _ = __ _

. -5-

. r- ' environmental inspection of the facility in December,1974.

The inspector stated that this inspection did not involve the statis- tical sampling portion of the Sandia Inspection Program at TMI-1.

The inspection of TMI-2 which was conducted concurrently was part ~ ., of the routine inspection program for that facility.- -

' B.

Reported Environmental Incidents (TMI-1) .. . .

.

The inspector stated that he reviewed each of the reported Environ-mental Incidents, EI 50-289/75-01 through EI 50-289/75-08 and m-examined the licensee's corrective actions with resp.ect to each.

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- . hlorine / 1.

C

? " The lic'ensee stated that the special chlorine study at TMI had just ended on September 15, 1975, and that the results of that program have not yet been reviewed.

The licensee expected that some changes in the chlorination regime and/or monitoring requirements may result.

(Details, Paragraph 6.a.)

see 2.

Additional Training 's..

,. . The licensee stated that additional training was b'eing given

  • }

to personnel regarding the requirements of the Appendix B, ,, Technical Specifications and the procedural modification's ' , ' ) implemented to prevent recurrence of Enviro,ncental Incidents.

l"~ The licensee stated that this training would be completed in ' - October, 1975.

(Details, Paragraphs 6.b. and 6.c.). . " 3.

Timeliness of Reports ', . The inspector stated that two of the reported Envir'onmental Incidents, EI 50-289/75-04 and EI 50-289/75-07, were not reported to the NRC by telephone and telegraph within the required 24 hours, nor were the corresponding 7-day written reports submitted within the required time frame.

The in- . . spector stated that this was in aoncompliance with Section 5.6.c of the Appendix B, Technical Specifications.,(Details, Paragraph 7) C.

Nonroutine Environmental Reports The inspector stated that he reviewed the circumstances sur.round-ing each of the four nonroutine environmental reports dealing with tritium concentrations downstream that were in excess of four times ' 1536 004 v -- - .. .. _- - . . _ $ .

. -6- - . (.. or ten times the control levels.

The inspector stated that he also reviewed the liquid waste discharges during the periods of higher .. reported activities and the method of sampling the surface water.

Further, th'e inspector stated that the present method of sampling i ~ - did not appear to assure that the measured tritium levels were , representative of the river flowing past the sampling location i throughout the month.

More frequent sampling at a location to " give a ' larger number of samples per monthly composite was discussed j ~

as a method of obtaining more representative samples.

The licensee

[ stated that this would be evaluated.

j .. ! .... - The inspector also discussed with the licensee the method used by / R the licensee in establishing the " control station value" which was / . used to determine the reporting level for a given sample.

The / inspector stated that the " control sration value" implied that j level of activity measured at the upstream station during the f , sampling period as opposed to the "mean activity level for all samples ceasured to date".

The licensee stated that the term i..,. "'n " control station value" would be re-e.macined.

(Details, Paragraph 4.b.)

, pg gh . D.

Radiological Samoling, Analysis and Related Ouality Contr61

.y, The inspector discussed the following areas with the licensee,:

[ . - ( 1.

The use of hcl and NaHS03 in water samples t'o prevent selective _ ', ion plate-out on container walls and to retain volatile com-T ponents in the sample.

The licensee stated that this area was evaluated but that would be reviewed in conjunction with a study program conducted by a Met-Ed vendor.

-- . 2.

The acquisition and docu=entation of sufficient analytical $ data (background rates, chemical yields, and other pertinent $ parameters) to assure that required analytical sensitivities b: are met.

The licensee stated that this would be pursued with i their contractor.

- g 3.

The use of " low level spiked samples" supplied as " blind" g samples for analysis.

The licensee stated that at present the preparation of such samples is difficult because of lack of an adequate place to prepare them.

The licensee stated that . General Public Utilities (GPU) was building new laboratory

== . facilities and the possibility of GPU supplying the Qunlity Control samples for all GPU served utilities was discussed.

The licensee stated that this item would be evaluated with GPU.

(Details, Paragraph 5) e a 15B6 Da J .. _._ _ _ ,,, .:.t

, -7- . E.

Transformer Slag Pits w/ The inspector stated that during the TMI-l and 211-2 site tours, he noted that the station transformers were situated over slag pits . surrounde'd by concrete vaults.

The inspector inquired as to the method of routine drainage of rain water from these vaults to assure sufficient capacity to contain all the transforcer oil in the event of a major spill.

The licensee was not aware of any . surveillance procedure in this matter, nor whether routine drain-age was required.

The licensee stated that this would be pursued and appropriate action would be taken.

(Details, Paragraph 8) , ya ,Y" . ' I !

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7::: . DETAILS v . '"-

I.

Individuals Contacted =. - Metropolitan Edison ~ J. G. Herbein, Manager, Generation Operations - Nuclear, THI ! ' J. J. Colitz, Station Superintendent - Unit 1, TMI =. i J. E. Romanski, Supervisor, Radiation Protection 6 Chemistry, TMI i G. A. Kunder, Supervisor, Operations - Unit 1, TMI ~~ ./ - T. A. Jenckes, Radiation Saf ety & Environmental Engineer, Reading EE.. I / H. R. Buring, Radiation Safety & Environmental Engineer, Reading / R. W. Dubiel Project Engineer, TMI - , / J. G. Reed, Acting Chemistry Supervisor, TMI ~ ~ -l ,

2.

General - The special environmental inspection of TMI-1 was conducted to EE review the status and corrective actions relative to previously identified noncompliance items and the reported Environment'al ..? Incidents, EI 50-289/75-01 through EI 50-289/75-08.

Th.e inspector

. also reviewed the circumstances relative to the elevated H-3 con-i centrations downstream of the plant discharge and reported by the licensee as NonRoutine 30 Day Environmental Reports 74-2, 75-1 and-x ~ j 75-2 and NonRoutine 7 Day Report 75-1.

.- [,__ i .- , g- " The environmental inspection at TMI-2 was a routine review of the _ , controls exercised by the licensee over the envirencental inpacts during the construction of the station.

The requirements in this ' area are contained in the Construction Permit CPPR-66.

, t The inspection consisted of a selective examination of sacpling and analytical instrumentation, sampling and analytical procedures, records and reports, interviews with personnel and observations by . the inspector.

3.

Organization and Administration {:); ('.i ~ The inspector reviewed the organization and administration of the ' environmental programs at TMI.

The inspector determined that this area was essentially unchanged from that reported at the last ' . 1536 0u7 - ---. - ........ - -. -.. _ _. _ _.. _ _ ..

. . -9- . _) inspection of this area.

(See AEC-RO Inspection Report 50-289/74-34) The licensee stated that Mr. Ro=anski (now the Radiation ... Protection and Chemistry Supervisor). has the responsibility for

  • ~;

routinely. assuring that the construction activities do not cause unnecessary environmental impact.

The licensee further stated that - "" the Operations Department personnel perform at least weekly observa-tions of the site for evicence of oil spills, flooding, erosion, ' etc.

!

,, 4.

Radiological Environmental Monitoring I e . Milk /

  • a.

i ? The, inspector reviewed the licensee's corrective actions as described in the letter to the Commission, dated January 20, - 1975, in response to items of noncompliance identified in the AEC-RO:I letter of December 20, 1974 and the AEC-RO In-spection Report No. 50-289/74-34 as related to the sampling and analysis of milk.

The inspector stated that he had no further questions in this matter.

. The inspector examined the results of the milk monitoring program since November, 1974 and noted that all analyses for I-131 were performed within the required 8 days of, =- sampling and that the sensitivity of analysis war greater , - s ! than the minimum required, i.e., 0.5125%.pC1/ liter at [., ' - time of sampling.

The review of the data indicated the - ~ typical minimum sensitivity for I-131 was 0.04 to 0~.1 pCi/1.

The review of the data indicated all the required analyses y.

were performed.

. b.

Tritium Monitoring in Surface Waters Section 4.4.a, Table 3 of the Appendix B, T.S. for TMI-l re-quires that surface water sampled at the upstream, two down- . stream stations and at the City of Columbia be composited for i

quarterly critium analyses at each location.

Section 5.6.2 of the Appendix B, T.S. states, in part, that if a meas.ured level + of radioactivity in any environmental medium other than gaseous exceeds 10 times the " control station value", a written noti-fication will be submitted to the Commission within one week;

i if a measured level exceeds 4 times the " control station value", , written notification to the Commission will be submitted within 30 days.

. 1586 008 s . - - - ..

. . . " -10- . . W Based on the above requirements, the licensee has submitted a , number of such notifications since the last inspection of this ~~, - The inspector reviewed each of these incidents as identi-area.

'- fled in the SUMMARY OF FINDINGS, Unusual Occurrences. Ite: 7 of this report.

In addition, the inspector reviewed in detail the licensee's river sampling program, the liquid discharge '[[ _ _ _ _ - ~ records, and the licensee's evaluation of each event.

. , The licensee currently obtains daily grab samples of the river vater at the upstream (background) station, at the City of Columbia water treatment plant and at Brunner Island.

These z ~ daily samples are composited to form monthly composites for i tritium analyses.

The two locations downstream of the TMI ' ~~l.

  • discharge, off of Three Mile Island, are sampled on a weekly

""5 basis, with the four weekly grab samples composited for monthly analyses.

_ . The inspector noted that the reported elevated tritium levels were found at the latter two locations.

The licensee stated i that the discharge outf all water followed the shore" line of Three Mile Island to the southern tip and that mixing.with the ri river volume occurred only at the York Haven Dam, further i downstream. Thus, the surface water sampled at these two , ; i-downstream stations consisted of plant discharge water essenti- ~ ally undiluted by the volume of river water flowing past the s f plant.. . ..... j j The inspector also determined that the reported elevated tri-tium levels occurred only when one or more of the weekly grab samples of the monthly composite were taken during a liquid discharge from the plant.

From the review of the release records, it was determined that the weekly grab samples did not represent the activity levels present at the sampling location throughout the month.

Sometimes none of the grab =s[ samples were taken during a discharge so the composite indi-cated background concentrations of tritium.

At other times - one or more of the grab samples were taken during a discharge so that the tritium levels appeared unusually high.

Neither -- case appeared to be representative of the flow averaged tri-tium concentration at the sampling location.

An increase in sampling frequencies at the above locations was discussed with the licensee as a means of obtaining more representative samples.

The licensee stated that the use of an automatic ._ .

  • .

1586 009 ' ' ~ ' ' ' ~ ~ -- -- . M. A T _, m ..x

. . . t-11- , . . . . composite sampler vasconsidered but the lack of electrical ' power in the area was an economic consideration.

The licensee stated,that the use of daily grab samples and/or the automatic = samples would be reconsidered and appropriate action would be - taken.

The inspector discussed with the licensee the current method .) . used by the licensee in determining whether a particular measured activity value was four times or ten times the " control station value".

The licensee presently defined the " control station value" as the average preoperational activity level for that particular media and activity.

The inspector F stated that the " control station value" is generally inter-E preted as that activity level in that media as measured out-side the area of the plant influence.

That is, in the case of H-3 in river water, the " control station value" is that H-3 concentration measured at the upstream sampling station s for that particular sampling period.

The inspector noted that the same nonroutine reports would have been required under either criteria.

The licensee stated the definition of the " control station value" would be reviewed and made consistent with the general interpretation.

NN The inspector reviewed the levels of the reported releases, x ~) the quantities of H-3 released by TMI-1, and. the dicensee's ~ . evaluation of the radiological impacts.

The inspector re-

viewed the licensee's evaluation that no health and, safety questions were involved in that (1) the maximum levels re-ported were no more than 2% of the MFC, (2) the location sampled was not representative of the river concentrations, the latter being much louer, (3) the grab samples were not representative of the water at the sampling location during the month, and (4) the discharge levels were much lower than the applicable limits.

The inspector had no questions with _' this evaluation.

The licensee. recently installed a composite sampler at the discharge pit in a'further attempt to quantify .h . the average release levels of H-3 prior to dilution in the = . river.

No noncompliance nor deviations were noted.. 5.

Radiological Samoling, Analyses and Related Ouality Control . a.

The inspector discussed with the licensee the use of hcl and NaHS03 in water samples to prevent the selective plate-out of ions to the container walls and the loss of volatile com-ponents.

The licensee stated that af ter evaluating the use of the above substances, it was decided not to use the additives.

_ - 1536 07.0 . _ _ _ _ ._ . _ _ _ _ _ _ .

. .- . , , . -12- ,

  1. /77

'; The licensee stated, however, that the results of a study currently being performed by their contractor would be re- ~~ viewed and reconsideration would be given in this area.

.:.= - . b.

The inspector discussed with the licensee the use of " low - level spiked samples" to aid in evaluating the quality of the g... , analytical performance.

The licensee stated that at present it was difficult to submit such samples as " blind samples" because of inadequate facilities outside the plant to prepare the samples.

The licensee stated that General Public Utili- _ . ties (GPU) was creating new laboratory space.

The possibility [ of having GPU supply all the Quality Control samples for all b the GPU served utilities was discussed.

The licensee stated that this would be pursued with GPU.

' . The inspector discussed with the licensee the types of data c.

needed to assure,that the sensitivities of analyses meet those .._ ~ required.by Secti'on 4.4.a. Table 3 of the Appendix.B. T.S.

.;;.r= The types of required information that were discussed.in-cluded: the detailed analytical procedures, counting dates, t'imes, chemical yields (if appropriate), volumes, backgrounds, ,z ' " efficiencies, etc.

Methods and frequencies of verifying the analytical. sensitivities were discussed.

The licensee stated

.:.;.7

, that this would be pursued.

' / ' F ' - ., 6.

Nonradiological Monitoring of Ef fluents p - E ' - . a.

Chlorine l

l I ~ The licensee reported total chlorine residuals in the plant water discharge in excess of the 0.2 ppm limit on two , occasiens (EI 75-1 and EI 75-2) and the total chlorine resi-

duals in the discharge greater than 0.01 pps for longer than ~ two hours on one occasion (EI 75-3). The inspector reviewed ' the corrective actions taken by the licensee as stated in the licensee's reports of those events.

With respect to EI 75-1 and EI 75-2, the licensee stated that the 90-day study was ... just concluded on September 15, 1975, and the final, results $

were not yet available.

This study will be used to determine E an optimum chlorination prograc to maintain biological plant f= cleanliness at minimum environmental expense, to better correlate the chlorine demand with river conditions an'd , plant requirements and to better understand the chlorine levels in the circulation water to various points in the . ) )5S6 01\\ - _ _ gu-

. .. A - -13- . .

  • I plant and at the plant discharge during chlorination.

The licensee stated that the review of this study and any result-ing chlorination procedural change recommendations would not be completed until about January 1976.

. The licensee stated that the continuous chlorine monitor at the plant discharge monitering pit was a continuing source , of calibration problees.

The licensee stated that the monitor is calibrated daily but that it shifts out of calibration be-tween each chlorination.

The licensee is evaluating several other models of chlorine monitors to remedy this problem.

Meanwhile, grab samples of discharge water are analyzed with a J portable amperiocetric tritrator as required when the contin-

=- uous mohtior is out of service.

The review of the chlorine analysis indicated no other chlorine levels in excess of the limits.

.-.

With respect to EI 75-3, the licensee has modified the storage area and stcrage procedures to assure that chemical supplies, g.. including carboys of sodius hypochlorite, are stored such that !?m their contents will not end up on the plant discharge water in

the'; event of a spill or broken container.

The inspector stated F_ =" that he had no further questions in the above matters at this time.

- = . ) - .

-./ b.

Solids in Plant Effluents - The : licensee reported three Environmental Incidents since the - lastl inspection relative to solids in plant effluents.

The insppctor reviewed each incident and the resulting ccrrective actions, as appropriate.

- '. EI 78-4 resulted when the suspended solids in the plant , effluents exceeded the Section 2.2.2, Appendix B, T.S. limits

during the discharge of a water neutralizer tank.

This re- , sulted in procedural changes which require, in part, better communications between Operations and the Radiation Protection and Chemistry Departments.

. EI 75-5 was a result of failure to monitor the effluents for - chemical paramaters' required by Sections 2.2.2 and 2.2.3 of r!! the Appendix B, T.S.

Corrective actions in this matter are ~ = primarily geared to the increased training of personnel in-volved in the requirements of the Appendix B, T.S.

The licensee stated that this training should be completed by the end of October, 1975.

' i536 072 - _ _

  1. 8 er

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. . . ~ . -14- ..A ef \\. ' ') EI 75-6 was a result of unusual river conditions such that the dissolved solids in the intake water exceeded the allowable discharge limits.

The plant river discharge concentrations, .; thus exceeded the Section 2.2.2 Appendix B, T.S. limits.

The -- ~ licensee is planning a T.S. change in this regard to take into account unusual river conditions.

The inspector had no further ~ l r:,. questions with regard to the above matters at this time.. - N.i c.

Temperature of Plant Discharge Water }]; ... The licensee reported two occasions in which the plant river [.?" discharge temperatures were more than 30F below the river

~..

intake, temperatures in noncompliance with Section 2.1.9.(1) b, of the Appendix B, T.S.

EI 75-7 resulted when an operator adjusted the mechanical i cooling tower operation while trying to maintain the plant _1 effluent temperature differences between 00F and 30F as re- ['] quired when the river temperatures exceed 870F.

The licensee SE has issued further guidance to the operators for cooling tower . l . operations and made procedural modifications requiring closer

, observance of this operation.

operation

- 'S. EI 75-8 resulted when ambient atmospheric conditions cha'nged _ , ~ ) too rapidly to allow corresponding cooling, tower operations to [,_ -' follow during the approach of a storm.

The licensee may. re-p quest a T.S. change to allow for such temporary changes.

The [[.; inspector had no further questions in the above matters at E fjl this time.

- - . 7.

Timeliness of Reports . Section 5.6.c of the Appendix B, T.S. requires that in the event a ' Limiting Condition of Operation is exceeded, notification _must be made to the Commission within 24 hours.tur telephone and_ telegraph - and this is to be followed by a written report within 7 days.

The inspector determined that on two occasions, EI 50-289/75-04 and EI 50-289/75-07, the initial notification was received by the . Commission approxi=ately 27 days and 12 days, respectively, af ter the Limiting Condition of Operation was exceeded.

The followup reports were submitted within 7 days af ter the initial notifica-tiens.

The inspector stated that these notifications and reports were not submitted within the required time intervals and that this was in noncompliance with the T.S.

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-15- , T: . . . 8.

Transformer Slag Pits ,, ) During tnc tour of the TMI-l and TMI-2 sites, the inspector noted that the station transformers were located over slag pits surrounded by concrete vaults.

The inspector inquired as to the method of

' " assuring.the vaults do not fill with water from precipitation, there- . by, reducing their capacity to contain transformer oil in the event; , of a major spill or transformer rupture.

The licensee was unable F+=

{i was used to periodically check the level of water in the vaults.

~ g.il to determine if a maintenance procedure or surveillance procedure j mh ' The licensee stated that the construction of these vaults would be reviewed to determine if provisions were made for draining the pre I '#~ cipitation from the vault while retaining oil, if present.

The !

== licensee further stat'ed that appropriate action would be taken to / assure that transformer oil releases to the environment would be i! precluded.

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Protection of the Environment During Construction Activities E} The inspector examined the areas of construction on the TMI-2 site

to ascertain the provisions cade to prevent adverse environmental 7f} impact during construction activities. Most of the outside con-

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'= struction involving earth moving had been completed.

The licensee stated that weekly observations of the construction and ground drainage areas were made by the Operations Department for signs of .: oil or other chemical discharges and for signs of flooding or e w erosion.

The inspector noted no signs of oil, flooding, erosion l ) or siltation in,the drainage areas.

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