IR 05000289/1984036
| ML20140D748 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/06/1984 |
| From: | Shanbaky M, Struckmeyer R, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20140D741 | List: |
| References | |
| 50-289-84-36, 50-320-84-22, NUDOCS 8412190143 | |
| Download: ML20140D748 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-289/84-36 Report No. 50-320/84-22 50-289 Docket No.
50-320 DPR-50 C License No. DPR-73 Priority - Category C Licensee: GPU Nuclear Corporation P. O. Ban 480 Hladletown, PA 17057 Facility Name: Three Mile Island Nuclear Station, Units 1 and 2 Inspection At: Middletown, Pennsylvania and Harrisburg, Pennsylvania Inspection Condected: November 5-9, 1984 . Inspectors: /4/s V Richard K. Struckmeyer,
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' date Radiation Specialist, DETP A YA / % k PF Anthony A. Weadock, / ' d(te ' ' Radiation Specialist, DETP Approved by: W.
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/2/[[N Mohamed M. Shanbaky, C % f 'date ~ PWR Radiation ProtectF5n Section, RPB Inspection Summary: Inspection on November 5-9,1984 (Corr.bined Inspection Report Nos. 50-389/84-36: 50-320/84-22) Areas Inspected: Routine, unannounced inspection of the operational radiologi-cal environmental monitoring program, including management controls, the licensee's program for quality control of analytical measurements, meteorologi-cal monitoring, and implementation of the radiological environmental monitoring program. The inspection involved 60 hours of direct inspector effort by two region-based inspectors.
Results: Within the areas inspected, no items of noncompliance were identified.
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Individuals Contacted GPU Nuclear Corporation
- J. Auger, Licensing Engineer, TMI-2
- G. Baker, Manager, Environmental Controls C. Behnen, Environmental Technician
- T. Bradley, Ser.ior Environmental Scientist
- J. Byrne, Manager, TMI-2 Licensing R. Danahy, Environmental Scientist J. Garry, Environmental Scientist
- B. Good, Radiological Programs Manager, Environmental Controls
- C. Incorvati, Audit Supervisor, TMI-1
E. Kellogg, Quality Assurance, GPUNC
- R. Knight, Licensing Engineer, TMI-1 l
C. Kramer, Administrative Supervisor, Environmental Controls l.
P. Peavy, I&C Foreman, TMI-2 ! W. Ressler, Biological Program Manager, Environmental Controls L. Toke, Environmental Scientist T. Walsh, Environmental Scientist
- J. Whiteland, Emergency Planner USNRC
- R. Conte, Senior Resident Inspector, TMI-1
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- M. Shanbaky, Chief, PWR Section, RPB, Region I
- J. White, Radiation Specialist, Region I
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- F. Young, Resident Inspector, TMI-1
- Denotes those individuals present at the exit interview on November 9, 1984 2.
Management Controls The inspector reviewed the licensee's management controls for the Radio-logical Environmental Monitoring Program (REMP), including assignment of responsibility, program audits, and corrective actions for identified inadequacies and problem areas in the program.
a.
Assignment of Responsibility The inspector reviewed the organization and administration of the REMP, and confirmed that the present organization is as described in Amendments 77 and 92 to the Appendix A Technical Specifications for Unit 1.
Operation of the environmental monitoring programs at TMI is the responsibliity of GPUNC. Within this organization, the Radio-logical Program Manager, the Biological Program Manager, and an administrative manager each report to the TMI Manager of Environmental Controls. This individual reports through the Safety and Environmental u .
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< Controls Director, GPUNC, to the Vice President, Radiological and Environmental Controls, GPUNC. The inspector noted that the REMP, under the Radiological Program Manager, is divided >into several areas, for which individual Environmental Scientists have responsibility.
These include, for example, environmental sample collection, TLD program, and meteorological monitoring.
b.
Program Review and Audits ' The inspector reviewed the most recent audit conducted by the licen-see of its contractor for laboratory analysis of radiological environ-mental samples. Audit 0-COM-84-06, "QA Audit of Teledyne Isotopes" was performed March 1-2, 1984, by a GPUNC corporate auditor, accom-panied by technical specialists from the Environmental Controls group. The checklist, findings, and audit report were reviewed, and were found to provide satisfactory me:,,ce that the contractor is meeting its requirements.
The licensee stated that it has a separate contract with Midwest Lab-oratory, a division of Teledyne Isotopes, to perform analyses on its quality control samples (i.e., duplicates).
This contract went into effect in mid-1984, and so no official audit has yet been performed.
However, a survey of the laboratory's capabilities, including its suitability for the intended purpose, was done in say, 1984, using a format that is essentially an audit in scope, but no audit report was generated. The inspector reviewed the results of this survey, includ-ing checklists and comment sheets, and determined that the licensee had taken reasonable steps to assure itse!f of the laboratory's abil-ities. The licensee also assured itself of sufficient independence between the two laboratories, so that quality control results would be totally independent of normal sample results.
The inspector also reviewed the internal audit of the radiological environmental monitoring program for 1983, GPU Audit Report S-TMI-83-16, performed between November 1 and December 8, 1983. The previous audit of the REMP had been conducted between September 21 and November 5, 1982. The licensee stated that the 1984 audit is in progress. The inspector determined that the audits were performed within the required frequency specified in the Techni"1 Specifica-tions, and that audit findings had been addressed and corrective actions taken as required.
3.
Licensee Program for Quality Control of Analytical Measurements The licensee stated that,its quality assurance program for radiological environmental monitoring is accomplished by splitting samples from certain sampling stations between two laboratories, by requiring the laboratories to participate in the USEPA Cross-Check program, and by requiring the laboratories to perform duplicate analyses on every tenth sample.
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The inspector reviewed the licensee's procedures and program concerning the review of data as it comes back from the contractor's laboratory.
Procedure No. 9420-SUR-4523.03, " Radiological Environmental Monitoring Program Review", requires a five step review of the data to identify LLD violations, reportable levels, anomalous values, late results, etc.
Pro-cedure No. 9420-SUR-4523.05, " Determination of REMP Investigation Levels and Subsequent Actions", requires an investigation level to be calculated for each type of sample, based on the analysis results of background sam-ples: Investigation level = background level (or average of multiple back-ground levels) + 3.1 standard deviations. The results of samples from environmental indicator stations are then reviewed to see if they exceed the respective investigation levels. When an investigation level is exceeded, Procedure No. 9420-SUR-4523.05 outlines the subsequent actions to be taken. These include evaluating for sampling error and reanalysis of the sample.
The inspector reviewed selected vendor lab data reports, licensee data run-ning tables and calculated sample investigation levels for 1983 and 1984, and TMI Environmental Control Progress Reports for May through August, 1984.
It was noted that investigation levels varied widely from week to week and that significant numbers of samples were exceeding investigation levels.
In several of these instances, results were not followed up with the subsequent actions specified in Procedure No. 9420-SUR-4523. 05; instead, based on reviewer evaluation, they were judged as not signifi-cantly different from background and no further action was taken.
The inspector discussed the apparent problems in this area with the licen-see and found the licensee was aware of them and was planning actions to resolve them.
These actions include the use of the large pre-operational data base to calculate less variable background and consequent investiga-tion levels, and the revision of Procedure No. 9420-SUR-4523.05 to allow for a final determination of samples exceeding investigation levels based on reviewer judgement.
These actions will be reviewed during a future inspection of this area.
(289/84-36-01; 320/84-22-01) The licensee regularly participates in the International Environmental Dosimeter Intercomparison Project, sponsored by DOE and EPA.
The 1984 intercomparison had not been completed at the time of this inspection.
Results from the previous intercomparison indicated close agreement between the licensee's results and the actual dose delivered, as reported by the sponsors of the intercomparison project.
4.
Implementation of the R$diological Environmental Monitoring Program a.
Direct Observation The inspector examined selected environmental monitoring stations, including particulate and iodine air sampling equipment, direct radia-tion (TLD) stations, compositing water samplers, pressurized ion-chamber (PIC) gamma detectors and cryogenic krypten samplers. With the exception of one krypton sampler, which had been removed for repair, all of the selected stations were operating at the time of
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this inspection. The licensee met or exceeded the Technical Specifi-cations requirements in this area.
Specifically, the number of TLD stations exceeds the Technical Specifications requirement, and the use of PIC and krypton detectors is not required.
b.
Review of Reports and Records The inspector reviewed the 1982 and 1983 Radiological Environmental Monitoring Reports, and determined that these were complete and com-prehensive summaries of the sampling, analyses, and results of the REMP, including the various aspects of quality control.
c.
Procedures The inspector reviewed the licensee's procedures for implementation of the REM?, and noted that these procedures covered the overall plan for radiological environmental monitoring at TMI, as well as specific instructions for sampling each of the environmental media included in the program. Procedures for analyses of environmental samples are written and maintained by the contractor laboratories.
The licensee's procedure No. 9420-PLN-4520.01, Rev. 1, dated July 31, 1984, " Radiological Environmental Monitoring Program - Plan", con-tains the following statement in section 4.5.3: " Samples shall be analyzed in accordance with laboratory procedures which are to be reviewed and approved by GPU Nuclear Corp."
The inspector discussed with the licensee its method of approving procedures for sample analyses.
The licensee stated that it does not regularly review all procedures in detail, but instead relies upon a review of all procedures prior to contract award, plus selected review during audits of the laboratories. The licensee committed to provide documentation to the NRC to demonstrate how procedures are reviewed, the depth to which they are reviewed, and what constitutes adequacy for approval. The issue of whether laboratory procedures have been properly reviewed and approved will remain unresolved pend-ing the licensee's submittal of the necessary information.
(289/84-36-02; 320/84-22-02) 5.
Meteorological Monitoring The inspector examined the licensee's meteorological monitoring system, including the on-site meteorological tower, the recorder charts in the equipment house at the base of the tower, and the control room recorder charts.
In October of this year the licensee installed non-redundant wind direction and wind speed indicators at the 147 foot elevation. These indi-cators are still being tested; thus the Technical Specifications and FSAR have not yet been revised to incorporate any reference to the new instru-mentation.
It was noted that all instrumentation was operative, and that the meteorological data readouts from the equipment house and the Unit I control room were consisten. _- . _ _ _ _ _ _ _ _ _ _ ....
The licensee currently calibrates meteorological instrumentation quar-terly, thereby exceeding the Technical Specification requirement of twice yearly calibration. Prior to June of 1984 instrument calibration was per-formed by Technical Environmental Enterprises; this responsibility has now shifted in-house to the Unit 2 I&C department. The inspector -2 viewed calibration procedures and records for the 1983 and 1984 calibrations of the meteorological instrumentation and found them to be adequate.
6.
Exit Interview The inspector met with the licensee representatives (identified in Para-graph 1) at the conclusion of the inspection on November 9, 1984. The inspector summarized the purpose and scope of the inspection and the inspection findings. At no time during this inspection was written material provided to the licensee by the inspector.
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