IR 05000289/1988009

Insp Repts 50-289/88-09 & 50-320/88-04 on 880411-15.No Violations Noted.Major Areas Inspected:Radiological Effluent Control Program,Liquid & Gaseous Releases,Radiation Monitoring Sys Calibr & Functional Tests

ML20155D890
Person / Time
Site:	Three Mile Island
Issue date:	05/25/1988
From:	Davidson B, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155D885	List: IR 05000289/1988009 ML20155D881
References
50-289-88-09, 50-289-88-9, 50-320-88-04, 50-320-88-4, NUDOCS 8806150443
Download: ML20155D890 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report N /88-09 50-320/88-04 Docket N _ ,3M License No. OPR-50 OPR-73 Category C .

Licensee: G.P.U. Nuclear Corporation P.O. Box 480 Middletown, P Facility Name: Three Mile Island Units One and Two Inspection At: Middletown, Pennsylvania Inspection Conducted: April 11-15, 1988 Inspectors:  ! M B. S. Davidson, Radiation Specialist ' date Approved by: 1 4 :r w 4 25~ ff W. J. P[a ciak, Chief, Effluents Radiation /date/'

Protecv on Section, FRSSB, DRSS Inspection Summary: Inspection on April-11-15, 1988 (Combined Inspection Report Nos. 50-289/88-09; 50-320/88-04)

Areas Inspected: Routine, unannounced inspection of the licensee's radiological effluent control program. Liquid and gaseous releases, radiation monitoring system calibration and functional tests, air cleaning system test Results: No violations were identified. One unresolved item was identified, failure to have surveillance procedures for miscellaneous effluent monitors at Unit 2, (Section 5.0).

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Details 1.0 Persons Contacted

' Licensee Person'nel'

• R.1 dells, Lic'ensing Engineer, TMI-2

• D. Hassler, Licensing Engineer, TMI-1

• C. Incorvati, Audit Manager, TMI-2

• 0. Buchanan; Recovery Engineer, TMI-2

• J. Tarpinian, Mgr. Radiological Engineering, -TMI-2 -

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• J. Bondick, Supv. Radiological Engineer,TMI-2

• S. Williams, Radiological Engineer, TMI-1

• D.' Turner, Director, Radiological Controls, TMI-2

• J. Byrne, Licensing Manager, TMI-2

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1.2 NRC

• R. Conte, SRI

• T. Moslak, RI-TMI-2

• Denotes those present at the exit interview on April.15, 198 .0 Actions on Previously Identified Item 2.1 '(Closed) Unresolved Item (289/87-09-16) Review licensee's 7/1/86-12-31-86 Semi Annual Effluent Release Report. The inspector reviewed this report as well.as both reports for 198 The reports were submitted in a timely manner'and activity release quantities appear to be within expected values for PWR's of this design. The licensee reported twenty-six abnormal gaseous releases in the latter half of 1986 and five in the second ' quarter of 1987. Inspector review of these releases and the licensee's subsequent actions to modify the criteria under which releases were declared "abnormal" determined that the releases were within Technical Specification Limits. This item is close .2 (Closed) Inspector Follow-Up Item (289/87-SR-05) Radiological Effluent EAL's Revised. Generally, of the changes that were made to the EAL's, the significant changes were made to the low range gaseous

' release monitors setpoints (in most cases, by a factor of 2) and are based on the Technical Specifications and ODCM calculations. These changes were fcund to be acceptable. With respect to "abnormal releases", criteria now include that the duration of readings on a ,

monitor exceed alert setpoints for more than 15 minutes due to airborne or liquid discharges greater than twice MPC when averaged over one hour (initiate 50.73 notification), or uncontrolled /unan-ticipated releases greater than MPC on an instantaneous basi This item is closed.

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3.0 . Purpose The purpose of this routine inspection was-to' review the licensee's

' radioactive effluent controls program for the following elements:

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Effluent Release Records and Reports

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Effluent Sampling and Analysis

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Offsite Dose Calculations

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Air Cleaning System Tests

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Radiation Monitoring System Calibrations and Tests The licensee conducts separate programs at the two units. The TMI-2 program was reviewed in its entiret Portions of the Unit One program were briefly inspecte ' 4. 0 Radioactive Effluents Controls Program - Unit One

.The inspector reviewed portions'of the Unit One program as an overview and will conduct a thorough review in a subsequent inspectio Discussions with a-Radiological Engineer cognizant over the effluents program revealed that the licensee uses a computer program called "LAGER" (Liquid and Gaseous Effluent Release) which is used in initiating release permits for gaseous and liquid discharges. The inspector witnessed sample data entry and activity / concentration calculations, required dilution, and dose calculations for one gaseous and one liquid releas The review established the methodology by which the licensee demonstrates compliance with Technical Specifications 3.22.1, "Liquid Effluents" and 3.22.2 "Gaseous Effluents" and subparts for concentration, dose and dose rat The inspector also reviewed the following procedures:

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- 9100-ADM-4250.01, "Liquid . Release Permit" l

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• 9100-ADM-4250.02, "Gas Release Permit" l

! and the associated permits for liquid release No. L8804051 and 9as release 8803014. The inspector reviewed the licensee's Offsite Dose Calculation ~'. ual (0DCM), 9100-PLN-4200.01 and Operations Procedure 1101-2.1, "Ra * tion Monitor System Setpoints. No violations were noted. Dose C ..Jlations for the two releases were independently calculated by the NRC inspector and compared to the licensee's value The licensee's values compared very well with the inspector's calculation Within the scope of this review, no problems were note .

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. 4 5.0 Radioactive Effluent Controls Program - Unit Two The inspector reviewed'the Un'it Two program through discussions with the cognizant Radiological Engineer, review of. procedures and representation records and periodic-dose and effluent report The licensee provided records of samples for discharge of non-accident liquid effluent wastes. The inspector noted that the criteria for non-accident liquid wastes were met. The inspector reviewed gaseous radioactive effluent data, sample analysis and calculations-of released radionuclides; no problems were noted. However,.the licensee provided the inspector with a memo which summarized the results of .- !

comprehensive effluents audit which indicated that not all of the ga m us effluent release pathways had surveillance procedures for radiation-monitors. Specifically, the monitors for the Respirator and Laundry Cleaning Facility (RLMF), the Babcock and Wilcox Chemistry Trailer (B&WCT)

and Containment Air. Control Envelope (CACE) were identified as not having sampling surveiliance procedures. The RLMF Surveillance Procedures have been written but:have not been issued. Releases from-the B&WCT and CACE areas are being' incorporated in the Quarterly Radiological Release and Estimated Dose . Reports (ETS 5.6.lc) and the Semi-Annual Effluent Release Reports required by 10 CFR 50.36a. The inspector stated that;the lack of surveillance procedure for effluent monitors was unresolved (50-320/88-04-01). Technical Specification 6.8.la states that written procedures should be established, implemented and maintained covering.the activities recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972. Sections 7(a)2, "Sampling and Monitoring" and 7(a)3, "Discharging to Effluents" of "Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel e nosure)" of Appendix "A" would appear to have been violated and constitute a licensee identified violation against T/S 6.8.la. The timeliness of corrective action will determine whether the provisions for licensee identified violations in 10 CFR 2, Appendix C apply. This will be reviewed during a

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future inspectio .0 Radiation Monitoring System The inspector reviewed radiation monitoring system (RMS) calibrations and functional tests by review of Technical Specification and Procedure requirements for the following systems:

• EPICOR-II Vent System Radiation Monitor Flow Rate Monitor Calibration (4221-SUR-3526.02), T/S 2. EPICOR-II Building Vent (Discharge) Flow Rate Monitor Calibration (4221-SUR-3526.02), T/S 2. *

Vent / Purge Exhaust Radiation Monitor (4221-SUR-3661.05), T/S 2. <

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.' 5 RMS-Victoreen (4221-SUR-3661.13), T/S 4.3. EBERLINE Beta Air Monitor (AMS-3) (9200-SUR-3661.03), T/S 4.3. *

RB Purge Exhaust Monitor Functional Test (4221-SUR-3661.01), T/S 2. RMS Calibration-Eberline (4221-SUR-3661.14), T/S 2. EBERLINE RMS Operability Check (4221-SUR-3661.17), T/S 2. The AMS-3 monitors are used in the B&WCT, CACE and Waste Handling and Packaging Facility (WHPF). Calibrations and test for 1987 for the above RMS equipment were reviewed and found acceptable. The Liquid Effluent Line is blank flanged of Within the scope.of.this review, no concerns were note .0 Air Cleaning System Tests The inspector reviewed the licensees' program for air cleaning system operability and filter tests against Technical Specifications and Procedure Requirement Tests for the following systems were reviewe Control Room Emergency Vent System (4210-S'lR-3826) T/S 4.7. Auxiliary Building Air Cleanup System (4210-SUR-3829) T/S 4.9.1 Fuel Handling Building Air Cleanup System (4210-SUR-3830) T/S 4.9.1 No problems were note Records for 1986-1987 were reviewe Miscellaneous facilities (i.e. RLMR, WHPF, etc.) with filtration systems were reviewed for the methodology and frequency of filter change out and testin The inspector reviewed two preventative maintenance procedures,

• 00P Testing of Temporary and Miscellaneous Air Handling Systems (4224-PMU-3916.03)

Change of Air Handling Filters (4224-PMU-3820.03)

and determined that the licensee generally uses the appropriate DOP filter testing methods following filter change out or maintenance.

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However, the inspector noted that procedure 4232-0PS-4020.01, "Operation of the Respirator Cleaning Facility" Exhibit 9, "HVAC HEPA Replacement and Testing", Section C(10) states "Perform In Place Filter Tests" and C(9) states " Ensure AMS-3 is operational". Neither preventative maintenance procedure is referenced and the AMS-3 was replaced by an EBERLINE 'P!NG'. The licensee stated they would modify the procedur ~_

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l 6 No other concerns were identified.

l 8.0 Exit Interview The inspector met with licensee representatives (denoted in Section One)

, at the conclusion of the inspection on April 15, 1988. At no time during l the inspection was written material provided to the licensee by the

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