IR 05000289/1988014

Insp Repts 50-289/88-14 & 50-320/88-11 on 880711-15.No Noncompliance Noted.Major Areas Inspected:Operational Radiological Environ Monitoring Program & Program for QC of of Analytical Measurements Meteorological Monitoring

ML20207D297
Person / Time
Site:	Three Mile Island
Issue date:	08/05/1988
From:	Jang J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207D290	List: IR 05000289/1988014 ML20207D286
References
50-289-88-14, 50-320-88-11, NUDOCS 8808150314
Download: ML20207D297 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-289/88-14 50-320/88-11 -

Docket No. 50-289 50-320-License No. OPR-50 C

,DPR-73 Priority --

Category 1 Licensee: GPU Nuclear Corporation P.O. Box Middletown, PA 17057 Facility Name: Three Mile Island Nuclear Station, Units 1 and 2 Inspection At: Middletown, Pennsylvania and Harrisburg, Pennsylvnia Inspection Con cted: July 11-15,1988 l

Inspector: - E -

1 214 @ b

. C. Jang, Senior Rad ion Specialist date Approved by: '

W. J. Pa)ciak, s

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GLALChief Effluent Radiation 9/$ k 8

/ d/te Protection Section Inspection Summary: Inspection on July 11-15, 1988 (Combined Inspection Report Nos. 50-289/88-14; 50 320/88-11)

Areas Inspected: Routine, unannounced inspection of the operational radiological environmental monitoring program, including management controls, the licensee's program for quality control of analytical measurements meteorological monitoring and implementation of the radiological environmental monitoring program.

Results: Within the areas inspected, no items of noncompliance were identified.

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Details 1. Individual Contacted

• G. Baker, Director,-Environmental Controls T Bradley, Environmental Scientist

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W. Cooper, Environmental Scientist

• R. Danaby, Manager, Environmental Radioactivity Laboratory B.

Dearmond,

I&C Tech.-Senior, Unit 1 R. Gill,. Supervisor, Environmental Radioactivity Laboratory B. Good, Sr. Environmental Consultant

• W.z Ressler, Manager, Environmental Program

• E. Schrull, licensing, Unit 2 L. Toke, Environmental Scientist

• Denotes those individuals present at the exit meeting on July 15, 1988.

The inspector also interviewed other licensee personnel.

2. Licensee Actions on Previous Identified Findings (Closed) Follow-up Item (50-320/84-22-01) Control of investigation levels for environmental samples. The licensee revised Procedure 9420-SUR-4523.05, Determination of REMP Action Levels and Subsequent Actions, Rev. 5, July 21, 1987 to address investigation levels (action levels). Review of the revis-ion showed the "action-levels" to be technically adequate. This item is closed.

(Closed) Unresolved Item (50-320/84-22-02) Review of vendor laboratory

, procedures. The licensee reviewed the vendor laboratory procedures during technical review of bids received during the contractiig process.

The ifcensee determined that the procedures were technically adequate to determine radioactivities of the various radionuclides at environmental levels. Ongoing intra and inter laboratory comparisons of split and spiked samples and quality assurance oversight of vendor activities showed that the procedures were being followed and were producing acceptable' radio-analytical results. This item is closed.

(Closed) TI2500/22. Comparison of Collocated Environmental LTD results.

Comparisons of collocated TLD monitoring results were performed during this inspection (See Section 6.2 of this inspection report for detail).

This item item is closed.

3. Management Control The inspector reviewed the licensee's management controls for the radio-logical environmental monitoring programs (REMP), including assignment of responsibility, program audits, and corrective actions for identified inadequacies and problem areas in the program.

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. 3 3.1 Assignment of Responsibility The inspector reviewed the organization for administration of the radiological environmental monitoring programs and discussed with the licensee any changes made since the last inspection of this area. The inspector determined that the REMP remains essentially the same as it was at the time of the last inspection in this area.

3.2 Audits The inspector reviewed the following audit reports for the Radiological Environmental Monitoring Program (REMP) performed by the Site Audit Group, and audits of the contractor laboratory performed by the licensee:

• S-TMI-86-19, REMP, October 27-November 20 1986

• S-TMI-87-16, REMP, October 29-November 18, 1987

• 0-COM-87-01, Teledyne, February 26-27, 1987

• 9420-86-0144, Teledyne, April 3, 1986

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• 9410-87-2208, Teledyne, November 9, 1987 The inspector noted that the above referenced audits were very good, and audit findings and recommendations were excellent. The audits were performed by a qualified lead auditor, and appeared to be quite thorough and of sufficient technical depth to adequately assess capa-bilities of the REMP and the contractor.

4. GPUN Environmental Radioactivity Laboratory (ERL)

The ERL was established officially in October 1986 to assume the responsibility to analyze all environmental samples for TMI, Oyster Creek, and Saxton. The inspector evaluated the laboratory facility and operations against standard industrial practices. The inspector also reviewed analytical capability including QC sample results (see Section 5 of this inspection report), and staff during this inspection.

p 4.1 Facility and Staff The licensee's ERL has three sample process rooms and one radioisotope preparation room. All of these rooms were equipped with hood and sink. The ERL has one counting room with well controlled air conditioning for counting instruments. The ERL has six gamma spectrometry systems with Ge(Li) detectors, two gamma-beta coincident counting systems, three proportional counters, two liquid scintillation counters, two chemical balances, one pH/ ion analyzer, two drying ovens, and one muffle furnace. The ERL also has a large sample storage area.

The inspector determined that the licensee has sufficient laboratory equipment to perform environmental sample analyses.

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. 4 Currently, the staff at the ERL consists of one manager, one supervisor, and three analysts. The analysts hold Bachelor of P%ce (B.S.)

degrees and have several years of laboratory experience. The Manager ard Supervisor hold higher degrees, (Ph.D. and M.S.). The inspector determined that the staff have good laboratory experience (i.e. the Supervisor has 8 years radiochemistry laboratory experience) and academic training.

4.2 Sample Load The inspector discussed with the ERL staff laboratory sample load.

About 170 analyses were performed monthly in October 1986 for TMI environmental samples to analyze gamma and tritium. During that period time the ERL had 2.5 analysts.

Currently, the ERL receives environmental samples from TMI, Oyster Creek, and Saxton. The ERL received 836 samples (1292 analyses) in March,1988 and received 418 samples (498 analyses) in April,1988.

The inspector noted that the ERL received about 450 samples (560 analyses) every month from TMI and Oyster Creek. These samples were analyzed to comply the Technical Specification requirements for TMI and Oyster Creek.

5. Licensee Program for Quality Control of Analytical Measurements The inspector noted that the GPUN Environmental Radioactivity Laboratory (ERL) assumed the responsibility to analyze all environmental samples except I-131 and Sr-89/90 analyses. The analysis of I-131 and Sr-89/90 are performed by the contractor laboratory, Teledyne Isotopes.

5.1 Environmental Radioactivity Laboratory (ERL)

5.1.1 Procedures The licensee has administrative procedures, implementing procedures, operating procedures, and surveillance pro-cedures for tha REMP. All procedures were approved as required by the Technical Specifications.

5.1.2 ERL Quality Control Program Procedure 9420-ADM-4590.01, "Quality Assurance in the GPUN Environmental Radioactivity Laboratory-General Guidelines,"

Revisien 2, February 18, 1988 describes the ERL's quality assurance program. The inspector reviewed the ERL's Quality Assurance Report and noted that 230 quality control samples (i.e., duplicate samples, replicate samples, spike samples, etc) were processed by the ERL during the period of July 1987 through December 1987.

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The inspector also reviewed measurement system quality con-trol data including source check and background for gamma spectrometry, liquid scintillation counter, and gas proportional counter.

The inspector reviewed quality control data of EPA Cross-checks, duplicates, replicates, spikes, and interlaboratory comparison samples. These quality control results were generally good and occasional poor results were investigated within a week and resolved.

5.2 Teledyne Isotopes _

The inspector reviewed quality assurance reports submitted to the licensee by its contractor, Teledyne Isotopes. Teledyne Isotopes submits quality control data to the licensee every two months. The quality assurance report also included EPA Cross-check results. The inspector determined that the quality assurance reports were adequate.

6. Implementation of th:: Radiological Environmental Monitoring Program 6.1 Direct Observation The inspector examined selected environmental monitoring stations, including particulate and iodine air sampling equipment, direct radi-ation (TLD) stations, pressurized ion chamber gamma detectors (Reuter-Stokes Model RSS-111), and vegetable gardens. All of the examined stations were operating at the time of this inspection.

6.2 Review of Annual Reports The inspector reviewed the annual reports for 1985, 1986 and 1987.

These annual reports provided thorough summaries of the environmental sampling and analyses. Also, the inspector noted that these reports cover a great number and variety of environmental samples than is required by the Technical Specification. No problems were identified.

6.3 Procedures The inspector reviewed the following selected implementing procedures:

including sampling procedures of air, milk, water, and soil; sample preparation for counting; and laboratory instrument calibration. No problems were identified.

• 9220-IMP-4522.01. REMP Sample Collection Procedure, Milk Rev. 10, 6/18/87 l

9420-IMP-4522.04 REMP Procedure - Terrestrial Vegetation, i

Rev. 7 12/13/86 l

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• 9420-IMP-4522.05 REMP Sample. Collection Procedure -

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Air Iodine / Air Particula'es Rev. 13 5/3/88

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• - 9420-IMP-4522.08 REMP Sample Collection Procedure - Soil Rev. 9 6/20/88

• - 9420-IMP-4522.17 REMP Sample Collection Procedure - Air Tritium Rev. 0 5/10/88

9420-IMP-4592.04 Preparation and Analysis of Soil and Sediment Samples Rev. 1. 6/24/88

. 9420-IMP-4592.06 Preparation of Liquid Samples for Gamma Spectrometry. Rev. 0 7/3/86 7. Environmental'00simetry Program .

7.1 Environmental TLD Quality Assurance *

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The' licensee performed a study to. demonstrate compliance with Regula-tory Guide 4.13 (Performance, Testing, and Procedural Specifications i for Thermoluminescence Oosimetry (TLD): Environmental Application). .i The licensee published part of study results and results in the Health Physics Journal volume 46, Number 5, 1984. The inspector reviewed ,

other performance study results during this inspection and results were satisfactory.

The licensee participates the International Environmental Dosimeter Intercomparison Program. The inspector reviewed the results of the seventh (1984) and eighth (1986) intercomparisons and found that the results were reasonably in agreement.

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7.2 Environmental Dosimetry The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitor- E ing Network is operated by the NRC (Region I) to provide continuous measurement of the ambient radiation levels around nuclear power

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plants, (71 sites) throughout the United States. Each site is moni- *

tored by arranging approximately 30 to 50 thermoluminescent dosimeter (TLD) stations in two concentric rings extending to about five miles from the power plant. The monitoring results are published in NUREG-0837 quarterly.

One of the purposes of this program is to serve as a basis of compar-ison with similar programs conducted by individual utilities

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which operate nuclear power plants. In-general, several NRC TLDs are collocated with each licensee's TLD stations. During this inspection the monitoring results of the licensee's TL0s collcated with NRC's  ;

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were compared and the results are listed in Table 1. It should be emphasized that the collocated TLDs are not always situated next to each other, but may be as much as one tenth of a mile apart or more.

Although there are some differences between the NRC's and the licensee's results, they are generally in agreement.

8. Meteorological Monitoring The Unit 1 I&C Department has responsibilities to perform calibration and preventive maintenance of the meteorological instrumentation. The inspector reviewed the calibration procedure and the current calibration results for wind speed, wind direction, and air temperature at 33-ft and 150-ft levels.

Procedure 3302-SAI, Meteorological Instrumentation Calibration, Revision 5, April 8, 1988 describes all calibration steps including acceptance criteria. Calibration results performed on April 13, 1988 found them to be adequate.

9. Exit Interview The inspector met with the licensee representatives (identified in Para-graph 1) at the conclusion of the inspection on July 15, 1988. The inspec-tor summarized the purpose and scope of the inspection and the inspection findings.

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1 Table 1 Environmental Monitoring Results for Collocated TLDs

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Unit = mR/90 days

- IMI IMI IMI IMI TMI IMI IMI Yr/Qtr i NRC-5 H3-1 NRC-7 F1-1 NRC-9 01-2 NRC-30 Q15-1 NRC-35 Q2-1 NRC-37 M2-1 NRC-38 L2-l'

(1) (2)

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I i 1986 1 1 14.5t0.5 10.410.6 l 14.110.5 13.710.4 l 15.910.5 '13.410.5 i Missing 13.910.6 l 16.610.6 13.810.6 1 13.310.5 13.611.0 1 16.3t0.5 17.010.5 2 1 16.310.5 11.910.8 l 14.6t0.4 15.610.5 l 15.510.5 15.610.9 i TLD 16.310.7 l 16.910.5 14.610.6 l 14.510.4 12.810.4 l 17.510.5119.110.3

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3 l 17.110.6 10.010.3 1 15.410.6 13.110.6 1 15.910.6 13.610.7-l 18.810.7 16.210.8 l 18.910.7 14.510.6 l 15.610.6 11.710.7 1 18.710.6 16.110.7 4 l 10.710.8 12.210.4 l 9.210.8 15.310.3 l 10.710.8 15.110.5 1 12.410.8 16.110.6 l 13.110.8 15.510.5 l 9.110.8' 12.110.7 1 11.810.8 17.410.5

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1987 1 1 15.010.5 13.412.1 1 15.210.5 18.112.6 l 16.210.5 - 14.010.5 l 13.610.6 13.910.6 l 17.710.6 13.210.3 l 13.910.5 10.610.3 1 16.710.3 15.8 0.5

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2 1 12.410.5 11.710.5 l 11.510.5 14.310.3 1 12.510.5 14.310.6 1 17.410.6 17.310.6 1 15.310.6 -14.811.4 l 11.610.5 14.811.4 l 14.210.6 17.110.9 3 l 13.010.5 10.410.5 l 13.310.5 14.110.5 l 15.410.6 15.010.7 1 16.610.6 14.310.8 1 15.610.6 15.410.6 1 13.310.5 10.910.4 1 17.710.6 15.310.6 4 1 12.910.9 11.610.4 1 11.710.8 15.510.7 l 12.110.8 14.110.4 i TLD 15.510.3 1 TLD 14.710.5 I 9.810.8 13.5t0.5 l 13.510.5 17.710.5 l l l l Missing l Missing l l

(1) NRC: Panasonic TLD, Ca50 4

Tm, Reporting Unit = mRis.d., Quarterly Monitoring (2) IMI: Panasonic TLD, Ca504 :Tm, Reporting Unit = eRis.d., Quarterly Monitoring T

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