IR 05000293/1979002
| ML19269D244 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/02/1979 |
| From: | Crocker H, Serabian J, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19269D247 | List: |
| References | |
| 50-293-79-02, 50-293-79-2, NUDOCS 7903200324 | |
| Download: ML19269D244 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-293/79-02 Docket No. 50-293 License No. DPR-35 Priority
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Category C
Licensee:
Boston Edison Company 800 Boyleston Street Boston, Massachusetts Facility Name:
Pilgrim Nuclear Power Station, Unit 1 Inspection at:
Plymouth, Massachusetts Inspection conducted _: January 10-12, 1979
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Inspectors:
, / #-fA.o.
F [ /7f
.,#. Whit, Radiat n Specialist
'date signed
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2-l/ l1 9
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. A. Serabian, Radiation Specialist (Intern)
/ dage si'gned date signed s
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6::?/62 /-79.
Approved by H. W. Crocker, Acting Chief, Radiation
' da(te signed Support Section, FF & MS Branch Inspection Summary:
Inspection on January 10-12,1979 (Recort No. 50-293/79-02)
Areas Inspected:
Routine, unannounced inspection by two NRC regional based inspectors of the Radioactive Waste Systems during operation. Areas inspected included radio-active effluent releases - liquid and gaseous, records and reports of radicactive effluents, effluent control instrumentation, procedure for controlling the release of effluents, tests of reactor coolant water quality, and solid radioactive waste hdndling. Additionally, tours of plant areas were made to observe implementation of waste management control systems. The inspection involved 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> on site by two NRC inspectors.
Results:
Of the seven areas inspected, no items of noncompliance were found.
7003200301 Region I Form 12 (Rev. April 77)
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DETAILS 1.
Persons Contacted
- J. Nicholson, (Acting) Station Manager
- C. J. Mathis, Senior Plant Engineer
- M. Hensch, Chief Radiological Engineer
- A. Trudeau, Senior Health Physics Engineer
- R. Smith, Senior Chemistry Engineer
- C. Vantrese, Chief Technical Engineer V. Stagliola, Senior Waste Management Enginear The inspector also interviewed several other licensee employees including members of the Chemistry Department.
2.
Licensee Action on P'revious Inspection Findings and Circulars References:
(a)
IE Circular 76-03, " Radiation Exposure in Reactor Cavities,"
dated September 13, 1976 (b) Boston Edison Con'pany (BECo) Response to IE Circular 76-03, dated November 23, 1976 (c)
IE Inspection Report 293/78-07, Notice of Violation, dated April 18, 1978
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(d) BECo Response to the Notice of Violation (dated April 18, 1978), dated May 12, 1978 (e) BECo Supplemental Response to the Notice of Violation (dated April 18, 1978), dated July 6, 1978 (f)
IE Inspection Report 293/78-15, Notice of Violation, dated June 21, 1978 (g) BECo Response to the Notice of Vmlation (dated June 21, 1978), dated July 14, 1978 (h) BECo, Radioactive Effluent and Waste Disposal Report, dated September 1, 1978
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(Closed) IE Circular (293/76-CI-03):
Radiation Exposure in Reactor Cavities. The inspector reviewed the licensee's response, Reference (b), against the requirements stated in Reference (a).
During tours of the facility taken on January 10 and 12,1979, the inspectors verified that High Radiation Areas were controlled as stated in Reference (b).
(Closed) Infraction (293/ E 07-05):
Failure to snip Radioactiva Waste in accordance with 10 CFR 71.3.
The inspector reviewed the licensee responses, Reference (d) and (e), to the flotice of Violation, Reference (c), and verified that the licensee is shipping Low Specific Activity (LSA) material in excess of Type A quantities only in certified containers in accordance with 10 CFR 71.3.
(Closed) Inspector Followup Item (293/78-07-06):
Monitoring of a man wounded in a radiologically controlled area on March 10, 1973.
On May 10, 1978, the licensco performed followup monitoring on the wound received by an individcal.
The results of the monitoring were as follows:
Cs-137, Body Burden Estimate, 2.2%
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Mn-54, Body Burden Estimate,1.4%
The inspector noted that the results of this measurement indicated negligible activity deposited in the wound area.
(Closed) Infraction (293/78-15-01):
Failure to adhere to Radiological Procedure 6.1 022.
The licensee's response, Reference (g), to the flotice of Violation, Reference (f), was reviewed, and the inspector verified that the licensee is now utilizing job specific RWPs, and is conducting worker briefings prior to allowing work to be per-formed under the control of RWPs.
The inspector also verified that perronnel were re-instructed by Health Physics Management in procedural requirement for work in radiological areas.
(Closed) Inspector Followup Item (293/78-15-02):
Followup on BECo Audit 78-01.
The inspector reviewed the corrective action implemented in response to the nine items identified in the audit and noted that the licensee action appeared to adequately address these finding.
(Closed) Report Review and Verification (293/78-PR-04):
Radioactive Effluent and Waste Disposal Report - January 1 through June 30, 1978, dated September 1,1978.
The inspector reviewed Reference (h) and submitted comments to the licensee regarding the following deficiencies in the report:
Failure to provide a summary description of the method used
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for estimating overall errors in measurements in accordance with Regulatory Guide 1.21, Section C.ll.a; Failure to properly complete Table 3, Section A.2 of the
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report regarding the isotopic content of disposal of radioactive waste.
The inspector also reviewed the raw data used to generate Reference (h) to determine the accuracy of the report.
3.
Radioactive Effluent Records and Reports Liquid:
The inspector reviewed all of the liquid effluent release records from January through December,197P, for compliance with Technical Specification (TS) 4.8A, " Liquid Effluents," Sections 1-6.
The following specifications were examined.
TS Requirement Section No.
Records of liquid effluent release concen-trations, volume, average dilution flow, and length of time of discharge 4.8.A.1 Sanioling and analysis for gross radio-activity (8, y) and concentration of each ganma energy peak prior to batch releases 4.8.A.2 Weekly composite analysis for Ba-La-140 and I-131 4.8.A.3
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TS Requirement Section No.
Monthly composite analysis for principal gamma emitting nuclides, tritium, Sr-89, and gross radioactivity (4, 8, and y)
4.8.A.4 Monthly composite analysis for dissolved fission and activatad gases 4.8.A.5 Quarterly composite analysis for Sr-90 4.8.A.6 The inspector noted that all of the required recoros were main-tained anj that the required radioactivity analyses were conducted at the sr acified time intervals.
Gaseous:
The inspector reviewed 70% of the gaseous effluent release records for the period between January 1 and December 31, 1978 against the requirements of TS 3.8.B, " Airborne Effluents," and the asso-ciated surveillance requirements of TS 4.8.B.
The following specifications were examined:
TS Requirement Section No.
Instantaneous release rate not to exceed the specifications of TS 3.8.B.
3.8.B.1 Gross and particulate gaseous vastes released will be monitored and recorded.
4.8.B.1 and 2 The release rate of radiciodines and particulates with half-lives greater than eight days will be limited to the specifi-cation of TS 3.8.B.
3.6.B.2 The quarterly limit on the average release rate on radioiodine and particulates with half-lives greater than eight days shall not be exceeded.
3.8.B.2.b The amount of iodine-131 released shall not exceed 2 Ci/ reactor / quarter; and 4 Ci/ reactor /
12 consecutive months.
3.8.B.2.b and e
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TS Requirement Section No.
Isotopic analysis shall be made of gaseous radioactivity being released.
4.8.B.3 Tritium samples shal. be analyzed at least quarterly.
4.8.B.4 Samples of off-gas effluents shall be taken at least every 95 hours0.0011 days <br />0.0264 hours <br />1.570767e-4 weeks <br />3.61475e-5 months <br /> and a ratio of long-lived or short-lived radioactivity shall be determined.
4.8.B.5 All waste gas monitors shall be calibrated at least quarterly.
4.8.B.10 The inspector noted that the licensee had satisfactorily ful-filled these requirements, and has maintained records sufficient to demonstrate compliance with the Technical Specifications.
Semi-Annual Effluent Report The licensee's report, "Radioacti Effluent and Waste Disposal Report" - January 1 through June 30, 1978, dated September 1, 1978 (submitted in accordance with TS 6.9.C, " Unique Reporting Requirements") was reviewed to verify certain of the information summarized against the licensee's records.
The inspector noted minor discrepancies, (i.e., failure to summarize the method used to estimate overall errors in measurements; and failure to properly complete Table 3, Section A.2). The licensee rep-resentative indicated that these discrepancies would be amended in future reports.
No items of noncompliance were identified in this area.
4.
Radioactive Effluent Release The inspector reviewed records of liquid effluent discharge permits and monthly summary sheets for 1978.
Ten discharge permits were examined to determine compliance with the instantaneous gross radioactivity release concentration limits specified in 10 CFR Part 20, Appendix B, (TS 3.8. A " Liquid Effluents," Section 1).
The inspector also examined each of the monthly liquid effluent summary sheets in order to determine compliance with the TS quarterly limit for liquid effluent rates (TS 3.8.A, Section 2).
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The licensee's gaseous releases for 1978 were reviewed against the limits identified in TS 3.8.B.1 and 2.
The inspector noted that the licensee's methodology for monitoring gaseous releases is based on the most restrictive limits presented in the Technical Specifications in order to assure that none of the limits are inadvertently exceeded.
No items of noncompliance were identified in this area.
5.
Reactor Coolant Water Quality a.
Radioactivity Control The inspector reviewed records of reactor coolant system radioactivity iodine levels and analyses for compliance with the requirements of TS 3.6.B and TS 4.6.B, " Coolant Chemistry,"
Sections 3 and 1 respectively, for the period of January through December 1978.
Also reviewed were all of the Iodine Isotope Analysis records from January through June and 20% of the records from July through December.
It was verified that the specified reactor coolant system radioactivity concentration did not exceed 20 microcuries of total iodine (TS 3.6.B.1).
A review was conducted of all the records necessary to demonstrate compliance with TS 4.6.B.1 requirements for reactor coolant radioactivity sample analysis and monthly iodine isotope analysis.
The inspector noted that sample analysis and monthly isotope analysis had been conducted as required and at the specified time intervals.
No items of noncompliance were identified in this area.
b.
Chemical Control The inspector reviewed records of reactor coolant chemistry for compliance with the requirements of TS 4.6.B " Coolant Chemistry," Sections 2 through 5.
The following documents relative to these requirements were examined:
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Reactor Water - 4 Hours Testing For Startups and Steaming Rates < 100,000 lbs/hr (February 6,1978 - October 30, 1978)
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Daily Analyses Results, Reactor Water (January 1,1978 -
January ll, 1979)
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Reactor Operations Log Book (March 8-9,1978)
The inspector reviewed all conditions involving steaming rates and startups for the period of examination, (January 1,1978 through January ll,1979), relative to the limits on reactor coolant conductivity and chloride ion content identified in TS 3.6.B, " Coolant Chemistry," and the associated surveillance requirements of TS 4.6.B, Sections 2 and 3, which specify frequencies of sampling and analysis for chlorides and conductivity for certain steaming rates.
In the course of this review, the inspector noted that TS 4.6.B.3.a states,
"With steaming rates of 100,000 pounds per hour or greater, a reactor coolant sample shall be taken at least every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> and analyzed for conductivity and chloride ion content."
- The bases of this requirement states, in part,
"The conductivity of the reactor coolant is continuously monitored.
The samples of the coolant which are tak-every 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> will serve as a reference for calibration of these monitors and is considered adequate to assure accurate readings of these monitors.
If conductivity is within its normal range, chlorides and other impurities will also be within their normal ranges."
The inspector noted that, with few differences, this same concept is described in the licensee's Final Safety Analysis Report (FSAR), Section 4.2.8.3, " Limiting Conditions for Operation," and Section 4.2.8.4, " Surveillance Requirements."
The inspector noted that while the licensee was able to demon-strate compliance with TS 4.6.B.3.a in regard to analysis for chloride content, the licensee could not demonstrate compliance in regard to the specified condcctivity analyses for the period between January 1,1978 and January 11, 197.
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The licensee representative indicated that in lieu of per-forming the surveillance on conductivity as specified in TS 4.6.B.3.a, another continuously monitoring (secondary) conductivity cell had been installed in series with the primary conductivity cell identified in the Technical Specifications; and that this secondary cell was recorded and compared with the primary cell daily.
Since the primary cell is calibrated teekly by use of a Wheatstone Bridge, the licensee used the reimary cell as the
" reference cell" for the purpose of this camparison and presumed that this form of surveillance fulfilled the requirement of TS 4.6.B.3.a.
The licensee indicated that it was necessary to perform this particular surveillance different from the method described in the Technical Specification since taking a sample of the reactor coolant from the sampling cock necessitated contact of the sample with air, which would cause a change in the characteristic conduc.tivity of the sample.
It was further indicated by the licensee that since this phenomenom was recognized, a request to change the Technical Specification has been submitted to NRC, Division of Operating Reactors, on March 22, 1978, which proposed that the Technical Specifict. tion Basis be amended to delete the concept that the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> sample is necessary as a reference for calibration of the continuous monitors.
The following differences between conductivity measurements made by the continuously monitoring conductivity cells (primary and secondary) and a sample collected from the reactor coolant sample sink were noted by the inspector on January 12, 1979:
Conductivity Measurements - umho/cm Primary Cell Secondary Cell Coolant Sample 0.32 0.35 0.84 According to the licensee, the difference between the Coolant Sample and the continuously monitoring conductivity cells is due to the interaction of the sample with air during sample collection from the sample cock.
During a demonstration by a licensee technician of the technique used to collect the sample, the inspector noted that the tech-nician did not aMy the methods described in ASTM D3370-76,
" Sampling Water," which identifies techniques to be employeed when collecting samples for chemical and physical analyses from cocks or valves when contact with the air would cause change in characteristics of the constituent to be determine _ - - _ -. - _
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The inspector noted that this item would remain unresolved pending)further evaluation at the NRC Regional Office (Phila-del
'a.(79-02-01).
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6.
Solid Radioactive Waste The inspector reviewed 70% of the licensee's shipments of solid a
radioactive waste material for 19/s, against certain of tne require-F4 L ments specified in the following:
i '2 10 CFR 71, " Packaging of Radioactive Material for Transport and
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Transportation of Radioactive Material Under Certain Circumstances."
49 CFR 170-189, " Hazardous Materials Regulations."
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Health Physics Procedure 6.9-160, " Shipment of Radioactive Material."
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No items of noncompliance were identified in this area.
7.
Effluent Control Instrumentation
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The inspector reviewed the following effluent control instrumentations against the listed requirements:
J Instrumentation I
Main Stack. Channel A and B
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Reactor Building Vent, Channel A and B Peactor Building Closed Cooling Water, Channel A and B Radioactive Waste Effluent
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Off-Gas Radiation Monitor (Steam Jet Air Eject 6r), Channel A and B j;/
Refueling Area Exhaust Monitor, Channel A and B Requirements TS 4.2.0, " Radiation Monitoring Systems - Isolation and Initiation
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Functions."
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Requirements TS 4.8. A.7, " Liquid Effluent Monitoring Systems Calibration Requirement."
TS 4.8.B.10, " Gaseous Effluent Monitoring System Calibration Requirement."
He items of noncompliance were identified in this area.
8.
Effluent Control Procedures The inspector reviewed the following procedures against TS 6.8
" Procedures:"
Procedure No.
Title 7.9.1 Gaseous Waste Discharge Procedure 7.9.2 Liquid Waste Discharge Procedure 7.4.10 Source Calibration of Main eteam Monitor 7.4.12 Source Calibration of Off-Gas Monitor 7.4.14 Source Calibration of Main Steam Monitor 7.4.15 Source Calibration of G.M. Type Process Monitor No items of noncompliance were iac7tified in this area.
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they ai, acceptable,.itens 6f nonconpliance, or deviations.
An unresolved item di; closed during the inspection is discussed in Paragraph 5.b.
10.
Exit Interview The inspector met with the licensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on January 12, 1979.
The inspector summarized the scope and findings of the inspeccion as noted in this report.
The insoector indicated that the matter regarding the performance of conductivity analyses in accordance with TS 4.6.B.3.a would be further evaluated at the NRC Regional Office (Philadelphia).