IR 05000333/1978017
| ML19274D920 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/26/1978 |
| From: | Shanbaky M, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19274D907 | List: |
| References | |
| 50-333-78-17, NUDOCS 7902270232 | |
| Download: ML19274D920 (14) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
78-17 Docket No.
50-333 License No.
DPR-59 Priority
--
Category C
Licensee:
Power Authority of the State of New York (PASNY)
10 Columbus Circle New York, New York 10019 Facility Name:
James A. FitzPatrick Nuclear Power Plant (JAF)
Inspection at:
Scriba, New York Inspection conducted:
September 11-15, 1978 Inspectors:
W,
/nIeM/
h/28//9 7(2 M. M. Shanbaky, Rad'(ation Specialist
/ date signed date signed date signed Approved by:
/0
f J./P. Storr, Chief, Environmental and Special
'date' signed Projects Section, FF&MS Branch Insoection Summary:
Inspection on September 11-15,1978 (Report No. 50-333/78-17)
Areas Inspected:
Routine, unannounced inspection of environmental monitoring programs for operations, including:
the management controls for these programs; the licensee's program for quality control of analytical measurements; implementation of the environmental monitoring programs - radiological; implementation of the environmental monitoring programs - biological / ecological; nonradioactive effluent release rates and limits; and, a followup on the licensee's action on previous environmental inspection findings. The inspection involved 50 inspector-hours onsite by one NRC regional based inspector.
Resul ts:
Of the six areas inspected, no items of noncompliance were found in three areas.
Eight items of noncompliance (Infraction - inadequate radio.ogical analyses of lake water samples - Details 5.d; Infraction - failure to follow the plant radio-logical protection procedures - Details 8; Deficiency - failure to set the alarm points and discharge controls on the neutralizer tank - Details 7.b; Deficiency -
failure to calibrate environmental gamma radiation monitor - Details 5.b; Deficiency -
Region I Form 12 (Rev. April 77)
790227oa.3 failure to record hourly discharge temperature - Details 7.a; Deficiency - exceeding the ETS discharge limit for solutes - Details 7.c; Deficiency - failure to report to the NRC excessive discharge solutes within the required 30 days - Details 7.c; and, Deficiency - failure to maintain chemical analyses records - Details 7.c) were identified in three area DETAILS 1.
Individuals Contacted
- J. D. Leonard, Resident Manager, JAF
- V. Childs, Assistant to Resident Manager, JAF
- R. A. Burns, Radiological and Environmental Services Supervisor, JAF
- R. Pasternak, Superintendent of Power, JAF
- E. Abbott, Operations Superintendent
- B. A. Gorman, Supervisor, Environmental Protection, JAF
- A. P. McKeen, Assistant to Superintendent - Radiological and Environmental, JAF H. N. Keith, Assistant to I&C Superintendent, JAF R. H. Pirong, Computer Specialist, JAF K. Szeluga, Radiological and Environmental Technician D. Zimmerman, Radiological and Environmental Technician P. R. Welsch, Texas Instrument, Oswego Field Site Manager, TI H. J. Flanagan, Technical Leader, TI P. Korta, Field Technician, TI denotes those present at the exit interview.
- 2.
Licensee Action on Previous Inspection Findings (0 pen) Unresolved (77-21-01):
Fish kill contingency plan.
The licensee stated that the required fish kill contingency plan has not yet received approval from the New York State Departmer,t of Environmental Conserva-tion (DEC), and the NRC Regulatory Staff.
The inspector stated that this item remains unresolved, pending the approval of a fish kill contingency plan by the NYS-DEC and by the NRC (77-21-01)(Details, Paragraph 6).
(Closed) Unresolved (77-21-06):
Completion of corrective action for Sr-90 and gamma analyses of milk samples.
The inspector determined through dis-cussions with the licensee and review of the milk sampling and analytical procedures, that the licensee's corrective action was completed and all the environmental milk samples were collected and analyzed, as required, during the period from August,1977 to August,1978 (Details, Paragraph 5.e).
(0 pen) Unresolved (77-21-07):
Environmental analytical laboratory and procedures.
The inspector noted that the licensee has initiated corrective action in this area; however, completion of the environmental laboratory is now pending approval of needed funds for laboratory equipment.
This item remains unresolved (Details, Paragraph 5.f).
(Closed) Noncompliance (77-21-02):
Failure to submit anomalous measurement reports. The inspector determined that the licensee's corrective action provided in the licensee's correspondence to NRR-Region I, dated November 15, 1977, was completed as specified.
The inspector noted that as of August, 1977, anomalous measurement reports were submitted to the NRC as required (Details, Paragraph 5.c).
(Closed) Nonconipliance (77-21-03):
Failure to follow procedures. The licensee records showed that corrective actions in this area were completed as dacribed in the licensee's letter to the NRC, dated October 24, 1977 (Details, Paragraph 5.c and 5.e).
(Closed) Noncompliance (77-21-04):
Failure to composite air particulates as required.
The inspector reviewed the environmental air particulates sampling and analytical records and noted that the onsite samples and the offsite samples were composited separately as required.
The licensee's corrective action in this area was implemented immediately after the pre-vious NRC environmental inspection, which was conducted on July 26-28, and August 2-5,1977 (Details, Paragraph 5.c).
(Closed) Noncompliance (77-21 J5):
Failure to perform adequate analyses of I-131 in air samples.
The inspector noted that the licensee's pro-cedures were changed to provide for timely counting of the air samples and adequate counting time. Acceptable minimum detectable limits (MDLs)
for I-131 were achieved after implementing the new procedures (Details, Paragraph 5.c).
3.
Management Controls a.
Assianment of Responsibility The inspector reviewed the organization and administration of the environmental monitoring programs with respect to changes made since the last inspection of this area.
The inspector determined that these areas remained essentially as described in NRC:IE Report No. 50-333/77-21.
One change was noted, in that the radiological analyses of all the required environmental media, with the exception of air and water, are now performed by the Radiation Management Corporation (RMC).
This area was previously contracted to Eberline.
The required environmental media sampling, including milk, is now performed by Texas Instruments, Inc. (TI), Oswego Laboratory.
b.
Program Review and Audits The inspector reviewed the program audits and noted that documented audits were performed by PASNY staff during 1978. The inspector noted that several laboratory and analytical problems were identi-fied in an audit of the previous radiological contractor (Eberline).
The Eberline audit was conducted on January 1-4, 1978.
The in-spector noted that the licensee's management was apprised of the audit results and corrective action was comoleted to preve
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currence of inadequacies identified during this audit.
The i1censee stated that after several correspondence with the previous con-tractor, it was decided that the analytical responsibility be changed to RMC. The inspector noted that since April,1978, RMC has been performing the environmental sample analyses. The licensee stated that a documented audit of the RMC laboratory will be per-formed prior to the end of 1978.
The biological contractor (TI) audit was performed on June 12, August 9 and August 16, 1978.
This audit included both the TI field laboratory in Oswego, New York and the TI analytical labora-tory in Dallas, Texas.
The results of this audit showed that, other than minor program inadequacies, TI has completed all the required sampling, analyses and data processing and evaluation.
The inspector determined through discussion with the licensee and review of program documentation that, noticeable improvements were made in the licensee's management controls as related to the en-vironmental monitoring program.
4.
Licensee Program for Quality Control of Analytical Measurements a.
Radiologica_1_
The inspector reviewed the licensee's program for quality control (QC) of analytical measurements as related to the radiological analyses of environmental media.
The inspector noted that as of April,1978, progress was made in this area.
The analytical con-tractor in this area has prepared detailed written procedures for the QC program which were approved and implemented as of April, 1978.
The licensee stated that environmental samples were also split with the State of New York, Department of Environmental Con-servation. The licensee stated that the contractor QC data was reviewed and evaluated on a routine basis. The inspector deter-mined through discussion with the licensee that plans are in pro-gress to expand the spiked samples to RMC for analyses.
The licensee stated that this portion of the QC program will be implemented after the completion of the onsite laboratory. The inspector noted that required funds were requested for the completion of the environmental laboratory. The inspector had no further questions in this area at this tim b.
Biological The inspector discussed with the licensee the QC measures taken to assure validity of biological sampling, sample identification, analytical measurements and data processing and evaluation.
The licensee representative (TI) stated that with regard to sample collection, all sampling equipment, including thermistors and flow meters are checked and/or calibrated on a routine basis.
Stand-ardization was also performed for turbidimeters, pH meters and D.0. meters.
The licensee representative stated that as part of the current QC program, all the field data sheets are reviewed to verify their accuracy prior to mailing them to the TI labora-tory in Dallas, Texas.
The inspector noted that adequate keys were used for fish identification, in addition, to a reference collection for different fish species collected from the area.
No items of noncompliance were identified in this area.
5.
Implementation of the Environmental Monitoring Program - Radiological a.
Routine and Nonroutine Reports The inspector reviewed the licensee's annual radiological environ-mental report for the period from January 1 to December 31, 1977.
The inspector verified that the report was submitted to the NRC on the required schedule and included the required analytical data.
The inspector also reviewed the licensee's nonroutine reports in this area (LERs) including Report Nos. 77-56, 77-57 and 78-68.
The inspector reviewed the circumstances surrounding these reported events including their cause, licensee's evaluation and the plant effluent and operating condition prior to and during these events.
The inspector noted that the routine and nonroutine reports in this area were submitted to the NRC as required, b.
Environmental Direct Radiation Environmental direct radiation is measured with thermoluminescent dosimeters (TLDs) and continuous gamma radiation monitors. The inspector examined the environmental TLDs and the continuous gamma radiation monitors.
All the examined continuous radiation monitors appeared in an operable condition at the time of inspection.
The inspector also noted that the installation of the environmental TLDs appeared in nonconformance with the NRC Regulatory Guide 4.13 and the ANSI Standard (ANSI N-545-1975) recommendations. The inspector noted that some of the TLDs were positioned in a manner which would result in a partial shielding from the station mounting post (S 12 inches in diameter - wood). The inspector discussed with the licensee the
potential shielding problems and the distortion of the gama radiation field at the monitoring locations.
The licensee stated that the direct plant shine contribution to the gamma radiation field at these locations would be minimal and the TLDs were positioned in this manner for ease of accessibility during the winter season.
In a subsequent telephone discussion with the licensee on October 2,1978, the licensee stated that the environmental TLDs would be repositioned in such a manner to minimize shielding problems. The inspector stated that until the new locations of TLDs are verified during a subsequent inspection, this item is considered unresolved (78-17-01).
The inspector reviewed the licensee's maintenance and calibration records for the environmental continuous gamma radiation monitors. The inspector noted that the required maintenance and calibration were performed for all of the continuous gamma monitors with the exception of Monitor J.
This monitor was not calibrated on a semi-annual basis during the period from July 12,1977 to March 15, 1978.
The inspector stated that failure to calibrate the continuous gama radiation monitor as required by Procedure No. S-RTP-29 was in noncompliance with Section 5.5.1 of the ETS (78-17-02).
The inspector reviewed the direc^ gamma radiation monitoring data during the period from September,1977 to June,1978.
The quarterly dose equivalent average calculated from the offsite TLD monitoring locations during 1977 was 15.5 mrem.
The inspector discussed with the licensee the apparent discrep-ancies between the TLDs and continuous radiation monitor readings. The licensee stated that the continuous radiation monitors are not as sensitive as the TLDs and a proposal to delete them from the ETS requirements is being discussed with NRR.
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The inspector discussed with the licensee the apparent difference between the average dose equivalent measured during the last quarter of 1977 and the rest of the year.
The licensee stated that the relatively higher levels detected during the last quarter were apparently due to seasonal variation in natural background radiation and the Chinese nuclear weapons testin.
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The inspector reviewed the plant operation logs and the gaseous radiological effluents from the site and noted that the increase in the direct radiation levels measured during the last quarter of 1977 appeared to be unrelated to the plant operation. The inspector had no further questions in this area.
c.
Air Iodine and Air Particulates Sampling and Analyses The inspector examined a sample of the onsite and offsite environmental air sampling stations. The inspector noted that the monitoring stations were in an operable condition and located at the required locations at the time of the inspection.
The inspector noted that cracks had developed in the rubber tubing of the sampling systems which could lead to'a leak in the system. The licensee stated that system maintenance including tubing replacement will be performed this fall in accord with the station's maintenance schedule.
The inspector reviewed the air particulate sampling and analytical data for the period from July, 1977 to July, 1978. The licensee's sampling and analytical data review procedures were changed to insure timely review and evaluation of data and to eliminate redundancy in data logging. The licensee stated that this will ensure timely reporting to the NRC of any measurements which exceed ten times that of the control station. The inspector noted that during the pericd from September,1977 to August,1978, all nonroutine environmental radiological monitoring reports were submitted to the NRC as required.
The inspector verified, through records and procedures review, that the air particulate compositing procedure (S-CRP-9) was changed to reflect the ETS requirements with regard to the separate compositing of the onsite and offsite air particulate filters. The licensee sampling and analytical records showed the new particulate compositing procedure was implemented.
The analyses of air particulate and radiciodine samples are still performed at the plant.
The licensee stated that, since the last quarter of 1977, the sample preparation was performed at the Environmental Laboratory and the samples were counted for longer counting periods within 1 to 2 days after samp;e collection.
The inspector noted a general improvement i, the
MDL for radiciodine; however, since the samples are still being counted at the plant, the potential for inadequate analyses, as a result of sample contamination, or high backgrcund, still exist. The licensee stated that in the near future these samples will be counted in the Environmental Laboratory at the Energy Center (Details, Paragraph 5.f).
d.
Lake Water The inspector reviewed the results of the lake water sampling (NMP-1 intake; JAF intake; and Oswego City water intake) and analyses since the first quarter of 1977.
The inspector noted that the licensee has reported to the NRC (Annual Environmental Operating Report 1977) relatively high concentrations (100 -
850 pCi/1) of Co-60, Co-58, Cs-134, Cs-137 and Zn-65 at these sampling locations, including the control station at Oswego City water intake. The inspector reviewed the plant operations and effluents during 1976-1977 and noted that the detected radionuclide concentrations were not attributable to the plant operation.
The inspector also reviewed the environmental changes in the above radionuclides concentration as a result of natural background variations or man-made sources. The inspector's review showed that the reported concentration could not be attributed to changes in natural background concentration or other man-made sources including nuclear weapons testing. The inspector reviewed the licensee's lake water analytical procedures and noted that the lake water samples were counted in the plant (JAF) with a relatively high background radiation. The licensee acknowledged that the relatively high background radiation has resulted in inadequate gamma spectroscopic analyses of lake water samples during the period from January to July,1977.
The inspector stated that the analyses of lake water samples are considered inadequate to meet the requirements of Section 4.3, Table 4.3-1 of the ETS and that this is an item of noncompliance (78-17-03),
e.
Milk The inspector reviewed the 1977-1978 milk sampling and analytical data in the 1977 annual report and in the licensee's data reports. The inspector determined through selective data verification that the required sensitivity of analysis for I-131 in milk had been satisfied and that the samples were
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analyzed within the required eight days.
The inspector also determined through the review of the licensee's sample collection records that all of the required milk samples had been collected, adequate sample volumes were used, and the milk sampling and the new analytical procedures were followed.
f.
Environmental Analytical Laboratory The inspector examined the Environmental Analytical Laboratory at the Energy Information Center. The inspector noted minor changes with regard to the completion of the laboratory.
En-vironmental samples including air particulate, radionuclide and lake water samples were still being counted at the plant.
The licensee stated that the required funds were proposed in this year's budget and if the needed funds are approved, the laboratory will be completed and operational within the next few months. The licensee added, if the required funds are not approved, environmental samples will no longer be counted at the plant and all required samples will be sent to the analytical contractor. The inspector stated that this item will remain unresolved pending the completion of the corrective action (77-21-07).
g.
Meteorology The inspector examined the meteorological instrumentation during the inspection and noted that the required instrumentation appeared to be functioning properly at the time of inspection.
The inspector also determined from the examination of the records that the instruments had been calibrated on a routine basis. The inspector examined the Calibration Procedure S-ISP-IC-61.3 and discussed with the licensee the system mainten-ance. The inspector noted that the meteorological data readout systems in the control room were operational at the time of the inspection.
No items of noncompliance were found in this are.
6.
Implementation of the Environmental Monitoring Program - Biological /
Ecological The inspector reviewed by discussions with the licensee and contractor representatives (Texas Instruments, Inc.) selective program pro-cedures and results. The inspector discussed with the licensee the 1977 annual aquatic ecology report and LER 77-40.
The reports were submitted in accordance with the ETS reporting requirements and in-cluded the required data. Areas directly observed by the inspector included fish impingement and viability studies. The inspector noted that detailed written procedures were used by TI biologists during the performance of these studies.
The inspector visited the TI field laboratory in Oswego, New York and examined the contractor's reference collection of fish and discussed with the contractor re-presentatives the environmental data collection and processing.
The contractor representative stated that all the raw sampling and analytical data were kept at the TI Laboratory in Dallas, Texas.
The inspector discussed with the licensee the data availability problem and stated that it is expected that all the required tests, surveillance and program results be available at the time of the inspection.
The licensee stated that the raw sampling and analytical records availability at the site and at the contractor field laboratory in Oswego will be assessed. The inspector stated that until all the required biological sampling and analytical data are available at the time of the inspection, this item is considered unresolved (78-17-04).
The inspector reviewed the status of the JAF Fish Impingement Con-tingency Plan, which is required by the NRC Facility License No.
DPR-59. The licensee stated that the required plan was submitted to the NYS-Department of Environmental Conservation (DEC) in March, 1977. The licensee added that since that time no further written communication had taken place between PASNY and DEC. The licensee stated that the PASNY biologists are still following up on this is-sue with the NYS-DEC. The licensee stated, in the interim ana until the plan is approved by NYS-DEC and the NRC, the proposed plan will continue to be used as the JAF Fish Impingement Contingency Plan. The inspector stated that this item is still considered unresolved pending the acceptance of the required Fish Impiagement Contingency Plan by the DEC and the NRC (77-21-01).
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7.
Nonradioactive Effluent Release Rates and Limi_ts, a.
Thermal The inspector reviewed a sample of the plant thermal discharge records for the period from August, 1977 to August, 1978.
The inspector noted that the plant thermal releases were below the ETS limits.
The inspector examined the discharge temperature monitoring system and noted that the temperature sensors (RTDs) were located as required, were scanned by the plant computer, and the intake, discharge and AT were recorded on an hourly basis.
The inspector reviewed the system maintenance records and noted that the required temperature sensor accuracy was not verified by the licensee. The licensee stated that the RTDs used for AT monitoring are very stable monitoring devices; however, the need for periodic system calibration and verifica-tion of sensor accuracy will be evaluated. The inspector stated that until the required RDT accuracy is verified, this item is considered unresolved (78-17-05).
The inspector noted, through records review, that due to the reported (LER 77-68) plant computer outage on December 4, 1977, the temperature sensors were not scanned every sixty seconds as required. During the plant computer outage periods the discharge-intake temperatures are read manually and recorded on an hourly basis. This method is used by the licensee as the backup temperature monitoring procedure. The inspector noted that, during the plant computer outage periods, this backup monitoring method was used except on December 5, 1977.
The licensee stated that it appears that the Plant Operator did not take the temperature on an hourly basis as required on December 5, 1977.
The inspector stated that failure to record the plant inlet / outlet temperature on an hourly basis was an item of noncompliance (78-17-06).
b.
Neutralization Tank pH The inspector examined the neutralization tank pH monitoring system. The system is provided with alarm points which control the tank discharge valve. The licensee stated that once the
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pH monitoring cells are buffered and the alarm set points are established (6.0 - 8.5) by the Plant Chemistry and Health Physics Technician, a permit is given to the Control Room to discharge the tank.
When the pH value in the tank discharge reaches the alarm set point the tank discharge valve will automatically close.
The inspector noted that immediately after the neutralization tank discharge on September 13, 1978, that the alarm set poiat appeared to be set above the required 8.5 pH value.
To verify the actual alarm set point, the licensee cleaned the pH moni-toring cell and added a buffer standard of 9.18 pH.
This buffer did not cause a pH monitoring alarm in the control room. The licensee had to turn down the pH alarm set point about 1 pH unit prior to initiation of alarm condition.
Based cn the inspector's observations and the licensee's test, the pH upper alarm set point had been set above the required 8.5 limit. The inspector stated that failure to set the neutraliza-tion tank pH monitor alarm as required by Section 2.2.4, ETS was an item of noncompliance (78-17-07).
c.
Other Chemicals The inspector reviewed a sample of the plant chemical releases since August,1977, including the analytical procedures, ana-lytical records and results.
The inspector noted that the solutes in the plant discharge exceeded the ETS limits on several occasions.
These instances of exceeding the ETS solute limits were reported to the NRC in LER Nos. 77-62, 78-11, 78-24, 78-25, 78-38 and 78-53.
The inspector stated that since these reported events have resulted in chemical releases to the environment, they are considered in noncompliance with Section 2.2.3 of the ETS (78-17-08).
The inspector reviewed the chemical analytical data for the solutes and noted that the iron and sulfate limits were ex-ceeded on March 10, 1978.
This was not reported to the NRC until May 6, 1978 (LER 78-25). The inspector stated that failure to report the above event within the required 30 days (Section 5.6.2, ETS) was an item of noncompliance (78-17-09).
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The inspector reviewed the solutes analytical records and noted that, with one exception, records for standardization graphs and analytical results were maintained as required.
The manganese analytical records for the atomic absorption analyses performed on effluent samples collected on May 16, 1978, were not maintained as required.
Several unsuccessful trials were made by the licensee to locate these analytical records. The inspector stated that failure to maintain the analytical records as requireo (Section 5.7.1, ETS) was an itemofnoncompliance(78-17-10).
8.
Restricted Area Rules During the inspection, on September 14, 1978, the inspector observed that an individual leaving the restricted area at the control point at the Health Physics office did not monitor himself or the tools he was bringing out from the restricted area.
The inspector determined through discussion with the licensee that this individual has received the required Radiological Protection briefing and training.
This individual was returned to the restricted area by the HP personnel. The individual and the tool he was carrying were then monitored for contamination. The insoector stated that failure to follow the required procedures (Section 5.c, JAF, Radiation Protection Operating Procedures) was an item of noncompliance with Section 6.11 of the Technical Specifications (78-17-11).
9.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncompliance. Unresolved items disclosed during this inspection are discussed in Details 5.b 5.f, 6 and 7.a.
10.
Exit Interview On September 15, 1978, at the conclusion of the inspection, the in-spector met with the licensee representatives (denoted in paragraph 1). The scope and findings of this inspection, including each unresolved item and item of noncompliance were discussed.
The licensee acknowledged the findings.