ML18041A130
| ML18041A130 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Humboldt Bay |
| Issue date: | 08/10/1964 |
| From: | Rich Smith US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Peterson R PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML17342B389 | List: |
| References | |
| FOIA-85-665 NUDOCS 8602210022 | |
| Download: ML18041A130 (18) | |
Text
5.S.
NUCLEAR REGULATORY COMMISSION REGION I Report Nos.
50-220/86-14 50-410/86-45 Oocket Nos.
50-220 50-410 License Nos.
DPR-63 Priority CPPR-112 Category B
C Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse New York 13202 Facility Name:
Nine Mile Point Nuclear Station Units 1 and 2
Inspection At:
Scriba New York Inspection Conducted:
Jul 21-25 1986 Inspectors:
R. Struckmeyer, Radiat' Specialist ate ra aric, Radi tion Specialist date Approved by:
W. Pasciak, Chief, Efflue s Radiation Protection Section, EPR B
da e
Ins ection Summar:
Ins ection on Jul 21-25 1986 Combined Ins ection Re ort Nos. 50-220/86-14 50-410/86-45 Areas Ins ected:
- Routine, announced inspection of the radiological environ-mental monitoring program including:
management controls; the licensee's program for quality control of analytical measurements; implementation of the radiological environmental monitoring program; and a follow-up on the licensee's actions on previous inspection findings.
Results:
Within the areas inspected, no violations were found.
1.
Individuals Cont@ted
- 1. 1 Nia ara Mohawk Power Cor oration "H. Flanagan, Environmental Protection Coordinator
- T. Galletta, Assistant Environmental Protection Coordinator W. Joseph, I&C Assistant Supervisor "E. Leach, Superintendent, Chemistry and Radiation Management J.
Lupa, Nuclear Generation Specialist, ICC
- T. Perkins, General Superintendent N. Spagnoletti, Nuclear Division M. West, Environmental Technician A
1.2 New York Power Authorit
- J. Brons, Senior Vice President, Nuclear Generation "R. Converse, Resident Manager "B. Gorman, Chemistry General Supervisor, RES L. Johnston, guality Assurance Supervisor E. Mulcahey, Radiological and Environmental Services Superintendent
- R. Patch, (}uality Assurance Superintendent E. Salvetti, Senior Technician, RES D. Simpson, Training Superinterdent "A. Zaremba, Assistant Emergency Planning Coordinator "Denotes those present at exit interview on July 25, 1986.
2.
Status of Previousl Identified Items (Closed) Inspector Follow-up Item (220/83-21-01):
Protection of air sampler particulate filters from precipitation.
Shields to protect against precipitation were in place on the air samplers observed during this inspection.
In addition, a review of the licensee's records revealed no instances in which samples were lost due to precipitation damage of filters.
The licensee's method for collection of particulate samples appears to be adequate.
(Closed) Inspector Follow-up Item (220/83-21-02):
Procedure to prohibit CST releases during reverse circulating water flow.
The inspector reviewed two procedures that were revised to include prohibitions against liquid waste discharges while in reverse flow mode:
NI-CSP-4V, "Liquid Waste Sampling, Analysis, and Recordkeeping,"
Revision 0, May 1986 (replaced NI-PSP-4, with same title), and Operating Procedure NI-OP-28, "Liquid Waste System,"
Revision 16, June 1986.
These procedures appeared adequate to prevent recurrence of the problem, which had resulted in the issuance of an.LER.
No other LERs were issued.
(Closed)
Inspector Follow-up Item (220/83-21-03):
Assessment of Cs-137 in sediment.
The licensee provided a comprehensive assessment in its 1983 annual Radiological Environmental Operating
- Report, including a descrip-tion of the sampling and analyses performed for Cs-137, Cs-134, and Co-60
in sediment, as ~11 as an evaluation of the dose impact due to these nuclides done in 'accordance with Regulatory Guide
- 1. 109 methodology.
The inspector performed an independent calculation of the dose
- impact, based on concentrations of radionuclides reported by the licensee.
The results of both the licensee's and the inspector's calculations indicated that doses due to radionuclides are a small fraction of natural background radiation, and may be considered negligible.
(Closed)
Inspector Follow-up Item (220/81-02-03):
Achievement of fish analysis LLDs.
Amendment 66 to the Nine Mile Point Unit 1 Technical Specifications established new LLDs for fish in accordance with the Radiological Assessment Branch Technical Position, Revision 1,
November 1979.
3.
Mana ement Controls The inspector reviewed the licensee's management controls for the radiological environmental monitoring program, including assignment of responsibility, program audits, and corrective actions for identified inadequacies in the program.
a.
Assi nment of Res ons~ibilit The inspector reviewed the organization and administration of the environmental monitoring program.
The program is run by the Environ-mental Protection Coordinator, who reports to the Superintendent of Chemistry and Radiation Management, who in turn reports to the General Superintendent, Nuclear Generation.
The inspector noted that responsibilities for sample collection and analyses for the Radiological Environmental Monitoring Program (REMP) are shared between the Niagara Mohawk Power Corporation (NMPC), which operates the Nine Mile Point Nuclear Station, and the New York Power Authority (NYPA), which operates the James A. Fitzpatrick Nuclear Power Plant.
Sample collections are performed by two groups.
A large portion, including milk, food crops, and fish, is performed by Ecological
- Analysts, Inc.
The remainder, including in-plant canal sampling and air samplers, is performed jointly by personnel from the Nine Mile Point Nuclear Station and the James A. Fitzpatrick Nuclear Power Plant.
The licensee stated that radiological analyses (other than those conducted on-site) are contracted to Teledyne Isotopes.
Certain environmental samples are analyzed by the Site Environmental Laboratory, These samples are:
air particulate filters (for gross beta and gamma spectral analysis),
airborne radioiodine (gamma spectral analysis),
and lake water (gamma spectral analysis).
Pro ram Review and Audits The inspector reviewed the licensee's audits of its contractors for environmental sampling and analyses.
These audits are required by the licensee's procedure S-ENVSP-6.
This procedure did not specify the frequency for performance of these audits.
The licensee stated that the procedure would be revised to specify a biannual frequency, as a minimum, for each contractor.
This will be reviewed in a future inspection (220/86-14-01).
The inspector reviewed the audit of Ecological Analysts, Inc. (EAI),
performed in January
- 1986, and the audit of Teledyne
- Isotopes, Inc.,
performed in January 1985.
Both audits were conducted by the Envi-ronmental supervisors from NMP and JAF.
The EAI audit covered radiological sample collection, including procedures, specific sampling activities, shipping and inventory, data handling, and administrative matters.
The Teledyne audit covered sample receipt and data handling, selected procedures (including those for deter-mination of gamma emitting radioisotopes and for determination of radiostrontium in milk), instrumentation (including calibrations),
and quality control.,
No open items were identified in either audit.
The licensee stated that the audit of Teledyne's quality control covered only its performance with"respect to EPA crosscheck
- samples, The inspector stated that the audit should also include a review of other aspects of the quality control program, including control
- charts, analyses of duplicate and replicate
- samples, etc.
As required by Technical Specifications, audits were performed under Safety Review and Audit Board (SRAB) cognizance of all aspects of the radiological
- program, including the radiological environmental moni-toring program.
The inspector reviewed the following audits:
1985 SRAB Audit D:
Radiological/Meteorological/Radioactive Waste Handling, conducted by Impell Corporation, December 9-13, 1985.
Radiological, Meteorological, and Radioactive Waste Handling, conducted by KLM Engineering, December 17-21, 1984.
The 1985 audit report contained brief summaries of the auditors observations concerning the radiological environmental monitoring and meteorological monitoring programs.
The 1984 audit report contained no summaries covering these
- programs, but provided a list of procedures and records that were reviewed'.
The licensee stated that the auditors had reviewed these procedures and records, but did not provide a discussion of the audit results because there were no negative findings.
The inspector stated that the report should summarize the auditors'bservations, positive and/or negative, in order to adequately document that the audit was performed in suffi-cient depth and scope.
The licensee stated that an effort would be made to obtain additional documentation for the 1984 audit from KLM
Engineering~and that in the future, audit reports conducted under the cognizance of SRAB would include the necessary documentation to show that these programs were adequately reviewed.
This will be reviewed in a future inspection (220/86-14-02).
4.
Environmental Laborator ualit Assurance The inspector reviewed the program for the quality assurance of radio-analytical measurements performed by the Environmental Laboratory, which is operated by the James A. Fitzpatrick Nuclear Power Plant.
The program was reviewed against the criteria of Regulatory Guide 4. 15,'"Quality Assurance for Radiological Honitoring Programs (Normal Operations)-
Effluent Streams and the Environment."
The inspector reviewed the following procedures:
ESP-12 (JAF)
Rev.
4 Environmental Surveillance Program; S-ENVSP-12 (NMP)
Quality Assurance/Quality Control Program ESP-5 (JAF)
S-ENVSP-5 (NNP)
Rev.
1 Rev.
8 Analysis of Environmental Samples R
ESP-11 (JAF)
Rev.
1 Environmental Lab Gamma Ray Spectrometer System The inspector reviewed the following quality control data:
intercomparison results for the period January 1986 to the present; daily resolution, energy and source check data for germanium detectors 1, 2, and 3 during the period January 1986 to the present; weekly background checks for germanium detectors 1, 2, and 3 during the period January 1986 to the present.
Within the scope of this review, the following concern was identified:
The laboratory's'omputer-based gamma spectroscopy system uses a
built-in quality control program for resolution,
- energy, background and source checks.
The software automatically compares the results of these checks to control limits established by the software vendors The laboratory personnel did not appear to be familiar with the software and could not explain the basis for the calculated values or the control limits.
The inspector stated that control charts established by the software, in the absence of the user's knowledge and under standing of the methodology
- employed, do not provide the level of control over the measurement process that can be achieved through the direct involvement of the laboratory personnel.
Io responseWo this concern, the licensee stated that it would initiate an improvement to the laboratory quality control program.
The laboratory personnel will perform a gamma-spectral analysis of a check source daily on each of the instruments when they are in use.
Control charts for each instrument will be established according to a documented method.
The results of the daily source checks will be plotted on the control charts and compared to the limits established for each instrument.
As a minimum, the laboratory personnel will plot the ratio of the daily analytical result to the known value for each of three radionuclides:
Cd-109, Cs-137, and Co-60; and the resolution for the 1332 KeV peak of Co-60.
The licensee stated that these control charts will be in use no later than August 31,
- 1986, and the procedure covering Environmental Labora-tory quality control will be revised to incorporate these changes no later than September 30, 1986.
The inspector also identified the following concerns:
Procedures ESP-12 (JAF),
and S-ENVSP-12 (NMP) indicate that the USNRC participates in annual sample splits with the licensee.
The bSNRC does not participate in sample splits with any licensee for the purpose of laboratory quality control.
The licensees stated that these procedures will be revised to remove the reference to the USNRC as part of the licensee's interlaboratory quali ty control program.
Ouring the review of source check data for Oetector ¹3, the inspector noted that an efficiency calibration had not been performed for the source check geometry.
The licensee stated that this calibration was performed prior to the conclusion of the inspection.
Procedure ESP-5/ENVSP-5 provides instruction for the gamma spectral analysis of water samples.
The preparation involves the evaporation of a 4 liter sample down to 100 milliliters, followed by the addition of nitric acid.
The inspector stated that the nitric acid, which is used to prevent plate-out of nuclides, should be added at the time of sampling and not following evaporation.
The inspector further stated that there is a possibility of losing volatile nuclides from the sample during the evaporation process.
Procedure ESP-5/ENVSP-5 specifies that the 100 cc counting geometry be used for gamma analysis of vegetation samples.
- However, the licensee indicated that the gamma spectrometry system is also cali-brated for vegetation samples using a
1 liter Marinelli beaker,'nd that analyses are performed using this counting geometry.
'I
Tge licenseesstated that procedure ESP-5/ENVSP-5 will be revised to, add the 1 liter Marinelli counting geometry for vegetation analyses and to specify that nitric acid is added to water samples at the time of sampling (this should be stated in the appropriate sampling procedure as well).
The licensee plans to perform an evaluation of the method for analyzing samples of water by gamma spectroscopy using the 4 liter Marinelli counting geometry instead of the evaporation technique.
The licensee stated that the results of'his evaluation will be used to determine the optimum method for analyses of water samples, including consideration of LLDs and sample counting time.
Procedure ESP-11 states that plots of current energy vs channel number are typically linear and any departure from linearity suggests a problem.
The inspector discussed this matter with the licensee since a non-linear fit is commonly used in an energy calibration.
The licensee agreed that a quadratic fit or a cubic fit would also provide an effective calibration and did not neces-sarily indicate a problem.
The licensee stated that this procedure ill be revised.
The inspector stated t,hat the procedure revisions and improvements to the Environmental Laboratory guality Assurance Program will be reviewed in a future inspection (220/86-14-03).
Im lementation of the Radiolo ical Environmental Monitorin Pro ram a.
Direct Observation b.
The inspector examined selected environmental monitoring stations, including air samplers for iodines and particulates, TLDs for direct radiation measurement, and continuous water sampling equipment on the inlet canal at the JAFNPP.
All equipment was operational at the time of the inspection.
Review of Re orts The inspector reviewed the licensee's Annual Radiological Environ-mental Operating Reports for 1983, 1984 and
- 1985, and not'ed that all samples required by the Technical Specifications were reported for each year.
There is also discussion of the monitoring program, the various kinds of samples
- analyzed, the interrelationships between the Fitzpatrick and Nine Mile Point Programs, and deviations from the required sampling schedules.
As a result of this review, the inspector determined that the licensee has complied with its Technical Specification requirements for sampling frequencies, types of me'asurements, analytical sensi-tivities, and reporting schedules.
The analysePof environmental samples indicated that doses to humans from radionuclides of station origin were negligible.
Procedures The inspector reviewed selected procedures for analyses of samples by the Environmental Laboratory.
Observations concerning procedures related to laboratory quality assurance are presented in Section 4
of this report.
In addition, the following procedures were reviewed:
ESP-2 (JAF)
ESP"4 (JAF)
S-ENVSP-4 (NMP)
ESP-7 (JAF)
S-ENVSP-7 (NMP)
ESP-9 (JAF)
Rev.
1 Rev.
11 Rev.
2 Rev.
6 Rev.
2 Rev.
1 Environmental Data Review Environmental Station Inspection and Sample Collection Calibration of Environmental Monitors Low Background Proportional Counter ESP-14 (JAF)
Rev.
1 LB 5100 Low Background Counter The inspector also reviewed records and data related to these procedures.
The review of ESP-14, LB 5100 Low Background Counter, indicated that a step necessary for proper calibration of the instru-ment was not included in the procedure, and that an existing step was not being implemented.
The missing step, which was recommended in the manual supplied by the instrument manufacturer, instructs the user to move the signal cable from the beta port to the alpha-plus-beta port as part of the calibration, in order to accumulate gross counts in channel B'of the instrument.
This is to be followed by repeated counts of a check source at increasing voltage increments, and a graph of response (counts per minute) versus voltage is to.be prepared.
The procedure specified (step 4.4.8) that the user should plot averaged beta counts per minute versus voltage, and averaged alpha-plus-beta counts per minute versus voltage.
The inspector reviewed calibration records for this instrument and determined that the user had not performed the plot of alpha-plus-beta counts per minute versus voltage.
The inspector stated that Procedure ESP-14 was not properly implemented, and that this was a violation of Section 7.2 of the James A. Fitzpatrick Nuclear Power Plant Techni-cal Specifications as stated in NRC Region I Inspection Report No.
50-333/86-12.
The licensee revised the procedure to include the missing step and instructed laboratory technicians on the proper method of calibration prior to the end of the inspection.
The inspector reviewed the licensee's revised procedure and found it adequate.
This item is considered closed.
1
Meteorolo ical MRitorin The inspector examined the licensee's meteorological monitoring system, including the primary, backup, and inland meteorological
- towers, as well as the digital readouts in" the equipment buildings at each tower and the strip chart recorders in the control room.
The equipment on each tower appeared to be operating properly at the time of the inspection.
The primary tower has sensors for wind speed (WS) and wind direction (WD) at three elevations:
30 feet, 100 feet, and 200 feet.
In addition, this tower has provisions for measuring hT and sigma-theta.
The backup tower has WS and WO sensors at an elevation of 92 feet.
The inland tower has sensors at the 32-foot level; its purpose is to detect differences in weather conditions relative to the towers at the site, which are influ-enced by the effects of Lake Ontario immediately to the north.
The inspector reviewed the licensee's calibration procedures for its meteorological monitoring equipment, and noted that calibrations have been performed semiannually as required by Technical Specifications.
These calibrations appear to have been performed satisfactorily.
Prep erational Radiolo ical Environmental Monitorin Pro sam - Unit 2 The licensee stated that the REMP for the operating units serves as the preoperational REMP for Unit 2.
The existing program was reviewed against the criteria in the USNRC Radiological Assessment Branch Tech-nical Position (Rev.
2, November 1979).
It was determined that most of the suggested types and quantities of samples are collected at the frequencies specified.
The Branch Technical Position provides for variations in the number,
- media, frequency and location of sampling, depending on site-specific factors.
One such variation at the Nine Mile Point site concerns routine ground water monitoring, which is not required because the hydraulic gradient is in the direction of Lake Ontario; i.e., station effluents into the lake do not affect local wells and ground water sources in the area.
Exit Interview The inspector met with licensee representatives denoted in Paragraph I
at the conclusion of the inspection on July 25, 1986.
The inspector summarized the purpose and scope of the inspection, and discussed the findings.
At no time during this inspection was written material provided to the licensee by the inspector.
0