ML18079A660
| ML18079A660 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/06/1979 |
| From: | Shanbaky M, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18079A656 | List: |
| References | |
| 50-272-79-02, 50-272-79-2, NUDOCS 7908020070 | |
| Download: ML18079A660 (18) | |
See also: IR 05000272/1979002
Text
U.S~l!CLEAR REGULATORY COMMISSION e
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
Report No. 50-272/79-02
Docket No. 50-272
....:....--=..:-=----
License No. DPR-70
---~-=-----
Priority
-
........_ ____ _
Category --lol...-----
Licensee:
Public Service Electric and Gas Company (PSE&G)
80 Park Place
Newark, New Jersey* 07101 *
Facility Name:
Salem Nuclear Generating Station Unit l (SNGS-1)
Inspection at:
SNGS-1 Hancocks Bridge, New Jersey
Inspection conducted:
January 8-12 and 15-17, 1979
Inspectors:
- ~ ~~~Y
M. M. Shanbaky, RadiatioK Specialist
Approved by:
date signed
Environmental and Special
FF&MS*Branch
lCfa tes 1 gned
Inspection* Summary:
_ _ .
Inspection on January 8-12 and 15-17, 1979 (Report No.'50-272/79-02)
Areas Inspected:
Routine; unannounced inspection of environmental monitoring
programs for operations- including: management controls for these programs; the
licensee programs 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; a followup on the licensee's actions on previous
- inspection findings; and, review of licensee reports.
A facility tour
was conducted. *rhe inspection involved 54 inspector-hours onsite by
one NRC regional based inspector *
Region I Form 12
(Rev. April 77)
-.
Inspection Summary
2
Results:
Of the five areas inspected, seven items of noncompliance were identified
in one area (Infraction - exceeding the condenser 6T Limiting Condition for Operation
(LCO) - Paragraph 4.a; Deficiency - failure to have reviewed chlorinatibn procedures -
Paragraph 4.b; Deficiency - exceeding the LCO for suspended solids in the plant
discharges - Paragraph 4.c: Deficiency - failure to report to the NRC all instances
of exceeding the condenser 6T LCO - Paragraph 4.a; Defi~iency - failure to have
a reviewed procedure.: for chemical inventory - Paragraph 4.d; Deficiency - Failure
to analyze the discharge sample for suspended solids as required - Paragraph 4.c; and
Deficiency - failure to collect and analyze the required river samples for chlorine -
Paragraph 4.e).
DETAILS.
1.
Persons Contacted
Public Service Electric and Gas Company
H. J. Midura, Station Manager
J. M. Zupko, Chier Engineer
- R. Silverio, Assistant to Manager
- J. C. Stillman, Station QA Engineer
L. K. Mi 11 er, Station Performance
L. Fry, Senior Performance Supervisor
- M. Stocknoff, Technical Supervisor
- J. Gueller, Senior Performance Supervisor
- F. Schnarr, Operating Engineer
- M. F. Metcalf, Resident QA Group
- W. Grau, QA Staff Assistant
- D~ Lyons, QA Specialist
- R. P. Douglas, Licensing Manager
D. E. Cooley, Principal Staff Engineer
- R. Roble, Senior Engineer
- W .. E. Polhemus, Principal Staff Engineer
- M. D. London, Biologist
N.
C~ Allman, Engineer
R .. F .* Yewda 11, Engineer
R. W. Lambdin, Health Physicist
Radiation Management Corporation (RMC)
C'. A. Sakenas, En vi ronmenta l Scientist
Ichthyolgical Associates (IA)
V. J. Schuler,. Biologist
- denotes those present at the exit interview.
- denotes those contacted by telephone *
4
2.
Licensee Action on Previous Inspection Findings
(Open) Noncompliance (272/78-04-01)~ Exceeding the Limiting Condi-
tion For Operation (LCO) for condenser tlT.
The inspector reviewed
several of the licensee circulating water condenser LiT records for
1978.
The daily summary computer printout records showed that the
condenser AT limit: was exceeded on several occas,J qns.
The i nspec-
tor stated that failure to maintain the condenser AT within the LCO
is a repeated item of noncompliance.
(272/79-02-01).
(Details,
Paragraph 4.a)
(Open) Noncompliance (272/78-04-02): Failure to meet the required
. temperature monitors range and failure to monitor the intake and
discharge temperature during* computer outage periods.
A proposed
ETS change. was submitted to NRR requesting the change of the RTD's
range to 32-150°F.
The inspector stated that this item will remain
open until the proposed ETS change is. reviewed and. approved by NRR.
(Closed) Unresolved (272/78-04-03): Condenser discharge temperature
averaging method.
Further discussions with the licensee and NRR
staff and. review of the ETS (Basis and Definitions) showed that the
condenser discharge temperature averaging method is acceptable.
This. item is closed.
(Closed} Noncompliance (272/78-04-04):
Exceeding the free chlorine
LCO in the circulating and service water systems discharge.
The
licensee grab sampling and manual analysis records showed that the
chlorine limit was not exceeded during 1978.
The inspector noted,
through review of the licensee's chlorination records, that the
continuous chlorine analyzer was not used for monitoring chlorine
discharges and instead grab samples were taken and analyzed for
chlorine during the chlorination cycle. *The licensee stated that
it appears that the continuous chlorine analyzer will not be* used
in the near future because of the continuous electronic problems
with the analyzer.
The inspector stated that the acceptability of
using the grab sampling and manual analysis method for*-<what'.appea+ed to
be ~n indefinite period of time will be considered unresolved
- .
pending NRR staff review (272/79-02-03).
(Details, Paragraph
4.b.)
(Closed) Noncompliance (272/78~04-05): Exceeding the required
maximum chlorination period and frequency.
The chlorination dura-*
tions and frequencies were manually logged rather than using the
continuous chlorine analyzer charts. These records *showed that the
-chlorination duration and frequency were in accordance with the ETS
requirements during 1978.
This item is closed.
5
This method of record keeping was used because the* continuous
chlorine analyzer was out of service during 1978.
The acceptability
of using the grab sampling and manual analysis method will be
considered* unresolved pending NRR staff review {272/79-02-03).
{Detajls, Paragraph 4.b)
{Open) Noncompliance {272/78-04-07): Failure to have chlo.rination
procedures.
The inspector noted that the required chlorination
procedures are still in a draft form.
The inspector stated that
failure to review and implement the required chlorination procedures
is an uncorrected item of noncompliance {272/79-02-02).
{Details,
Paragraph 4.b)
{Open) Noncompliance (272/78-04-09): Exceeding LCD.for suspended
solids.
The total suspended solid annual limit (LCD) was exceeded
for 1978.
The inspector stated that this is an. unco*rrected item of
noncompliance (272/79-02-06).
(Details, Paragraph 4.c)
(Open) Noncompliance (272/78-04-lD): Failure to report exceeding
the ETS LCO for condenser AT.
The inspector noted that occasions
of exceeding LCD for condenser tff during 1978 were not reported to .
the NRC as required.
The inspector ~tated that this is a repeated
. item of noncompliance (272/79-02-04).
(Details, Paragraph 4.a)
(Open) Noncompliance. (272/78-04-11): Failure to have chemical
inventory procedures.
The inspector noted that the required chemi ca 1
inventory procedures are in a draft form.
TDe inspector stated
that the failure to review, approve. and implement the required
procedures is an uncorrected item of noncompliance (272/79-02-05).
(Details, Paragraph 4.d)
(Closed) Unresolved (272/78-04-13): Temporary deicing system at
the intake structure.
The licensee stated that because of emergency
need for power and plant safety considerations, the temporary
deicing system was built and used for a few days (January 28-
February 1, 1978).
The inspector examined the intake structure and
noted that the temporary deicing system was dismantled.
This item
is closed.
(Closed) Noncompliance (272/78.:.04-15):
Failure to meet the required
Minimum Detectibility Limit (MDL) for Sr-89 in milk.
The inspector
e~ami~ed a sample of the analytical result~ for Sr-89 in milk and
noted that the required MDL was met.
(Details; Paragraph 7.c)
6
(Closed) Unresolved (272/78-04-16):
TLD performance evaluation.
The inspector reviewed the TLD performance study results. The
study concluded that the licensee environmntal TLD meets the established.
performance criteria in Regulatory Guide 4.13. This item is closed.
3.
Management Controls
The inspector reviewed the licensee's management controls. Areas
reviewed included assignment of responsibility, audit results,
analytical and sampling procedures and criteria and instructions
for recognizing, correcting and followup action on inadequacies and
problem areas in the* program.
The inspector noted through review
of audit results, discussion with the. 1 i censee and review of program
records, that the environmental radiological, biological and meteoro-
logical monitoring programs were conducted under adequate management
controls, however, problems continued to exist in the nonradiological
monitoring program.
(Details, Paragraph 4)
4~
Nonradioactive Effluent Release Rates and Limits
The plant non.-radiological effluent monitoring requirements including
the thermal and chemical discharges are listed under Sectjon 2.0
(Limiting Conditions for Operation), SNGS-1, Environmental Technical
Specifications (ETS).
The inspector reviewed the chemical and
thermal effluent parameters with regard to system layout, monitoring.
instrument capability and calibrations, type and frequency of
measurements, total release limits, rates of release, and the
differential intake-discharge limits, as applicable. Areas reviewed
included the following:
a.
Thermal Releases
Section 2.1 of Appendix B, (ETS) provides a specific thermal
release requirement to limit thermal stress to the aquatic
ecosystem in the plant vicinity by limiting the maximum differen-
tial temperature (t.T) across the condenser, the maximum discharge
temperature and the rate.of change of discharge temperature.
These limits were based on an extensive field and laboratory
studies performed by the licensee and other organizations.
Section 2.1.1.a of the ETS requires that the maximum t.T
across the* condenser shall not exceed 16.5°F during normal
operation with all six circulating water pumps operating.
In
the event that the specification is exceeded, corrective
action shall be taken to reduce the t.T to within specifica-
e .
7
tion~ Each of the condenser inlets and discharge lines {llA,
B; 12A, B; 13A, B) were provided with an RTD.
(Six RTD's
located at the condenser inlets and six RTD's located at the
discharge lines *. } The RTD
1 s are .scanned by the computer every
hour* and instantaneous temperature measurements are printed
out.
The licensee stated that this printout is only available
at the end of the day and includes the hourly temperature
- records for the previous -24 hour period. This printout was
- referred to by the licensee as the daily summary (NPDES printout).
The licensee stated that the daily surrmary (NPDES printout) is
the: only document which includes continuous ho~rly temperature
- records, however the AT will alarm on the plant CRT in the
control room whenever the AT is above l6.5°F.
The control
room operator action is based on. the CRT AT~7.s:P,-lay. The CRT
AT di.splay is based on the same RTD readings which are recorded
on the computer daily summary (NPDES printout).
The inspector reviewed a sample of the *daily summary (NPDES.
printout) records for 1978 and* noted that, with all six circulating
water pumps in operation, the* ETS AT limit across the condenser
was. exceeded for several hours on December 9, l 0, 11 and 12,
1978.
On December 9, 1978, the condenser AT hourly printout
showed an average AT of 18.5°F and 19.9°F at 2300 and 2400,
. respectively.
The condenser* AT continued* above the ETS limit
( 16. 5°F) through 0200 on December 10, 1978.
The condenser AT
was above the ETS limit from 2300 on December 11 through 0700
on December* 12, 1978.
The inspector noted through review of
the Control Room* Daily Log (CRDL) and discussion with the
licensee personnel, that no immediate corrective action was
taken to restore the condenser AT to within the ETS limit.
Section 2.1.l.b.2 of the ETS' (A-T.li.mit*df.lringi~pump outage)
specifies that the maximum AT across the condenser shall not
exceed 16.5°F for more than 72 consecutive hours for reasons
of pump failure.
The inspector discussed with *the licensee
the possibility of pump failure during .1978.
The licensee
stated that the pumps are reliable equipment and that pump
failure was not a problem during 1978; however, failure of
pump associated equipment (i.e. , intake traveling screens) was
a problem during 1978.
Section 2. 1. 1. b. l of the ETS (LlT limit during pump outage)
specifies that the maximum AT across the condenser shall not
exceed 16~5°F for more than 24 consecutive hours.because of
scheduled maintenance and inspection.
The inspector reviewed
a sample of the daily summary (NPDES *printout) and noted that,
during maintenance and inspection and with less than 6 circulating
water pumps in operation, the ETS AT limit across the condenser
was exceeded for more 24 consecutive hours on several occasions
in 1978 including the following periods:
8
December 4 (0900) through December 7 (1100) - 75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />
November 20 (0800) through November 23 (1400) - 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br />
November 15 ( 0100) through November 19 * ( 1700) - 113 hours0.00131 days <br />0.0314 hours <br />1.868386e-4 weeks <br />4.29965e-5 months <br />
November 24 (0900) through November 26 (1000) - 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />
September 11 (0400) through September 12 (1700) - 38
hours
August 24 (2200) through August 26 (0700) - 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />
July 26 (0500) through July 27 (2300) - 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br />
The inspector noted, through review of the Control Room Daily
Log and discussion with the licensee, that no immediate
corrective action was taken to restore the condenser llT to
within the ETS limit.
The inspector stated that exceeding the
llT LCO and failure to take adequate corrective action to
restore llT to within the ETS limit was an item of noncompliance
(272/79-02-01). This is a repeated
item.
(The previous
item was 272-78-04-01.)
Section 5.6.2 of Appendix B, ETS requires that a report shall
be submitted in the event a limiting condition for operation
is exceeded.
The event shall be reported within 30 days by a
written report to the Director of the Regional Inspection and
Enforcement Office (with a copy to the Director of Nuclear
Reactor Regulation).
The inspector determined, through review
of all the submitted License Event Reports (LER) for 1978 and
a discussion with the licensee, that no LERs covering the
above events of exceeding the LCO for llT were sumbitted to the
NRC as required.
In a memorandum from the PSE&G General
Manager, Licenseing and Environment, to the General Manager,
Electric Production, dated November 14, 1978, the Electric
9
Production management was informed that it appeared that the
ETS_ tiT 1 imits were exceeded on several occasions and requested
review regarding the submittal of LER's to the NRC.
This
memorandum included specific dates, duration and circumstances
of exceeding the condenser tiT LCO during 1978.
The inspector
stated that failure to report to the NRC all instances of'
exceeding the condenser tiT LOC was a repeated item of noncompliance
(272/79-02-04). _(The previous item was 272/78-04-10.)
The condenser tiT LCO was previously exceeded on several occasions
in 1977.
This was discussed with the 1 i censee in February
1978 during Inspection No. 272/78-04.
The licensea attributed
this to erroneous and unrepresentative temperature measurements.
The licensee stated, at that time, that the RTDs were very
close to the condenser outlet and should be relocated down--
stream in the 48 inch ID discharge line to allow for better
mixing and to avoid the thermal stratification zone near the
condenser.
The RTDs were taken out of service and sent to the RTD vendor
for* modification. The RTD element length was extended several
inches. This design change was completed in June 1978 and the
modified RTDs were* relocated at about 20 feet downstream from
the condenser water boxes in the* 48 inch ID discharge- lines._
The licensee stated that the RTD temperature range is still
between 32-300°F which is contrary to the Section 2.1, ETS
requirement of a temperature range of 0-150°F. This was
previously an identified item of noncompliance (272/78-04-02).
The licensee stated that an ETS change request was submitted
to NRR in June 1978 to change the ETS, RTD range requirement
to 32-300°F.
The inspector stated that this item will remain
open pending NRR review.
Section 2.1 of the ETS requires the thermal discharge monitoring
system to have an accuracy of+ 0.5°F.
The inspector noted,
through discussion with the licensee and review of records,
that the system was not calibrated after the system modifications,
which were performed in June 1978.
The inspector noted that
the intake RTD, (6 elements) readings varied between 2 and 4°F
on several occasions.
The inspector questioned the fact that
these RTDs did not measure the same temperature at the same
time and under the same operation condition (i.e., circulating
water pumps). * The 1 i censee stated that all the non-safety
related RTDs in the plant are required by the plant procedures
(IC) to be calibrated every 3 years and that the condenser RTD
b.
10
calibration is due in July 1979.
The licensee stated that the
variability in the intake RTD temperature readings could
possibly be attributed to other than calibration problems and
this area would be evaluated to identify the cause of such
variability. The inspector stated that until the system is
calibrated and the calibration results are reviewed, the RTD
accuracy is. considered unresolved (272/79-02-08).
The, licensee stated* that the discharge-intake temperature- and
the* circulating water pump status data which are both recorded
on the daily summary sheets (NPDES printout), are* instantaneous
11 ~nap shot
11 readings and did not take into. account the discharge-
intake temperature and any pump operation changes during the
entire hour.
The licensee stated that although, the daily
summary sheet indicates that the b.T temperature limit was
continuously exceeded, it is possible that the b.T hourly
average might have been below the ETS limit.
The licensee
- stated that once the control room operator clears. up the b.T
alarm on the* CRT, the plant b.T was considered to be within the
ETS limit. The licensee stated that, if the CRT b.T alarm
could not be cleared, corrective actions would be initiated
and a new 24 or 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period started.
The inspector stated
that any corrective actions taken were evidently not adequate
to restore the b. r to wi thi'n the ET_S l iinit for the subsequent
hour as. reflected. in the instantaneous hourly temperature
records.
The inspector stated that this was previously discussed
(IE_ Inspection No. 50-272/78-04).
In a letter from NRC to
PSE&G dated May 19, 1978, it was established that the computer
records (Dafly Summary - NPDES printout) are the official
condenser b.T records.
The licensee stated that an ETS change
request will be submitted to NRR to change the condenser AT
limit from 16. 5 to 18. 5° F.
It wi 11 be al so requested from NRR
that the maxi'mum period (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) allowed for reason of pump
failure will be applied to failure of any other equipment
associated with the circulating water pumps (i.e. traveling
screens) and not just the pumps themselves as is the case now.
Chlorine Releases and Chlodnation
Section 2.2.l of Appendix B, ETS requires that the concentra-
tion of free chlorine in the Circulating Water System and
Service Water System shall not be greater than 1.0 mg/liter at
the outlet of the final heat exchan.ger.
Circulating Water and
Service Water pump intakes shall not be chlorinated more than
3 times per day.
Chlorination periods shall not exceed 30
minutes.
Chlorination of more than 3 Circulating Water pump
intakes at one time shall not be permitted.
ll
The inspector reviewed the licensee chlorination and chlorine
monitoring records for 1978.. The inspector- noted. that the
chlorination frequency during 1978 was significantly lower
than that of 1977.
The chlorination log book. showed that ETS
chlorine limit, frequency and duration were* not exceeded in
1978.
Section 2.2.l of Appendix B, ETS requires that the outlet
water.boxes of the consenser shells that are being chlorinated
shall be continuously monitored for free chlorine residual
- during treatment*.
The Service Water System shall be monitored
at the 30-inch supply header to the turbine generator area
during treatment.* The continuous monitoring (during treatment)
shall be performed using a Wallace & Tiernan Series 50-236
free. chlorine residual analyzer equipped with a strip chart
recorder.
The Circulating Water System and the Service Water
System each have a separate free chlorine* residual analyzer.
The chlorine monitors shall be calibrated once per month with
anamperometric titrator and using ASTM Methods D-1235 and D-
142,. to 0.01 ppm accuracy.
If the chlorine monitors are
inoperable, free chlorine residual shall be determined by
manual analysis* of a grab sample taken during the chlorination
eye.le.
The inspector noted that all the analytical results for chlorine
were based on the analyses of grab samples.
The licensee
stated that the grab sampling method was used since the continuous
chlorine analyzer was inoperable.
The inspector discussed
with the licensee the continuous chlorine analyzer outage
periods during. 1978.
The licensee stated that the continuous
chlorine analyzer was never used duri~g 1978 due to continuous
analyzer problems.
The licensee stated that efforts were made
to repair and calibrate the continuous chlorine analyzer but
that the continuous chlorine analyzer would not be put back in
service in the near future .. The inspector stated that the
grab sampling method was intended only as a backup monitoring
method for periods of continuous analyzer outage.
The inspector
stated that the chlorine monitoring area will be considered
unresolved pending NRC verification of the acceptability of
using the grab sampling method on a continuous basis.
(272/79-
04-03.)
c.
12
ETS Section 5.5.2 requires that the plant operating.procedures
shall include provisions to ensure the plant and all its
systems and components are operated in compliance with the
LCO.
Through records review and discussion with the licensee,
the inspector noted that the plant operating procedures did
not .. include chlorination procedures for operating the circu-
lating and service water chlorination system in compliance
with the LCO established in Section 2.2. 1 of the ETS.
The
licensee stated that draft chlorination procedures were prepared,
(CI-PD-3.4.029), including the manual. semi-manual and automatic
chlorination modes.
The inspector reviewed the draft procedures
and noted that they were not reviewed and approved for implemen-
tation by appropriate licensee management.
The inspector
stated that Section 5.3.2 of the ETS requires that the Station
Operations Review Committee (SORC) shall review plant procedures
which have a potential impact on the environment.
The inspector
stated that failure to review the chlorination procedures as
- required was an item of noncompliance (272/79-02-02).
The
inspector stated that this is an uncorrected item of noncompli-
ance* (272/78-04-07) and it was brought to PSE&G management
attention in a letter from the NRC dated March 23, 1978.
In a
letter dated April 24, 197.8, from PSE&G to the NRC in reply to
this item, PSE&G committed to complete the chlorination procedures
by August 1, 1978.
Suspended Solids
Section 2.2.2, ETS, LCD, requires that the average suspended
solids concentration in the effluent from the Nonradioactive
. Chemical Liquid Waste Disposal System (NLWDs)* shall not
exceed 25 mg/liter on an annual basis. through records review
and discussion with the licensee, the inspector determined
that the LCO for suspended solids in the NCLWD System discharges
was exceeded for 1978.
The 1978 average suspended solids .in
the NCLWD System discharges was approximately 35 mg/liter.
The inspector stated that this was an item of noncompliance
(272/79-02-06).
The inspector stated that this is an uncorrected
item of noncompliance (272/78-04-09), as corrective action was
not completed as stated in PSE&G letter to the NRC dated April
24, 1978.
This letter stated, to prevent further items of
noncompliance, an ETS change request wi 11 be submitted to the
NRC to change the maximum suspended solids limit from gross to
net (i.e., plant discharge - River ambient level). The
licensee stated that the proposed change of the ETS limit for
suspended solids was .submitted to NRR as stated in the PSE&G
letter of April 24, 1978, however, this proposed change was
withdrawn pending the issuance of the State of New Jersey
suspended solids limit.
d.
13
The inspector reviewed the sampling and analytical results of
the NCLWD system during 1978.
The inspector noted on several
occasions, including November 8, October 24 and September 26,
1978, that no analytical results for suspended solids were
reported.
The licensee stated that the samples were collected
and sent to the analytical contractor for analysis. The
licensee stated that the analytical contractor went out of
business before sending to PSE&G the required analytical
results. The inspector stated that failure to perform the
required analysis (ETS, 2.2.2) was an item of noncompliance
(272/79-02-09}.
.
Chemical Inventory
Section 3.1.1.5, ETS, requires, in part, that a physical
inventory of indentifiable chemicals discharged directly to
the river shall be maintained and submitted as part. of the
annual report.
The inspector reviewed the licensee's draft
chemical inventory data for 1978.
The final results of the
inventory were not available at the time of inspection.
The
licensee stated that the 1978 chemical inventory will be
completed by March 1979.
The inspector noted that no written
procedures were used in performing the required chemical
inventory (Section 3. 1.1.5, ETS).
Section 5.5, ETS requires
that detailed written procedures, including applicable check-
lists and instructions shall be prepared and followed for all
activities involved in carrying out the ETS.
The inspector
stated that failure to prepare the required procedures for
physical inventory of indentifiable chemicals was an item of
noncompliance (272/79-02-05).
The inspector.stated that this is
an~uncorrecteditem of noncompliance (272/78-04-11).
In response
to the previous item, in a letter dated April 24, 1978, PSE&G
Co. informed the NRC that to prevent further items of noncompli-
ance the required written procedures will be prepared, approved
and this action will be completed by August 1. 1978.
The
licensee stated that written procedures are in a draft form
and will be completed, reviewed and approved in the near
future.
The licensee stated that the performance of the
chemical inventory responsibility was assigned* to the plant,
however,.at the present time the inventory is being conducted
by the Licensing and Environmental group~ Communication
problems are now being corrected and the procedures will be
established, reviewed and approved *
14
e.
River Water Qua 1 i ty
The inspector reviewed the licensee's program covering the
river water quality during 1978.
Water quality parameters
were monitored in the Delaware River as required by Section
3.1.l of the ETS.
The river water quality program included
monitoring of chlorine, dissolved. gases, suspended solids, and
other chemicals (Table 3.1-1, ETS).
The inspector reviewed a
sample of the analytical results and sampling records for
1978.
The inspector noted that the required weekly river grab
samples were not taken during plant chlorination cycles and
analyzed for free and total residual chlorine for August 1978.
The inspector stated that this was an item of noncompliance
(272/79-02-07).
The inspector stated that this is a repeated
item of noncompliance (212/78-04-08).
The licensee stated
that significant improvements were made in this area, however,
communication problems between the plant and the Energy Labora-
tory are not completely resolved.
The licensee stated that
better communication methods between the plant and the sample
collector (The Energy Laboratory) wi-11 be evaluated.
5..
Routine and Nonroutine Reports
The inspector reviewed the licensee's annual environmental radio-
logical and biological monitoring reports for the period from
January l to December 31, 1977.
The inspector verified that the
reports were submittted to the NRC at the required time and included
the required. environmental monitoring data.
The inspector also
reviewed the licensee's nonroutine reports (LERs 78-47, 78-37, 78-
32, 78-24, 78-23, 78-20,*78-19, 78-15, 78-10, 78-09, 77-93, 77-91
and 77-78).
The inspector examined these events and circumstances
related to each of the submitted reports.
The inspector noted,
through his review, that these LERs were submitted to the NRC as
required.
6.
Licensee Program for Qua l .i ty Centro 1 of Anal yti cal Measurements
The inspector reviewed the licensee's current quality control pro-
gram for analytical measurem~nts. The inspector discussed with the
licensee and the licensee's representatives (RMC) the scope of the
QC program including number of spiked, split, and duplicate samples,
15
counting instrument checks and calibrations,. frequency of the QC
analysis for different media~ and the criteria for analytical
measurements evaluation. Also discussed were the management controls,
data review and procedures to*correct analytical inadequacies and
problems.
The inspector reviewed a sample of the QC analytical
results*.
The licensee QC program was conducted during 1978 in
accordance with the RMC-QC manual.
The licensee representative
stated that every 50th sample. was either split or- recounted and the.
analytical results were compared and evaluated.
In addition,
thirty or twenty extra samples for different environmental media
were used monthly by the laboratory QC manager as blind samples.
Other than the Sr-89, 90 yield determination problems (Paragraph
7.C) no analytical difficulties were encounted during 1978.
No items of noncompliance were identified in this area.
7.
Implementation of the Environmental Monitoring Program - Radiological
a.
Air Sampling and Analyses
The* inspector examined several of the 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 inspection.
The inspector
reviewed a sample of the-air particulate analytical results
for 1977-1978 and noted that the air particulate samples were
collected and analyzed as required.
b.
Environmental Direct Radiaticin
Environmental direct radiation is measured with thermolumi-
nescent dosimeters (TLDs).
The inspector determined from data
review, exami~ation of the environmental monitoring stations,
and discussions with the licensee, that the TLDs were located,
collected, and read as required by Table 3.2-1 of the ETS.
The inspector reviewed the direct environmental radiation
monitoring results for 1978.
The inspector determined that
the monitored locations near the site indicated direct radi-
ation levels between 12"."16 mR/quarter.
The control location
indicated essentially the'same radiation levels as detected at
the monitoring locations near the site.
16
The inspector discussed with the licensee representative
(RMC), the TLD handling practices with regard to environmental
TLD. testing and performance evaluation.
The licensee repre-
sentative stated that most of the TLD performance studies
listed in the NRC Regulatory Guide (4.13) and the ANSI Standard
(ANSI-N-545~ 1975) were performed. *The inspector reviewed the
RMC performance evaluation report for the environmental TLDs.
The study results showed that the environmental TLDs were
within the acceptance criteria established in the NRC Regulatory
Guide 4.13.
The inspector discussed with the licensee represen-
tatives participation in the QC studies including. those sponsored
by D.O.E.
c.
Milk Sampling and Analyses
The inspector reviewed the milk sampling and analyses program
for* 1978.
The inspector verified that the co 11 ected milk
samples were counted within eight days from sampling d~tes.
The inspector reviewed the I-131 analytical data and verified
that the required MDLs were met.
Positive I-131 concentrations
in milk* ranging between 0. 5 and 12 pCi /liter were detected
during April 1978.
Review of the licensee's radiological
effluents showed that no I-131 air releases were made during
this period.
The licensee attributed the I-131 concentrations
to the Chinese nuclear test of March 1978.
The inspector
determined that the required milk animal census was performed
as required during 1978.
The milk samples were collected from
all the required locations with the exception of location No.
2FT.
Milk production was terminated at this farm.
This
station was replaced with a nearby farm location and the new-
location was designated No. 2F4.
This was reported to the NRC
as required in a letter dated April 3, 1978 *
- '
17
The, inspector* reviewed the Sr-89, 90 analyses in milk and
noted that all the required milk samples were collected and
analyzed.
In reviewing the raw analytical and QC data for Sr-
89, 90, the inspector noted high variability in chemical yield
determinations.
The. Sr-89 yield. varied.between 1 and 60%.
The: inspector noted. that significant improvements were made in
this, area, however, chemical yield determination problems are
still being encountered. The inspector stated that this area
will be ree~amined during a subsequent inspection (272/79-02-
10).
d.
Other Environmental Media
The inspector reviewed the licensee's sampling and analytical
results for other environmental media including drinking
water, game, fish, and vegetation.
The inspector noted that
the. environmental samples were collected and analyzed as
required.
The inspector had no further questions in this
area.
e.
Meteorology
The inspector examined the meteorological tower and the asso-
ciated readout system in the control room.
The*inspector
noted that the required meteorological instruments were in an
operable condition at the time of the inspection.
The inspector
reviewed the system calibration and verified that the system
was frequently calibrated, maintained, and kept in an operable
condition in accordance with Section 3.3.3.4 of Appendix A,
Technical Specifications. The inspector examined a sample of
the meteorological data collected during 1978 and verified
that the meteorological data recovery was above 90% for all
the monitored meteorological parameters.
No items of noncompli-
ance were identified in this area.
8.
Implementation of the Environmental Monitoring Program Biological/
Ecological
The biological and ecological studies required by Section 3.1.2,
ETS were contracted to Ichthyological Associates, Inc. {IA).
The
inspector examined the fish return system at the circulating water
intake structure. The inspector noted that all the required
"'
18
biol_ogical samples _including. the traveling screen fish impingement
samples were* collected during 1978.
Several of the impinged fish
samples were not collected from the.Service Water System traveling
screens. This was identified by the licensee and corrective action
was taken. Several other biological .samples were not collected
during 1978 because of hazardous weather conditions.
The inspector
- noted that: a 11 of these instances were documented by the 1 i censee
and the biological contractor (I .A.).
Fish* impingement* problems encountered during 1978 (weakfish) were.
discussed in details.
The licensee stated that action levels could
not be determined because of the limited data and the extreme
seasonal variation in fish populations, however, any relatively
high fish impingement event will be reported to the NRC as required.
The inspector reviewed a sample of the biological data collected
during 1978, including the fish impingement.
The reviewed data
showed that the biological samples were collected and analyzed as
required.
No items of noncompliance* were identified in this area at this
time.
9.
- untesolved*rtems
Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, items of
noncompliance, or deviations.
Two unresolved items were disclosed
during this inspection. These items are discussed in Paragraph 4.a
and *4. b.
10.
Exit Interview
On January 17, 1979, the inspector met with the licensee- representa-
tives indicated in Paragraph 1.
The inspector summarized the
purpose and the scope of the inspection and the inspection findings.
The i:nspector discussed in detail each item of noncompliance .