ML19207B198
| ML19207B198 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/25/1978 |
| From: | Berkson H, Bores R, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19207B193 | List: |
| References | |
| 50-289-78-08, 50-289-78-8, 50-320-78-16, NUDOCS 7908230544 | |
| Download: ML19207B198 (18) | |
See also: IR 05000289/1978008
Text
{{#Wiki_filter:- , . - . 3 - -- ; . , - ,- . - - f. .. NUCLEAR REGULATORY COMMISSL . - ' T. . - .- 1' - 0FFICE OF INSPECTION AND ENFORCEMENT Region I 50-289/78-08 W Report No. 50-320/78-16 MM N Y 50-289 8# p t w not esimm Q Docket No. 50-320 p m Acc*D*d * - DPR-50 C License No. DPR-73 Priority Category B-2 -- t. :. Licensee: Metrocolitan Edison Comoany (Met Ed) [.!. O P. O. Box 542 h i Reading, pennsylvania '19603 Facility Name: Three Mile Island Nuclear Station, Unit 1 and 2 (TMINS - 1 & 2) ) Inspection at: TMINS - 1 & 2, Middletown, Pennsylvania and at the Corporate -
Offices of Metropolitan Edison, Reading Pennsylvan u Inspectiar conducted: Aori 17-21, 1978 Inspectors: gfS-2.f ~/8 R. J. Bor'es, Radiation Specialist date signec ccompanied by: Harold Berkson. Environmental Soecialists ' Brancn, NRR:DSE (April 17-18,1978) cate signed cate signed Approved by: '/pZ . k S'/2f[M78' J. P. 5tonr, Cnlef, e m ronmenta & cate signed Special Projects Section, FF&MS Branch Inscection Summary: Inspection on Acril 17-21,1978 (Combined Recort Nos. 50-289/78-08; 50-320/7R 16) Areas Inscected: Routine, unannouncec inspection or environmental monitoring pro- grams for operations, including: the management controls for these programs; the licensee program for quality control of analytical measurements; implementation of the environmental monitoring programs - radiological; implementation of the environ- mental monitoring programs - biological / ecological; nonradioactive effluent release rates and limits; radiation levels around the Borated Water Storage Tank (SWST); and a followup on the licensee action on previous inspection findings. The inspection involved 36 inspector-hours onsite by one NRC inspector. Results: Of the six areas inspected, no items of noncompliance were identified in four areas. Three apparent items of noncompliance (Infraction - radiation levels in excess of limits in an unrestricted area - Detail 9; Deficiency - failure to sample and analyze air particulates and iodines - Detail 6.c(2); Deficiency - failure to meet Sr-89 analytical sensitivity for drinking water - Detail 6.c(3)) were identified - in two areas. Region I Form 12 gggZ7f (Rev. April 77) _. _ '7908230M[ _ _ - ~ _. . . . . . . . . . . . - . . . . . . . . . - - - - . . . . . . . . . . . . . . . . . . . . . . , , . .
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Metrocolitan Edison Ccmoany - TMINS [5 ' -
- J. P. O'Hanlon, Unit 1 Superintendent
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- R. W. Dubiel, Supervisor of Radiation Protection and Chemistry
[ J. G. Reed, Unit 1 Chemistry Supervisor [ R. R. Harper, I&C Supervisor . E. G. Lawrence, Unit 1 I&C Foreman D. E. Weaver, Unit 2 I&C Foreman ~ J. A. Brummer, Unit 2 I&C Engineer ~ ' D. E. Barry, Unit 2 Technical Analyst E. C. Fuhrer, Unit 1 Engineer II/ Nuclear H. B. Shipman, Unit 1 Operations Engineer R. S. Harbin, Unit 1 Administrative Assistant L. J. Landry, Health Physics Engineer Metrocolitan Edison Comoany - Corcorate (Readino)
- T. A. Jenckes, Supervisor - Radiation Safety and Environmental
Engineering (RS&EE) M. R. Buring, Senior Technical Analyst - RS&EE
- J. E. Mudge, Engineer III - RS&EE
B. J. Beck, Engineering Assistant - RS&iE J. Thompson, Licensing Engineer Ic chyological Associates, Inc. (IA) B. Lathrop, Biologist R. Ritota, Biologist
- denotes those present at the exit interview at TMINS on April 19,
1978.
- denotes those present at the exit interview at Met Ed Corporate
Offices on April 20, 1978. 2. Licensee Action on Previous Insoection Findings (Closed) Deficiency (289/77-04-02): Failure to meet Sr-89 and Sr- 90 analytical sensitivities for sediments. The inspector determined through discussions with the licensee, review of the analytical .. _ .. . . . - .. .g. .. e... .m... .a.m.**=" ' " ' * * -
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.. M 3 results, and review of the licensee's records of corrective and t. ... preventive actions, that the licensee had met the analytical sensi- tivity requirements for this medium during 1977, and that the l- ,_ 1icensee's corrective / preventive actions were implemented as stated in the letter dated April 29, 1977 to the Region I Office. The D.. inspector had no further questions with regard to this item. (Closed) Unresolved Item (289/77-04-04): Adequacy of sensitivity .. [p of analyses for Sr-89 and Sr-g0 in milk, fish, and precipitation. The inspector determined through discussions with the licensee, revie'. of the analy tical records since the beginning of 1977, and the ceview of the licensee's documentation of followup on this item, that (a) the licensee had met the analytical sensitivity requirements for these media since the beginning of 1977, and the licensee had taken appropriate timely action in terms of procedure modification, resampling and reanalysis, as necessary, in those instances in 1976 and 1977 when the sensitivity requirements were not initially achieved. The inspector had no further questions in this area at this time. (Closed) Unresolved Item (289/77-04-05): Discrepancy between indi- cator and backgrcund air particulate gross beta to gama ratios. The inspector ruiewed the licensee's analytical records subsequent to the 1975 data in question and the licensee's review of this data and discussed this item with the licensee. The higher (ten to 100 times greater) background air particulate gama levels over the indicator station levels during 1975 without a corresponding gross beta increasa, were attributed to the much higher Be-7 (non-reactor produced gama-emitting nuclide) reported during this time period at the background stations. The cause of these higher levels at the background stations has not been definitely established. However, since Be-7 can be linked with heavier particulate loading, this may be one cause.~ The 1976 .nd 1977 air particulate data still indicates higher background than indicator station Se-7 levels, although the difference is not nearly as pronounced. The . inspector had no further . questions in this area at this time. (Closed) Open Iter .0/78-08- 01): Procedure modifications for aT moni tori ng. The ..ector determined through a review of Procedure 2104-3.8, Mechanical Draft Cooling Tower Operation, review of - installed instrumentation and. discussions with the l'censee, that - (1) the above procedure had been modified to assure :ommunication/ ccordination between Unit 1 and Unit 2 regarding th.:rmal effluent ^ - limitations, and (2) the necessary thermal monitoring instrumenta- ._.. tion had been installed and is operable, to allow the monitoring of .w. - compliance with respect .to thermal effluents. 'The inspector had no - further questions. - - - - e-- - ' - - _ _ _ _ . - , , g,- - - ~ ~~ .j3 } h ~ ^ ~ ' ~
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, - _ .. 4 - ' (Oper/ Deficiency (289/77-04-03): Failure to meet Sr-89 ana!ytical sensitivities for drinking water. The inspector's , _ ruiew of the licensee's analytical records and environmental _ radiological report for 1977 indicated that the required anal 3tical sensitivites for Sr-89 in drinking water were not a acnieved for the Second, Third, and Fourth Quarters of 1977. . The inspector stated that this item has recurred since the last inspection. (289/78-08-04) (See Detail 6.c(3)) 3. General i- On February 8, 1978, Three Mile Island Nuclear Station - Unit 2 was L issued an operating license, DPR-73. Consequently, as of that date the requirements for the environmental monitoring programs at TMINS are contained in the following Environmental Technical Specifications (ETS) documents: Unit 1 - Appendix B, through Amendment 38, of Operating Licr .se DPR-50 Unit 2 - Appendix B, through Amendment 6, of Operating License DPR-73 f Prior tc February 8,1978, the environmental monitoring require- ments on TMINS - Unit 2 were contained in Construction Permit CPPR- c6. 4 Manacement Centrols . a. Chances The inspector determined through discussions wi'.h the licensee, review of the licensee's organization responsible for managing the environmental programs, and review of applicable procedures, that essentially no changes had been made in the follcwing areas since the last environmental inspection: (1) Assignment of responsibilities and authorities; (2) Provisions for audits and inspections of environmental activities; (3) Provisions for identifying, documenting and reporting, - correcting and following up on program inadequacies and inspection / audit cesults; and (4) Review of program results.
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==ammwnux - . - - - . - . L P117 Brie llg6 i The changes that had occurred had been primarily in docu- ' . . menting the assignment of the "esponsibilities and authori- ties, as well as, the establishment of a documented, specific program to assure the environmental programs are reviewed and >= audited at a specified frequency, and that identified items 'd are resolved. ==": - 't The inspector detennined that Porter-Gert: Consultants con- E tinue to provide radiological environmental data evaluation ' services for Metropolitan Edison Company (Met Ed). The inspec- - tor also noted that Teledyne Isotopes, Inc. had been contracted ~ as the prime laboratory for environmental radioanalytical services since October 1, 1977. Radiation Management Corpora- tion (RMC) provides. quality control radioanalyses en split and duplicate samples. . The inspector determined that the above changes resulted in management controls which are as good as or better than observed during the previous inspection (50-289/77-04). b. Licensee Audits /Insoections The inspector determined through discussions with the licensee that one audit had been conducted in the environmental area since the previous inspection. The inspector's review of the audit recort indicated that the area covered was limited to radiological environmental sample collection and media prepar- ation for transport to the analytical laboratory. The inspector determined that any identified areas needing corrective action were satisfactorily resolved in a timely manner. The inspector noted that one licensee inspection had been per- formed relative to control of erosion along transmission right-of-ways. The completed inspection fincings were not yet available at the time of the inspection. (The inspector noted that the bulk of the biological / ecological activities to be inspected by the licensee had just begun in accordance with the ETS -Unit 2.) The inspector determined that a complete Met Ed QA audit had ... not been performed on the environmental programs during 1977 or 1978 to date. The inspector. noted that such an audit was required at least every two years. The inspector had no further questions in this area at .this time. . -
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- __ ~ ( _ ( . . ._ - . - . - . . . - 6 - . 5. Licensee Procram for Ouality Control of Analytical Measurements a. Radiolooical . . . . The inspector determined through discussions with the licen- see, review of the consultant's reports of data evaluation, E and the review of the results of.the quality control program since January 1977, that the program had provisions for the: l (1) Assignment of responsibility to manage and conduct the program; (2) Type and minimum number of quality checks; (3) Acceptance criteria for measurement results; and (4) Followup on identified program inadequacies. The inspector determined that the radiological environmental quality check program was operated in accordance with a docu- mented procedure; that solit and duplicate samples were analyzed by the primary contractor and by a second laboratory routinely; results were compared and evaluated by a consultant; and were reported to Met Ed. Discrepancies in measurements of gross beta activities, tritium, and external radiation are being pursued. b. Radiolooical/Ecolooical With respect to the biological / ecological programs, the inspector verified the provisions for quality control in regard to: assignment of responsible personnel for conducting / managing this program; inspection requirements; mechanisms for reporting identified inadequacies to management and for initiating ' necessary corrective actions; and the followuo on these items. Detailed types and frequencies of quality checks have not been fully developed at this time for all areas because of the diverse nature of the monitoring programs. The degree and type of quality checks needed are still being evaluated. The inspector had no further questions in this area at this time. . 4 m i L - . . . . . . -_ _ . . . t
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, .. E t _ y. . 7 e - fr . 6. Imolementation of the Environmental Monitorino Procram - Radiolacical a. Direct Observation .._.. The inspector examined selected air sampling, water sampling, , and TLD stations. The inspector determined that the examined stations were located as required by the Units 1 and 2 ETS and that the air sampling units were operating at the time of the
inspection. , b. Review of Recorts . (1) Annual Recort The inspector reviewed the licensee's annual radiological environmental monitoring report for the period January 1 through December 31, 1977. The inspector oetennined that the report contained the recuired information relative to samoling locations, media, frequencies, analyses and evaluations, and comparisons with'the preoperational data as controls, as appropriate. (2) Nonroutine Recorts The inspector reviewed the environmental aspects of the inadvertent release of gaseous radioactivity as a result of a seal water line break on October 23, 1977, and as reported to the NRC as Licensee Event Report (LER) 289/77-25/3L in a letter dated November 18, 1977. The inspector's review of the results of the environmental monitoring program for this time period indicated that no detectable increases in radiation / radioactivity levels in the environs were attributable to the TMINS-Unit I release. The inspector had no further questions in -egard to this time. The inspector also reviewed the circumstances and licen- see's evaluations relative to LER 289/77-32/4T, submitted to the NRC by a letter dated December 30, 1977. concern- ing the reported Zn-95, Ru-103, Cs-13d, and Ce-141 levels in sediments at a downstream indicator station which were . . . = .. . . . . . . . . . - . . . - - .
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- . . . . _ .. ::~ 8 . . . - . . i!! in excess of 10 times that of the control station. The -inspector's " review of the 1977 sediment analytical data and comparison - with the 1976 data indicated that a similar situation had occurred in 1976 following the Chinese weapons test in Fall of . 1976. The similarity of thesa results, along with the absence E of a significant increase in TMINS liquid effluent releases, indicate that the reported asults are attributable, at least F....... . - in part, to the 1977 Chinese weapons testing debris. The t inspector had no further questions in this area at this time. j.L c. Other Records i (1) Thermoluminescent Dosimeters (TLDs) /) (J..h' ? .Q The inspectcr reviewed the licensee's records of TLD [ environmental monitoring since the beginning of January % 1977, and determined that the measurements were made at the specifind frequencies and locations with the follow- ing exception. At location 14S2, Shelly Island, none of the quarterly TLD readings were available for 1977. The inspector's review of the TLD placement and collection records indicated that the TLD at this location had been stolen during the First, Second, and Third Quarters of 1977 (they were replaced at the beginning of each Quarter) and Shelly Island was not accessible at the end of the Fourth Quarter 1977; due to hazardous river conditions. This item was discussed with the licensee, who said that the TLDs were hidden at this location to try to prevent the theft; but this too was unsuccessful. The licensee further stated that a proposed ETS change was being pre- pared for the Unit 1 ETS to convert the radiological monitoring program for Unit I to be identical to the Unit 2 program. (The latter program has eliminated the 1452 TLD location.) The inspector had no further ques- tions with regard to the above item at this time, however, this item is considered unresolved until a more secure - placement location has been selected or the station is . - - eliminated via an ETS change. .(289/78-08-07) _ . _ . . , , . , The inspector noted that *.he TLD measurements during the Fourth Quarter 1977 were consistently higher at all .. locations ti.an during the first three quarters. The . _ _ . . - ,_ _~ _
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9 k ! inspector also noted that Teledyne Isotopes (TI) became the prime radiological contractor at this time, replacing Radiation Management Corporation (RMC). The above data along with the licensee's quality control data indicate'. ,.' consistently higher (by approximately 60%) results at the same locations and time periods as measured by TI than , RMC. The licensee stated that TI is currently evaluating TLD performance to determine whether the TI system can - meet the recorrmendation:, of NRC Regulatory Guide 4.13 and ANSI N-545-1975. The inspector noted that the Unit 2 ETS require that the TLD performance criteria be that of Reg. Guide 4.13 or comparable. The inspector stated that until the perforinance evaluation program has been com- pleted and is subsecuently reviewed by the NRC, the TLD performance is considered unresolved. (289/78-08-01; 320/78-16-01) (2) Air Monitorina - The inspector reviewed the results of the environmental air monitoring program since January 1977 and determined that weekly continuous air particulate and airborne iodine samples were collected and analyzed in acccrdance with the requirements, with the following excepticns. No samples were collected during the following time intervals at the following stations: Time Interval Station Medium 5/11 - 6/1/77 TM-AP-lCl Air Particulates 5/11 - 6/8/ o iM-AI-lS2 Air Icdines 5/18 - 6/8/77 TM-AP-IS2 Air Particulates 6/ 08 - 6/22/77 TM-AP-12B1 Air Particulates 8/17 - 9/7/77 TM-AP-5Ai Air Particulates 8/17 - 9/7/77 TM-AI-5Al Air Iccines .. The inspector stated that the failure to collect and nalyze these media on a weekly basis was in noncompli- E= ance with the reouirements of Section 4.4.a of the Unit 1 ETS. The inspector noted that while the licensee had obtained a spare sampling unit since the last inspection - (50-289/77-Ga),-this item has recurred. (289/78-08-02) ' _ - ~_
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( ' I _ . - a . =r s - 10 _~ . . . . _.. Discussions with the licensee indicated that at the present time, air sampling units are on a limited pre- .._ ventive maintenance schedule. When a sampler fails, 17 plant personnel either replace or repair the failed unit. The timeliness of this action is dependent, howeser, on u. _ plant operational status at the time of failure. The F licensee stated that at the present time the dry gas
meters employed with the air samplers are not routinely calibrated. The licensee stated that the preventive
maintenance program for tne air sampling systems and the L calibration of the dry gas meters would be re-evaluated. The inspector stated that pending completion of these . evaluations, this item is considered unresolved. (289/ 78-08-03; 320/78-16-02) (3) Surface Water The inspector reviewed the licensee's records for surface water sampling and analysis since January 1977 and deter- mi'ned that each of the samples were collected as required and analyzed for the required parameters. The review of the analyses indicated that the analytical sensitivities had been met with the following exception. Surface water sampled frcm the City of Columbia water intake during the last three quarters of 1977, was not analyzed with suffi- cient sensitivity to meet the Se.; ion 4.a.a, Unit 1 ETS minimum sensitivity of 1 X 10-9 uCi/ml for Sr-89. The inspector stated that this was in noncompliance with the requirements and was a recurrent item. (259/78-08-04) The inspector determined that the licensee had taken some corrective action since the last inspection as stated in the letter to the NRC, dated April 29, 1977, in that some modifications were made in aliquot size analyzed and count times. The licensee, however, had not, as of the time of the inspection, submitted a charge request for Unit 1 ETS in this regard as stated in that letter. The licensee stated that this delay was due, in part, to the delay in obtaining the Unit 2 Operating License and ETS. (The Unit 2 ETS does not requira Sr-89 or Sr-90 analyses of surface water.) .:- ,m.. 7228/,ib l f. - . . . . . - . . . . . J.. . . . . . . . - _.
- ! j [ - II 11 . [ (4) Other Media .. The inspector reviewed the results of the other media samoled and analyzed since January 1977, including milk, river water, soil, sediment, fish, and vegetation. The ,.. inspector determined that these media had been sampled - . and analyzed in accordance with the ETS requirements. d. Meteoroloaical Monitorina The inspector examined the meteorological instrumentation in the Control Rooms of bcth Unit 1 and Unit 2 and determined that all appeared to be functioning properly at the time of inspec- tion. The inspector further determined, through discussions with licensee personnel and review of selected calibration records and procedures, that the meteorological instrumentati.on had been calibrated, was checked routinely in accordance with the requirements, and is on a routine calibration schedule. The inspector had no further questions in this area. 7. Imolementation of the Environmental Monitorinc Procram - Bioloaical/Ecoloaical a. Direct Observations The inspector reviewed selected portions of the Unit 2 biological / ecological monitoring programs through discursions with licensee and contractor personnel, selected reviews of sampling and analytical prccedures, and diract observations of the following program tasks: ichthyop1.ankton entrainment sampling at the Unit 1 intake; larvae fish sampling in Lake Frederick in the vicinity of TMINS, including the measurement of selected air and water envircraental parameters and the preservation of samples; and the sampling of bentnic organisms (macroinverte- brates) in the vicinity of TMINS. b. Recorts and Records The inspector reviewed a draft report of the 1977 TMINS bio- logical /ece ogical study results and discussed selected pro- cedures, analytical results and evaluations with the licensee. Areas reviewed included the fish creel census; impincement moni- toring; fish population studies in Lake Frederick; the thermal plume studies; the aerial remote sensing program; and the water quality measurements. - 6 . ~" ,_ . . . . . . - . .
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. 3~= :W- = * - :4%-~- --L - .. . . . _ _ . . , 12 ~ s _ - A c. Other Areas The inspector ex& mined the Program Description Document and Implementing procedures relative to the following programs / . program changes required by Condition 2.E(2) of Facility F... Operating License DPR-73, for TMINS Unit 2: (1) fish creel ' census; (2) comparability study of towed nets vs pumps for sampling entrained ichthyoplankton; (3) the true and false color, low-altitude aerial photography and associated ground , truth measurements; and (4) notification and action require- ments as a result of exceeding Limitino Conditions of, Ooerations or Other Permits. The insoector determined that the above Program Description Document and procedures had been developed and were implemented or ready for implementation. The licensee stated that the changes made to the Program Description Docu- ment would be reported to the NRC within the next two weeks after the inspection. The inspector noted that these addi- tions had been made prior to the May 7,1978 License Condition deadline. . The inspector stated that he had no further questions a the above areas at this time. 8. Nonradioactive Effluent Release Rates and Limits a. Thermal The inspector reviewed selected thermal discharge records for TMINS Unit i since January 1977 and the site thermal discharge records since Marcn 1978. The inspector determined that for those time intervals examined, the thermal discharges were in accordance with the ETS requirements with the exceotion of those instances reported to the NRC in the following letters: Letter Date Reoort No. Event 3/22/77 289/77-02/4T aT exceeding 12 F above inlet - ETS 2.1.b(1) - 3/31/77 289/77-05/4T Discharge temp change exceeding _ 2 F/hr - ETS 2.1.b(2) - 8/12/77 289/ 77-20-4T AT exceeding 3 F below inlet - . - ~ ~ ETS 2.1.a(1) - . -
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' ( . - - t 13 . . . . . . , The inspector reviewed the above events through discussions e with the licensee and review of the licensee's reported ~Z , corrective actions and procedure modifications and determined F' that corrective actions had been taken, as reported. The ~"~ inspector stated that he had no further questions regarding the above items. h. .. The inspector examined the installed Unit 1, Unit 2 and site thermai monitoring systems, through discussions with the , licensee, review of installed instrumentation, review of . pertinent d awings and records, and determined that the site AT was measured from the Unit 1 intake structure wing-wall position to the radiation monitoring pit position, dvwnstream of the confluence of the Unit 1 and Unit 2 mechanical draft cooling tower discharges. The inspector determined tha. at the present time a single inlet sensor provides the thermal information to both units, as well as, to the backuo recorders at the mechanical draft cooling towers. The licensee stated that a second sensor would be installed to provide a redundancy for inlet temperature measurements. The inspector discussed with the licensee the provisions for obtaining thermal informa- tion in the event of a failure of the primary cooling water system thermal monitoring system. The licensee stated that current procedures incluce provisions to contact the other control room in the event of recorder problems, to utilize the backup recorders at the mechanical draft cooling towers, and as a final resort and in the event of sensor failure, to physically measure the temperatures with a calibrated thermometer. The inspector discussed the use of a bucket thermcmeter for such applications. The licensee stated that a bucket thermometer is being considered for this area. The inspector had no further cuestions in the above area at this time. The inspector attempted to review the calibration of the thermal monitoring systems for each unit. The inspector reviewed the records of the " loop" calibration for Unit 1, exclusive of the Resistance Temperature Deta tor (RTD) sensors. The licensee stated that the Unit 1 ETS did not soecifically require calibrations of this system. The inspector determined that the Unit 2 ETS did recuire such calibrations, such that, the sensor and sensor system meet soecified accuracy and sensitivity criteria. The licensee was unable to produce these calibration records at the time of the inspection. ._ r . ); _ ::. : - - . . . -. ~: -
.- _ .. 14 The inspector stated that without documentation of the cali- brations, he was unable to determine whether the thermal - monitoring system meets the required accuracy / sensitivity .._. requirements. The inspector stated that until the above calibration records are available for inspection and are reviewed at a subsequent inspection, this item is considered
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unresolved. (320/78-16-03) (See Detail 8.c for a related . area.) b. Chemical Discharces . The inspector reviewed selected neutralizer regenerant waste discharges for Units 1 and 2 since January 1977, the chemical analytical procedures, and surveillance checks of the online pH cell (Unit 2). The inspector determined, for the records examined, the releases were within the specified ETS require- ments with the following exception, reported to the NRC as LER 289/77-13/47 in a letter dated June 7, 1977. The inspector reviewed the circumstances and potential environmental conse- quences as a result of this reported release of suspended solids in excess of the ETS limits. The inspector stated he had no further questions in regard to this item. The inspector also examined the industrial waste treatment system (IWTS), discussed its operation with licensee recre- sentatives and reviewed selected records of effluent releases. The inspector also reviewed the circumstances and applicable corrective actions with respect to the Nonccmpliance Notifica- tions reported for the IWTS, as follows: Letter Date Recort No. Event 3/13/73 78-01 discharge with pH and total suspended solids (TSS) outside limits 3/8/78 , 78-02 discharge of untreated waste 3/27/78 78-03 discharge of oil and grease in excess of limits 3/31/78 78-04 discharge of iron in excess of limits 4/13/78 78-05 discharge of oil and grease in excess of limits 4/17/78 78-06 discharge of iron and TSS in excess of limits 4/19/78 78-07 discharge of oil and grease in excess of limits . 't W S O hh . _. ._ -- .-. ! .._ - .. . . . _
. . - ' ... . . . . . . . . 15 _ . . , .. ~ The licensee stated that operational problems had developed with the IWTS in terms of treatment polymer addition and in the filteration system. The present filters had clogged cad --- the licensee was working with the vendor to correct these problems. The licensee stated tha't the IWTS should be fully y~. . operable within two months. The inspector stated that he had - no additional questions with respect to the above specific events at this time. . . The inspector attempted to verify compliance with the dis- F charge requirements and monitoring requirements through a
review of the records. The inspector determined that because of the present TMINS racordkeeping system, it was very difficult ~ to locate the required records for flows, analytical results, instrument checks / calibrations to verify compliance. The . inspector was able to verify compliance with the exception of the above discussed Noncompliance Notifications, for March and April 1978. c. Records The inspector discussed with the licensee the present TMINS recordkeeping system, in that, required records were difficult to find or not filed such that all the needed data was avail- able in the same area (Detail 8.b), or the data couldn't be located at all (Detail 8.a). The licensee stated that this had oeen recognized as a less than ideal situation and the records system would be reevaluated. d. Other Areas The inspector toured the TMINS site and looked at the major discharge outfall areas. The inspector noted that the chemi- cal treatment ponds were presently full of licuid from the preoperational flushing from Unit 2. The licensee stated that within the next week, these ponds would be treated to reduce the phosphate loading and then they would be drained through the IWTS and discharged. The inspector examineo the area of the east dike in which the rock rip-rap had moved down the slope of the dike, as reported by the licensee as LER 320/78-15/99T in a letter dated February 21, 1978. The inspector noted that this area had been repaired and he observed no other areas in need of such repair at the time of the inspection. =
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. . . _ . . . _ p 16 ' . . . . . p The inspector observed that the yard drains on the east side ~~ of the TMINS drained to two small holding basins. The northern most basin discharged to the second basin which discharged through the east dike to the Susquehanna River via an adjustable wei r. At the time of the inspection, both of the above basins f were essentially filled with silt and sediment so as to severely limit the residence time of any runoff water entering the basins, and hence, the settling capabilities of the basins. The inspector noted that the drainage ditches leading to these basins showed signs of significant erosion. The inspector's . discussions with the licensee revealed that the licensee had no discharge requirements at the present time for this outfall, ~ although discussions along this line are being conducted with Pa DER (Pennsylvania Department of Er.vironmental Resources). The licensee stated that the settling basins wi1~. be cleaned to restore settling capacity and they wil1 be inspected and maintained on a routine basis. The licensee further stated - that now that Unit 2 is essentially completed, final grading will be done and vegetative covers will be established in these areas to minimize erosion and sediment runoff. The inspector stated that until the settling basins are cleaned and inspected / maintained on a routine schedule, this item is considered unresolved. (289/78-08-05; 320/78 16-04) 9. Other Inscection Areas During the site tour the inspector observed a roped-off area, posted as a " Radiation Area" in the yard, adjacent to the Unit 1 Borated Water Storage Tank (SWST). Discuosions with the licensee and review of the radiation survey recards for this area, revealed that radiation levels up to 10 mR/hr had existed in the yard at the fence and up to 5 mR/hr had existed at the boundary of the area defined by the rope and radiation signs. The licensee stated that the radiation levels were a result of the return of the barated water to the BWST after refueling Unit 1 and they h6; commenced several days before the inspector's observations on April 18, 1978. The licensee stated that surveys had been performed, the area was roped off, and that security personnel patrol this area at least twice on each four hour tour. . i _ _ -._ __ _ M i~. . . _ . . . . . - - _ _ _ _ - _ _ . . . _ . . . . . ..- "~" . . . .
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' 17 . .. p. .._.. - - . , _ The inspector discussed the regulations or 10 CFR 20.105 regarding permissible radiation levels in unrestricted areas, and the defini- tion of an " unrestricted" area in terms of controlling access for ~ purposes of radiation protection. The inspector stated that the
rope with " Radiation Area" signs. and the security guard tours did not restrict access to this arsa for purposes of radiation protection i so as to meet the above definition. The inspector further stated - that having radiation levels such that an individual could receive in excess of two mR in any one hour, if he were continuously present in this unrestricted area, was in noncompliance with 10 CFR 20.105(b)(1). ~~ (289/78-08-06) 10. Unresolved Items Unresolved items are matters about which more information is required ~ in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during this inspection are described in Details 6.c(1), 6.c(2), 8.a, and 8.d. 11. Manacement Interviews On April 19, 1978, following the TMINS onsite portion of the inspec- tion, the inspector met with the individuals denoted in Paragraph 1. On April 20,1978, the inspector met with the licensee representative; denoted in _ Paragraph 1 (**) to- discuss the findings of the biological / ecological portion of the inspection. On May 5, 1978, the inspector contacted Mr. O'Hanlon, Unit 1 Superintendent and Mr. Dubiel, Supervisor of Radiation Protection and Chemistry by telephone. During these meetings / discussions, the purpose and scope of the inspection were summarized and the inspection findings. including each item of noncompliance 6nd unresolved item were discussed. With regard to Unresol',cd Item (289/78-08-05; 320/78-16-04) - a. sedimentation basin maintenance and inspection, the licensee stated that as of May 5,1978, a purchase recuest had been made to have the basins cleaned within the next couple of weeks. . + . . e. ,- . . _ . . ' m. . - ~ . . - . _ - . - - . ~ . .
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p .. ffE_ b. The inspector also discussed the problems encountered in -- trying to review records of calibrations, surveillance tests, f.?% analytical results, etc. , when licensee personnel had difficulty .g_.-. in detemining where the specific records were located. The licensee stated that the recordkeeping system at TMINS would - - - - be reviewed. ~~~~ c. The licensee acknowledged each' item of noncompliance. I . . . . .g . h . . . . . . _ _ . . . _ . . - . 7 - . 1= --- - -- . . - . ..-.. - }}