ML19256D456
| ML19256D456 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/10/1974 |
| From: | Bores R, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D440 | List: |
| References | |
| 50-289-74-34, NUDOCS 7910180791 | |
| Download: ML19256D456 (13) | |
See also: IR 05000289/1974034
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U.S. AT0!!IC ENERGY CC'::!ISSION
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IIIRECTORATE OF RECUIATORY OPERATIONS
.
REGION I
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RO Inspection Report No:
so_2Ao/74_14
Docket No:
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Licensce:
Metropolitan Edison Ceepany
License No: DPR-50
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P. O. Box 541
Priority:
Reading, Pennsylvania 19603
_ Category:
C
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Location:
Three Mile Island Nuclear Plant - Unit 2
,
Middletown, Pennsylvania
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Typ'e of Licensee:
PWR, 819 MWe
(B&W)'
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Type of Inspection:
Soecial, Unannounced (Environmental Monitoring)
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'h:tes of Inspection:
November 20 and 21, 1974
s
Dates of Previous Inspection: October 24 and 25, 1974
Reporting Inspector.:
@d. b o. % / L
/2-to.'f4
h R. J. Bores,/ adiation S ecialist
Date
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2
Accompanying Inspectors:
None
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Other Acccmpanying Personnel:
None
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'teviewed By:
J b "J0.gan_m.-
ps.go dy
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atuar, acawr r nvironmental spectatist
Date
7910180
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SUMMARY OF FINDINGS
Enforcement Action (Environmental Monitorin2)
1.
I-131 activity in milk samples was not, in all instances, determined
within the specified time or within the specified sensitivity re-
quired by Section 4.4.C of Appendix B, Technical Specifications.
(Details, Paragraph 4.b;
2.
Fish impinged on the traveling screens were not weighed in
accordance with the requirements specified by Section 4.1.1.A of
Appendix B, Technical Specifications.
(Details, Paragraph 6)
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3.
Negative temperature differential between the river water and
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plant water discharge in excess of 3 F on July 11, 15, 17 and 19,
1974 in violation of Section 2.la(1) of Appendix B, Technical
Specifications.
(See Item 1, Unusual Occurrences Section)
_
4.
Excessive free chlorine concentration at the plant river discharge
on Septe=ber 26, 1974 in violation of Section 2.2.la of Appendix B,
Technical Specifications.
(See Item 2, Unusual Occurrences Section)
5.
pH of Waste Neutralizing Tank discharges were in excess of limits
6.0 to 9.0 on August 31, September 15, 20 and 23, 1974 in violation
of Section 2.2.3 of Appendix B, Technical Specifications.
(See
Item 3, Unusual Occurrences Section)
Licensee Action on Previousiv Identified Enforce =ent Action (Environ-
mental Monitorinz)
1.
The licensee's corrective actions were submitted by letter to the
Director, RO:I dated April 11, 1974 in response to violations
identified in the RO:I letter dated March 29, 1974 and RO Inspec-
tion Report Nos. 50-289/74-07 and 50-320/74-02.
The licensee's
response was clarified in the telephone conversation on April 16,
1974 and these understandings were verified in the RO:I letter
dated April 23, 1974.
The licensee's corrective actions relative
to Items 2 through 6 of the referenced correspondence were reviewed
during this inspection.
(Items 1.a and 1.b referenced in the
correspondence were closed in previous inspection reports.)
These items are closed.
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2.
The inspector also reviewed the corrective actions relative to
Environmental Incident Nos. 74-1 through 74-7, referenced in the
licensee's letter to RO:I dated July 18, 1974.
These items are
closed.
Design Changes
None
.
Unusual Occurrences
'
1.
Negative te=perature differential between the river water and plant
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river discharge in excess of 3 F.
This occurrence, Environ = ental
Incident No. 74-8, was reported in accordance with the Technical
Specifications in the licensee's letter to the Director, RO:I
dated July 24, 1974. The circu= stances and licensee's corrective
actions were reviewed during this inspection and found to be con-
sistent with those described in the licensee's report.
This item
is considered closed.
(Details, Paragraph 8)
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2.
Excessive free chlorine concentrations at the plant river water
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discharge.
This occurrence was reported as Environ = ental Incident
~,
No. 74-9 in the licensee's letter to the Director, RO:I, dated
s_,
,
October 3, 1974. The circumstances and licensee's corrective
actions were reviewed during this inspection and found to be con-
sistent with those described in the licensee's report.
This item
is considered closed.
(Details, Paragraph 9)
3.
pH of Waste Neutralizing Tank discharges in excess of the limits
6.0 to 9.0.
This occurrence was reported as Environ = ental Incident
No. 74-10 in the licensee's letter to the Director, RO:I dated
October 4, 1974. The circumstances and licensee's corrective actions
'
were reviewed during this inspection and found to be consistent with
those described in the licensee's report.
This item is considered
closed.
(Details, Paragraph 10)
4.
Measured air particulate filter activity in excess of four ti=es
the control station value.
This occurrence was reported as Non-
routine 30-Day Environ = ental Report 74-01 in the licensee's letter
to the Director, RO:I, dated October 4, 1974.
The circumstances
and the licensee's evaluation of the atypical activity level were
reviewed during this inspection.
This item is considered closed.
0 Details, Paragraph 4.a)
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Other Significant Findings
A.
Current Findings
None
B.
Status of Previousiv Reported Unresolved Items (Environ = ental
Mcnitoring)
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None identified
Management Inte rview
On November 21 1974, following the inspection, a meeting was held in
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the conference room at Three Mile Island Nuclear Power Station.
The
following individuals were in attendance:
Mr. R. J. Bores, Radiation Specialist, USAEC, RO:I
Mr. J. G. Herbein, Station Superintendent, Met-Ed (TMI)
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Mr. J. E. Romanski, Engineer-Nuclear, Met-Ed (TMI)
Mr. J. P. O'Hanlon, Nuclear Engineer, Met-Ed (TMI)
Mr. M. R. Buring, Radiation Safety & Environ = ental Engineer, Met-Ed (Reading)
_,
Ms. A. D. Taylor, Engineering Assistant, Met-Ed (Reading)
u
During this meeting and in the subsequent telephone conversation between
Mr. Bores and Mr. Herbein on Nove=ber 25, 1974, the following items were
discussed:
A.
General
The inspector stated that this was a special environmental inspection
aimed at reviewing the previously identified violations and the
reported Environ = ental Incidents since the last environ = ental inspec-
tion.
The inspector stated that the licensee's corrective actions as
described in letters frco Met-Ed to the Director of R0:I, dated
April 11, 1974 and July 18, 1974 were verified and these matters are
now considered closed.
B.
Unusual Ocn rences
The inspector stated that the circumstances and the licensee's
corrective actions relative to the violations of the Appendix B,
Technical Specifications, described as Environ = ental Incident
Nos. 74-8, 74-9 and 74-10 relating to water te=perature differential,
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free chlorine concentrations and pH of discharges, respectively,
were also reviewed.
(Details, Paragraphs 8, 9 and 10)
Similarily, the circumstances pertaining to the Non-Routine 30-Day
Environmental Report 74-01, relating to the " hot particle" on a
particulate filter was reviewed.
The inspector stated that he had
no further questions in the matter.
(Details, Paragraph 4.a)
C.
I-131 in Milk
The inspector stated that the Appendix B, Technical Specifications
required that milk be analyzed uonthly for I 131 and quarterly for
Sr-89 and 90 from the cows pastured on the four pastures within a
5-mile radius of the plant with the highest anticipated radioactivity
concentrations. The require =ent also specifies that the I-131 be
analyzed within eight days of sampling and that sensitivity of
analysis be such that 0.5 picocuries of I-131/ liter of milk at the
time of sampling can be detected within an overall error of analyses
of 225%.
The inspector stated that on several occasions the analyses
had not cet the ebser specifications in violation of the require =ents.
On these occasions the milk was not analyzed within eight days of
sampling, the 0.5 picocurie / liter sensitivity was not met, or the
overall error of analysis exceeded 225%.
The inspector noted that
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in most instances the requirements had been met.
The inspector
discussed with the licensee severa] =ethods of preventing recur-
rences of this type.
(Details, Paragraph 4.b)
D.
Fish Impingement
The inspector stated that Section 4.1.1.A of the Appendix B.
Technical Specifications require that fish icpinged during the
sampling periods ce counted, identified, weighted, and exa=ined
for condition and reproductive status. The inspector stated the
Technical Specifications require individual fish weights be ob-
tained whereas, the total weight of all fish of each species or
grouping was obtained in violation of this require =ent.
(Details ,
Paragraph 6)
E.
Sampling, Analytical Technicues and Ouality Control
The inspector discussed a number of ite=s relating to environmental
sampling, analytical techniques and quality control, including:
1.
The use of hcl in water samples to prevent selective ions
from plating out on the container walls.
.
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2.
The need for the ~lcensee to be familiar with the analytical
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procedures, capat(11 ties and limitations of the contractors
to assure that representative samples are analyzed and the
results are valid.
3.
The use of low level radioactive " spiked" samples and split
or duplicate samples to evaluate the contractor's performance
of radiological analyses of environ = ental samples.
The licensee stated that these areas would be evaluated and
appropriate action would be taken.
(Details, Paragraph 5)
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DETAILS
1.
Persons Contacted
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Mr. J. G. Herbein, Station Superintendent, Met-Ed (TMI)
Mr. J. E. Romanski, Engineer-Nuclear, Met-Ed (TMI)
Mr. J. P. O'Hanlon, Nuclear Engineer, Met-Ed (TMI)
Mr. M. R. Buring, Radiation Safety & Environmental Engineers, Met-Ed
,
(Reading)
Ms. A. D. Taylor, Engineering Assistant, Met-Ed (Reading)
Mr. K. E. Beale, Radiation Protection Supervisor, Met-Ed (TMI)
Mr. G. Kunder, Engineer-Operations, Met-Ed (TMI)
Mr. J. Hayes, Engineer-Jr., Surveillance, Met-Ed (TMI)
Mr. R. Laughin, Environ = ental Sa=ple Collector, Radiation Manage-
ment Corp. (RMC)
,
Dr. S. Gertz, Porter-Gertz Consultants, Inc.
I
2.
General
.
This was a special inspection to deter =ine the status of previously
identified enforcement items of environmental nature and to review
,
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the circumstances and corrective actions concerning Environ = ental
Incident Nos. 74-8, 74-9 and 74-10
The inspection consisted of a selective examination of environ = ental
sampling stations, representative "wc.:edures, records and reports,
interviews with personnel and observacions by the inspector.
Spe-
,
cifically included in this inspection were the chemical and ther=al
discharge conitoring programs, the fish impingement program and the
radiological sampling program.
3.
Organization and Administration
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Several significant changes have been made in the administration of
the environmental program since the last inspection of this area
(R0 Inspection Keport 50-289/74-07, 50-320/74-02).
All of the
radiological sa=pling is now perfor:ed by contractor personnel
with the exception of several inplant sacples taken by licensee
personnel. The bulk of the environ = ental sa=ples are collected by
Mr. Laughin or his designee and sent to Radiation Monsge=ent Corp.
(RMC), Philadelphia, Pa. for radiological analyses.
In addition,
a number of samples are split and sent to Teledyne Isotopes, Inc.,
Westwood,
N.J., for quality control purposes.
Ichthyological
Associates, Inc. , who perfor= the aquatic studies for Met-Ed,
collects the required fish, aquatic vegetation and sed 1=ent samples
for radiological analyses.
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The licensee stated that the responsibility for overseeing the
environmental conitoring program has been shifted to the Radiation
Protection and Environmental Engineering Section of Met-Ed at their
Reading, Pa. office under the supervision of Mr. T. Jenckes.
The
sampler maintenance and repair responsibilities are funnelled
through the Radiation Protection Supervisor, as does the surveillance
require =ent to assure that all samples were taken and analyzed as
required.
4.
Radioloeical Environ = ental Monitoring
,
a.
Air Monitoring
The inspector exasined several of the air sampling stations and
noted that all were functioning properly at the time of inspec-
tion.
The review of the =aintenance and service records indi-
,
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cated few proble=s until recently when several failed because
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of broken belts.
The licensee stated thrt routine belt replace-
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ment would be added to the periodic maintenance list to prevent
future failures.
The inspector noted that the particulate
filters were subjected to precipitation and were wet on the
day of inspection.
The licensee stated that the effects of
reorienting the filter assembly from its present horizontal
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position to the vertical and drawing the air upward through
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the filters, would be evaluated in preventing precipitation
from hitting the filter.
The inspector reviewed representative air sampling data and
noted that the required analyses were performed.
No I-131
activity was seen above the Mini =um Detectible Concentrations
(MDC), which were typically 0.6 to 1.6X10-14 microcuries/ml
at the end of the sa=pling period.
The inspector also reviewed the licensee's analysis of the Non-
routine 30-Day Environmental Report 74-01 dated October 4, 1974
and submitted to the Director, RO:I in regard to a reported air
particulate gross beta activity 9.6 ti=es that of the control
station.
Based on the licensee's analysis and that of RMC,
including an autoradiograph indicating a single hot-particle
was involved, the inspector concurred with the licensee's
evaluation that the source of the activity was not related to
the TMI Nuclear Station.
This item is considered closed.
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b.
Milk
Section 4.4.C and Table 3 of Appendix B, Technical Specifications
require that milk be sa= pled monthly (when cows are on pasture)
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from those cows on the four pastures with the highest anticipated
radioiodine concentrations within a five mile radius of the
plant.
The milk is to be analyzed for I-131 within eight days
of sampling and with sufficient sensitivity cuch that an I-131
concentration of 0.5 picoeuries/ liter of milk (pCi/1) can be
determined at the time of sampling within an overall error of
e
125% at the one sigma confidence level.
The review of the licensee's data reveeled that the MDC for
I-131 in milk ranged to a lov of 0.037 pC1/1 and in most
instances the sensitivity and overall error of analysis were
within that specified,
i.e., 0.5 pCi/l !25%. However, in
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several instances, the above requirements were not met in that
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a) the samples were not analyzed within eight days of sampling,
b) the MDC was greater than 0.5 pCi/1, or c) the overall error
of analysia was greater than !25% at or above the 0.5pCi/l
level. The inspector stated that in the above instances, the
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requirements of the Technical Specifications were not met.
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The inspector discussed with the licensee several methods of
preventing the recurrence of this type of violation, including
a resampling program within the sa=e ti=e fra=e, to obtain
additional milk samples for analyses to replace samples
presenting analytical difficulties.
.
c.
Other Media
The inspector noted that the thermoluminescent dosimeters
(TLD's) now used in the environ = ental monitoring program were
furnished by RM; and were CaSO :Tm.
In addition, the licensee
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was using the r.berline service with LiF TLD's for continuity
of that nregram while evaluating the RMC system.
Selective
review sf the records revealed no atypical data.
Examinreion of the precipitation collectors showed considerable
improvement over those used at the previous inspection.
Funnel
collectors were used to reduce evaporation so that adequate
samples were collected for each analysis.
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The licensee stated that aquatic vegetation was not found in
the vicinity of the plant discharge nor downstream of that
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point.
In the past water willow had been sampled as aquatic
vegetation, but these samples were no longer taken since water
willow is a terrestial plant that grows along the banks of
the river.
The licensee's records indicated that soil had been sampled
and analyzed to establish some background data even though
soil sampling is not required by the current Technical Speci-
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fications. The licensee stated that approximately 16 2-inch x
4-inch core samples were taken at each sampling station in
0-to 2-inch and 2-to 6-inch depths to determine some depth
profile of radioisotopic distribution.
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Other media sampled and analyzed, as required, included
terrestial (green) vegetation, river water, sediment and fish.
5.
Analytical Procedures and Quality Control
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The licensee stated that periodic samples were sent tc Teledyne
,
Isotopes, Inc., Westwood, N.J. to assure that the analysis performed
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by the primary contractor are reliable.
The review of the records
and discussions with the licensee indicated that these samples
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included: air particulates (collected weekly with a duplicate sampling
system at a, regular sampling station and analyzed for gross beta
activity weekly and quarterly by ga=ma spectral analysis), air
iodine (collected and analyzed one week each quarter), river water,
drinking water, rainwater, milk (analyzed for I-131 and Sr-90), and
sediment.
In addition, the Eberline TLD system was used as a check
on the RMC system.
The inspector discussed with the licensee the requirement that each
contractor have ccmparable analytical sensitivities if the results
of the analysis are of value to assure quality of the work.
In
particular, the MDC for I-131 in milk was approximately 5 to 7 pCi/l
.for the quality control sa=ples, whereas, that of RMC was generally
< 0.5 pCi/1, at approximately the same level as found in the milk
samples.
The inspector discussed the use of " spiked" samples,
psrticularly low-level " spikes", as an alternative method of quality
contr'l for these samples.
The licensee stated that this would
be evaluated and appropriate action would be taken.
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The inacactor also discussed several other areas relating to
samplins or analytical techniques, including:
a.
The use of hcl with NaHS0 in water samples to reduce the
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tendency of selective ions to plate-out onto the walls of the
container prior to analysis of the sample.
b.
The assurance that representative samples of media (especially,
soil, sediment and vegetation) are analyzed.
.
c.
The need to be familiar wit'a techniques and procedures used
by the contractors, instrument backgrounds and efficiencies,
and capabilities or limitatlons of the methods of analysis used.
The licensee stated that these items would be evaluated and approp-
riate action would be taken.
,
.
6.
Fish I=oincement
Paragraph 4.1.1.A of the Appendix B, Technical Specifications
requires that fish impinged on the traveling screens be sa= pled at
semi-monthly intervals and analyzed by counting, weighing, determining
the reproductive status and condition of the organism, and identifying
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to the lowest positive taxon.
The inspector reviewed representative
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records of the impingement study performed for the licensee by
Ichthyological Associates.
The inspector noted that the fish were
counted, identified, measured and the reproductive status and con-
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dition of the organism were noted.
The records indicated that the
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total weight of the fish of each identified taxon was recorded
rather than the individual weight of each fish, as required.
The
inspector stated that this was a violation of the requirements.
7.
Other Studies
.
The inspector examined the results of the required studies performed
to determine number of birds inspected by the natural draft cooling
towers and found the requirements of this study were met.
The towers
appeared to have a very minor influence in causing bird lethality
due to impaction.
The inspector also examined the selected results of the heavy metal
analyses perfor=ed on river water.
No atypical results were noted.
8.
Thermal Discharges
The inspector reviewed the circumstances surrounding the reported
Environ = ental Incident No. 74-08 relating to the negative te=perature
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differential between the river water discharge and plant discharge
water in excess of 3 F on July 11, 15, 17 and 19, 1974 in violation
of Section 2. (a)(1) of Appendix B, Technical Specifications.
The
licensee's investigation indicated that a failed transducer caused
both the control room delta temperature recorder and the alternate
delta temperature recorder in the pump house of the =echanical draft
cooling tower to be inoperative. As a result the licensee was un-
aware of the excessive negative delta temperature.
The licensee's
corrective actions included additional procedures and training so
as to obtain the required delta temperatures by alternate means.
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The inspector examined these procedures and discussed them with
the licensee. The corrective actions were found to be consistent
with those reported in the Met-Ed letter to the Director, RO:I
dated July 24, 1974.
The inspector stated that he considered this
iten closed.
.
9.
Chlorine Releases
The inspector examined the circumstances and the licensee's corrective
actions with respect to total chlorine and free chlorine concentrations
released to the river in excess of the limits.
In particular, he
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reviewed those concerning the reported Environmental Incident No. 74-09
relating to free chlorine in the river discharge equal to 0.1 ppm
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on September 26, 1974 in violation of Appendix B, Technical Speci-
fications 2.2.1.a.
The licensee's corrective actions were found to be as stated in his
letter to the Director, RO:I dated October 3, 1974. As cart of these
actions, the chlorine injection rate was reduced and consultants have
been contracted to prevent recurrences. The inspector examined the
progress reports of one of these consultants, Wapora, Inc. of
Washington, D.C.
In addition, the manufacturer of the installed
ampero=etric titrator has sent representatives to aid in resolving
instrumentation problems.
The inspector asked whether the chlorine
demand of the intake river water was routinely determined.
The
licensee stated that this had not been done but that this would be
evaluated with the consultants.
The inspector stated that the above
matter was considered closed.
10.
pH of Discharges
The inspector reviewed the circu= stances and corrective actions
relating to reported Environmental Incident No. 74-10, pH in excess
of the limits 6.0 ta 9.0 on August 31, September 15, 20 and 23, 1974
in violation of Appendix B, Technical Specifications, Section 2.2.3.
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The inspector determined that the corrective actions were consistent
with those reported in the Met-Ed letter to the Director, RO:I dated
October 4, 1974 and included an updated calibration program for the
installed pH instrumentation and a change in procedures such that
prior to draining the Waste Neutralizing Tank, a sample must be
drawn and analyzed to assure the pH is within the specified limits.
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The inspector stated that this item was considered closed.
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