ML19274D913
| ML19274D913 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/20/1978 |
| From: | Leonard J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19274D907 | List: |
| References | |
| JAFP-78-620, NUDOCS 7902270217 | |
| Download: ML19274D913 (7) | |
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POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. FirzPATRICK N UCLE AR POWER PLANT S
JOHN D. LEONARD, JR.
P.o. Box 41 Resident Manager Lyccmmg, New York 13093 315-342-3840 November 20, 1978 JAFP 620 Mr. Boyce H. Grier United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Reference:
Docket 850-333 IE Inspection 78-17
Dear Mr. Grier:
With reference to the inspection conducted by Dr. M. Shanbaky of your office on September 11-15, 1978 at the James A. Fit: Patrick Nuclear Power Plant, and in accordance with the provisions of Section 2.201 of Part 11 of Title 10 of the Code of Federal Regulations we are submitting our reply to Appendix A Notice of Violations transmitted by your letter dated October 30, 1978 as recei Wd by the undersigned on November 2, 1978.
We have reviewed Inspection Report 50-333/78-17 and take issue with the fact that items A, E and F were included in Appendix A Notice of Violation in view of the fact that these items were licensee identified items which were previously reported to your office and that corrective action has been taken.
Further details on these items are given below:
Infraction A Section 4.3.1 and Table 4.3-1 of appendix B (ETS) requires, in par +, *uat three lake water samples from the hine Mile Point Unit 1 iu m e, James A. FitzPatrick plant intake and Oswego City water sit d l :e collected and analyzed on a monthly basis for gamma a s by germanium lithium detector spectroscopic analysis.
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790227062l1
Page 2 November 20, 1978 Contrary to these requirements, the monthly lake water and Oswego City water samples were analyzed under adverse analytical conditions for environmental sample analysis, including a relatively high background, resulting in erroneous analytical results for the 1977 monthly analyses including January, February, March, April, May, June and July.
Reply to Infraction A This item was identified by the Authority in its Annual Environmental Operating Report submitted to your office via our transmittal dated March 31, 1978 (JAFP-78-160).
In this report we stated (page 3,Section III. A.6) Lake Water-Tables 6, 6A):
"The analysis for the first half of 1977 had poor analytical sensitivities yielding unrepresentative data, upgraded laboratory techniques contributed to more valid analysis beginning with the August 1977 samples" This item should not be listed as an item of non-compliance since it was identified, documented and corrective action was taken.
Infraction B Section 6.11 of Appendix A, Technical Specifications, requires, in part, that procedures for personnel radiation protection shall be prepared and adhered to for all plant operations.
These procedures shall be formulated to maintain radiation exp3sures received during operation and maintenance as far below the limits specified in 10 CFR 20 as practicable. The procedures shall include planning, preparations and training for operation and maintenance activities.
They shall also include exposure allocation, radiation and contami-nation control techniques, and final debriefing.
Section 5.C of the J. A. FitzPatrick Nuclear Power Plant Radiation Protection Operating Procedures, " Restricted Area Rules," requires, in part, that: (1) each person exiting from a restricted area where there is a possibility of contamination, shall check themselves for contami-nation at the control points; (2) all tools and equipment shall be checked for contamination by the Radiation Protection group before removal from a restricted area.
1.
Contrary to these requirements, at the time of the inspection on September 14, 1978, an individual leaving the restricted area failed to check himself for contamination at the control point.
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Page 3 November 20, 1978 2.
Contrary to these requirements. at the time of the inspection on September 14, 1978, a tool was not checked for contamination by the Radiation Protection group before removal from a restricted area.
Reply to Deficiency B Both items of this infraction were caused by a temporary employee who although he had received training, was not completely familiar with contamination control practices during his first days on the job. This infraction was immediately corrected by radiation protection personnel, the tools and the individual involved were monitored and found to be " clean".
Shortly after the incident occurred radiation protection personnel were stationed at exits from restricted areas to ensure that personnel and equipment in use for the refueling outage were surveyed before being removed from the area.
We will continue to use the monitors during our refueling outage when large numbers of inexperienced contractor personnel are on site.
We believe we are now in full compliance in this regard.
Deficiency C Section 2.2.4 of the Appendix B, Environmental Technical Sepecific-ations (ETS) requires, in part, that neutralizer tank effluents shall be continuously monitored for pH during discharge to the discharge canal.
The pH monitor alarm shall be set to alarm at pH levels below 6.0 and above 8.5.
Contrary to these requirements, the neutralizer tank pH monitor upper limit alarm set point was set above 8.5 on September 13, 1978, during tank discharge.
Reply of Deficiency C Investigation of this matter revealed the following:
1.
The make-up neutrali:er tank pH meter alarm points were set at 6.0 and 8.5 at 0910 on 9/13/78.
2.
Tank discharge began at 0920 and concluded at 1030 on 9/13/78.
3.
The NRC inspector visited the rad-waste building control room at 1500 9/13/78.
4.
The pH meter high alarm was checked with a pH 9.2 buffer at 1730 hrs and the alarm did not sound on the pH meter indicating that the alarm point was set too high.
Page 4 November 20, 1978 We have every reason to believe that the tank was discharged with the pH alarms properly set.
Although the inspection report (page 12, section 7 b) states that the alarm set point was checked "immediately after the neutralization tank discharge" we find that it was checked some 4 hrs. later.
After tanks are discharged the alarm points on the pH meter are sometimes changed to facilitate neutralization of the tank as it is again filled.
Although we believe a non-compliance did not occur in this instance we are taking the following actions:
1.
Revision of the Operating Procedure (OP-7) to ensure that the pH meter alarm points are properly set at 6.0 and 8.5 before each tank dischage.
2.
Investigate the feasibility of the addition of a second pH meter to be used for tank neutralization so that the alarming pH meter will only be used for discharging of tanks.
Deficiency D Section 5.5.1 of the Appendix B (ETS) requires, in part, that detailed written procedures including applicable checklists and instructions be prepared carrying out the environmental monitoring program.
Procedures include sampling, data recording and storage instrument calibration, measurements and analyses.
Site Procedure No. S-RTP-29, " Radiation Protection Technical and Analytical Procedures,"
requires, in part, that the environmental station radiation monitors shall be calibrated semi-annually.
Cov.rary to these requirements, Environmental Station Radiation hionitor J, which is required by Section 4.3, Table 4.3-1 of the ETS, was not calibrated semi-annually during the period from July 12, 1977 to March IS, 1978.
Reply to Deficiency D Corrective action for this item will be taken consisting of incorporation of a surveillance check sheet for the calibration of the environmental station radiation monitors into the JAFNPP environmental management review procedure to ensure calibrations are performed in a timely manner. These monitors have since been calibrated on a semi annual basis and we are now in compliance in this area.
a Page 5 November 20, 1978 Deficiency E Section 2.1.1 of the Appendix B (ETS) requires, in part, that the AT between the main condenser inlet and the plant outlet shall be monitored and recorded once per hour.
Contrary to these requirements, the AT between the main condenser inlet and the plant outlet was not recorded once per hour on December 5, 1977.
Reply to Deficiency E Since this item was identified by the Authority and reported to your office via LER 77-68, and since corrective action discussed has been successfully implemented this item should not be listed as an item of non-compliance.
Deficiency F Section 2.2.3 of Appendix B (ETS) requires, in part, that the concentration of any solute in the plant discharge not exceed the lake ambient concentration of these solutes by more than 5%.
Contrary to these requirements, the concentration of these solutes in the plant discharge exceed the lake ambient concentration of these solutes by more than 5% on several occasions including:
sodium in October, 1977, February, 1978, and April, 1978; manganese in February, 1978, April, 1978, May, 1978 and August, 1978; iron in September, 1977, January 1978 and March, 1978; and sulfate in March, 1978.
Reply to Deficiency F This item has been identified in each of the following LER's Nos.
77-62, 78-11, 24, 25, 38, 53.
Corrective action is in progress and this item should, therefore, not be listed as an item of non-compliance.
It should also be noted in each of the above LER's the soluble concentration was not greater than 5% but because of the ambiguity of the ETS we are required to report apparent excess concentrations.
Deficiency G Section 5.7.1 of Appendix B (ETS) requires, in part, that records and logs be made and retained for the life of the plant including records of all data from environmenal monitoring, surveillance, and special surveillance and study activities required by the ETS.
Contrary to the above, the analytical records pursuant to Section 2.2.3 of the ETS, for the required manganese monitoring in the plant discharge for February, 1978, and March, 1978, were not maintained as required.
Page 6 November 20, 1978 Reply to Deficiency G We are taking the following corrective actions to ensure complete analysis records are maintained:
1.
The procedure for analysis of samples on the AA unit will be revised to ensure data records are filed in a proper manner.
2.
The environmental data review procedure will be revised to include inspections by management personnel of raw data sheets.
We will be in compliance in this area by January 31, 1979.
It should be pointed out that the analysis in question was performed and the data sheets required by the analysis procedures were completed and retained; only the strip chart from the atomic absorption (AA) unit was missing.
Deficiency H Section 5.6.2 of Appendix B (ETS) requires, in part, that a report be submitted in the event that a limiting condition for operation is exceeded. Those events not requiring prompt report shall be reported within 30 days by a written report to the Director of the NRC Regional Office (with a copy to the Director, Office of Nuclear Reactor Regulation).
Contrary to these requirements, a written report was not submitted within the required 30 day period when the limiting condition for operation was exceeded for iron and sulfate in the plant discharge on March 10, 1978.
The required report (LER 78-25) was subnitted on May 16, 1978.
Reply to Deficiency H The referenced LER appears to be " late" because the analysis data sheet was not turned over to an RES supervisor until all of the analysis for the month was complete.
In this case the March analysis was not completed until April 7, 1978 at which time the data was available for management review. Because this has been a repetitive occurrence and calculations illustrate it was not an actual violation it was not flagged for management attention on a priority basis.
The data was reviewed by management on April 20, 1978 and the LER was submitted on May 16, 1978, twenty six days from the apparent violation.
Page 7 November 20, 1978 To ensure review in a more timely manner we are instructing our technicians that rather than wait for complete analysis of the samples they inform supervisory personnel immediately if a particular analysis result exceeds an acceptance criteria even though it is only an apparent instead of actual violation.
Repetitive LER's (78-25), (78-38), (78-53) refer. Corrective action will be complete when the commission approves a technical specification submitted on 1-10-77 and still under discussion.
Sincerely,
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' ~ )hnk' eonard, Jr.&/\\
G A?LA' L
R sident Manager JDL:RAB:j lk cc:
G. T. Berry P. W. Lyons R. Rajaram G. Wilverding E. Kelly J. Davis J. Leonard R. Pasternak S. Wells H. Fish R. Burns Main File DCC