ML19276H248
| ML19276H248 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/20/1978 |
| From: | Herbein J Metropolitan Edison Co |
| To: | Brunner E NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19276H245 | List: |
| References | |
| GQL-1088, NUDOCS 7910150873 | |
| Download: ML19276H248 (3) | |
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PCST cFFICE SCX 542 RE AclNG. PENNSVLVANI A 19603 TELE *wCNE 215 - 929 2601 e
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631 Park Atenue i'i:5 cf Fr.ssia, Pennsylra ia 191.C6
- ear Mr. 3r:r.ner:
?ree Mile Island :iuclear Static, Unit 1 C;erating license Uc.
??-50 Decket He 50-239 Espectic: Repore Uc. 76-06 This letter and the attachment are in response to your inspectics letter of May 31, 1978, ccccerning Dr. R. 3cres' inspectie: cf SC-1 and the resultant finding of three apparent infractic s.
Sincerely,
/
/
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J. G. Herbei Vice President-Generatic Attach:en:
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. 3.e wg3 iesignated alternate receives the envirce: ental ecliecticn data sheets c:
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a sensitivity Oc =eet the d '.= analytical sensitivities specified in "able 3 Centrary to these require =e :3, the water sa=ples, ecliec*ed frc: the ity of Celumbia vater intate during the Secc d, ~'hird and Fe=th,uarters c' 197,
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and count ti=es, vere ta'cen as described in the le*:er to 2.C dated h-19-77 O
Also indicated in that letter vere plans to request a chan,se to the Unit i
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e Ec-inst.,1ction cf the ec=sultant labcratcry that I' S Sr-39 sensitivities 1.
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Review cf cc sultant laboratory procedures to insure each Sr-89 analysis result is revieved to assure adequate sensitivity of analysis.
3 Review of f tre Sr-59 analysis results to assure ec=pliance and re-analysis vhere required.
e abcve described actic s vill asse s ec fer=a.cc vith the I~"S sensitivity
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.a 1419 034
Y ke UNITED STATES NUCLEAR REGULATORY COMMisslON Dr ? 6 REGION I 3.$ % M,j 631 PARK AVENUE A
gr j winc oF PRUS$1 A PENNSYL V ANI A 19406
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MM 311973 Decket Nos L50 2S M 50-320 Metropolitan Edison Ccmpany ATTN: Mr. J. G. Herbein Vice President P. O. Box 542 R.eading, Pennsylvania 19603 Gentlemen:
Subject:
Combined Inspection 50-2S9/78-08; 50-320/78-16 This refers to the inspection conducted by Dr. R. Bores of this office on April 17-21, 1978, at Three Mile Island Nuclear Station, Middletown, Pennsylvania, and at the Metropolitan Edison corporate offices in Read-ing, Pennsylvania, of activities authorized by NRC License Nos. DPR-50 and DPR-73, and to the discussions of our findings held by Dr. Bores with Messrs. O'Hanlon, Dubiel, and other members of your staff at the conclusion of the inspection, and to a subsequent telephone discussion between.Dr. Bores and Messrs. O'Hanlon and Dubiel on May 5,1978.
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consitted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Our inspector also verified the steps you had taken to correct the items of nonccmpliance brought to your attent. ion in a letter dated April 6, 1977. We have no further questions regarding the steps you took to correct item B.
With regard to items A and C, we note that these items have recurred, as detailed in items B and C of Appendix A to this letter.
In your respcnse to this letter please give these matters your particular attention.
With respect to Unit 1, NRC License No. DPR-50, based on the results of this inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth.in t.he Notice of Violation, enclosed herewith as Apcendix A.
These items of noncompliance have been categorized into the levels as described ir our corresoondence to you ca:ed Cecem::er 31, 1974.
This notice is sen :o you pursuant to the crovisiens of Section 2.201 of the ":.C's "Cules of DJF6 IU3 E g 9onsossi Go ftCH E ' AD0ff SS
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Metropolitan Edison Company 2
Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have ieen taken by you and the results achieved; (2) corrective steps whic' will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
With respect to Unit 2, MRL License No. DPR-73, within the scope of this i.nspection; no items of nonccmpliance were observed.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Poom.
If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered.by the Commission as listed in subparagraph (b) (4) of Section 2.790. The information sought to be withheld shall be incorporated as far as'possible 9
into a separate part of the affidavit.
If we do not hear from you in this regard within the specified period, the report sill be placed in the Public Document Roon.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, d
Paul R. Nelson, Chief Fuel FacMity and Materials Safety Branch 1419 036
Metropolitan Edisen Company 3
Enclosures:
1.
Appendix A, Notice of Violation 2.
Office of Inspection and Enforcement Combined Inspection Report Number 50-289/78-08; 50-320/78-16 cc w/encis:
R. L. Wayne, QA Manager, Design & Construction T. Broughton, Safety & Licensing Manager R. W. Heward, Jr., Project Manager R. C. Arnold, Vice President, Generation L. L. Lawyer, Manager, Generation Operations - Nuclear G. P. Miller, Superintendent J. P. O'Hanlon, Unit 1 SLperintendent J. L. Seelinger, Unit 2 Superintendent Gerald Charnoff, Esquire I. R. Finfrock, Jr.
Miss Mary V. Southard, Chairman, Citizens for a Safe Environment (Without Report)
G till>
!4I9 037
APPENDIX A NOTIrc ' 'lIOLATION Metropolitan Edison Comr r Reading, Pennsylvania 1^603 Docket No. o0-289 Based on the results of an NRC inspection conducted on April 17-21, 1978, it appears that certain of your activities were not conducted in full compliance witn NRC regulations and the conditions of your NRC Facility License No. DP<-50, as indicated below. ' Item A is categorized as an Infraction. Items B and C are Deficiencies.
A.
10 CFR 20.105(b)(1) "Pennissible levels of radiation in unrestricted areas," requires that radiation levels in unrestricted areas be limited so that if an individual were continuously present in the area, he could not receive a dose in excess of twc millirems in any one hour.
Contrary to this requirement, on a number of (ays, including April 18 and 19,1978, radiction levels existed in an unrestricted area along and outside the fence enclosing the Unit 1 Borated Watet Storage Tank (BWST) of up to 10 millirems per hour, such that if an 9
individual haa been continuously present in the area, he could have received a dose in excess of two millirems in one hour.
B.
Section 4.4.a and Table 3 of the Environmental Technical Specifi-cations (ETS) require, in part, that air particulates and air iodines be sampled and analyzed on a weekly basis at each of the specified locations.
(1) Contrary to these requirements, air particulates were not sampled and analyzed weekly at a number of required locations, i~ncluding:
TM-AP-lCl May 11 - June 1, 1977 TM-AP-lS2 May 15 - June 8, 1977 TM-AP-12B1 June 8 - June 22, 1977 TM-AP-5Al August 17 - September 7, 1977 (2) Contrary to these requirements, air iodines were not sampled and analyzed weekly at a number of required s ations, including:
TP-AI-lS2 May 11 - June 8, 1977 TM-AI-5A1 August 17 - September 7, 1977.
1417 038 g q o o3d Qo ncM A00ttGSS)
Appendix A 2
C.
Section 4.4.a and table 3 of the ETS require, in part, that water samples collected at the City of Columbia water intake be analyzed with sufficient sensitivity to meet the minimum analytical sensi-tivities specified in Table 3.
Contrary to these requirements, the water samples, collected from the City of Columbia water intake during the Second, Third and Fourth Quarters of 1977, were not analyzed with sufficient analyt-ical sensitivity to meet the specified minimum sensitivity for Sr-89.
- 4l'1 039
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
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50-289/78-05 lort No. 50-320/78-16 50-289 Docket No.
50-320 DPR-50 C
License No.
DPR-73 Priority Category B-2 Licensee:
Metrooolitan Edison Comoany (Met Ed)
P. O. Box 542 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 Pennsylvania Inspection conducted:
Ayrg7-21,1978 Inspectors: /
prM giS-2.f ~/8 R. J. Bor'es, Radiation Specialist cate signed Acenmpanied by:
Harold Berkson. Environmental Soecialists Branen, NRR:DSE (April 17-18,1978) cate signed cate signed h
Approved by:
W..
ad 6
5 /778' J. P. Stonr, Cnier, enfironmenta &
' cate signec
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Special Pro.Jects Section, FF&MS Branch Inscection Summary:
Insoection on Acril 17-21, 1978 (Combined Reoort Nos. 50-289/78-08: 50-320/78-16)
Areas Inscected:
Routine, unannounced inspection of 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; nonrr licactive effluent release rates and limits; radiation levels around the Borated Wa.ar Storage Tank (BWST); and a followup on the licensee action on previous insoection findings.
The inscection involved 36 inspector-hours onsite by one NRC inspector.
Results:
Of the six areas inspected, no items of noncomoliance were identified in four areas.
Three apparent items of noncomoliance (:nfracticn - radia-ion levels in excess of limits in an unrestricted area - Detail 9; Ceficiency - faiicre to samole and analyze air particulates and iodires - Detail 5.c(2); Ceficiency - failure to
- - Sr-39 analytical sensitivity #cr Pinking watsr - Detail 5.:(~:) e.ere identified 141-)
040
- .: areas.
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3 results, and review of the licensee's records of ccrrective and preventive ac-ions, that the licensee had met the analytical ensi-tivity recuirements for this medium during 1977, and that the licensee's corrective / preventive actions were implemented as stated in the letter dated April 29, 1977 to the Region I Office.
The inspector had no further questions with regard to this item.
(Closed) Unresolved Item (285/77-04-04): Adequacy of sensitivity of analyscs for Sr-89 and Sr-90 in milk, fish, and precipitation.
The inspector determined through discussions with the licensee, review of the analytical records since the beginning of 1977, and.
the review of the licensee's doct. mentation of followup en this item, that (a) the licensee nad met the analytical sensitivity requirements for these media since the beginning of 1977, and the licensee had taken appropriate timely action in tenns 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 background air particulate gross beta to gamma ratios.
The inspector reviewed the licensee's analytical records subsequent to the 1975 data,in question and the licensee's revi*ew of this data and discussed this item with the licensee.
The higher (ten to 100 tunes greater) background air particulate gama levels over the indicator station levels during 1975 without a corresponding gross beta increase, were attributed to the much higher Be-7 (non-reactor produced gama-emitting nuclide) reported during this time period 3
at the background stations. The cause of these higher levels at the background stations har not been definitely established.
However, since Be-7 can be linked with heavier particulate loading, this may be one cause.
The 1976 and 1977 air particulate data still indicates higher background than indicator station Be-7 levels, although the difference is not nearly as pronounced.
The inspector had no further questions in tnis area at this time.
(Ciosed) Open Item (320/78-08-01):
Procedure modifications for f.
monitoring.
The inspector determined through a review of Procedure 2104-3.8, Mechanical Draft Ccoling Tcwer Operation, review of installed instrumentation and discussions with the licensee, that (1) the above procedure had been modified to assure communication /
ccordination between Unic 1 and Unit 2 regarding thermal effluent limita-icns, and '2) -he necessary thermal moni:cring instrumenta-tica Mac been ins alled ar.d is c:erable, allow -he m nitoring of
- liance ai, es ec- : -hermal ef#luents.
7he ins:ec::r hac no br!Ee# Jes!1 r.s.
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4 (0 pen) Deficiency (289/77-04-03): Fai]ure to meet Sr-89 analytical sensitivities for drinking water.
The inspector's review of the licensee's analytical records and environmental radicalogical report for 1977 indicated that the required analytical sensitivites for Sr-89 in drinking water were not achieved 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 On February 8, 1978. Three Mile Island Nuclear Station - Unit 2 was 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 License DPR-50 Unit 2 - Appendix B, through Amendment 6, of Operating License DPR-73 9
Prior to February 8,1978, the environmental monitor,ing require-ments on TMINS
. Unit 2 were contained in Construction Permit CPPR-66.
4.
Manacement Controls a.
Chances The inspector determined through discussions with 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 following areas since the.last environmental inspection:
(1) Assignment of responsibilities and authorities; (2)
Provisions for audits and inspections of environmental activities; (3)
Provisiens for identifying, documenting and reporting, correcting and folicwing up on orogram inadecuacies and inspection / audit results; and
'l; Review of prcgram resuits.
1419 042
5 The changes that had occurred had been primarily in docu-menting the assignment of the responsibilities and authori-ties, as well as, the establishment of a documented, specific program to assure the environmental programs are reviewed and
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audited at a specified frequency, and that identified items i
are resolved.
The inspector determined that Porter-Gertz Consultants con-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 laboratcry for environmental radioanalytical services since October 1, 1977.
Radiation Management Corpora-tion (RMC) prcvides quality control radicanalyses on split and duplicate samples.
The inspector determined that the above changes resulted in management controls which.re as good as or better than observed during the previous inspection (50-289/77-04).
b.
Licensee Audits /Insce:tions The inspector determined through discussions wi.th the licensee that one audit had been conducted in the environmental area since the previous inspection. The inspector's review of the I
audit report indicated that the area covered was limited to i
radiological environmental sample collection and media prepar-l ation for transport to the analytical laboratory. The inspector j
determined that any identified areas needing corrective action were satisfactorily resolved in a timely manner.
I I
The inspector noted that one licensee inspection had been per-i formed relative to control of erosion along transmission right-of-ways. The completed inspection findings were not yet i
available at the time of the inspection.
(The inspector noted that the bulk of the biological / ecological activities to be i
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 1973 to cate.
The inspector noted that such an audit was recuired at least every two years.
The ins::ector had no further ;uestions in this area at this time.
1419 043
6 5.
Licensee Procram for Quality Control of Analytical Measurements a.
Radiolocical
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The inspector determined through discussions with the licen-
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see, review of the consultant's reports of data valuation, and the review of the results of the quality control program since January 1977, that the program had provisions for the:
(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 decordance with a docu-mented procedure; that split and duplicate samples were analyzed by the primary contractor and by a second laborato y 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 radiatice-are bei.19 pursued.
b.
Radioloaical/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 followup 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.
14l'1 044
7 6.
Ieolementation of the Environmental Monitorino Prcoram - Radiolecical 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 determined that the report contained the reouired infomation relative to sampling locations, media, frequencies, analyses and evaluations, and comparisons with the preoperational data as controls, as appropriate.
(2) Nonroutine Recorts The inspector reviewed the. environmental a'spects of the inadvertent release of gaseous radioactivity as a result of a seal water line break on October 28, 1977, and as reportud to the NRC as Licensee Event Report (LER) 239/77-25/3L 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 1 release.
The inspector had no further questions in regard 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, Rn-103, Cs-134, and Ce-141 levels in sedim2nts at a downstream indicator station which were
! 4 l ')
045
8 4F
- ,=
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 these results, along with the absence of a significant increase in TMINS liquid effluent releases, indicate that the reported results are attributable, at least in part, to the 1977 Chinese weapons testing debris.
The inspector had no further questions in this area at this time.
c.
Other Records (1) Thermoluminescent Dosimeters (TLDs)
The inscector reviewed the licensee's records of TLD environmental monitoring since the beginning of January 1977, and determined that the measurements were made at the specified 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 9
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 1 to be identical to the Unit 2 program.
(The latter program has eliminated the 14S2 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 the TLD measurements during the Fourth Quarter 1977 were consistently higher at all locations than during the first three cuarters.
The g
1419 046
i 9
inspector also noted that Teledyne Isotopes (TI) became the prime radiological cL1 tractor at this time, replacing Radiation Management Corporation (RMC).
The above data i
along with the licensee's quality control data indicated 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 recommendations 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 performance evaluation program has been com-pleted and is subsequently 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 accordance with tha requirements, with the following exceptions.
I No samples were collected during the following time intervals at the following stations:
Time Interval Station Medium 5/11 - 6/1/77 TM-AP-lC1 Air Particulates 5/11 - 6/8/77 TM-AI-lS2 Air Iodines 5/18 - 6/8/77 TM-AP-lS2 Air Particulates 6/08 - 6/22/77 TM-AP-1281 Air Particulates 8/17 - 9/7/77 TM-AP-5Al Air Particulates 8/17 - 9/7/77 TM-AI-5Al Air Iodines The inspector stated that the failure to collect and j
analyze these media on a weekly basis was in noncompli-ance with the requirements of Section 4.4.a of the Unit 1 s
ETS.
The inspector noted that while the licensee had cbtained a spare sampling uni since the last inspection I
(50-289/77-04), this i em has recurred.
(289/78-08-02)
I4i7 047
-4
10 Discussions with the licensee indicated that at the present time, air sampling units are on a limited pre-ventive maintenance schedule. When sampler fails, plant personnel either replace or repair the failed unit.
The timeliness of this action is dependent, however, on plant operational status at the time of failure. The licensee stated that at the present time the cry gas meters employed with the air samplers are not routinely calibrated. The licensee stated that the preventive maintenance program for the air sampling systems and the calibration of the dry gas meters would be re-evaluated.
The inspector stated that perding completion of these evaiuations, 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 Januar, 1977 and deter-mined that each of the samples were collected as required and analyzed for the required parameters.
The review of the analyses indicated that the analytical sensitivitier had been met with the following exception.
Surface water sampled from the City of Columbia water intake duririg the last three quarters'of 1977, was not analy' zed with suffi-cient sensitivity to meet the minimumsensitivityof1X10gection4.4.a. Unit 1ETS uCi/ml for Sr-89.
The inspector stated that this was in noncompliance with the requirements and was a recurrent item.
(289/78-08-04)
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 change 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 require Sr-89 or Sr-90 analyses of surface water.)
1419 048
11 (4) Other Media The inspector reviewed the results of the other media sarmled and analyzed since January 1977, including milk, river water, soil, sediment, fish, and vegetation.
The ins;ector determined that these media had been sampled and analyzed in accordance with the ETS requirements.
d.
Peteoroloaical Monitorino The inspector examined the meteorological instrumertation in the Control Rooms of both Unit 1 and Unit 2 and determined tnat all appeared to be functioning properly at the time of insr.ec-tion..The insoector further determined, through discussions with licenser personnel and review of selected calibration records and procedures, that the meteorological instrumentation had beea calibrated, ve.< checked routinely in accordar.ce with the requirements, and is on a routine calibration schedule.
The inspector had no further questions in this area.
7.
Imolementation of the Environmental Monitorina Procram -
Biolooical/Ecolocical a.
Direct Observations The inspector reviewed selected portions of the Unit 2 biological /
ecological monitoring programs through discussions with licensee and '.ontractor personnel, selected reviews of sampling and andiytical procedures, and direct observations of the following program tasks:
ichthyopl.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 environmental parameters and the preservation of samples; and the sampling of benthic organisms (macrainverte-brates) in the vicinity of TMINS.
b.
Recorts and Records The inspector reviewed a draft report of the 1977 TMINS bio-logical / ecological study results and discussed selected pro-cedures, analytical results and evaluations with the licensee.
Areas reviewed included the fish creel census; imoincement meni-tcring; fish peculation studies in Lake Frederick; the tnermai plume studies; the aerial remo e sensinc program; and the wa ar cua.1 y measurements.
1417 049
12 c.
Other Areas The inspector examined the Program Description Document and Implementing procedures relative to the following prograns/
program :hanges required by Condition 2.E(2) of Facility 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 Limitina Concitions of Ocerations or Other Permits.
The inspector cetermined 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 in 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 1 since January 1977 and the site thermal discharge records since March 1978.
The inspector determined that for those time intervals examined, the thermal discharges were in accordance with the ETS requirements with the exception of those instances reported to the No.C in the following letters:
Letter Date Report 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) 8/12/77 289/77-20-47 27 exceeding 3*F below inlet -
ETS 2.1.a(1) i4!? 050
13 0
The inspector reviewed the above events through discussions with the licensee and review of the licensee's reported corrective actions and procedure modifications and determined that corrective actions had been taken, as reported.
The l
inspector stated that he had no further questions regarding the above items.
The inspector examined the installed Unit 1 Unit 2 and site thermal monitoring systems, through discussions with the i
licensee, review of. installed instrumentation, review of l
pertinent drawings 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, downstream of the confluence of the Unit 1 and Unit 2 mechanical draft cooling tower discharges. The inspector determined that at the present time a single inlet sensor providas the thermal information to both units, as well as, to the backup recorders i
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 include provisions to contact the other G
control room in the event of recorder probler,, to utilize the backup recorders at the mechanical draft cooling towers, and as a final, resort and in the event of sensor failure, to
=
l physically measure the temperatures with a calibrated thermometer.
The inspector discussed the use of a bucket thermometer for i
such applications. The licensee stated that a bucket thermometer l
is being considered for.this area.
The inspector had no further questions in the above area at this time.
i I
The inspector attempted to review the calibration of the I
thermal monitoring systems for each unit.
The inspector l
reviewed the records of the " loop" calibration for Unit 1, exclusive of the Resistance Temperature Detector (RTD) sensors.
The licensee stated that the Unit 1 ETS did not specifically require calibrations of this system.
The inspector deternined i
that the Unit 2 ETS did require such calibrations, such that, the sensor and sensor system meet specificd accuracy and sensitivity criteria.
The licensee was unable to produce these calibration records at the time of the inspection.
1419 051
14 O
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 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 ins;:ector determined, for the records examined, the releases were within the specified ETS require-ments with the following exception, reported to the NRC as_LER 289/77-13/4T 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 9
system (IWTS), discussed its operation with licensee repre-sentatives and reviewed selected records of effluent releases.
The inspector also reviewed the circumstances and applicable corrective actions with respect to the Noncompliance Notifica-tions reported for the IWTS, as follows:
Letter Date Recort No.
Event 3/13/78 78-01 discharae with pH and total suspended solids {TSS)outsidelimits 3/27/78,
78-02 discharge of untreated waste 3/8/78 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 4/10/78 78-07 discharge of oil and grease in excess of I m ts g
14 U 052 So g*
15 The licensee stated that coerational problems had developed with the IWTS in terms of treatment polymer addition and in the filteration system. The present filters had clogged c.M the licensee was working with the vendor to correct these problems. The licensee stated that the IWTS should be fully coerable within two months.
The inspector stated that he had no addi;ional questions with respect to the above specific events'at this time.
The inspector attempted to verify compliance with the dis-
- harge requirements and monitoring requirements through a review of the records.
The inspector determined that becaus.e of the present TMINS recordkeeping system, it was very difficult to locate the required records for' flows, analytical results, instrument checks / calibrations to verif;, 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 dat$ couldn't be located at all (Detail 8.a).
The licensee stated that this had been 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 liquid 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 examined the area of the east dike in which 'the rock rip-rap had moved down the slope of the dike, as reported by the licen,ee as LER 320/78-05/99T in a letter dated February 21, 1978.
The inspector noted tnat this area had been repaired and he observed no other areas in need of such recair at the time of the insoection.
Q IAll 053
16
[
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 weir. At the time of the inspection, both of the above basins 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 sigrificant erosion.
The inspector's discussions ~ with the licensee revealed that the licensee had no discharge requirements at the present time for this outfail, although discussions along this line are being conducted with Pa DER (Pennsylvania Department of Environmental Resources).
Tha licensee stated that the settling basins will be cleaned te restore settling capacity and they will 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 G
considered unresolved.
(289/78-08-05; 320/78-16-04) 9.
Other Insoection 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 (BWST).
Discussions with the licensee and review of the radiation survey records 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 borated water to the BWST after refueling Unit 1 and they had 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.
1Al) 054
17 The inspector discussed the regulations of 10 CFF 20.105 regarding permissible radiation levels in unrestricted areas, and the defini-tion of an " unrestricted" area in tenns 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 area for purposes of radiation protection 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. Management Interviews G
tion, the inspector met with the individuals denoted in Paragraph On April 19, 1978, following the TMINS onsite portion of the inspec-1.
On April 20, 1978, the inspector met with the licensee representatives 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 sunmarized and the inspection findings, including each item of noncompliance and unresolved item were discussed.
a.
With regard to Unresolved Item (289/78-08-05; 320/78-16-04) -
sedinientation basin maintenance and inspection, the licensee stated that as of May 5,1978, a purchase request had been made to have the basins cleaned within the next couple of weeks.
IAl) 055
18 b.
The inspector also discussed the problems encotntered in trying to review records of calibrations, surveillance tests, analytical results, etc., when licensee personnel had difficulty in determining wnere the specific records were located.
The licensee stated that the recordkeeping system at TMINS would t.e reviewed.
c.
The licensee acknowledged each item of noncompliance.
e G
14l'1 056
_