ML20010B354
| ML20010B354 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 07/24/1981 |
| From: | Bores R, Todd Jackson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010B347 | List: |
| References | |
| 50-289-81-09, 50-289-81-9, 50-320-81-09, 50-320-81-9, NUDOCS 8108140394 | |
| Download: ML20010B354 (12) | |
See also: IR 05000289/1981009
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
50-289/81-09
Report No.
50-320/81-09
50-289
Docket No.
50-320
C
License No.
Priority
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Category
C
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Licensee:
Metropolitan Edison Company (Met Ed)
P. O. Box 480
Middletown, Pennsylvania 17057
Facility Name: Three Mile Island Nuclear Station, Units 1 & 2 (TMINS-1&2)
Inspection at: TMINS-1&2, Middletown, Pennsylvania
Inspection conducted: April 22- 4, 27-May 1,1981
7~o8- 8/
Inspectors:
Ac
1. J.G/ K's n, Ra iat, ion Specialist
date signed
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Approved b :
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R. J. Bores, Ehief,' Independent Measurements and
date signed
Environmental Protection Section, EP&PS Branch
Inspection Summary:
Inspection on April 22-24, 27-May 1, 1981 (Combined Report Nos. 50-289/81-09;
50-320/81-09)
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Areas Inv?cted:
Routine, unannounced inspection of en.'ironmental monitoring
program, for operations at TMINS, including: the management controls for these
programs; the licensee's program for quality control of analytical measurements;
implementation of the environmental programs - radiological; implementation of
the environmental monitoring programs - biological / ecological; and nonradiological
effluent release ra' as and limits. The inspection involved 50 direct inspector-
hours by one regionally-based NRC inspector.
Results: Of the five areas inspected, no items of noncompliance were identif;ed
in four areas. One item of noncompliance (Failure to meet Sr-89 analytical
sensitivity for drinking water - Detail 5.c) was identified in one area.
Region I Form 12
(Rev. April 77)
8108140394 810729-
DRADOCKOSOOOg
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DETAILS
1.
Individuals Contacted
General Public Utilities - Nuclear Group (GPUNG)
- H. Hukill, Director, V.P. TMI-1
- M. Roche, Manager, Environmental Controls
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- W. Reithle, Manager, Environmental Controls - TMI
R.' Fenti, Site Audit Manager
- L. Harding, Supervisor of Licensing, TMI-1
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- G. Baker, Radiological Programs Manager - TMI
- W. Ressler, Biological Programs Manager - TMI
- T. Grace, Environmental Licensing - TMI
M. McBride, Environmental Scientist
H. Blauer, Environmental Scientist
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J. Garry, Staff Project Coordinator
T. Walsh, Meteorologist
M. Snyder, Unit 1 Preventive Maintenance Supervisor
D. Weaver, Unit 2 I&C Lead Foreman
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G. deed, Unit 1 Chemistry Foreman
.1. Meiser, Manager - Information Systems
Others
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G. Nardacci, Project Director, Ichthyological Associates
- denotes those present af, the exit interview.
2.
Licensee Action on Previous Inspection Findi m
(Closcd) Infraction (320/79-10-20): Accident-Environmental samplers not
calibrated (Item 6). The inspector reviewed Procedure OP 1302-5.24,
" Environmental Monitor Calibration," Revision 4, dated November 26, 1980,
regarding calibration of environmental air samplers which specifies
annual calibrations. The licensee stated that it is intended in the near
future that these calibrations be performed semi-annually in accordance
with Regulatory Guide (Reg Guide) 8.25.
The inspector also reviewed Procedure M-9, " Inspection of Air Environmental
Monitors, Frame Size 24," Revision 2, dated June 20, 1980, describing
quarterly preventive maintenance on the air sampling equipment, and noted-
that this procedure covered those preventive maintenance activities
recommended by the air sampler pump manufacturer.
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The inspector reviewed environmental sampler calibration records as
described in Detail 5.c and noted that calibrations were performed as
required. The inspector had no further questions in this area at this
time.
(Closed) Unresolved Item (289/79-23-01; 320/79-28-01): Responsibility.
and organization of environmental monitoring programs. The inspector
rerwed the current licensee organization responsible for implementing
tne s..vironmental technical specifications (ETS) as described in-Detail 3
of this report and in the licensee's November 18, 1980 response to Combined
Inspection Report Numbers.50-289/79-23 and E9-32/79-28. The inspector
determined that this organization appeared to provide adequate assurance
that the environmental monitoring requirements of the ETS could be satisfied.
The inspector had no further questions in this area at this time.
(Closed) Infrac* ~m (289/79-23-02; 320/79-28-02):
Failure to audit
material includea in environmalta1' monitoring program reports. This item
pertained to the 1978 Annual Report. The licensee's August 14, 1980
response to this item had described the audits performed by or under the
auspices of the TMI-1/ Environmental Impact Assessment Group (now Environ-
mental Controls) following the November 1979 inspection of the area. The-
inspector determined that the 1979 and 1980 Annual Reports had been
reviewed and audited as required prior to their submittal to the NRC.
The inspector also reviewed the additional licensee audits as described
in Detail 3 pertaining to the fulfillment of the ETS requirements. The
inspector had no further questions in the above area.
(Closed) Deficiency (289/79-23-03; 320/79-28-03):
Failure to follow
procedures - environmental monitoring. There were four examples cited
for this item which have been resolved as follows:
a.
Radiological Environmental Monitoring Program (REMP) sample collection
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sheets for the period April - November, 1979 were not available at
the time of the last inspection. These sheets had been located
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since that time and the inspector reviewed the completed sheets.
This particular item is therefore not considered to be part of the
item of noncompliance from combined inspection report 50-289/79-28
and 50-320/79-28.
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b.
Demineralizer regenerant waste neutralizing tank discharge permits
had not been filled out for discharges occurring on several occasions
in 1978 and 1979. The licensee's August 14, 1980 response had
stated that the applicable procedure, OP-2104-2.11, had been modified
and that waste neutralizing tank discharges were no longer directly
discharged to the River but through the Turbine Building Sump, thus
-enabling further treatment as necessary. The licensee also informed
the inspector that there have been no discharges from the waste
neutralizing tank since November 1979. The inspector reviewed the "
modified procedure and had no further questions.
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c. and d. Unit 1 Procedure IC-39 and Unit 2 Procedure 2014-3.8 were included
in a citation for failing to calibrate the plant thermal monitoring
systems during 1978 tid 1979. The inspector reviewed the applicable
revised procedures re ' erred to in the licensee's May 5,1980 response
and determined that the systems had been. calibrated according to
procedures since the last inspection (See Detail 8). The inspector
had r.o further questions at this time.
(Closed) Unresolved Item (289/79-23-04; 320/79-28-04):
Re-evaluation of
air sampler design at station SA1, Met Ed Observction Center. The inspector
reviewed the air sampler located at the observation center and determined
that the design of this sampler was consistent with samplers at other
stations and did not have any excessively long sample lines. There were
no further questions in this area at this time.
(Closed) Deficiency (289/79-23-05; 320/79-28-05):
Failure to collect
and analyze required drinking water samples.
Drinking water samples from
the City of Columbia were not collected for part of 1978.
In the August
14, 1980 response to the inspection, the licensee had stated that additional
water sampling equipment had been obtained as backup for equipment failures
and that the new organization of the environmental monitoring group would
enable increased surveillance of sampling equipment. The inspector
observed the sampling apparatus and set-up at the Columbia water treatment
plant and reviewed the analytical data produced since November 1979 and
noted that these samples had been collected and analyzed as required.
There were no further questions at this time.
(Closed)
Infraction (289/79-23-06; 320/79-28-06):
Failure to collect
and analyze required environmental air particulate and air iodine samples.
The licensee's August 14, 1980 response had detailed several corrective
actions including purchase of additional sampling equipment as replacement
for failed samplers, increased surveillance of samplers, and simplification
of the process for notification of repair personnel wh-r equipment failures
are identified.
The inspector reviewed selected air u.linc stations
and determined through discussiors with the licensee , s review of_ sampling
data and surveillance records thi.z the licensee had been chscking mid-way
through the sampling period any samplers identified as having failed or
having other equipment problems.
The licensee stated that for samplers
which have not been repaired by the time of this mid-week check, another
request for repair would be submitted. Any samplers which can not be
repaireo are replaced. The inspector noted that improvements in reliability
of equipment had been achieved but that overall reliability of the samplers
still appears to be a problem. This area is discussed further in the
transmittal letter for this report and in Detail 5.c.
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(Closed) Deficiency (289/79-23-07; 320/79-28-07):
Failure to collect
and analyze required milk samples.
In the Ma; 5 and August 14, 1980
reply letters the licensee had stated that sub xquent control of sampling
and program review by the Environmental Impact Assessment Group, new
Environmental Controls (EC), would insure collection of all rec 9 red
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samples.
In addition, the licensee stated that EC personnel would be
used to deliver samples directly to the anal 'ical contractors and thereby
reduce the chances of losing samples in transit or through excessive
delay. The licensee stated that at the time of this inspection, EC
personnel were contit.d ng to del'iver samples. The inspector examined the
analytical data and samp:e collection sheets for milk samples collected
since November 1979 and deermined that samples had been collected and
analyzed as required. The inspector had no further questions in this
area at this time.
(t. i o sed) Deficiency (289/79-23-08; 320/79-28-08):
Failure to meet
required analytical sensitivities (a L a see items 289/78-08-04 and
289/77-04-03 for related items). The licensee's August 14, 1980 response
had described the organizational and procedural changes which were intended
to assure that required analytical sensitivites were achieved. The
inspector reviewed the program data obtained since November 1979 and
determined that drinking water and airborne I-131 sensitivities had been
achieved as required. The inspector also determined that the required
analytical sensitivity for "r-89 in drinking water had not been achieved
for all samples, and that this therefore resulted in a related item of
noncompliance (See Detail 5.c).
(Closed) Deficiency (289/79-23-09):
Exceeding the Limiting Condition
for Operation (LCO) for thermal discharges.
The inspector noted that no
thermal discharges had occurred since the last NRC inspection of the area
and that the LCO therefore could not have been exceeded. There were no
further questions in this area at this time.
(Ciosed)
Infraction (320/79-28-09):
Failure to conduct required environ-
mental studies.
The licensee's December 21, 1979 reply described the
organizational and procedural changes which had been initiated to assure
that such a termination of required study prograns could not recur. The
inspector discussed with the. licensee and with the licensee's biological
contractor the current status of all required special study programs and
determined that the cequired fish study programs were being conducted at
the time of the inspection. There were no further questions in this area
at this time.
(C' sed) Deficiency (320/79-28-10):
Failure to submit required report.
T'.e licensee's November 18, 1980 response stated that future thermal
utscharge records would be regularly reviewed to assure that any required
notifications to the NRC were made. The inspector noted that no thermal
discharges had been made since November 1979 and that therefore no reports
to the NRC concerning thermal discharge limits had been required.
There
were no fu.ther questions in this area at this time.
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(Closed) Deficiency (289/79-23-10; 320/79-28-11):
Failure to maintain
reccrds of environmental nonitoring data.
In the November 18, 1980
response the licensee stated that Procedure OP 1104-37 had been revised
such that alternative methods for measurement and recording of thermal
effluent temperatures and AT were described along with priorities for use
of each method. The licensee had stated that adherence to the provisions
of this revised procedure would assure that records were made and maintained
for M 1 periods of thermal discharges. The inspector reviewed Procedure
OP 1109-37, " Mechanical Draft Cooling Tower Operation," Revision 15,
dated March 17, 1981 and noted that the priority for measurement of
discharge AT was specified as ststed as in the November 18, 1980 response.
The inspector also noted that no thermal discharges-had oeen made since
November 1979. There were no further questions in this area at this
time.
(Closed) Infraction (289/79-23-11; 320/79-28-12):
Failure to have-
cdequate procedures.
In the August 14,'1980 and November 18, 1980 response
letters, the licensee had stated that the applicable procedures had been
revised and additionally, a generic sampling procedure (CP 1800.5) had
been written to address the items of noncompliance.
The inspector reviewed
the procedures involved and determined that the identified problem areas
in each had been adequately addressed by the licensee. The inspector had
no further questions in this area at this time.
3.
Management Controls
a.
Organization
The inspector reviewed the licensee's management organization for
implementation of the environmental monitoring programs.
The licensee
stated that the current organization is as described in Amendment 58
to the Appendix A Technical Specification for Unit 1.
Operation of
the environmental monitoring programs at TMI is conducted by the
General Public Utilities Nuclear Group (GPUNG). Under this organiza-
tion,'the EC Radiological Project Manager, the EC Biological Project
Manager and the EC Staff Project Coordinator report to the TMI
Manager of Environmental Controls (EC). The inspecter reviewed a
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July 24, 1980 memo from the TMI Manager of EC which assigned specific
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lead responsibilities for, and the teams to carry out, EC functions.
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The TMI Manager of EC reports to the GPUNG Manager of EC, who also
has responsibility for EC at Oyster Creek Nuclear Generating Station.
The GPUNG Manager of EC reports to Mr. R. Heward, VP - Radiological
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and Environmental Controls in GPUNG. The inspector determined that
this organization appears to offer adequate assurances that the
required environmental monitoring programs can be successfully
carried out, and had no further questions at this time.
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b.
Licensee Audits
The inspector reviewed the following audits as part of this inspection.
Audit
Dates
Areas Covered
Technical Review
December 14, 1979
Radiation Management
Corporation (RMC)
GPU QA Audit
December 12, 1979
Environmental Monitoring (as
- S-TMI-79-06
part of broader audit)
Audit #0-TMI-80-14 December 17-18,
RMC
1980
Audit #S-TMI-81-02
1anuary 13-14,1981 Teledyne Isotopes
Audit #S-TMI-81-01 January 16, 1981
Ichthyological Assosicates, Inc.
The inspector determined that audit findings had been addressed and
corrective actions taken as required and in a timely manner.
No items of noncompliance were identified in this area.
4.
Licensee Program for Quality Control of Analytical Measurements
a.
Radiological Environmental Monitoring Program (REMP)
The inspector discussed with the licensee the quality control (QC)
program for analytical measurements and reviewed Procedure ECP 504,
" Environmental Controls Surveillance Procedure." This procedure
discussed the use of checksheets for each sample medium incorporated
in the REMP and included checks that samples were collected as
required, samples were received by the respective laboratory for
analysis, and that aralytical results were received by EC. Checs.neets
were completed weekly, monthly or quarterly as appropriate for each
sample medium.
The licensee stated that samples are regularly split
between RMC and Teledyne as an additional QC measure, with Teledyne
the primary environmental analytical contractor and RMC acting as QC
lab. The inspector also discussed with the licensee the use of
spikes
-?d to evaluate lab performance in the measurement of
specific
.clides at expected environmental levels, the use of
specific criteria for the acceptance / rejection of QC data, and the
value of complete documentation of program objectives, procedures,
and resuits. The inspector determined that provisions existed for
each of the above points. The licensee stated that the quality
assurance / quality control program was under continual review and
revision by the REMP Review Committee (REMPRC) and that the above
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considerations would be reviewed. The inspector reviewed selected
REMPRC meeting minutes and stated that this area would be re-examined
during a future inspection.
No items of noncompliance were identified in this area.
b.
Biological / Ecological
The inspector discussed with the licensee the biological QC program
including the activities of the licensee's contractor, Ichthyological
Associates (IA). The inspector reviewed selected monthly progress
reports and monthly analysis notification sheets which were submitted
by IA to TMI-EC. The licensee stated that specimen counts were
checked periodically, that only qualified rersonnel perform species
identification, and that outside consultants were used to confirm
species identification as necessary. The inspector had no further
questions in this area at this time.
5.
Implementation of the Environmental Monitoring Program - Radiological
a.
Direct Observations
The inspector examined selected environmental monitoring stations
including some for surface water, drinking water, air particulate,
air iodine, and direct radiation sampling, and noted that all equipment
examined at these stations was functioning properly at the time of
the inspection. The inspector also observed the sampling of on-site
monitoring wells (MW) and observation wells (0W).
Water sampling equipment consisted of automatic compositors at fixed
locations in combination with weekly grab samples from other locations.
Air samplers consisted of filter holders and vacuum pumps with " dry
gas" volume meters in-line between filters and pump. The inspector
discussed with the licensee methods of assuring that filters were
installed properly and with adequate seals after filter changes.
The inspector noted that vacuum gauges were not installed as part of
the air sampling apparatus and discussed with the licensee the need
for accounting for pressure-drop effects across the sampling _ filters
on sample volume measurements and in the calculation of. airborne
radioactivity levels. Because the volume meter is operating at
reduced pressure relative to ambient atmospheric pressure the volume
meter will record a larger volume for the same quantity of ambient
air sampled. Therefore, a correction to this volume measurement is
necessary to " normalize" it to atmospheric pressure. Review of
licensee calibration records, completed at least annually according
to Procedure OP 1302-5.24, "Enviconmental Monitor Calibrations,"
Revision 4, dated November 26, 1980, revealed that the samplers
operate at vacuums within the range of 3.5-10.4 inches of mercury.
A vacuum gauge to measure vacuum has been temporarily installed
during the calibration procedure, although actual operating vacuum
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during sampling is not measured.
The inspector stated that subsequent
correction of sampling results for vacuum effects could have a-
significant impact on sample volumes and therefore on the lower
limits of detection (LLD) for these samples.
The inspector stated
-that the adequacy of air sample volume is considered an unresolved
issue pendirj a determination by the licensee of the magnitude of
compensation necessary for vacuum effects on discrete weekly samples
and the implementation of appropriate corrections (289/81-09-01;
320/81-09-01).
b.
Review of Reports
The inspector reviewed portions of the 1979 and the 1980 Annual REMP
Reports as part of this inspection and verified licensee followup
and resolution of technical problems and exceptions to reported data
as described in the reports. No items of noncompliance were identified
in this area.
c.
Other Records
The inspector reviewed selected records of REMP data collected since
the last NRC inspection of this area and noted that samples had
included the media required by the ETS and were collected at the
frequency required by the ETS. The inspector determined that the
LLD for Sr-89 in drinking water specified by Table 3 of Section 4.4
of the Unit 1 ETS had not been achieved at Station _7G1, City of
Columbia, for the fourth quarter of 1979 or for the first three
quarters of 1980. The inspector noted that prior to the end of this
inspection, the licensee had sent instructions to both analytical
contractors that redefined the LLD to be achieved for this analysis.
The licensee stated that the contractor labs had in error been given
an incorrect LLO of 5 pCi/l to achieve. The licensee agreed that
the ETS specified value of 1 pCi/1 could be reached by the labs.
The inspector stated that failure to achieve the required LLO was.an
item of noncompliance (289/81-09-02). The inspector also noted that
the impact of this failure was minimal since the LLD achieved was <
5 pCi/1, and the Unit 2 ETS, in line with proposed Reg Guide 4.8, do
not contain any requirements for Sr-89 analyses.
The inspector reviewed air sampling data, calibration procedures and
data, and routine preventive maintenance procedures and data sheets.
The inspector noted that there appeared to be a relatively high
frequency of mechanical problems with the air sampling equipment.
In the past such problems had resulted in extended periods of sampler
outage and subsequent loss of samples (see Combined Inspection
Report 50-289/79-23 and 50-320/79-28).
In response to this problem
the licensee had increased surveillance of the equipment and had
instituted a preventive maintenance program.
The TMI-EC group now
rechecks faulty equipment again within three days to determine if
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requested repairs have been completed, and will issue another mainten-
ance request if necessary. The inspector also reviewed Procedure
M-9, " Inspection of Air Environmental Monitors," Revision 2 (June
20,1980), which had been performed quarterly beginning in 1980, and
nuted that this procedure incorporated all the preventive maintenance
recommendations of the vacuum pump manufacturer. The inspector
discussed with the licensee the overall reliability of the air
sampling equipment.
The licensee stated that the reliability of
this equipment would be reviewed, and the inspector stated that this
review and any subsequent action to_ improve equipment performance
would be re-examined during a future inspection (289/81-09-03;
320/81-09-02).
The inspector noted that past calibrations had occasionally resultcJ
in lost samples or in reduced sample volumes due to improper handling
of filters during the calibration procedure.
The licensee had
instituted a program of EC personnel participation in future calibra-
tions to assure that samples will be maintained. The inspector
stated that the effectiveness of this corrective action would be
reviewed during a subsequent inspection.
6.
Implementation of the Environmental Monitoring Programs - Biological /
Ecological
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a.
Direct Observation
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The inspector toured the laboratory facilities of the licensee's
biological contrattor and observed the processing of sediment samples
in the lab. No items of noncompliance were identified in this area.
b.
Reports and Records
(1) Routine
The inspector reviewed portions of the following reports as
part of this inspection.
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An Ecological Study of the Susquehanna River near the
Three Mile Island Nuclear Station: Annual Report for 1979
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1979 Annual Environmental Operating Report
1979 Monitoring of Cooling Tower Operational Effects on
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Vegetation in the Vicinity of TMINS
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1979 Hydraulic Survey
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An Ecological Study of the Susquehanna River near the
Three Mile Island Nuclear Ststion: Annual Report for 1980
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1980 Annual Environmental Operating Report
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1980 Monitoring of Cooling Tower Operational Effects on
Vegetation in the Vicinity of TMINS
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1980 Hydraulic Survey
The inspector determined that the above reports contained the
specified information (with the exception of the fish studies
omitted from the 1979 Ecological Study as discussed in Detail
2) and were submitted as required. 'The inspector had no further
questions in this area at this time.
(2) Non-Routine
The inspector also reviewed the circumstances and licensee's
evaluations relative to Noncompliance Notifications (NN) 80-01
and 80-02 (March 3, 1980) concerning oil and grease discharges.
The licensee stated that the corrective action was to increase
operator surveillance at the Industrial Waste Treatment System
(IWTS), and the inspector noted that such discharg(s had not
recurred. The inspector also discussed the evaluations of NN
80-03 (June 19,19C0) and NN 80-04 (February 23,1981) concerning-
exceeded discharge pH limits and pH monitoring, and failure to
- ollect the minimum number of oil and grease samples during
December, 1980. The inspector noted that the environmental
impact of these occurrences was negligible and that there had
not been recurrences. Also discussed was NN 80-015 (which
discussed a July 21, 1980 occurrence) concerning discharge AT
limits and calibration error in the River Water Outlet Temperature
instrument loop. The inspector discussed with the licensee the
corrective actions taken including corrections to the system
troubleshooting procedure and calibration methodology.
The inspector had no further questions in this area at this
time.
No items of noncompliance were identified.
7.
Meteorology
The inspector examined the licensee's meteorological monitoring program
and discussed with the licensee the operation, maintenance and calibration
of the meteorological monitoring equipment. -The inspector reviewed
semi-annual calibration records completed by the licensee's contractor
and the licensee's calibration of the associated computer system and
control room recorders. The licensee also performed weekly equipment
functional tests according to Procedure IC-41.
The inspector noted that
the equipment was functioning as required at the time of the inspection.
No items of noncompliance were identified in this area.
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8.
Nonradioactive Release Rates and Limits
The inspector reviewed the thermal monitoring system and system calibrations
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performed at 18 month intervals according to Procedure 2322-R2, Revision
1 (July 26, 1978), and OP 1302-5.33, Revision 0 (June 5, 1980).
Calibrations
had been performed as' required since the last NRC inspection in November
1979, and no thermal discharges had been made since that time. Also
reviewed was tFe priority for sources of thermal data as specified by
Procedure OP 1104-37, Section 3.4.3, " Operation When Normal Temperature
Indication Not Available" (Revision 15, March 17, 1981).
The inspector also reviewed the licensee's chemical discharge mcnitoring,
including Procedure OP 1104-18, Revision 12 (February 2,1981), Makeup
Demineralizer Neutralization Tank Discharge," Procedure SP_1301-9.10,
Revision 4 (November 11, 1979), " River Water Discharge Sampling," and
generic sampling procedure CP 1800.5, Revision 0 (September 30, 1980).
The inspector determined that these procedures-addressed the related
noncompliances described in Combined Report 50-289/79-23 and 50-320/79-28
(see Detail 2 for further information).
9.
Unresolved Items
t.: resolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of noncompliance-
or deviations. One unresclved item was disclosed during this inspection
and is discussed in Detail 5.c.
10.
Exit Interview
On May 1, 1981, at the conclusion of the inspection, the inspector met
with those' individuals denoted in Paragraph 1, at the EC offices at
Harrisburg Airport in Middletown, Pennsylvania. During the meeting the
purpose and scope of the inspection were summarized and the inspection
findings were discussed. The licensee acknowledged the item of noncompliance.
,