ML20137H451

Responds to Questions Asked on 961217 Re Offsite Spike in Data from Citizens Radiological Monitoring Network Surrounding Plant.Excerpts from Insp Rept 50-293/96-10 on 970207 Encl

ML20137H451
Person / Time
Site:	Pilgrim
Issue date:	03/24/1997
From:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Ott M AFFILIATION NOT ASSIGNED
Shared Package
ML20137H454	List: ML20137H451 ML20137H461
References
NUDOCS 9704020237
Download: ML20137H451 (19)

See also: IR 05000293/1996010

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March 24,1997

Ms. Mary Ott

196 Chestnut St.

Duxbury, Massachusetts 02332

SUBJECT: Radiological Monitoring Data For December 6,1996

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Dear Ms. Ott:

This letter is in response to questions you asked Richard Laura, the NRC Senior Resident

inspector at the Pilgrim Nuclear Power Station, on December 17,1996 concerning an

offsite " spike" in the data from the citizen's radiological monitoring network surrounding the

Pilgrim Nuclear Power Station (PNPS). Immediately after that telephone conversation,

Jack Hoover, the citizen's radiological network representat:ve, contacted the NRC at your

request providing a graph of offsite data for December 1 - 7,1996. Our staff in Region I

reviewed the graph and identified several follow-up actions which have been completed.

Enclosure 1 to this letter contains an excerpt from NRC Inspection Report 50-293/96-10,

dated February 7,1997, that documented our review of onsite activities at the PNPS during

the subject time period. The plant operated at or near full power with no unusual activities

in progress. Based on our review of a plant computer print-out of hourly average effluent

readings, the gaseous effluent releases from PNPS were significantly less than the technical

specification limits. Further, as part of the core NRC inspection program, an NRC Region I

specialist inspector recently completed a planned inspection of the gaseous effluent control

program at PNPS as documented in NRC inspection Report 50-203/96-08, dated December

18,1996. Enclosure 3 is an excerpt of the pertinent section and please note that the

violation cited has nothing to do with the subject " spike").

We also contacted Robert Hallisey, the Commonwealth of Massachusetts Director of the

Radiation Control Program, to evaluate the characteristics and significance of the offsite

spike on December 7,1996. His review has concluded that the subject " spike" in radiat.on  ;

level was unlikely due to Pilgrim effluents. Based on the review of the PNPS onsite and j

offsite gaseous effluent data, public health and safety was always maintained with the 1

releases from PNPS significantly less than technical specification limits. We encourage you

and other interested citizens to discuss these effects with representatives of the

Commonwealth.

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9704020237 970324

PDR ADOCK 05000293

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Ms. Mary Ott -2-

I believe this information addresses your questions, and if you have any further questions

for onsite activities please call Richard Laura at 508-747-0565 or for offsite radiological

monitoring questions contact Robert Hallisey at 617-727-6214.

Sincerely,

,sAf

harles W.L.

.Hehl , Director

Division of Reactor Projects

Enclosures: As Stated

cc:

Mr. R. Hallisey, Commonwealth of Massachuesetts

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R. Laura, RI '

H. Eichenholz, RI l

R. Bores, RI i

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l' M. Oprendek, DRP (Al 96 046)  !

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,DATE 037/97 7 03/ T/97h'bm.N' 03/jy/97 03/ /97 03/ /97

OFFICIAL RECORD COPY

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Enclosure 1

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Excerpt from

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NRC Inspection Report

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50-293/96-10

l Dated February 7,1997

l Onsite Operational Activities

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IV. PLANT SUPPORT

R1 Radiological Protection and Chemistry (RP&C) Controls

R1.1 Gaseous Activity Release Review

a. I_nsoection Scooe (71750)

A review was performed of main stack, offgas and reactor building ventilation gaseous

release data from December 6 - 9,1996 to verify compliance with technical specification

(TS) limits. During this time period, the reactor operated at or near full power.

b. Observations and Findinos

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The inspector obtained an EPIC plant computer printout for the hourly averages of gaseous

activity for the reactor building ventilation release rate (microcuries/sec.), offgas release rate j

(MR/HR) and main stack release rate (microcuries/sec.). Chemistry personnel routinely add

the hourly average readings each day to develop a total 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> release number which was

compared to TS limits. Inspector review of the hourly average readings detected no

unusual or inconsistent increases in the gaseous release data for 12/6-9/96. In all

instances, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> total release data for main stack and reactor building ventilation was

much less than 1.0% of the TS release limits.

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c. Conclusions i

No unusual or inconsistent increases occurred in the gaseous releases from PNPS to the

environment during December 6 - 9,1996. The main stack and reactor building ventilation

24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> release totals were less than 1.0% of the TS limit and no unusual spikes occurred

in the hourly average readings. Positive chemistry performance was noted.

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Enclosure 2

Excerpt from

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l 50-293/96-08

i Dated December 18,1996

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i; Gaseous Effluent

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j Control Program

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l IV. PLANT SUPPORT

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l R1 Radiological Protection and Chemistry (RP&C) Controls

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l R1.1 (Open) VIO 96-08-02: Imolementation of the Radioactive Effluent Control Proaram

(RECP)

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l a. Insoection Scone (84750)

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The inspector evaluated implementation of the RECP through a review of radioactive liquid

effluerit release permits and radioactive gaseous effluent release reports, associated

I procedures, sampling performance, the licensee's method for quantifying radioactive liquid

and gaceous releases, the recent revision of the Offsite Dose Calculation Manual (ODCM),

and projected dose calculations. The above areas were inspected against Section 3/4.8 in

the TS, the ODCM, and UFSAR commitments.

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b. Observations and Findinas j

Selected radioactive liquid release permits from the neutralizing sump and miscellaneous

tanks, and weekly and monthly reports from the reactor building vent (RBV) and main stack l

were complete. The liquid release permits contained pertinent information such as a

description of the tank or sump, the volume of liquid in the tank or sump, and activity

concentration. Similarly, the gaseous effluent reports included results of weekly air j

particulate and charcnal sample analyses, and monthly and quarterly composite analyses, i

The licensee's method for quantifying radioactive liquid and gaseous releases were

performed according to the ODCM.

The permits are the records of all routine releases from the plant and the sample results are

used to calculate the projected doses to the public. The inspector reviewed the dose

calculations from January to October 1996. The doses to the public, as a result of liquid

and gaseous effluent, were calculated by a Senior Environmental Radiochemist weekly, 1

more frequently than required by TS. The permits, dose projections, and assessments were l

verified by a Chemistry Manager. The dose projections were performed according to the  !

methods described in the ODCM and are below regulatory limits. I

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The inspector observed a chemistry technician exchange the charcoal cartridge and

particulate filter, and collect a noble gas sample from the RBV. The technician followed l

Procedure No. 7.3.25, " Particulate and lodine Monitoring at the Main Stack and the Reactor l

Building Vent," and Procedure No. 7.3.37, " Determination of Conversion Factors for

Gaseous Plant Vent Monitors," and demonstrated satisfactory sampling techniques and l

practices.

Review of the sample and analytical program revealed the sample and analytical frequency

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for the neutralizing sump, as established by the licensee, was inconsistent with TS. The

l inspector verified on October 1,1996, that the sample and analytical frequency of the

l neutralizing sump had not been conducted in full compliance with the Technical

l Specification 4.8.A.L Table 4.81 up until third quarter 1994. Technical Specification

l 4.8.A.1 states, in part, that monthly composites shall be analyzed for tritium (H-3) and

I gross alpha radioactivity and quarterly composites shall be analyzed for strontium-89

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(Sr-89), strontium-90 (Sr-90), and iron-55 (Fe-55). The licensee analyzed for gross

gamma, iodine-131 (1-131), and entrained and dissolved noble gases on each batch prior to

discharge, as required, but did not sample and analyze the monthly and quarterly

composites from this sump if no gamma activity was detected. This practice was described

in Procedure No. 7.9.5, " Waste Neutralizing Sump Discharge Procedure," which allowed the

normally non-contaminated sump to be discharged as a non-radiological release based on

the non-detection of any gamma-emitting activity. When no gamma activity was detected,

the procedure contained no provisions for the collection and analyses of monthly and

quarterly composites for Sr-89, Sr-90, Fe-55, H-3, and alpha activity.

A batch sample result in July 1994 indicated gross gamma activity and H-3 in the

neutralizing sump. Chemistry investigated the source of the H-3 and discovered that the

neutralizing sump, usually used for non-contaminated liquids, had been receiving water from

the Turbine Building Closed Cooling Water (TBCCW) system since June 1993. The licensee

determined the cause was a degraded seal between TBCCW and feedwater in the outboard

seal of the "A" Reactor Feed Pump (P-103A). The licensee repaired the leak in November

1994. Since the neutralizing sump was considered " contaminated", after this finding, the

licensee followed a different procedure (Procedure No. 7.9.2, " Liquid Radioactive Waste

Discharge") and analyzed the sump samples as required by TS. Although implementation of

the technical specification after July 1994 is evidenced through records of sample results,

this is not considered corrective action because the licensee did not recognize the

noncompliance and as a result, the Procedure No. 7.9.5 would again permit discharges

without compositing and analyzing if gamma activities again dropped.

The results of the July 1994 batch indicated a concentration of 6.23E-4 microcuries per

milliliter ( Ci/ml) of H-3 in the neutralizing sump. (No other radionuclides were detected.)

Lacking any other reference analysis-confirming previously released contents were not

similarly contaminated, this concentration was assumed to have been released from each

batch and the discharges were re-evaluated by the licensee back to June 1993 when H-3

was assumed to have entered the system. Based on this information, the licensee

corrected the quarterly dose reports and determined the total amount of H-3 released

increased slightly from 2.61 Ci to 2.66 Ci, the dilution increased from 1.63E9 liters to

1.87E9 liters based on the actual amount of water discharged, and the total body dose to

the maximally exposed member of the public from allliquid pathways decreased from

6.OE-2 mrem /qtr to 5.2E-2 mrem /qtr for the second quarter in 1993. Corrections were

performed for the subsequent quarters and the results were similar. The dose effect was

inconsequential, given the amount of dilution volume and negligible change in reported H-3 L

activity. The licensee documented the correction in the Semi Annual Effluent Release l

Report for 1994. Consequently, the inspector confirmed that this matter did not result in I

any safety consequence to public health and safety or the environment. The failure to ,

sarrpie and analyze monthly and quarterly composites of the neutralizing sump to analyze l

tbc non-gamma activity, in accordance with the requirements of the applicable technical

specification, constitutes a violation of TS 4.8.A.1, Table 4.8-1 (VIO 50-293/96-08-02).

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c. Conclusion

Overallimplementation of the radioactive liquid and gaseous waste sample and anal;tical

programs was very good, however the observed inconsistency and associated violation

indicated a need for thorough review of procedures, the technical specifications, and

management oversight. The violation appeared to be isolated to the sample and analytical

requirements of the technical specification regarding the neutralizing sump because the

associated discharge procedure inadequately conveyed the intent of the technical

specification.

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The licensee's assessment and evaluation were appropriately documented using a j

conservative approach to assess the total quantity of tritium that may have been released I

during the periods in question and the resultant cont ibution to total dose to the j

environment. The licensee's assumptions were valid and reasonable, the additional tritium j

contribution to dose to the public was negligible. I

R1.2 Radioactive Liauid and Gaseous Effluent and Process Instrumentation

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a. Inspection Scope (84750)

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Setpoints and operability for the liquid and gaseous effluent and process monitoring j

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iristrumentation were inspected against TS Sections 3/4.8.B and 3.4.8.E, the ODCM, and

the UFSAR. l

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b. Observations and Findinas

Operability was demonstrated by performing the channel calibrations and functional tests

for the following Plant Radiation Monitors (PRM):

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- Main Stack Effluent Monitoring System

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Reactor Building Ventilation Effluent Monitoring System

- Steam Jet Air Ejector Radioactivity Monitor

The electronic and radiological calibrations and the functional tests were performed at the

frequencies specified by TS. The results of these calibrations were within the established

acceptance criteria prescribed in the associated procedures. The calibrations were

performed using standards traceable to the National Institute of Standards and Technology

(NIST), as recommended by Regulatory Guide 1.21. The functional tests verified that the

instruments were functioning properly. A Chemistry Manager reviews the results of the

calibrations and compares the results to the previous year to verify reproducibility,

reliability, and stability of the systems.

The setpoints were determined using the methods in accordance with the ODCM. The

inspector observed the licensee calculate the setpoint using Procedure No. 7.3.37,

" Determination of Conversion Factors for Gaseous Plant Vent Monitors."

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The inspector observed the readouts of effiuent PRMs in the main control room and toured

the turbine building and reactor building vent PRMs. The PRMs were operable with their

alarm / trip setpoints set to ensure that the limits specified by TS would not be exceeded,

c. Conclusions

The inspector concluded that the licensee has an excellent program to ensure operability of

the radioactive effluent and process instrumentation. No discrepancies were noted in either

the TS, the UFSAR, or ODCM.

R1.3 Testina of Air Cleanina Systems

a. Insoection Scooe (84750)

The licensee's program for testing the following air cleaning systems was inspected against

specific criteria in TS 3.7.B, and compared to the standards of ASME N510-1989, " Testing

of Nuclear Air Cleaning Systems." Commitments in the UFSAR were also reviewed.

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Standby Gas Treatment System (SBGT)

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Control Room High Efficiency Air Filtration System (CRHFS)

b. Observations and Findinas

The following tests were included:

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- HEPA filter bank in-place test

- adsorber bank in-place test

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airflow capacity test

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precsure drop test

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laboratory testing of adsorbent

The inspector toured the areas of the SBGT and the CRHF systems. During the tour, train B

of the SBGT was operating. The licensee proceeded to conduct a check of the train

including a verification that the pressure drop across all the filter banks was less than 8 !

inches of water. Using the Procedure No. 8.7.2.1, " Measurement of SBGT Filters and Fan i

Capacity", the licensee verified the pressure drop was within the criteria. l

The procedures provided the required guidance to perform the above tests and meet the TS

criteria. All reviewed test results met the criteria specified by TS. The tests were

performed at frequencies specified by TS.

c. Conclusion

The inspector concluJeu that the licensee had implemented the TS requirements for testing

the air cleaning systems effectively. No discrepancies in the UFSAR were noted.

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R 1.4 Imolementation of the Radioloaical Environmental Monitorina Proaram

a. Inspection Scope (84750)

The inspector observed and assessed the licensee's capability to implement the radiological

environmental monitoring program (REMP). The program was inspected against Sections

7.0/8.0 of the Technic il Specifications (TS), Section 7.0 of the ODCM and Sections 2.6

and 7.14 of the Updated Final Safety Analysis Report (UFSAR).

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b. Observations and Findinas

The REMP was governed by administrative and implementing procedures, some of which 1

were reviewed for technical content and application.

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Procedure 7.12.1, Administration of the Radiological Environmental

Monitoring Program

Procedure 7.12.5, Review and Evaluation of REMP Results

Procedure 7.12.10, Assuring Proper Sampling Schedule is Maintained

Procedure 7.12.25, Air Particulate and Air lodine Filter Preparation and

Collection

Procedure 7.12.30, Surface Water Sampling l

Procedure 7.12.35, Milk Sampling

Procedure 7.12.40, Exchanging TLDs

Procedure 7.12.60, Garden Census i

Procedure 7.12.65, Milk Animal Census

Procedure 7.12.80, Maintenance and Calibration of the Nuclear Air Sampler

and Standard Sprague Dry Gas Meter  !

The above procedures, written to provide guidance for implementing the REMP, were clear, ,

concise, and of very good technical content. Adherence to the procedures was evidenced )

through review of detailed documentation of discrepancy reports and logs; records of j

sample submission forms; reports of analytical results of environmental samples; records of l

air sampler calibration results; and visiting selected air, water, and milk sampling stations

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and locations where thermoluminescent dosimeters had been posted. Thc inspector

observed contractor personnel, General Test Division (GTD), collect a " grab" sample of

water from an upstream location and water from the compositor located at the discharge

canal, collect milk and silage from the indicator farm, exchange air particulate filters and air

iodine cartridges from the air samplers, and exchange certain thermoluminescent

dosimeters.

Procedures 7.12.60 and 7.12.65 were used to conduct the Land Use Census required by

TS. The census, performed in 1995, detailed garden and milk locations within 5 miles

around the site. The results confirmed no significant changes from the previous census.

The results were published in the annual REMP report. The census for 1996 had been

recently performed, therefore, the results were preliminary. The finalized results will be

published in the REMP report for 1996.

Included within this inspection was a review of the effect, if any, of Hydrogen Water

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Chemistry (HWC) to members of public and environment using environmental TLDs.

Quarterly environmental and onsite TLD results from 1990 - 1996 were compared as a

mechanism for determining the impact of the HWC. It was noted that a certain onsite TLD

showed an average delta dose increase of 13 mR/qtr base.1 on an average dose before and

after HWC. Other site TLDs were compared and simih results were noted. The

environmental TLDs showed no increase, evidenced oy the quarterly results published in the

annual REMP report and confirmed in NRC ccIlocated TI.Ds close to the site published in

NUREG-0837, "NRC TLD Direct Radiation Monitoring Network."

No significant changes were made to the ODCM during 1995 and 1996 regarding the

REMP. No deviations from the UFSAR regarding REMP commitments were noted.

c. Conclusion

Based on the above review, direct observations, discussions with personnel, and

examination of procedures, the inspector determined that: (1) trending the impact of HWC

on the environment and the public was an excellent initiative; and (2) the REMP continued  ;

to be excellent and implemented in accordance with the TS, ODCM, and UFSAR l

commitments.

R1.5 Meteoroloaical Monitorina Proaram (MMP) I

a. Inspection Scope (84750) i

The MMP was evaluated to determine whether the instruments and equipment were

operable, calibrated, and maintained according to the Emergency Preparedness

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Administrative Procedure, the Emergency Plan, and Section 2.3 of the UFSAR.

b. Observations and Findinas

The Facilities and Equipment Team of the Emergency Preparedness Department continued to

have responsibility to ensure that surveillances, calibrations, and maintenance of the

meteorological monitoring equipment was performed. Contractors from GTD are responsible

for performing weekly surveillances, which include maintenance as needed, and quarterly

calibrations. Execution of surveillances, calibrations, biweekly exchanges of the strip chart l

recorder paper, and any occurrences pertaining to the primary and secondary towers were  ;

documented in a log book. The results of surveillances and calibrations were sent to the l

Facilities and Eauipment Specialist for review of completeness and filing. The results of the l

surveillances and calibrations were within the defined acceptance criteria, documented in j

Procedure No. EP-AD-421, " Surveillance, Maintenance, and Calibration of MeDAP l

Equipment."  ;

The primary meteorological tower is equipped with wind speed, wind direction, and

temperature sensors at the 33-foot and 220-foot elevations, and the 160-foot backup tower i

is equipped with wind speed, d?ection, and temperature sensors at the 33-foot and 160- I

foot levels. The inspector observed the sensors and their readouts and noted that the

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meteorological data were available in the equipment house via digital display using a

j portable computer and in the control room via digital display from the system computer, and  !

j via analog strip chart recorders as noted in the UFSAR, Section 2.3.  ;

The inspector witnessed a portion of the weekly calibration check of the meteorological

instrumentation at the primary tower, including an examination of the strip chart recorders

to verify the expected response to the calibration. The results were within the acceptance

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criteria. The chart recorders in the control room and the instrumentation at the primary

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tower were well maintained at the time of the inspection.

During a quarterly calibration in May 1995, the cable used to raise and lower the tower ,

instrumentation snapped, causing the instrumentation to slide down the tower resulted in  !

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damaging the instrumentation. A Problem Report was generated, the root cause analysis

was performed and immediate and long-term corrective actions were recommended and i

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implemented to prevent recurrence. One recommendation was to revise the procedure to

} affect certain inspections and maintenance performed quarterly, yearly, and/or every five

i years. While the primary tower was inoperable, the backup tower became the primary

source for , :teorological data.

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The inspector ruviewed Procedure No. EP-AD-421, " Surveillance, Maintenance, and .

Calibration of MeDAP Equipment," Revision 2, dated December 15,1995, and verified

incorporation of preventive maintenance.

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c, Conclusion ,

a Based on the above review, direct observations, discussions with personnel, and

! examination of procedures and records for calibration of equipment, the inspector

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determined that: (1) calibrations and maintenance of the equipment were performed .

according to the procedure, (2) system reliability was high, and (3) the licensee continued to

1 implement the program in accordance with UFSAR commitments and Regulatory Guide 1.23

recommendations.

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R6 RP&C Organization and Administration

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R6.1 Oroanization Chanoes and Responsibilities

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a. Inspection Scope (84570)

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. The inspector reviewed any organization changes and the responsibilities with the

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b. Observations and Findinos

Tnere were no significant organization changes relative to oversight of the Radioactive

j Effluent Control Programs, since the previous inspection conducted in October 1995.

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c. Conclusion

Based on discussion with the responsible personnel and the results of this inspection, the

inspector determined that oversight of the effluent programs essentially remained

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R6.2 Semiannual Radioactive Effluent and Waste Disposal Reoorts

a. Insogntion Scope (84570)

The Semiannual Radioactive Effluent and Waste Disposal Reports and the Annual Dose

Assessment to the General Public from Radioactive Effluents reports were reviewed to '

verify the implementation of Section 6.9.C.1 of TS. '

b. Observations and Findinas

The semiannual reports for 1993,1994,1995 and first half 1996 provided a

comprehensive summary of the total released radioactivity in liquid and gaseous effluents.

Each report was submitted in accordance with the technical specification and was in

accordance with Appendix B of Regulatory Guide 1.21 (Revision), dated June 1974. For

example, the number of abnormal (unplanned or uncontrolled release of radioactive material

from the site boundary) relaases, including the total curies of radioactive materia! released,

were documented in these reports, if such a release occurred. included was a brief

discussion of the release and a projected dose assessment was performed and documented,

as required. No obvious omissions, mistakes, anomalous results and trends were noted.

A supplemental report, the Annual Dose Assessment to the General Public from Radioactive I

Effluents, contained detailed summaries of the projected dose to individuals and populations

from all exposure pathways during the previous year as a result of plant operation.

Changes to the Offsite Dose Calculation Manual (ODCM) were submitted, as required in the

effluent reports.

c. Conclusion

Based on the above review, the inspector concluded that the licensee effectively

implemented the Technical Specifications for reporting effluent reknes and dose j

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assessment to the public and determiled that the responsible personnel are dedicated and

highly knowledgeable in this area.

R6.3 Manaaement Controls

a. Insoection Scope (84570)

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l The inspector reviewed organization changes and the responsibilities relative to oversight of  !

the REMP and MMP, and the Annual Radiological Environmental Monitoring Report to verify

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b. Observations and Findinas  !

i There were no major changes in the organization and responsibilities pertaining to oversight

of the REMP and MMP since the previous inspection conducted in March 1995. Although l

titles had been changed, the reporting chain was similar to that of the previous inspection I

and the responsible personnel cognizant in these programs essentially remained the same. ,

The Annual Radiological Environmental Monitoring Reports for 1994 and 1995 provided a

comprehensive summary of the results of the radiological environmental surveillance ,

activities for the report period including a summary of the results of analysis of all  ;

radiological environmental samples and environmental radiation measurements taken from ,

locations specified in the ODCM, results of the land use census, and an assessment of the '

observed impacts nf the plant operation on the environment around the Pilgrim site. The  !

l results of these analyses and measurements were summarized and tabulated in the format

of the table in the Radiological Assessment Branch Technical Position, Revision 1,

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November 1979. Discussions of program deviations from the sampling schedule of i'

Table 8.1-1 were documented in the report. These program deviations were discussed with

cognizant personnel. The inspector determined that the deviations did not negatively _

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impact the intent of the environmental sampling program.  ;

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Analytical data from 1996 were reviewed for sample frequency and analysh requirements  !

l as specified in Section 7.0 of TS. The data indicated no obvious impact to the environment

public as a result of plant operation. The reports contained no omissions, mistakes, obvious  ;

j anomalous results and trends.

c. Conclusion

The inspector determined that the licensee implemented very good management control and

oversight of the REMP and MMP ano effectively implemented Section 6.9.C.2 of the TS

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requirements.

R7 Quality Assurance in RP&C Activities  !

R7.1 Quality Assurance Audit and Surveillance Proaram  !

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a. Insoection Scope (84750)

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Quality Assurance (QA) Audit 95-12 Chemistry Programs and several surveillances were

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b. Observations and Findinas l

No deficiencies had been identified in the report; however, five recommendations had been  !

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docurm ited for review and consideration to enhance the chemistry programs.

The audit was performed by the Quality Assurance team and was of sufficient technical ,

i depth and scope to effectively assess the quality (strengths and weaknesses) of the

program.  ;

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c. Conclusions  !

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The inspector concluded that the QA team conducted an audit of sufficient technical depth

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and adequately assessed the quality of the radioactive effluent control programs.- '

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R7.2 Quality Assurance Audit Proaram .

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a. Insoection Scope (84750) i

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l The Quality Assurance audit and surveillance reports of the REMP and MMP were reviewed . i

l against criteria contained in the Quality Assurance Department procedures, the Emergency l

l Plan, and Regulatory Guide 1.33. ,

b. Observations and Findinas -i

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Audit 95-10, " Radiological Environmental Monitoring Program" dated November 13,1995, I

was performed by Quality Assurance Team personnel and a technical specialist during the

period October 16 - November 1,1995. Procedure No.18.01, " Preparation, Performance,  !

Reporting, and Follow-up of Quality Assurance Department Internal Audits" was used as  !

guidance. The audit. scope included air sampler calibration and filter exchanges, TS and l

ODCM requirements, REMP procedures, sample preparation, collection and analysis, self- ,

assessment process, and eight QAD surveillances. No findings, three recommendations, l

and two previously identified items were reviewed and documented. 'j

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One surveillance, Surveillance No. 96-15, " Milk Sampling," dated February 15,1996, was

conducted to supplement the next REMP audit, scheduled for October 1996. No findings or

deviations were noted as a result of the surveillance. {

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c. Conclusion j

The inspector concluded that the QA team conducted an audit of sufficient technical depth j

to adequately assess the quality of the radiological environmental monitoring and the j

meteorological monitoring programs. _ The audits were performed in accordance with the l

guidance of the procedure and Regulatory Guide 1.33, " Quality Assurance Program i

Requirements (Operation)."

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R7.3 Quality Assurance of Analytical Measurements

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a. Inspection Scone (84750) '

The inspector reviewed the quality assurance (QA) and quality control (OC) programs

against the recommendations of Regulatory Guide 4.15, " Quality Assurance for Radiological

Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" to

determine whether the licensee had adequate control with respect to sampling, analyzing,

and evaluating data for the implementation of the REMP. )

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b. Observations and Findinas )

The inspector reviewed the " Semi-Annual Quality Assurance Status Reports" for 1995 and ,

the first half 1996, which summarized the analytical results from the blind duplicate (split) J

samples and interlaboratory programs. Most of the results were within the acceptance  !

criteria. Where discrepancies were found, reasons for the differences were investigated and

resolved.

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c. Conclusion i

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The inspector determined that the licensee continued to implement a very good quality I

assurance program in accordance with regulatory requirements. I

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P1 Conduct of EP Activities )

P1.1 Emeroency Preparedness Emeroency Exercise (71750) l

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a. Insoection Scope

BECo conducted a Pilgrim station emergency preparedness exercise on October 16,1996.

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l The inspector reviewed the exercise scena~io and observed BECo's emergency response in

1 the operations support center (OSC) and technical support center (TSC) to evaluate

l emergency responsa organization performance. In addition, the inspector attended the

subsequent formal critique presented to senior station managers on October 23 to assess

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the comprehensiveness of the review.

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b. Observations and Findinas

The annual emergency evaluated exercise was evaluated by Pilgrim evaluators and

controllers. An NRC ovaluation team did not witness the exercise this year, as allowed by

the revised rules in 10CFR50 Appendix E. The Massachusetts Emergency Agency (MEMA)

and the Massachusetts Department of Public Health (MDPH) partially participated by

sending representatives to the emergency operations facility IEOF).

This year's exercise had a number of objectives in the areas of exercise planning,  ;

emergency response organization (ERO) performance, incident assessment and

classification, notification and communications, and radiological consequence assessment.

The scenario included a steam leak, p!ane crash, loss of offsite power, and loss of reactor

coolant and exercised the organization through the most serious emergency classification of

General Emergency. As observed in the September activation drill documented in IR 96-06,

new, ORC-approved emergency plan implementing procedures were used during the

exercise.

The inspector observed prompt ERO response tu the OSC and TSC as evidenced by TSC

and OSC activation within 30 minutes of the Alert declaration. The OSC checklist and  ;

habitability determination were performed as required by procedure EP-IP-230, OSC

Activation and Response. The Emergency Plant Manager frequently briefed the OSC/TSC as

plant conditions changed. The inspector also observed OSC Supervisor briefings when the

task list became large. These briefings served to focus OSC coordinators on high priority

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items and keep them apprised of OSC-related tasks. This observation indicated

improvement from the full-participation evaluated exercise in December 1995, as

documented in NRC IR 95-25, Section 8.0.

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The inspector noted good communication between the Radiological Protection Coordinator

in the OSC and the Radiological Supervisor in the TSC which aided timely dispatch of OSC

field teams. The OSC Supervisor suggested that the craft personnel don modesty garments  ;

while waiting for task assignments to reduced the time for field team deployment. The )

response organization followed the new procedures well, as noted when a task was j

assigned to retrieve modesty garments from the plant.

The exercise critique provided a detailed review of objectives, areas for improvement and I

corrective action, and the identified weakness. BECo assessment of the critique was  !

thorough and balanced. Observations made by the inspector were verified to be captured l

by the drill evaluators. l

c. Conclusions

The 1996 Pilgrim Station Emergency Preparedness Exercise was conducted well. Observed

response organization actions in the OSC and TSC were appropriate and in accordance with

ernergency implementing procedures. The Emergency Plant Manager and OSC Supervisor

conducted timely b iefings to update OSC and TSC pe" onnel on plant conditions,

emergency declarations, and task priorities and status. Good communication between the

Radiological Protection Coordinator in the OSC and the Radiological Supervisor in ine TSC

aided timely dispatch of OSC field teams. The exercise critique was thorough and

addressed both positive and negative aspects of emergency response organization

performance during the drill.

V. MANAGEMENT MEETINGS

X1 Exit Meeting Summary

The results of the effluent controls program inspection were presented to members of

licensee management on October 4,1996. The inspector presented the environmental

inspection results to members of licensee management at the conclusion of the inspection

on October 18,1996. TM licensee acknowledged the findings presented at each exit

meeting.

The inspectors presented the resident inspection results to members of licensee

management at the conclusion of the inspection on December 11,1996. The licensee

acknowledged the findings presented.

Also, on October 3,1996, Region I conducted an Enforcement Conference on an apparent

violation related to Containment Electrical Penetrations Short Circui' Protection. BECo

handouts are attached. The disposition of this matter was addressed in an NRC Letter

dated October 21,1996. The attached handouts were revised by BECo on October 7,

1996, as marked.

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Enclosure 3

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Commonwealth of Massachuesetts  !

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Letter dated January 28,1997

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