ML20151T848
| ML20151T848 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/05/1986 |
| From: | Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20151T807 | List: |
| References | |
| 50-277-86-01, 50-277-86-1, 50-278-86-01, 50-278-86-1, NUDOCS 8602100376 | |
| Download: ML20151T848 (9) | |
See also: IR 05000277/1986001
Text
.
.
. . .
.
.
1
. .
- L
'
.
i
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
'
50-277/86-01
Report No.
50-278/86-01
50-277
Docket No.
50-278
DPR-44-
C
-
License No. DPR-56_
Priority
-
Category
C
Licensee:
Philadelphia Electric Company
2301 Market Street
Philadelphia, PA 19101
Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3
Inspection At:
Delta, PA
Inspection Conducted: January 6-10, 1986
i'
Inspectors:
8
,2- 3 - M
Richard K. Struckmeyer, E diation Specialist
date
Approved by:
f/VAIk
eEd
1-T
E
Walter J. GP sciak, Chief, Effluents
date
Radiation Protection Section, EPRP8
Inspection Summary:
Inspection on January 6-10,-1986 (Combined Inspection
Report Nos. 50-277/86-01; 50-278/86-01
Areas Inspected: Routine, unannounce~d inspection of the licensee's radioactive
liquid and gaseous effluents program. Areas reviewed included:
radioactive
effluent release records, effluent control instrumentation, effluent control
procedures, reactor coolant chemistry, and ventilation systems. The
,
-inspection. involved 36 inspector hours on site by one regionally based
inspector.
Results: Within the areas inspected, one item of noncompliance was identified
in one area (failure to account for all radionuclides released in liquid
effluents, paragraph 4).
8602100376 060206
'
.
ADOCK OD000277
I
G
PDR-
i
I
-
.
.
.
DETAILS
1.
Individuals Contacted
Principal Licensee Employees
R. Fleishmann, Station Superintendent
- J. Winzenried, Superintendent - Plant Services
- D. Smith, Superintendent - Operations
- D. Oltmans, Senior Chemist
- A. Hilsmeier, Senior Health Physicist
- A.'Fulvio, Technical Engineer
- T. Wilson, QA Site Supervisor
- W. Lorenz, Health Physicist, PECO
The inspector also interviewed other licensee employees, including
members of the chemistry and health physics staff.
- T. Johnson, Senior Resident Inspector
- J. Williams, Resident Inspector
- denotes those present at the exit interview on January 10, 1986.
2.
Status of Previously Identified Items
'
(0 pen) Inspector Follow-up Item (50-277/85-09-03; 50-278/85-09-03)
Tritium measurement disagreement. A second sample, taken during
inspection 277/85-28; 278/85-28, was split and resulted in another
disagreement. A spiked simulated liquid effluent sample will be sent to
the licensee for analysis. This item remains open, and is further
discussed in Section 8.
(0 pen) Inspector Followup Item (50-277/85-09-04; 50-278/85-09-04)
Chemistry software documentation and verification. The licensee has
initiated a'three phase program to ensure the validity of computer
codes.
In Phase I, source listings are to be removed from disks normally
in operation, to minimize the opportunity for inadvertent modifications.
In Phase II, procedures are to be written to provide a method for software
modifications.
In Phase III, existing software listings are to be
verified by individuals knowledgeable in the area.
The licensee stated that Phase I had been completed; however, the
inspector has not yet verified this. A draft procedure, HPA-7E " Software
Modification Review," dated December 4, 1985, had been written but had
not yet been PORC approved. The licensee further stated that Phase III
had not yet begun. This item remains open.
g(3'-
3
3.
Management Controls
The inspector reviewed the licensee's management oversight for the
control of liquid and gaseous effluents, including assignment of
responsibility and program audits.
3.1 Assignment of Responsibility
The Chemistry department has primary responsibility for control of liquid
and gaseous effluents,-including release permits, offsite dose calcula-
tions, effluent monitor calibrations, and preparation of Semiannual
Radioactive Effluent Release Reports. Chemistry.1s headed by the Senior
Chemist, who reports through the Superintendent of Operations to the
Station Superintendent. The superintendents of Peach Bottom, Limerick,
and Nuclear Services report through the Superintendent of the Nuclear
Operation Division to the Manager, Nuclear Production. A separate Quality
Assurance Division has the responsibility for conducting audits of station
activities.
3.2 Audits
The. inspector reviewed audits conducted by the Audit Section of the
Quality Assurance Division, including the following:
Audit No.
Date
Title
,
AP85-28 HPC
4/85
Chemistry and Radiochemistry Activities
(PBAPS)
AP85-71 HP
10/85
Offsite Dose Calculation Manual
AP85-59-50
10/85
Liquid and Gaseous Effluent Releases
These audits appear to be reasonably thorough and complete; they address
both acceptable and unacceptable findings, and corrective actions as
appropriate.
The inspector noted an error in the audit of Liquid and Gaseous Effluent
Releases.
In a review of licensee commitments and responses to IE
Bulletin 80-10, the auditor stated that "IE Bulletin 80-10 response was
closed by the NRC in Inspection 50-277/83-26..." The inspector reviewed
NRC Inspection Report No. 50-277/83-26, and found that Bulletin 80-11 was
closed, not Bulle tin 80-10, as stated in the licensee's aedit report.
Bulletin 80-10 remains open.
This was brought to the attention of the QA
site supervisor, who stated that the audit report would be corrected.
.
-,,,-w,
.
.
4
4
4.
Effluent Release Records
The inspector reviewed selected radioactive liquid effluent release
permits, selected monthly summaries of liquid and gaseous releases and
resultant off-site dose estimates, and the " Semi-Annual Effluent Releases
Report" for the last half of 1984 and the first half of 1985. Also
reviewed were the new Radiological Environmental Technical Specifications,
the Offsite Dose Calculation Manual, and various procedures covering
in plant and effluent sampling, and liquid and gaseous effluent
controls.
This review indicated that no regulatory or Technical Specification limits
were exceeded with regard to radioactivity in liquid or gaseous effluents.
The liceasee appears to be conducting a generally effective program for
the control of radioactive effluents. However, the review of the Semi-
Annual Effluent Releases Report No.19, January 1 - June 30,- 1985, 'indi-
cated that P-32 and Fe-55, which were identified as present in samples
taken from liquid waste tanks prior to release, were omitted from the
semiannual release report. Sampling and analysis for Fe-55 is required
by Table 4.8.1 of the Technical Specifications. The inspector stated that
failure to include Fe-55 among the nuclides listed in the Semi-Annual
Effluent Releases Report is an apparent violation of the licensee's
Technical Specifications, Section 6.9.2.h(2) (277/86-01-01; 278/86-01-01).
The inspector,also noted that the estimates of total body and bone dose
. contained in Semi-Annual Effluent Releases Report No.19 did not include
the contributions from P-32, Fe-55, Sr-89, Sr-90, and H-3.
The contri-
butions to dose from these nuclides were correctly estimated on a monthly
basis using procedure ST 7.5.1.f, ." Analysis for P-32, Fe-55, Sr-FG and 90,
and Tritium Activity in Liquid Radwaste Composites," and data sneets ST
7.5.1.f-1 and ST 7.5.1.F-2.
This error does not constitute r. violation
because the Technical Specifications do not require that dose estimates be
included in the Semi-Annual Effluent Releases Report.
Tecnnical Spect-
fications (as amended December 31,1984) now require these estimates to be
included in an annual Radiation Dose Assessment Report, however.
The
first such report, covering 1985, is required to be submitted to the NRC
by April 30, 1986.
The inspector reviewed selected radioactive liquid release permits and
determined that these were properly completed according to the format
provided by procedure HP0/CO-18, Rev.16, " processing Li uid Radioactive
q
Waste." However, the procedure states that the tank to be released must
be recirculated prior to sampling (this ensures that a representative
sample is obtained).
For Laundry Drain Tanks, recirculation for 50-50
minutes is required; for Waste Sample Tanks and Floor Drain Sample Tanks,
the required time is 25-35 minutes. The release permit contains no space
for verification that this requirement has been met.
The licensee
stated that the release permits are filled out by a Chemistry technician,
l
.
.
5
whose responsibility begins after the taak has been recirculated and the
sample taken by Operations. The inspector stated that such verification
should include information as to the times at which the recirculation pump
was started and stopped, the elapsed time, and the signature or initials
of the individual responsible for verifying'this information. The
licensee stated that the issue of specific verification of this procedural
requirement would be investigated, and a method would be chosen for
ensuring that the minimum recirculation times are obtained (277/86-01-02;
278/86-01-02).
5.
Effluent Control Instrumentation
The inspector. reviewed selected procedures and records for calibrations
and calibration checks of liquid and gaseous effluent monitors.
The
Chemistry Department performs the calibration of the radiation detectors,
using radioactive sources appropriate to the type and range of the
detector.
Calibration of the associated electronics is performed by the
Susquehanna Tests group. Those reviewed, with their required calibration
frequency, include: Main steam line high radiation, 3 months; refueling
area exhaust, 3 months; reactor building exhaust noble gas, 12 months;
main stack noble gas, 12 months; steam jet air ejector monitors, 3
months; and liquid radwaste monitor, 12 months. The records indicated
that these monitors had been calibrated at the required frequencies.
The inspector noted that the procedures covering these calibrations
contain acceptance criteria, but that these criteria vary considerably
among the monitors. Neither the Chemistry personnel who perform the
calibrations, nor Chemistry supervision, knew the origin of the acceptance
criteria, or why the differences exist. Chemistry representatives stated
that the criteria had been developed prior to the beginning of commercial
operations.
The inspector stated that the department responsible for
_ performing the cali'. rations should have sufficient understanding of the
basis for acceptance criteria to evaluate whether the detector response
remains within acceptable bounds. The criteria developed in the early
1970s may be inadequate by more recent standards. The licensee stated
that an effort would be made to determine the basis for the existing
acceptance criteria, and that it would ascertain the need for new or
revised criteria. This will be reviewed in a future inspection-
(277/86-01-03; 278/86-01-03).
6.
Testing of Air Cleaning Systems
The inspector reviewed the licensee's air filtration system testing with
respect to the Technical Specifications requirements.
The inspector
reviewed the results of the HEPA filter and charcoal adsorber in place
tests conducted in 1984 and 1985 for the Standby Gas Treatment System and
the Main Control Room Emergency Ventilation System. The tests met the
Technical Specifications requirements. The inspector also reviewed
selected records of the quarterly functional tests required for the
.
.
6
Control Room Emergency Ventilation system, including pressure drop across
filters, test of automatic initiation, and air intake radiation monitor.
The results were satisfactory.
7.
Hot Shop Contamination Incident
The inspector discussed with the licensee an incident in which its hot
shop change area was contaminated.
The licensee investigated the
incident which occurred on November 19, 1985, and listed the probable
cause of the event in an internal memorandum.
The inspector reviewed the memorandum and related documentation, toured
the facility, and discussed the incident with the licensee. The licensee
stated that there had been no apparent release of radioactive material to
the exterior of the facility. The hot shop is served by two filtered
exhaust systems, each with a low volume sampler for collection of parti-
culates. However, neither exhaust system is equipped with a radiation
detector.
In addition, the licensee stated that the filters in these
exhaust ventilation systems are not subject to testing to determine
their collection efficiency.
The inspector stated that radiation detectors and/or filter surveillance
tests are not necessarily required for the hot shop facility, and that
these issues should have been addressed by the l_icensee's safety
evaluation prior to putting the facility into service. At the exit
interview, licensee representatives stated that they were not aware as to
whether these issues had been considered.
The inspector stated that the
licensee's compliance with 10 CFR 50.59 would remain unresolved pending
clarification of its pre-use evaluation of the hot shop facility
(277/86-01-04; 278/86-01-04).
8.
Radiological Confirmatory Measurements
The licensee's analytical capability to make consistently accurate
radioactivity and chemical measurements during normal operations was
l
evaluated.
Verification tests and calculations were used to evaluate the
licensee's measurement capabilities.
The results of an effluent sample split between the licensee and NRC:I
.
during a previous inspection on July 22-26, 1985 (Combined Inspection
'
Report Nos. 50-277/85-28; 50-278/85-26) were compared during this
,
inspection. The analyses, which require wet chemistry, were performed by
the licensee's vendor laboratory and by the NRC reference laboratory,
Department of Energy, Radiological and Environmental Sciences Laboratory
(RESL). Joint analyses of actual effluent samples are used to verify the
licensee's capability to measure radioactivity in effluent samples with
l
respect to Technical Specification requirements and other regulatory
I
requirements.
.
%
7
The results of the sample measurements comparison indicated that the
tritium value was in disagreement under the criteria _used for comparing
results.
(See Attachment I). The results of the comparison are listed
in Table 1.
As a result of the disagreement, a simulated liquid effluent sample
.containing one or more radionuclides will be sent to the licensee for
radioactivity analyses requiring wet chemistry. The analyses will be
performed by the licensee's vendor laboratory. The laboratory's results
will be compared with the known values when received at a later date and
will be documented in a subsequent inspection report.
(277/85-09-03;
278/85-09-03).
9.
Unresolved Item
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of
noncompliance, or deviations. An unresolved item disclosed during this
inspection is discussed in paragraph 6.
10.
Exit Interview
The inspector met with the licensee representatives (identified in
paragraph 1) at the conclusion of the inspection on January 10, 1986.
The inspector summarized the purpose and scope of the inspection and the
inspection findings. At no time during this inspection was written
material provided to the licensee by the inspector.
The licensee agreed to perform the analysis discussed in paragraph 8 and
report the results to the NRC.
I
o-
,
. *'.
c
ATTACHMENT 1
Criteria for Comparing Analytical Measurements
This attachment provides criteria for comparing results of capability tests
and verification measurements. The criteria are based on an empirical
relationship which combines prior experience and the accuracy needs of this
-program.
In these criteria, the judgement limits are variable in relation to the
comparison of the NRC Reference Laboratory's value to .its associated
uncertainty. As that ratio, referred to in this program as " Resolution",
increases the acceptability of a licensee's measurement should be more
selective. Conversely, poorer agreement must be considered acceptable as the
resolution decreases.
Resolution = NRC REFERENCE VALUE
RATIO = LICENSEE VALUE
REFERENCE VALUE UNCERTAINTY
NRC REFERENCE VALUE
Resolution
Agreement
<3
0.4 - 2.5
4-7
0.5 - 2.0
8 - 15
0.6 - 1.66
16 - 50
0.75 - 1.33
51 - 200
0.80 - 1.25
>200
0.85 - 1.18
"
,.
..
b
v
L -
TABLE 1
,.
PEICH BOTTOM 2 and 3 VERIFICATION TEST RESULTS
SAMPLE
ISOTOPE
RESULTS IN uCi/ml
COMPARISON
NRC VALUE
LICENSEE VALUE
FOST.
'H-3
'(1.76 i 0.03) E-03
(1.15 i 5%) E-03
Disagreement
-7/26/85
(2..i 5.)
E-08
<8.9 E-08
No Comparison
i
. 0850 hrs Sr-89
(2.1 1 0.7)
E-08-
(2.2 1 41%) E-08
Agreement
(0 1 4)
E-09
<8.2 E-09
No Comparison
L
l
l
!
l-
i
I
- .
I
!
k_.