ML20151T848

Insp Repts 50-277/86-01 & 50-278/86-01 on 860106-10. Violation Noted:Failure to Account for All Radionuclides Released in Liquid Effluents

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: ML20151T804 ML20151T823 ML20151T848
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

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U.S. NUCLEAR REGULATORY COMMISSION

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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).

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8602100376 060206

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PDR ADOCK OD000277

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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.

USNRC

• T. Johnson, Senior Resident Inspector

• J. Williams, Resident Inspector

• denotes those present at the exit interview on January 10, 1986.

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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.

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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:

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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.

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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 Liq uid Radioactive

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,

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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

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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

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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

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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.

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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

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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 Fe-55 (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

Sr-90 (0 1 4) E-09 <8.2 E-09 No Comparison

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