ML20198J116
| ML20198J116 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/17/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Lampert M MASSACHUSETTS CITIZENS FOR SAFE ENERGY |
| Shared Package | |
| ML20198J096 | List: |
| References | |
| NUDOCS 9812300091 | |
| Download: ML20198J116 (2) | |
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,h UNITED STATES p
j NUCLEAR REGULATORY COMMISSION
[t WASHINGTON. D.C. 20555 4001 wkV
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December 17, 1998 Ms. Mary Elizabeth Lampert Massachusetts Citizens for Safe Energy Duxbury Nuclear Advisory Committee 148 Washington Street Duxbury, MA 02332
Dear Ms. Lampert:
I am responding to your letter to Chairman Jackson of the U.S. Nuclear Regulatory Commission (NRC), dated October 6,1998, in which you exoressed concerns about the possible sale of the Pilgrim Station and about waste disposalissues. Although we are aware that Boston Edison Company (BECo) has announced plans to sell the Pilgrim Station to Entergy Nuclear Generating Company, to date we have not received en application for transfer of the license, nor have we seen any contract of sale between BECo and Entergy. Therefore, we are not in the position to render a view on any terms or conditions of the sale. When an application is submitted for approval of the transfer of the license, the NRC will not approve such an application unless it finds, among other things, that the new licensee is financially qualified to both operate and decommission the plant.
As discussed in detail herein, our regulations require that licensees maintain a written record of the disposal sites or site surveys of radioactive contamination, and that these records be available for,our inspection. However, our regulations do not require that these records be submitted to the NRC. The radiological environmental monitoring programs required by the NRC are sufficiently comprehensive to provide an adequate assessment of the radiological impact of plant operation on the offsite environment. The available monitoring data for the Pilgrim Station support the conclusion that operation of the facility has not resulted in any significant environmental impacts.
Section 20.2002 of Title 10 of the Code of Federal Reaulations (10 CFR 20.2002), which replaced 10 CFR 20.302, allows disposal of materials contaminated with low levels of radioactivity under some conditions not otherwise authorized in 10 CFR Part 20, and if reviewed and approved by the NRC staff. We have searched our records and found that the NRC did approve one disposal under 10 CFR 20.302 on May 4,1993. We have enclosed Inspection Report 93-17 for your information regarding this disposal. Until 10 CFR 20.304 was rescinded on January 28,1981, BECo could make onsite disposals without NRC's approval if certain conditions were met. We are not aware of any disposals made under the provisions of this regulation. "Subpart L--Records" of 10 CFR Part 20 contains NRC's requirements for maintaining records for radiation protection, including 10 CFR 20.2108, " Records of waste disposal." This regulation would include disposal by burialin soil authorized under old parts 10 CFR 20.302 and 304. In addition, Section (g) of 10 CFR 50.75, " Reporting and recordkeeping for decommissioning planning," requires maintenance of (1) records of spills or any unusual occurrences involving the spread of contamination in and around the facility and (2) documentation of as-built drawings and modifications of structures and equipment in restricted areas in which radioactive materials are used and/or s'ored and of locations of possible inaccessible contamination such as buried pipes.
9812300091 981221 PDR ADOCK 05000293 H
E. Lampert As to your concerns regarding decommissioning, licensees determine how much sampling and analysis are needed 'o adequately characterize the site on the basis of available historical onsito radiation survey records and known history of site uses regardless of who may own the plant at the time it enters decommissioning. This initial site characterization study is performed for the purpose of decommissioning planning and estimating decommissioning costs.
l After decommissioning activities are completed, the licensee must furnish additional documentation of radiological evaluations to demonstrate compliance with the radiological criteria contained in "Subpart E-- Radiological Criteria for License Termination" of 10 CFR Part i
- 20. The licensee's radiological environmental monitoring program is maintained in effect throughout the entire decommissioning process so that the potential environmental impacts of all decommissioning activities are monitored. The NRC periodically inspects the licensee's l
decommissioning program throughout the decommissioning process and reviews the licensee's final radiological survey data. The NRC can, if needed, perform an independent radiological review of the survey data. The NRC can also,if needed, perform an independent radiological survey of the licensee's site to verify the licensee's compliance with regulatory requirements.
l The NRC will terminate the license only when it is satisfied that the licensee's site is remediated to the levels specified in the regulations.
Thank you for sharing your concerns with the NRC. I trust you find this letter responsive to your concerns.
Sincerely, 0
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I uel J. Col ' s, Director j
Office of No ear Reactor Regulation j
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Enclosure:
Inspection Report 93-17 cc w/o encl: See r. ext page i
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- UNrrED STATES
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NUCLEAR f.ECULATORY COMMISSIEN REGloN I -
i i[I 47s ALLENDALE ROAD g
KING OF PRUS$1A, PENNSYLVANIA 194061415 SEP 2 E 1993,
Docket No. 50-193 j
E. Thomas Boulette, PhD Senior Vice President - Nuclear Boston Edison Company
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Pilgrim Nuclear Power Station Rocky Hill Road Plymouth, Massachusetts 02360
Dear Dr. Boulette:
SUBJECT:
Inspection No. 50-293/93-17 This letter refers to the safety inspection conducted by Ms. Iaurie Peluso of this office on August 30 - September 3,1993, of activities authorized by NRC License No. DPR-35 at the j
Pilgrim site, Plymouth, Massachusetts and to the discussions of our findiags held by Ms.
Peluso with Mr. Knft and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection, involving your Radiological Environmental
/g Monitoring Program, are important to public health and safety and are described in the NRC i
Region 1 Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Within the scope of this inspection, we noted that the Chemistry Department continues to maintain an excellent Radiological Environmental Monitoring Program and that the responsible individuals were qualified and knowledgeable with respect to the above program.
No safety concems or violations of NRC requirements were identified in your program.
No response to this letter is required. Your cooperation with us in this matter is appreciated.
Sincerely, T
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es H. Joyn[C ef Facilities Radio Safety and Safeguanis Branch Division of Radiation Safety and Safeguards D
Enclosure Dioos o asT I >.
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
50-293/93-17 l
Docket No.
50-293 License No.
p23-11 l
Licensee:
Boston PAison Comanny RPD #1 Rocky Hill Pand Plymouth. Mnemmehuemc 02360 Facility Name:
Pilerim Nuclear Power Station
' Inspection At:
Plymouth. Mmmachusetts Inspection Conducted:
Aueust ' 1 - Scotember 3.1993 2,9h.4 Inspector:
Laurie Peluso, Radiation Specialist Date p,
Effluents Radiation Protection Section (ERPS)
Facilities Radiological Safety and Safeguards Branch (FRSSB)
OM2V/f1 Approved by:
s 6bert J. ges, Chief, ERPS, FRSSB, Date Division orRadiation Safety and Safeguards (DRSS)
Areas Insoected: Announced safety inspection of the Radiological Environmental Monitoring Program including: management controls, quality assurance audits, meteorological monitoring program, quality control program for analytical measurements, and implementation of the above programs and the Offsite Dose Calculation Manual (ODCM).
Results: Within the areas inspected, the licensee continued to maintain an excellent REMP.
The responsible individuals in the Chemistry Department were qualified and knowledgeable
.with respect to implementation of the above programs. No safety concerns or violations of NRC requirements were identified.
b TOTAL P.11 1 /OO.O ON 9//.
g DETAILS
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r 1.0 Individuals Con'a*d
...1 1,. ]
Ilcensee Personnel xU
- G. Basilesco, Senior Compliance Engineer i
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- N. Desmond, Compliance Division Manager
- P. Pamulari, Quality Assurance Department Manager
- R. Gay, Senior Compliance Engineer. r.1 c
- E. Kraft, Vice President Nuclear Operationss
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D.~IeVitere, General Test Division
- R. Izwis, Radiological Training Support; y.< r
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- P. Markson, Communications Sp~h1N
- D. Montt, Chemistry Division Manager... ;./.
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C. Morrill, General Test Division
- M. Most, Chemistry Supervisor.. :.>. <
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- L. Schmeling, Plant Manager K. Sejkora, Senior Environmental Engineer J. Spangler, Emergency Preparedness Manager
- L. Wetherell, Radiological Protection Manager
,# A. Williams, Station Services Section Manager,
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1.2 Nuclear Rerulatory Commission 04RC) Personnel p..
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- A. Cerne, Resident Inspector
- J. Macdonald, Senior Resident Inspector
- Denotes'those individuals present at exit interviek on September 3,.1993...
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.,:o Other licensee personnel were also contacted.or interviewed during this inspection.m..
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i 2.0 Pumose
...., 7 The purpose of this inspection was to verify the licensee's capability to implement the Radiological Environmental Monitoring Program (REMP) and the Meteorological Monitoring Program (MMP) according to Technical Specifications (TS), the.Offsite. e Dose Chlculation Manual (ODCM), and appropriate procedures during normal and
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)danggement Controls 3.1 Organization The inspector reviewed the organization and administration of the REMP and discussed with members of the Chemistry Depanment any changes since the last inspection conducted in September 1992. ~ Members of the Chemistry Department have responsibility for the REMP. There have been no significant changes in the oversight of the REMP since the previous inspection.
3.2 Oumlity Assurance Audits and Surveillances The inspector reviewed the Quality Assurance Audit and Surveillance Reports as pan of the evaluation of the implementation of the TS requirements. Audit Report 92 01, " Radiological Environmental Monitoring Program", was reviewed during the last inspection. The licensee stated that an audit of the REMP is scheduled to be conducted during September 1993. The inspector reviewed the audit schedule and plan and noted that the REMP audit was planned according to the frequency specified in the Technical Specifications and the scope of the audit plan was appropriate for the REMP. The 1993.QA Audit results will be reviewed during a subsequent inspection.
The inspector reviewed the surveillance reports that supplement the audit, nese surveillances included the Beach Survey, Garden Census, Air Particulate and Air Iodine Filter Collection, and Milk and Vegetable Sampling. The inspector noted that the surveillances were based on the TS requirements and probed for performance and procedural weaknesses. No weaknesses were found during these surveillances. The inspector noted that a qualified technical specialist performed the surveillances. The inspector determined that the surveiljances were of sufficient technical depth to supplement the REMP audit.
3.3 Annual 3tenort The inspector reviewed the Annual Radiological Envimnmental Monitoring Program Report for 1992, as well as the selected analytical data for 1993.
The report provided a comprehensive summary of the analytical results of the REMP around the Pilgrim site and met the TS reporting requirements. The reviewed results indicated that all samples were collected and analyzed as required by TS. No obvious omissions or anomalous data were identified.
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4 4.0 Radiolonical Environmental Monitorine Procram
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l 4.1 Direct.Obamations l
ne inspector examined selected nmpling stations to detennine whether samples were being obtained frun the locations designated in the TS and the ODCM and whether air samplers were operable and calibrated, nese sampling stations included air samplers for particulates and airborne lodines, the composite water sampling station at the discharge canal, and a number of thermoluminescent dosimeter (TLD) stations for measurement of direct ambient radiation, ne inspector witnessed the weeldy exchange of charcoal cartridges and air particulate filters at selected sampling stadons, a water grab sample from an indicator surface water location, and the weekly water i
coDection from the composite water sampler located at the discharge canal.
All reviewed air sampling equipment and the composite water sampler were operational at the time of the inspecdon. The TLDs were placed at the designated locations as specified in the ODCM. Sample coUection was performed according to the appropriate procedures. The observed air l
sampling equipment was weU maintained, and the associated air volume measurement equipment was in calibration at the time of the inspection, j
4.2 Review of the REMP Procedures I
,.De inspector reviewed a number of procedures as part of the evaluation of the implementation of the REMP in accordance with TS and the ODCM. The following procedures were reviewed, e 7.12.25, " Air Particulate and AirIodine Filter Preparation and CoUection" e 7.12.30, " Surface Water Sampling" e 7.12.40, " Exchanging TLDs" e 7.12.70, " Environmental TLD Quality Assurance Program i
l The inspector noted that the above procedures have been updated and revised.
l The reviewed procedures were concise and provided the required direction and guidance for implementing an effective REMP.
In addition to the procedure review, the inspector reviewed the calibration results of the volume meters for the air samplers. De calibrations were performed as scheduled and results were within the licensee's acceptance criteria.
l As part of this inspection, the inspector reviewed the licensee's program j-concemmg IB Bulletin No. 80-10 (issued May 6,1980), " Contamination of t
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5 Nonradioactive System and Resulting Potential for Unmonitored, UncontroUed Release of Radioactivity to Environment". He inspector discussed the implementation ofIE BuUetin No. 80-10 with members of the Chemistry Department. De inspector reviewed the site plan, each of the discharge points and sampling locations for the yard drain systems. De discharge drains are routinely sampled and analyzed and the results are reviewed by the responsible individual. De inspector also discussed with the licensee the method for identifying aU potential sources of release from the site and the inclusion of these sources in the program. He inspector determined that the program is effective and facilitates the identification of potential sources of radioactive liquids and solids within and from the facility.
During this inspection, the inspector reviewed the relocation and placement of slightly radioactively contaminated construction soil within the licensee owner-concolJed boundary in accord with an NRC approved 10 CFR 20.302(a) application. De inspector examined the re-location site. De inspector determined that the relocated soil is not located in the near proximity of the wetlands and would not likely be affected by them. Because this area is owner-controUed, members of the public have limited access to this onsite area. De licensee's surveys indicated that no dose rates above the normal background levels for the area were detected. De inspector noted that the licensee collected and analyzed sufficient soil samples to fully characterize the f
material prior to the relocation. The inspector also noted that the licensee had accurately quantitized the amount of the soil to be moved based on records of the number of loads of material stored. The licensee hr.d performed adequate surveys and measurements prior to, during and after the relocation of this material. De inspector concluded through discussions with the licensee review of applicable records and direct inspection of the areas, that the licensee conducted this project thoroughly and appropriately. Radiological impacts from this soil to the public and the environment are negligible. The inspector had no further question in this area.
Based on the above review and discussions with the licensee personnel, the inspector determined that the licensee has implemented an exceUent REMP.
4.3 Environmental Dosimetry Program Comnarison ne results of the NRC TLD Direct Radiation Monitoring Network are published quarterly in NUREG-0837. His network provides continuous measurements of the ambient radiation levels around 72 nuclear power plant sites throughout the United States. Each site is monitored by approximately 30 to 50 TLD stations in two concentric rings extending to about five miles from the nuclear power plant.
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One purpose of this network is to provide a means of comparing the results of
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i the direct radiation monitoring programs conducted around individual nuclear
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power plants.with that of the nationwide NRC program. Therefore, several j
NRC TLDs are collocated with selected licensee TLD stations. The NRC employs the Panasonic Model UD-801 TLD that consists of two elements of l
lithium borate activated with copper and two elements of calcium sulfate i
activated with thulium. The two calcium sulfate elements are used to determine the environmental exposure level during normal operations. Twelve 1
NRC TLDs (one at each collocated station) are collocated with licensee TLDs j
at the Pilgrim site.
The licensee currently places two types of Panasonic environmental TLDs, one 2
Model UD-801 ed one Model UD-814, at each specified monitoring location.
Both TLDs consist oflithiuin borate elements activated with copper and I
j calcium sulfate elements activated with thulium. De UD-801 contains two lithium borate and two calcium sulfate elements. The UD-814 contains one lithium borate and three calcium sulfate elements. Only the five calcium sulfate elements are used by the licensee to determine environmental exposure l
i levels during normal operations.
During this inspection, the inspector compared the monitoring results of the collocated TLDs for 1992 and the first half of 1993. For both the NRC and the licensee, the results are provided in Table 1 as the net exposure result i random uncertainty expressed as one standard deviation. Table 1 also includes
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the NRC " historical average" data for each location as a basis for comparing the quarterly NRC results to those measured previously; these historical averages also provide a means of comparison with the results of the licensee.
The data begin in 1983 and include the data through the first quarter of 1993.
The reported values are the mean i I standard devistion for ali quarters for which net data were available. The relatively small standard deviations for the historical averages indicate that the NRC results have remained consistent over the ten-year period, with one exception. The quarterly results for location NRC 1 (the casite Overlook Area) have been higher than the historical average since 1991. NRC 1 is subject to exposure to scattered radiation from N-16 turbine shine during periods of operation. The introduction of hydrogen water chemistry 6ning 1991 somewhat enhanced this phenomenon. The quarterly TLD results for this location are typically higher than the historical average when the plant is operating and lower than the historical average (2nd quarter 1993) when the plant is shut down (background level). This variation in exposure with power operations accounts for the higher standard deviation for the historical average for this location.
De licensee's quarterly results during 1992 were sightly higher than those of the NRC. This difference may be due to different transit doses, diff:rences in
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4 time of field exposure, and specific TLD Jocation variations. With the above uncertainties and variabilities considered, the results of the two sets of TLDs are in good comparison.
The inspector noted that the Environmental Program Manager of the Chemistry Department tracks, trends, and reviews the TLD msults including those of the NRC collocated TLDs.
Based on the above review, the inspector determined that the licensee continued to maintain an excellent environmental dosimetry program.
5.0 Quality Assurance and Onelity Control for Analv'ieil Measur_ements The inspector reviewed the licensee's programs for quality assurance (QA) and quality control (QC) to drAermine whether the licensee had adequate control with respect to sampling, analyzing, and evaluating data for the implementation of the REMP.
The quality control progam for analysis of environmental samples is conducted by the Yankee Atomic Environmental Laboratory (YAEL), located in Framingham, MA.
The laboratory conducts a blind duplicate prognm, an intralaboratory quality control program, and participates in the EPA-cross check prognm to verify the quality of labontory analyses. The inspector reviewed selected results from these programs and n
I noted that the reviewed results were within the licensee's acceptance criteria.
The inspector noted that the licensee continues to maintain an excellent quality assurance program to ensure that the routine and non-routine REMP sample results are thoroughly reviewed by the Environmental Project Manager. Any results that appear suspect are recounted and reviewed.
Based on the above reviews and discussions with the licensee, the inspector detennined that the licensee had excellent QA and QC programs.
6.0 Meteoro1orical Monitorine Program (MMP)
De inspector reviewed the licensee's MMP
- tetermine whether the instrumentation and equipment were operable, calibrated, and maintained. The Emergency Preparedness Division has oversight for surveillance, calibration, and maintenance of the meteorological instrumentstion and equipment. Calibrations are performed weekly and quarterly and surveillances am conducted daily, weekly, and biweekly by technicians of General Test Division using the vendor operation manual.
Calibrations and survei!Jances were performed according to the requirements specified in the Emergency Preparedness Procedure, EP-AD-421, " Surveillance, Maintenance and Calibration of McDAP Equipment". He inspector reviewed this procedure and
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temperature "at the primary and back-up meteorological towers! All reviewed
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the most recent calibration results for wind speed, wind direction, and delta calibration results were within the licensee's acceptance criteria and all calibrations i
were performed according to the frequencies required by the procedure.
1 The inspector witnessed the weekly calibration of the meteorologicalinstrumentation at the primary tower, including an examination of the strip chart recorders located in the control room to verify the expected response to the calibration. The calibration results were within the licensee's acceptance criteria. The inspector noted that the chart recorders in the control room and the instrumentation at the primary tower were j
operable and well m.intained at the time of the inspection.
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Based on the above inspector observations, record review and discussions with the l
licensee personnel, the inspector determired that the licensee continued to implement j
the MMP effectively.
7.0 Exit Interview I
j The inspector met with the licensec representatives denoted in Section 1.1 of this
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inspection report at the conclusion of the inspection on September 3,1993. Tlie j
inspector summanzed the purpose, scope, and findings of the inspection. The,
licensee acknowledged the inspection findings.
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- y feble I Environmental TLD Monitoring Results (mlUquarter) for 1992 end fire half 1993*
Comperison of NRC TLDs cellecesed widi Pilgrim TLDs M
L9*E 1e cener 2nd e rm Jed on 4di eder hlpoder 2nd asvmf NRC Amene**
NRCI 102.8 i 3.5 93.213.1 113.413.8 71.6123 109.113.7 41.4 i t.6 43.0128.2 FIL OA 107.014.4 117.3 i 9.7 120.9 i 5.2 7c.013.7 119.8 i 6.5 44.312.2 NRC2 17.0 i 1.1 14.610.9 20.8 i 1.1 14.610.9 16.7 i 1.0 15.810.9 16.712.8 Pit PA 20.310.7 20.7 i 1.0 20.7 i 0.8 18.5 i 1.1 19.5 i 0.6 18310.9 NRC 6 13.4 i 1.0 12.8 i 0.8 15.6 i 1.0 13.510.9 13.210.9 15.710.9 14.4 i 1.8 FILJO 16.1 1 0.4 15.910.6 16.110.6 16.010.7 15 3 i 0.6 16.510.7 NRC7 17.1 1 1.1 17.9 i 1.0 19.0 i t.1 16.410.9 16.4 i 1.0 20.1 i 1.0 183 i 2.6 FIL WR 20.610.7 19.710.8 203 10.9 l9.6 i 0.9 19.2 i 0.6 20.111.0 NRC13 12.5 i 1.0 12.010.8 15.1 i 1.0 11.510.8 12.810.9 13.7 1 0.8 13.4 i 1.5 PIL ER 15.610.7 14.810.4 15.4 i 0.5 15.010.4 14.710.6 14.910.9 NRC 22 14.1 i 1.0
- D.8 i 0.8 15.1 i 1.0 12.610.5 13.410.9 14.710.8 13.5 i 2.1 PIL hlP 17.210.7 16.I i 05 15.510.4 16.110.7 15.910.6 15.610.9
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NRC 25 12.5 i 1.0 13310.9 14.4 i 1.0 13.710.9 12.9 i 0.9 15.010.8 14.0 i 1.9 PIL W R 15.7 i 0.9 15.010.7 15.210.5 15.410.8 15310.6 15.410.6 NRC30 15.2 i 1.0 15.710.9 16.2 i 1.0 15.010.9 14.8 i 1.0 18.910.9 16.0 i 1.8 PTL MS 18.310.4 17.610.5 18.210.7 18.110.5 17.310.6 18.710.6 NRC 37 15.0 i 1.0 13.9 i O.9 16.1 i 1.0 13.010.8 13.410.9 14.9 i 0.8 14.3 A l.9 Pit SP 16.210.7 15.110.6 15 3 1 0.8 15.510.9 14.510.6 15.110.7 NRC38 10.7 i 0.9 Il.210.8 12.610.9 10.7 i 0.8 NC 12.9 i 0.8 13.1123 PfL MB 16.110.7 15310.6 17.412.7 15.4 i O.5 NC 14.410.9 NRC 43 15.7 i 1.0 14.010.9 16.7 i 1.0 14.610.9 15.1 i 1.0 16.210.9 15.7 i 1.9 PIL NP 13.210.9 17.5103 17.810.8 17.810.6 17.510.6 15.410.9 NRC 47 I4.0 i 1.0 13.7 i 0.9 16.4 i 1.0 14.510.9 12.9 i 0.9 NC 14.9 i 1.9
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FIL EW 17.810.4
-17.110.4 16.610.7 17.710.6 15.8 i 0.7 17.8 i 0.8 NRC 48 15 3 1 1.0 17.7 i 1.0 18 3 i 1.1 18.0 i 1.0 13.910.9 NC 15.712.2 FILEW 17.510.4 17.1 1 0.4 16.610.7 I7.710.6 15.510.7 17.810.8 All data ere shown es the net tensh i I wandard deviarios fer the rendom eneertairifies.
- All met resehs are in millirecrrgets (mR) sed ere normeEted to e 9% fey quarter.
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- NRC historical average from 1953 (1st quarter) thmugh 1993 (1st qustter).
i NC = no cornperison becsose date are not eveilable (deo to nduirig er damaged TLD)
-