ML20244B626
| ML20244B626 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, FitzPatrick  |
| Issue date: | 10/19/1981 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Dalton P Sierra Club |
| References | |
| NUDOCS 8111250250 | |
| Download: ML20244B626 (7) | |
Text
__ . _. . - - - _ _
.,- ;_ , 'g 3 , c S v" hug ygLg oorg . <
g, , '4* L ,
,,,ggf TEKA i
OCT I 01981 Docket Nos. 50-220 50-333
[ '
- c. . - r, 3 Mr. Peter Dalton h . 74.f . ;r ..#5
- h i i / [.
Sierra Club Radioactive Waste Campaign -i ',OP] 6s 3164 Main Street ~1 % / -l Buffalo, NY 14214 g
k%g9A .., i
Dear Mr. Dalton:
i 9 ,roo e T .' ' ,,
I am responding to your letter to Mr. Philip Polk of our agency, dated June 19, 1981. In that letter you requested that the Nuclear Regulatory Commission l' inspect the Nine Mile Point and James A. FitrPatrick reactors to determine the source of radioactive cesium in milk from the 6rca near these plants. In -
support of your request, you enclosed a copy of the Sierra Club critique of the 1 report NUS-3620. "An Esaluation of the Cesium Concentrations in Environmental i Milk Sanples and their Significance at the Nine Mile Point - James A. FitzPatrick j Sites " j i
Members of my staff have prepared the enclosed rr:sponse to the Sierra Club i l report. This response is based primarily en the results of routine inspections 3 at the Nine Mile Point and James A. FitzPatrick plants during February 1981.
Those routine inspections included the review you requested concerning 1 the high concentrations of cesium-137 in nilk. These inspections also included ,
review of elevated levels of iodine-131 in :.ailk that are menticned in the Sierra '
Club critique. We realize that the results of these inspections were not available until after the date of your letter to Mr. Polk. Copies of these inspection reports (Nos. 220/81-02 and 50-333/81-05) are also enclosed.
In brief, the average levels of cesium-137 in milk near the site have not been consistently higher than the rest of the State. Our assessment of both the observed cesium-137 and iodine-131 concentrations in milk in this area is that, from the information available, one cannot determine precisely the relative contributions of fallout and reactor effluents to the detected radioactivity. The dose to the general public, at the observed levc15, and regardless of the source, would be only a small fraction of that received from natural background radiation. This small dose would be ;
well below regulatory limits even if one made an assumption that all observed radioactivity came from the reactors, i
- , sys/a 1 avassaso a wm um iL 3g0j#
fze Azoen oswea.:w q y -- - sp ;
')
W ;,
j N
Mr. Peter Dalton h j ji -
- a .
If you have any questions or require additional information regarding this 5 ;
matter please contact me. ll l Sincerely, l (Mginni sien d 117. l n.c.tu eung .;
Victor Stello, Jr. , Director .
Office of Inspection and Enforcement *
Enclosures:
as stated Distribution 9 /
VStello, IE
. [ A [ D RDeYoung IE HThornberg, IE [ .
LHigginbotbam, IE
_ JBuchanan, IE
, , , , p.4d
/
VA ,,4# Ap.4&[
j dh 9 R GSmith, RI q CSakenas, RI p S. +
Record Note: Original draft response prepared by D.I (Ref: Memorandum from G. H. Smith to F. Congel, NRR, 7/29/81). NRP/DSI/RAB concurs in this response that incorporates additional suggested information (Ref: Memo-randum F. J. Congel to L. J; Cunningham, 8/27/81). ELD (S. Burns) has no legal objections; ELD editcrial suggestions have been incorporated. '
lY. A b ,1N .
l l
, . ~ ,,
. \ %') / ?, -
WPU:JD RSI:'IE/ R $J ' ~ /RSBlIE'(LD:5%iIE Dif1 D > '. ,'
5520 J5u'chanan LCu ningha. $Higginbotham HM n urg F JungVte1(0 9/25/81,rO/'/81/B/2/81 / /S/ -[/81 ;0/ /81 jf/,j/81 lp/g/81 f
l l
yws +n+ '
gu .
m 4mw a v+ ppg & + ,e nm ,
ym '
gQfQ <
e ( 1. ,
2
,f .
h c;.
Enclosure s, G f p RESPONSE TO SIERRA CLUB REPORT ON HIGH CESIUM i 1:
H LEVELS IN MILK AT THE NINE MILE POINT AND
-JAMES A. FITZPATRICK SITES 1
}
As part of a routine inspection conducted at the Nine Mile Point (NMP) and the )p{
~ James A. FittPatrick (JAF) Nuclear Power Plants on February 9-13 and 24-17, s 1981, NRC staff investigated the elevated levels of Cesium-137 (Cs-137) in milk observed in 1979.
M 1 g In conjr. action with this investigation, the following were reviewed: T. .,,
- 1. State of New York, Department of Environmental Conservation Environmental ,
Radiation Bulletins. p
- 2. NMP and JAF site environmental monitoring program data and effluent data. 3
- 3. NUS-3620, "An Evaluation of the Cesium Concentrations in Environmental Milt Samples and their Significance at the Nine Mile Point - James A.
Fit 2htrick Sites."
)W ,
f E Based on 4 review of the abcve, it does not appear possible te rala out the NMP-JAF plar.ts as a source of son of the Cs-137 in milk, although neither does k
9" it appear likely that the plants are the only source. This view is taken for the Io11owing reascns. ,
x L There is no evider.ce of high Cs-137 levels in the air nest the site (see g' Table 1). n
- 2. There is no evidence of nigh Cs-134 levels in the air near the site, or in fact, of Cs-134 even being observed routinely in the air near the site.
The ts-134 concentrations measured at about 4\ miles SW from the site are indistinguishable from Cs-134 background levels and have large uncertain-ties associated with them (see Table 2).
- 3. Analyses for cesium are performed using gamma-ray spectroscopy. Thus, if Cs-134 were present in a sample, it would be detected along with Cs-137.
- 4. The average levels of Cs-137 in milk near the site have not been consis-tently higher than the rest of the state (see Table 3) and Cs-134 has not been routinely detected in area milk samples.
In addition, the ratio of Cs-134 to Cs-137 from plant airborne effluents could not be used to determine the expected ratio of Cs-137 present in milk from fallout to that from the plants because the ratio of Cs-134 to Cs-137 in airborne effluents was not consistent for 1979 (0.09 to 1.96). Also, other factors such as precipitation patterns, farming practices, etc., were not taken into consideration.
i
W,b v'.g*w* ,<~ +:gy
+w - -
p.9
&4 ,
y;.
7
- ' - Enclosure A@j 3
Regardless of the source of the Cs-137, the observed concentrations in milk j result'in relatively low doses to humans. Even the highest concentration, g !
53 pCi/1 (measured at' licensee monitoring station 25), would produce a whole- 3 1 body exposure of only 0.10 mrem / month to an adult (critical. Individual) and 4 1 0.69 erem/ month'to an infant liver (critical organ), which is calculated using' dj l methodology presented in Regulatory Guide 1.109 for maximum exposed individuals and assuming that the milk remained at this concentration for a month. . The d j
- measured level of 53 pCi/1 did not appear to persist.for more than one month' S ,
and was not identified'at any other sampling stations. Those doses are a small 'j fraction of natural background and of the 25 mrem / year regulatory limit for j) i members of the general public that.is required by the EPA Uranium Fuel Cycle '
Standard (40 CFR 190). !
s I
l 4 .
'3)
.p.
l- ,
1' 3
I L
L; , .
ka ______-__-___-________=
V lj, *i$$?"*fl*~"* ! +?""*= 7 "" " n* ' ' ' * * ,
.[* '
- n. ,
,7 K' i .
.y;-c -
- ~;>
.A h ~
CES10M-137 IN NY' AIR SAMPLES
- d.x d
4
- p L3 Average Concentration.n for 4
o Period in 10-3 pCi/m3**
~
q a
l q
I L Date . Oswego Co. . Albany-
- . 3.t
[~ ,
o
'~
1974 - 2nd Q 1.3 (13) 4.9 (12) 1975 -'Ist Q 1.' 3 <2 1975.- 2nd Q. '3.4 1. 8
.1975 -' 3rd Q ' 1. 2 < 1. 2 -
c 1975 - 4th Q .
< 1. 0 2.2
~
'1977'.- 1st Q (0.8 0.8 j
- j s
~1977.-.2nd.Q 1.7 1.C
-1977 -'3rd Q (1.5 < 0. 3 "!;
- 1.1 1977 - 4th Q <0.7
- y
^ Data from State of New York,. Department of Environment' ;
Conservation. Environmental Radiation Bulletins.
- Number of-samples in parentheses.
I 1
_ -_ .z-_-_- - - ------ - _-_ _ ---- _--_ - - - -_- - - - - - - - - _ - _ - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - -
1.
p:: g e;:*yw jy!- p* W + - + ee s geg p 9tiv*j5ps A y e>> + " ~ ~ ~
+ m %:-pgipg
, :g
~44 11 TABLE 2 fm g
1 CESIUM-134 IN NY AIR SAMPLES
- k 1
.i:
y J
Averace for period in 10 3 pCi/m3** '
l =a ;
Scriba, s 4 \ mi. SW, Albany, "
Date Oswego Co. (background) 1974 - 1st Q <0.E (12) <2 (14) 1974 - 2nd Q <0.7 (13) <2 (12) 1974 - 3rd Q <1 (12) (1(12) .
1974 - 4th Q <0.7 (14) 1. 3 1.1 (12) 1975 - 1st Q <0.8 <1 1975 - 2nd Q 1.1 : 1.0 3.2 1 1.0 1
1975 " ha Q :0.9 < 1.1 i 1975 - 4t! Q <0.9 <1.3 1977 + 1st Q <0.7 <0A I 1977 - 2nd Q <0.7
<0.5 197'i 3rd Q <1.4 (0.6 1977 - 4th Q <0.9 <0.6 1979 - 1st Q <0.6 <1.5 ,
- Data from State of New York, Department of Environmental Conservation, Environmental Radiation Bulletins. Similar data other years between 1971-1979 are not avilable for comparison.
- Number of samples in parentheses.
.I ,
f I il . - , t
- w o,~ y TABLE 3
$aj T: M O
CESIUM-137 IN NY MILK SAMPLES * <
]
- s
^
Average Concentration for Period in pCi/1** s Location of Date Osweoo Co. Background Background Station
- 1971 35 (11) 21 (22) Fassena 1973 12 (11) 11 (9) Massena' 1974 22 (11) <15 (12) Massena 1975 22 G3) 20 (12) Massena I 1976 - 1st Q 28 .2) 20 (3) N. Hempstead l 1976 - 2nd Q 22 (2) 19 (1) Syracuse ;
1976 - 3rd Q 2! (3) 15 (3) N. Mempstead 4
l 1975 - 4th Q (17 (3) <17 (22) Bracklyn 1977 <22-(n) <31 (B) syrature I
1978 - 3rd Q 17 (5) 21 (1) Metsena 1978 4th Q 19 (2) IS (1) N. Hr.mpstead 1979 - 3rd Q <12 (3) 19 (1) Syracuse
- Data from State of New York, Department of Environmental Conservation, Environmental Radiation Bulletins.
- Number of samples in parentheses.
, . - .. , . UNITES $TATES..m. .. .
NUCLEAR'REGUCATirR N<
JW % ,y y;fyf; PARK E:1Ni AVENUE . M4SSIONewNegg~gg}p&%g l
[Wlg(i ; f' *y' i
O 7@
~
Mw _ 1. f ax sM 4
o M vc.. y ,'. 4
, 7* KING OF PRU551A;PENN5YtVANIA 1M06 e ,%
~i ,, .
y
@& 'i DockeU@No? 1-220 N U L M. -33I Ar
- iT
" f.L ,
Niagara Mohawk Power Corporation 3 ATTN:' Mr. T. E. Lempges jVicePresident. lt Nuclear Generation 3 300 Erie Soulevard k'est i Syracuse, New York 13202 i Gentlemen:- ,
a
Subject:
Inspection 50-220/81-02 S 1
This refers to the routine safety inspection conducted by Mr. T. Jackson 1 of this office on February 9-13 and 24-27,1981 at Nine Mile Point j[
Nuclear Power Plant, Unit 1. Scriba, New York of activities authorized .% r by HRC' License No. OPR-63 and to the discussions of our findings held by , j (
Mr. Jackson with Messrs. Silliman, Roman, and others of your staff at i $
the conclusion of the inspection.
Y? ;
J Areas examined during this inspectier are described in the Office of ; L Inspection and Enforcement inspectfra Report which is enciesed with this f- i i letter. Within these areas, the inspectior, consistec of se?ectivi 'fif f f examinations of procedures and representative records, fr.terviews with h *$ '
i personnel, and observations by the it;spe: tor. 4
, Our inspector also verified the steps you have taken te correct the 4 )
items of noncompliance brought to your attentien in the enclosure to our Lt letter dated Hovember 9, 1c75. We have no further quntions regarding ?/
your actics at this time. ]';
y w. 1 Eased on the results of this inspection, it appears that one of your ~Y , !
activities was not conducted in full compliance wit.h NRC requirements,- ^
e M l as set forth in the Notice of Violation, enclosed lerewit.h as Appendix t A. This item of noncompliance has been categorized into the levels 31 described in the Federal Register Notice (45 FR M704) dated October 7, 1950. This notice is sent to you pursuant to the provisions of Section j 2 201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal 4 Regulations. Although Section 2.201 requires you to sut.r.it to this office, 1 within 25 days of your receipt of this notice, a written statement of ?
explanation, we note that this item of noncompliance was corrected prior to the completion of our inspection, and therefore, no response with re- y) j Spect to this mattW is required. T y -
^
R 609 ;m
____ - -= _ _ __ - __ ._ _
+
.j
}: a JUL 61981
(: . .' N't'agara* Mohawk Power Corporation 2 In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
,3 this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4),
it is necessary that you (a) notify this office by telephone within ten (10) days from the date of this letter of your intention to file a request for withholding; and (b) submit within 25 days from the date of this letter a written application tc this office to withhold such information. Consistent "
with section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the information should be withheld frem public disclosure. This section further requires the y statement to address with specificity the considerations listed in 10 CFR 2.790 (b)(4). The information sought to be withheld shall be incorporated ;
as far as possible into a separatt part of the affidavit. If we do not ;
hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room. The telephone notification of your intent to request withholding, or any request for an extension of the 10 day period which you believe necessary, should be made to the Super- ~'
visor, Files, Mail and Records, USNRC Region I, at (215) 227-5223.
Should yev have any questient concerni.ig this inspection, we will be pleased to discuss them with you.
Eince ely,
/
/ h G.L. der, C' l'f Disi on of L.c gency Preparedness and Program upport
Enclosures:
Appendix A, Notice of Violation Office of Inspection and Enforcement Inspection Report Number 50-220/81-02 cc w/encls:
M. Silliman, Acting General Superintendent, Nuclear Generation T. Roman, Station Superintendent R. Abbott, Operations Supervisor E. B. Thomas, Jr. , Esquire t
I
..y w
. i APPENDIX A .I 4
Notice of Violation 1 y
Niagara Mohawk Power Corporation Docket No. 50-220 g License No. CFR-63 l i
1 :l' Sased on the results of an NRC inspection conducted on February 9-13 and 4 2t-27, 1981, i.nd in accordance with the Interim Enforcement Policy, 45 FR j 66754 (October 7,1980), the following violation was identified: t Section 3.2.9 of the Environmental Technical Specifications (ETS) ;
specifies that the environmental radiation monitoring program specified %
in Table 3.2-1 shall be conducted. Table 3.2-1 of the ETS requires .l that airborne I-131 be analy:ed weekly at the required stations. 4 s
C.mntrary to tb: above, airborne I-131 was not adequately monitored at 11 of 10 stations for an extended per'od of time including the date of sample station inspection, in that sete of the air from the sample stres.m bypassed the charcoal sample carteidges due to lack of sealing Saskets in the cartridge holders.
1 7Ms is a Severity Level V Vtclat;cn (Supplement I).
A m
I
~
Qg hg-p-"{"]
- o l
I ':: ,
u.3
$ -f
- *w? .
w.PWeg. ;
~
ga
- U.SJ NUCLEAR REGULATORY COMMISSION ~
C 0FFICE OF: INSPECTION AND. ENFORCEMENT t' :: 1 Region It bl as ,
- .' Report No.-- 50-220/81-02 R+
Docket No. 50-220' 0 ,
-- Category C $ 'l
- License No.DPR-63 Priority
[ ~.
- . Licensee: . Niagara Mohawk Power Corporation (NMPC) h 300 Erie Boulevard West ,
Syracuse, New York .13202
. 7J Facility.Name: Nine Mil'e' Point Nuclear Stat %n, Unit 1 (fiMP-1) ' !
)
~
i c .
Inspection at: Scriba. New York ,
Inspection conducted. Febr ry 9-13. 24-27,1981 p
kl I @"* d/.
' Inspectors: f . ,/f d 4LC-y L -
I"'
T.J. NNi, Radiation Specialist
- k. # <
date signed l f-
. q n ,. y cEtt signed
~
f Approved by: _
f* g f/ -
~, R.J. Bores,kief.In&pendentMessuremer.t M b'
& Env$ronr. ental Protection Suetion. EP&PS Branch h W;
e Inspection Summary:
$j W
inspection on February 9-13, 24-27, 1981 (Report No. 50-220/81-02)
Areas Insoecteo: Routine, unannounced inspection of environmental monitoring management controls for these programs; programs for operations, including:
the licensee's program for quality control of analytical measurements; implementation of the environmental monitoring programs - radiological; implementation of the environmental monitoring programs - biological / ecological; nonradioactive effluent release rates and limits; and followup on licensee The inspection action on previous environmental inspection findings.
involved 34 direct inspection-hours by one regionally based tiRC inspector.
L Resul ts : Of the six areas inspected, no items of noncompliance were found in five areas. One item of noncompliance (Inadequate environmental airborne iodine sampling - Detail 5.a) was identified in one area. ,
t h ir Y S M f / 2 .( & 3 /[ 3 p Region I form 12 [
(Rev. 1.pri1 77}
4
, p _ . _ _ __ -y-- '"
- m e m*C k
l DETAILS f
- 1. Individuals Contacted -
Niacara Mohawk Power Corporation (NMPC)
- H. Silliman, Acting General Superintendent "T. Roman, Station Superintendent
'E. Leach, Superintendent Chemical / Radiation Management
'H. Flanagan, Environmental Protection Coordinator ,
'B. Taylor, Site ILC Supervisor R. Coon, Unit I&C Supervisor D. Palmer, Supervisor QC Operations G. Leskiw, Assistant Supervisor, QC Operations D. Regan, B" Technician N. Sereno, "C" Technician l J. Coates, "D" Technician power Authority of 19 State of New York (PASNY)
R. Pasternak, Resider.t Manager V Childs, Assistant to the Resident Manager R. Baker, Superintendent of Power R. Burns,1ssistant to Of Superintendtet of Fower M. Cospreve, Site CA Engineer D. Tall, Training Cxrditator '
)
R. Converse. 0;cration Superintechnt B. German, EmitormentSt Supervisor A, Mt.reco, /4ststrat t; Radiologiul and trstrenmental Services (* ES) n I
l Superintendent '
l V. Szeluga, f.ES "f" Techniciaa .
l R. Liseno, Shift Supervisor D. Jennsen, Control Rocm Shif t Cperator H. veith, I & C Supervisor
- denotes those present at the exit interview i
'b 3 4
- 2. Licensee Action on Previous Inspection Findings a
(Closed) Unresolved Item (220/78-15-01): Location of environmental y i TLDs. The inspector reviewed selected TLD stations and noted that S TLDs appeared to be appropriately located at the stations to minimize $
siting effects.
support posts.
Those TL0s observed were mounted on the plant-side of The inspector had no further questions regarding this k:
j ttem. ?'
(Closed) Deftetency (220/78-15-02): ' Failure to calibrate environmental 1 radiation monitor. Theinspectnrreviewedcalibrationsoftheenvironmental$.;
monitors compieted since NRC Inspection 50-220/78-15 and noted that y calibrations were performed as required, in accordance with the licensee's y d
j corrective action described in the December 1, 1978 response letter.
i The inspector had no further questions regarding this item.
(Closed) Unresolved Item (220/78-15-04 and 220/77-16-02): Environ- 4 mental Analytical Laboratory. The inspector reviewed the current $
laboratory facilities which are located in the Auxiliary Access Point i Building on the J. A. Fit:Patrir.k. site and noted that the necessary y equipment was calibrated and operating at the time of the inspection, 8 and that operations were conducted according to approved procedures. 9 The inspector had no further questions regarding this item.
i (Closed) Unresolved Item (220/78-15-05): Biological data availability.
The licensee's biological contractor, as of January 1981, was Ecological l $
Analysts, Inc., who replaces Texas Instruments, Inc. Sampling and 9 analytical records, the data in question, were maintained at the e contractce's field 'ffice in Oswego. The inspector had no further questions regarding this item. d{
(
x; (Closed) Infraction (220/78-15-06): Exceeding AT limit during flow %
reversal operations. The licensee's December 1, 1978 response letter 4' described, as corrective actions, procedure changes and an investigation 3 into failures of Gate "C" to function properly. The inspector reviewed h the appropriate procedure and selected thermal discharge records and
~
identified no further items of noncomi iance. The inspector had no further questions regarding this item (Closed) Deficiency (220/78-15-07): Exceeding AT limit during normal plant operations. The inspector reviewed licensee operations and corrective actions taken as described in response letters dated December 1, 197' and February 7, 1979, and reviewed selected thermal discharge records completed since September 1978. No further items of noncompliance were identified. The inspector had no further questions regarding this item.
l f
a
l
[!hh ],[D [ '4' yq
- p p p:' :( h j n
- i (Closed) Deficiency (220/78-15-08)
- : Failure to report exceeding AT ;
during normal plant operations. The inspector reviewed selected O j[; thermal discharge records and licensee event- reports (LERs) completed
) since the last inspection and noted that reporting requirements ..
f appeared to have been satisfied. The inspector had no further questiens
[ regarding this item. r.
k '
(Closed) Deficiency (220/78-15-09): Exceeding the annual disch.rge
! limit for phosphorus. The licensee stated that no chemical wastes, u including phosphorus, have been discharged from the plant since the Spring of 1979, and therefore, this problem did not recur. The inspector
@ had nolfurther questions regarding this item at this time.
f 3. Manacement Controls 1-x J The inspector reviewed the licensee's management r.ontrols 'or the i environmental monitoring programs. Areas reviewed included: Assign- -
Y ment of responsibility; program audits; corrective action for identified 0
inadequacies and problem areas in the program; and the reporting, analysis, and evaluation of program data.
[ a. Assionment of Responsibility p The inspector reviewed the organization and administration of the I
t environmental me n tering programs. The program is run by the k site Environmental Protection Coordinator who reports to the site Supervisor of Chemistry / Radiation Management, who in turn reports to the General Superintendent, Nuclear Generation.
l l'
The licensee stated that as of January, 1981, the biological monitoring programs are no longer conducted by Texas Instruments,
< Inc., but are now contracted to Ecological Analysts, Inc.
1'
- b. procram Review and Audits The following licensee audits were reviewed as part of this in-l spection.
Audit Dates procram Area Covered June 5, 1978 Environmental Station In-spection and Sample Collection October 10, 11, 12, 19 and Safety Review and Audit Board November 17, 1978 (SRAB) Radiological Audit-covered radiological effluents and envircemental monitoring October 10, 11, 12, and 19, SPAS Environmental Tech Spec 1978 (ETS) Audit-covered all nonradiological I areas sp
- MI \
@g, M a -
NJ se ,
a
%@ 1. M M
Cctober 16-17, 1979 -TexasInstrume'nts,Inc.(TI) M y{ .(biological' programs) d g :I ' October /16-18,1979 SRAB ETS:Audttt
( December 11-13, 1979 SRAB Radiological Audit m,j s
December 18-19, 1979 Radiation Management Corp. (RMC) 1 . .(radiological contractor) i,s
. June 24-25, 1980 " Environmental . Station Inspution . O and Sampling Collection" Surveillance Report.SR-80-13' October 14, 1980 Texas Instruments, Inc. (TI)
{
October 14-16, 1980 SRAB ETS Audit
] ,
October 15-17, 1980 SRAB Radiological Audit February 2-6, 1981 RMC The inspector noted that the audits of TI covered sample collection, ~
processing, analyses, and data reduction and reporting. Audits of PMC covered sample processing, analyses, and data reduction and reporting.
The inspector noted that the Itcensee, during the December 18-19, 1979 audit of RMC, had questioned the discrepancy between RMC results and EPA values for Cs-137 in EPA Crosscheck Program milk samples. RMC's response to the' licensee, dated January 10, 1980, stated that the discrepancy was due to the methodology used in RMC's analysis of the milk and.that-an alternative method was under investigation which would better assure the preservation of-any cesium in the sample. The
-inspector discussed with the licensee the methodology still being used by-the contractor and the possible effects of this methodology on radioactive cesium results reported for milk. The licensee stated that the contractor would perform a complete evaluation of the methodology used for gumma spectral analysis of mil;. .id its effect on cesium results. The inspector stated that the adequacy of gamma spectral cesium results would be considered unresolved pending completion of this study and subsequent review by the NRC (220/81-02-01).
4 Licensee prooram for Quality Control of Radiological Analyses The inspector reviewed the licensee's program for quality control (QC) of laboratory radiological measurements and noted that the analytical contractor (RMC) had its own QC program, and that the licensee conducted a OC program which included the contractor and those analyses performed
nn, +g n w v.. - , ,
J+l71. . '
6 d4gp~
- j. : ' '
};
f, Y 'h@
+
- C .. .
l l The. snalytical; contractor in this area 4nd the b
t byfPASNY personnel.
licensee had both prepared detailed written: procedures ~ for1thek respective-QC programs. Environmental samples were also split with il
[
h 9 r the New York State _ Department of Environmental Conservation. The. . . tk h
licensee stated that the contractor QC data was reviewed and evaluated- 7F
{ onia routine basis.
7
)
The licensee stated that the QC program was being upgraded and provided =
h
@ the inspector with a copy of the " Draft Environmental' Surveillance j p Program QA/QC Program" description. The inspector reviewed the draft program document and noted that there were clear provisions for:
y 61 Assignment of responsibility to manage and conduct the program; Mh Number and types of samples to be included; Acceptance criteria; and /
1e
-- Follswup action on identified discrepancies. i The ' draft program also contained provisions for detailed periodic 3' checks of environmental monitoring stations and equipment. ;
a The licensee stated that this upgraded version of the QA/QC program i would be implemented by May 1981. The inspector stated that this. .
program would be reviewed during the next inspection of the area. 9 a
No items of noncompliance were identified in this area. j
- 5. Implementation of the Environmental Monitorino procram - Radioleoical
- a. Direct Observation ,
The inspector toured the site environmental analytical laboratory and reviewed the associated procedures, logs, and instrument calibrations.
The inspector examined selected environmental air sampling and direct radiation monitoring stations, and observed the changing of the air particulate and air iodine collection media, measurement of sample flow rates, the recording of the required information for each sample, and the checks made on each sampler as it was returned to service. The inspector noted that at most air stations (with the exceptions of stations H, I, J, and K) the charcoal cartridge holder did not coatain seals so that the cartridges were therefore loose in the holders. This would allow some of the air from the sampling stream to bypass the cartridge. The inspector stated that this sampling arrangement did not provide adequate sampling of airborne iodine because the air flow through the charcoal cartridge was reduced by an indeterminate amount.
.i
+ + y- ~
,9 !
&ygmy".+ <
% i
?l;j The inspector stated that inadequate sampling of airborne ioM*e 'was an1 iM I item of noncompliance with regulatory requirements. . The inspector noted g that prior to the conclusion'of the; inspection:the licensee h i adequate seals at those sampler stations where they were lacking, thereby M j
correcting the problem. lj . j g
The inspector discussed with the licensee other aspects of environmental .l$ l' air sampling and noted that the air sampler inlet tubes each $
contained a 90 degree bend through which inlet air was deflected d before reaching the particulate filter. The inspector discussed 4 )
with the licensee the advantages of having the inlet air first 9 1 pass through the particulate filter, thereby eliminating the 7 possibility of line effects on air particulate sampling. The C- i licensee stated that the elbow had been incorporated to keep ..
precipitation from the reaching filter. The licensee stated that #;
the inlet design would be modified to eliminate any possible line $
effects and that precipitation protection would be provided by an i alternate mear.s. This area will be re-examined during a subsequent 4 inspection of the area (220/81-02-02). j j
- b. Review of Reoorts (1) Routine ;
q The inspector reviewed the following reports as part of this inspection. 1 Annual Environmental Operating Report, i January 1-December 31, 1978 Qa Annual Environmental Operating Report, It January 1,-Oecember 31, 1979 ['
RMC Environmental TLD System: Evaluation of Compliance with USNRC Regulatory Guide 4.13-August, 1978 The inspecter determined through discussions with the licensee, review of these reports, and review of data that the licensee had reported all required information.
(2) Nonroutine The inspector reviewed the circumstances and licensee's evaluations of the following anomalous measurements reports.
LER No. Date Subject Area 79-12 September 7, 1979 Mn-54, Co-60, Cs-137 in Cladophora 79-24 November 1, 1979 Cs-137 in milk
- p. L:
i 8.
$m4,.
- , , e ,
g:. , ,
y i
,; s V
[ -
The' inspector noted that tbdlevels of radioactivity re- h l ported in Cladophora represent?a minima 1' environmental- p )
impact based on the icw levels of activity measured'and the d {
dose consequences to man are: insignificant basedLon the low i F level of. radioactivity and the_ indirect dose pathways to man $jj involved. p, The insp ator discussed with the licensee the Cs-137 in b milk as tu asured on the one occasion-noted above and reviewed 4 l a report prepared for the licensec by 205 Corp, titled "An j {
Evaluation of the Cesium Concentrations in Environmental 3 Milk Sample and their Signif t:ance at the Nine Mile Point-James A, Fitzpatrick Site". This report was prepared in j
V response to an elevated Cs-137 level reported for a September 1979 milk analysis at Station No. 25. The: inspector stated )f y
that based on the above report, it did not appear possible Q
i
~
to rule out the Nine Mile Point-J.A. Fitzpatrick plants as 4 a source of the Cs-137 in milk, although neither did 'it j appear likely that the plants are the only source. It is 4 important to note that regardless of source, the reported 53 4' pCi/1 of Cs-137 in milk would produce a whole body exposure 4 of 0.10 mrem / month to an adult -(critical individual) and- @
0.89 mrem / month to an infant liver (critical organ), calculated J using methodology presented in Regulatory Guide 1.109 for maximum exposed individuals. The measured level of 53 pC1/1 did not appear to persist for more than one month and was
}j g '
not identified at any other sampling stations. These doses are a small fraction of the 25 mrem / year limit of 40 CFR 190 %g for members of the general public. The inspector had no J further questions with regard to this item at this time, j
- 3; The insp.ctor reviewed LER 80-30, dated January 5, 1981, 4 concerning problems in meeting required analytical sensitivities- _
for fish samples in 1980, as identified by licensee SRAB "
audit in October, 1980 and discussed licensee actions taken y to achieve the sensitivities. The licensee stated that possible improvements in sensitivities were still being "3 pursued with the analytical contractor. The inspector stated that the effectiveness of licensee actions would be reviewed during a subsequent inspection of the area (220/81-02-03).
The inspector conducted an independent evaluation of I-131 detected in milk in November, 1980 as described in LER 80-28 and reviewed all pertinent available data. Based on peak I-a f hf. __# h __
R, , $ '* ~*": " ' +-
- ^ jf*
- c; b
+
yp g
@ 131' airborne release rates from.both plants at the site just y y
k 1 prior to and_during the' period in which I-131 was' detected R"
in milk, using the pathway modelsidescribed in Regulatory Guides 1.109 and 1.111; it'wasenot-possible to identify as i
q li' the sole source either, plant! releases or the October 16, "
1980 Peoples Repubite of China 1 weapons: test'and resulting ,
s'
~
fallout. <
k .
f The. attachment to thistreport illustrates the airborne R Iodine-131 relcases from1both the NMP;and JAF. sites during 4 the interval Septembe' r;through November;:1980. Also shown ;
on the same plot are the'date"of'the' weapons test by the 2 Peoples Republic of China on October 15, 1980, and the-- g dates,. locations and the I-131 results of all milk samples with positive values. The maximum airborne release rate !g ~
(from JAF) for I-131 occurred during the week in which the 1 weapons test' occurred. Because of the near proximity to tb,- Y
, JAF-NMp source to the sampled milk farms, any deposition .h from this source should have taken place within hours of the ? ,
release.. Deposition from the weapons test, on the other 9#
hand, would first be expected to occur approximately two y weeks after the test because of the atomspheric diffusion and transport time. The deposition from the latter would M@
also be distributed in time over several weeks. jj Review of the milk data (and as depicted in the Attachment) '
has indicated that the first positive iodine measurements in ij milk occurred approximately two weeks following the weapons test at which time the todine release rates from both NMP %g and JAF plants had decreased by a factor of about 10. These positive milk I-131 samples were collected from several g@j locations including the control farm. Subsequent to this A date (November 3,1981) all sampled milk cattle in the area f1 (with the exception of Sampling Station No. 25) were removed from pasture for the winter. Sample Station No. 25 showed kA an increase in I-131 levels in milk to 10 pCi/1 and remained 9 at about that level (- 8 pCi/1) until the end of November, while the HMp-JAF releases continued at about a factor of 20 below the peak release rate.
Consequently, while one cannot easily rule out that the NMP-JAF releases contributed to the I-131 activities measured in these milk samples, it appears at least highly unlikely that these releases were the sole source of the measured activity.
Regardless of the source of the I-131 the expected dose consequences would be minor. Only one cow was present at Station No. 25 where the elevated levels were detected, and consumption of this cow's milk with 10 pCi/1 of I-131 for the one tnonth period involved would produce 3.8 mrem to an infant thyroid, although no infant consumed milk from this farm (an adult would receive a thyroid dose of 0.5 mrem). l
v a .gMy;gglyQsgMg*w-x . m'a w '+%Q@Mjphytb@' W m' % PN@q;g}
y q)s(o r :g y=jg o,# w ". e u : c;. 21
.CC;s=e T"'
pm ge n gg ,
g , ..g .
u d O :L (%,hj N O d W u n .erf
- ,*if t$ ".' w
- .q cc 1, 6 h .a t- q 00 Q) -[ . o I # .ei /, n -
c)
- a. g:
,'"t .z Q . > <>
. ;6 r
C 77 I o <>
l .,
79
% Z, ,,
s3 C)
C yu _g (sr.*ess)t/inds's (gj'rts.stris)g C
. fsy
. C)- f 9*'
O a "
. 1/63ds s ;?
CL g E p l 2~ Ki
.u Q) p4) u 1 - >
o
< *~
O.
o .
l
- Z e 1 Q) i J 51 '
C9 co o I.-. &s o ",;
t Q) .
~
't'~- .C *
!.,1 (t t *ris fl3ct*0
- _ _ o 1 --- g o - -
C) 4 y (tes; wen.C,t
( r ris t/imer ot e s t/iser o
.e_ g g l a o .5!
O
,,: : ::" . ._ . J n22
- s.u 1 o l
- e
,,,,, ; ; ;r : . i; L.-.- y~ . j" o
1 s so1.nvic- =a .
I O :q i
e u 1 . so > !!i I ";::: - . .
- f. _g e 1 :q o 1 m .
, -;j e e, I>
-. e$
90 a -
1
' .j I
.-.-. . ~ . _ ,, - . - . .J e-.- ;
i
,y -.-..--.l--.-.;,
1 g w
= ,m -
m 0
, 3 g g en 7 7
.C, o f y
- n
_ o i o
i o I s 8 O
O
- O cas /!an .
r k
6' e sa b y
- p. . - . .
ev 10-
+ - .
aj Q ^" -
~
'd i The inspector had no further questions regarding the above releases $
and their consequences at this time. No' items of noncompliance , ?!;{
were identified. p.
p
- c. Other Records MM The inspector reviewed selected results of analyses of the radiological
[M monitoring program, especially the 1980 data for which the annual : i' report was issued subsequent to the inspection, rand discussed 'i a with the licensee the methodologies used to calculate error and E : !
to calculate lower limits of detection (LLD). The inspector s determined that the required samples and analyses had been collected Xq and analyzed in accord with the ETS. 'j No items of noncompliance were identified relative to this area. @
R
- d. Meteorological Monitoring j q'
The inspector examined the site meteorological instrumentation, q including the meterological tower which is maintained by NMPC and the recorders in the Nine Mile Point, Unit 1 Control Room. The j$
licensee stated that the control room recorders amd the rest of 9 the meteorological instruments are checked on a biweekly basis 4 and calibrated semi-annually. 4 instrument calibration proceduresThe inspector and reviewed calibration recordsthe meteorological j completed since the last inspection of this area (50-220n S-15). Starting M speeds for the wind spced sensur: were discussed and the inspector .
M noted that the semi-annual instrument calibrations did not include a decertification that these sensors could meet the starting
'$ M-speed specifications of Section 3.1.1 and Table 3.1-1 of the ETS. jj The inspector noted that the type of instruments in use appeared ;J capable of meeting the required specifications and stated that l' 4 the issue of whether the installed instruments could in fact meet +M the starting speed specifications would remain unresolved pending Nf I licensee verification and subsequent NRC review (220/81-02-04). Q The inspector reviewed the licensee's evaluation regarding tne loss of data transmission f rom the met tower to the control rooms as described in LER 80-20, September 29, 1980 and examined the corrective actions taken to prevent recurrence. The licensee =
stated that a spare of the part which caused the problem is now maintained in case replacement is necessary.
No items of noncompliance were identified.
- 6. Implementation of the Environmental Monitorino program -
Biolooical/Ecolcotcal The inspector examined the impir.gement sampling apparatus at the plant side of the intake tunnel and reviewed selected sampiing and analytical precedures. The following reports were reviewed.
l I
\
s n &
3..,
1N N '. N NIY ?Y N W '
h.
b
- Report Oste -O j y 48-hour Daphnia pulex LC50 Test Using October 1, 1979 : '.
$, Naisperse-7348 and 7.188 4j 1 a1 y
Condenser Water Treatment: . Oct.' 26-29, January 11, 1980 ;j d 1979 Using Naisperse 7348 and 7388 1
e, c4
[r 1979'Nine Mile Point Aquatic Ecology March, 1980 ?. Q M Studies 6' 4
Environmental Impact Assessment for January 12, 1981 5 M Chemical Treatment of Hain Condenser A.
E Cooling Water ?n y
y@i The-licensee stated that it was currently not planned to use blocides in the main' condenser cooling water. The inspector also reviewed h
f- Th
+ selected records and data completed since the last inspection of this A area in September, 1978. #
M . . .
The inspector reviewed the circumstances concerning T missed impingement j&g l sample as described in LER 78-41 (December 28,1978), and noted trat 3 the associated environmental impact was negligible. r1
- 3. - !
No items of noncompliance were identified in this area. 3S D
- 7. Nonradioactive Effluent Release Rates and Limits @
f
, s. Thermal fM p , MKi k The inspector reviewed selected recores of the thermal monitoring
[ system since the last inspection of this area, including thermal 4f .
f discharge records, calibration records and related procedures. $
F The inspector also reviewed the circumstances and licensee's- 44
$ evaluations regarding LERs 80-06'(2/2/80) and 80-11-(7/22/80) 3@"
which described occurrences during which the ETS AT limit was exceeded. The inspector reviewed the chart recorder repairs made subsequent to LER 80-06 and the current operation of the thermal monitoring system. Calibration records pertinent in response to LER 80-02(1/16/80) concerning thermal sensors found out of tolerance were reviewed.
The inspector had no further questions concerning this area and no items of noncompliance were identified.
- b. Chemical The inspector examined selected results of chemical use monitoring completed prior to Spring, 1979, and LER 78-36 (November 2, 1978) describing Na and 50 releases. The licensee stated that no chemical wastes had been discharged from the site since Spring 1979.
The inspector had no further questions in this area.
h; y
__________:_--m
- e% %wa M skyw,yJ. w, , .c :
^ lgl#%ek4skk%;,m7%em
- 1. 44%7F
' ' , '?;d12? ,
S jp ' '
f;,
u .
o N, o- ,
, gi y
!b 8. Unresolved Items .
3
- t; LUnresolved items are matters about whidh more information is required 3j) i h ~ iniorder to ascertain whether they areTacceptable' items, items of.
[4
-noncompitance, or deviations. Two unresolved items were disclosed )h
,._ during this inspection and are discussed in Detatis 3.b and-5.d. .,+-
n 4 .:. , -
- 9. Exit Interview @q On February 27, 1981, at the conclusion of the inspection,.the inspector M met with those individuals denoted in Detail 1.- During this meeting
-$p the purpose and scope of the inspection vere summarized and the inspection f findings, including the item of noncompliance and the unresolved 4 items, were discussed. %
W ,sy
}' '
1,7
,g.
pr+ K' u 9- 1
..< ..$.. g A
- %g.
- , .' 's ww -. 4gUNITED STATE 8sas ~ . ,* "
pit G^%y9g}yy;gNUCLEAR ifQQgjnQlQy#gg, REGUCATORYtCOMMISSIONT 1 y"h
,w -_
f M Ul, s ,631 PARK AVENUeT W k, 4?*3 lth . .. .
e' ' KING OF PRUS$1A. PENN8YLVANIA 1M06 -
g-f kk'hf\
W @ Docket 1No. 50-333t t JUN 3 0 M1
[
i . Power ~Aiithority of the State of'New York
~
@.? ' }.i ~ (,h a - James A; Fit: Patrick Nuclear Power Plant C- U.
ib JQ y b8@
~
W N y ATTH:- lMr. R.;J. Pasternak w4 < Resident. Manager
% y,,, aowgrou .dn 3
c P. 0.2 Box 41 ,C Lycoming, New York 13093 \y 49 3
Gentlemen: Eb 5 t
1 P}'
Subject:
Inspectien 50-333/81-05 ,
p a 1 This refers to.the routine safety inspection conducted by Mr. T. Jackson of *
"i i
this. office on February 9-13 and 24-27,1981 at the J. A. Fit: Patrick Nuclear Power Plant site in:Scriba, New York of activities authori:ed by NRC License (i
I No. DPR-59 and to" the discussions of.our; findings held by Mr. Jackson with Mr.
I R. Pasternak and others of your staff at the conclusion of the inspection, and' to a -subsequent telephone discussion between Mr. Pasternak and Mr. Jackson on March'9, 1981.
I j- Areas examined during this inspection are described in the Office of, Inspection t and Enforcement 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 observattens by the e inspecter.
Our inspector _also verified the steps you have taken to correct the items of noncompliance brought to your attention in the enclosure to our letter dated
. October 30, 1978. We have no further questions regarding the steps you took
- 7) to correct items C, D, F, G, and H. With regard to item 8, this item was not reviewed during this inspection.
Based on the results of this inspection, it appears that certain of your activities were not conducted in full compliance with NRC .2quirements, as set forth in ..:o Notice of Violation, enclosed herewith as Appendix A. These items of noncompliance have been categorized into the levels described in the Federal Register Notice (45 FR 66754) dated October 7, 1980. You are required to respond to this letter and in preparing your response, you should follow the instructions in Appendix A.
With respect to Appendix A, we note that you have corrected item No. A, and therefore you need not address yourself to this matter in your response.
ss i L
0164 Tl106*30 DRADOCKOSOOOg c
61 ,. ,-
--- c i
f S
%j Y f.WW& % , f fR hj. Nk f rj y Wkhtpi% % W % > v&:RR{:
$/h,'t2 Ri% w ,"h@@} ,!.E' 4tj*Y*kkffh**4W4f}E
~
' " u / W F7 , 4 '9
&,LPower?Authorityof;theState U-4 MON"J l PJ6 N 2: 4 - !
ma '. eJof NewcYork I g) j In accordance with 10 CFR 2.790 of th'e Cammissions regulations, a copy of l
$ this letter.'and the enclosures will be placed in the NRC's Public Occument 4 '
{
V If sthit report contains any information that you (or_ your contractors)
~
Room. q l V believe.tolbe exempt from disclosure under 10 CFR 9,5(a)(4), it is'necessary j that'you.(a) netifyithis office by telephone:within ten (10): days from the 3 t; date of this ,lettbr. of your intention to file -a' request for withholding; and G
( j(b). submit?withinN5L days from theldate of't!irletter a written application .M E 'to this-office to yithhold such information.s: Consistent with sectionl2.790 1 b :(b)(1)P ariy?such' application mus'c be"acecmpanied by r an. affidavit executed by i
i 'the owner;of.the information V.ilch identifies:the; document or part sought to 3 be withheld, and 4hich contairs a full statement of the reasons:en the basis C' which it is claitred that the. information should be withheld from public dis- ~
closure. This section further equires the statement to address with spect- '
ficity the considerations listeo in 10 CFR 2.790(b);4). The information '
sought to be withheld shall be incorporated as far as possible into a separate 1>
part of the affidavit. If we do not hear from you in this regard within the e specified periods noted above, the report will be placed ta the Public Document Room. The telephone notification ef your intent to request withholding, or .
any request for an extension of the 10 day period which you believe necessary, f should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at 7 (215) 337-5223. o Should you have any questions concerning this inspection, we will be pleased to discuss them with you. ,
4 Sinc ely, 2y at U t pli Gary, . Snyd r, Ch ef, Emergency Prept edness and/ regram Support Branch, Division of Emergency Preparedness and 0;erational Support
Enclosure:
- 1. Appencix A, Notice of Violation
- 2. Office of Inspection and Enforcement Inspection Report Number 50-333/81-05 cc w/encis:
George T. Berry, President and Chief Operating Of ficer J. P. Bayne, Senior Vice President-Nuclear Generation A. Klausmann, Director, Quality Assurance M. C. Cosgrove, Site Quality Assurance Engineer J. F. Davis, Chairman, Safety Review Committee C. M. Pratt, Assistant General Counsel G. M. Wilverding, Manager-Nuclear Licensing J. Shanley, NYS Department of Environmental Conservation
d'$. i '
o
- 1
,;? J 4' "
~
, _ /C l y m .. e : APPENDIX A n # ,
"M# '
' NOTICE OF VIOLATION' 2 3' f '
@ { Power" Authority'of the State of New York .
JJamesA.: Fit:PatrickNuclearPowerPlant ~
S icense.No~. DPR-59. Docket No. 50-333 i, g F V 4 ased'on B he results of an NRC inspection conducted on February 9-13 and b 24-27,'1981; and in accordance with the Interim Enforcement Policy, 45 FR x
66754 (October 7, 1980), the following' violations were identified:- @%
t M
A.. Section 4.3.1 of the Environmental) Technical' Specifications'(ETS) _
J
- specifies that the environmental; radiation monitoring program specified h in: Table 4.3-1 shall be corducted. Table'4.3-1.of the ETS requires 3 that' airborne I-131 be analyzed weekly at the required stations. M
$5 Contr'ary to the'above, airborne I-131 was not adequately moni_tored at W 11 of-15 stations for an extended period ofg time including the date of sample station inspection, in that some of'the air from the sample ik l
stream bypassed the charcoal sample cartridges due to lack of sealing }f gaskets in the cartridge holders.
jx 2..
. This is a Severity Level V Violation (Supplement !). $G B. Section 5.3.1 of the ETS specifies that review and audit of environmental matters shall be performed as described in Section 6.5 of Appendix A to the Technical Specifications.
$df L(y w
Section 6.5.2.8 of Appendix A specifies that audits of facility activities shall be performed under the cognizance of the Safety Review Committee kI hi (SRC), and that these audits shall encompass the conformance of facility Ms ,
operation to provisions contained within the Technical Specifications $
and applicable license conditions at least once per 12 months.
Contrary to the above, the conformance of facility operation to the provisions contained within the ETS for several areas, including ETS l Sections 2.1, 2.2, 3.4, 4.1 and 4.3, was not audited at least once per 12 months since 1978. ,
I This is a Severity Level V Violation (Supplement I). 7 pursuant to the provisions of 10 CFR 2.201, power Authority of the Sta;;e of j New York is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply to l M07;70ico BT0630 2DR ADOCK 03000333 3 PDR n
~ ^ - r Ow,p 2 s ae r ,
pen' dix ( w'; % e;' , -
$$)' W eu ,
m' 4 >
? $Y *
'~ '
- id UMN3tlDdf., I"W .' j
- '"+jON@DR?
,. % ',o+p&Q9$& wk o<4hi b[A A. y iii&gm)t
+ 7:: .
my ; m , .
. +,
b'h;g[IieEBRE5i:1uding M(1)f the; correctin) ste;is %i$1ch f ave' beeri'laken:'andl Tresultsfachieved;t(2) correctiveisteps'shich Willibe"taken to' avoid ~further
. Eviolations';eand.(3);the'dateLwhen full compliance'will be achieved.- Under the j b Tauthority:of Section 182 of ~ the Atomic Energy Act of 1954,:as' amended this i Jresponse shall be submitted.under oath or affi ation. jf A
L
. . ?>
Dated.
/ ;
Gary ' . Snyder,.C f Emergency :1 Pre edness and ogram Support y Branch, Division of Emergency .
Preparedness and Operational Support 24 g
G Y
m 4
4
. a h
n -
4 Wq
~
(l 5
m;; z .- . -
Q; p-g.f@n y Qw -jMw .r
+
- *QpA&&fgi44;b6& - - - -
f
E .c 7 v
'e' 4
- d\ T -
1 w
I y
F " j
@ U. S. NUCLEAR REGULATORY: COMMISSION 13 L OFFICE OF INSPECTION AND ENFORCEMENT M t
k REGION I
)n
' Report No. 50-333/81-05 l 8 ,,-
. ' Docket No. 50-333 i e &
E License'No. OPR-59 Priority --
Category C j.
Licensee: Power Authority' of the State of New York'(PASNY) i i
P. O. Box 41 l Lycoming, New York 13093 7, R
Facility Name: James A. FitzPatrick Nuclear Power plant (JAF) l}
Inspection At:
Scriba, New York 3
Inspection Conducted: February 9-13, 24-27, 1981 '
.Inspeetors: s$!/ M .>4-T. J. Jigtsgin/ Radiation Specialist
[c17-8/
date
~
date Approved by: 2
' R. -J. Bores,pief, Iricepencent Measurements I* d f "f/
cate
& Environme r.al Protection Section, EP&PS Branch Inspection Summary:
Inspection on February 9-13, 24-27, 1981 (Recort No. 50-333/81-05)
Areas inspected: Routine, unannounced inspection of environmental monitoring programs for operations, including: management controls for these programs; the licensee's program for quality control of analytical measurements; imple-mentation of the environmental monitoring programs - radiological; implementa-tion of the environmental monitoring programs - biological / ecological; nonradio-active efficant release rates and limits; and followup on licensee action on previous environmental inspection findings. The inspection involved 34 direct inspection-hours by one regionally based NRC inspector.
Results: Of the six areas inspected, no items of noncompliance were found in four areas. Two items of noncompliance (Failure to conduct all aucits at required frequency - Detail 3.b; Inadequate environmental airborne iocine sampling - Detail 5.a) were identified in two areas.
g$I07170172re! O630 l
-PDR ADOCK 05000333 i
.G. PDR
h., s$ h %e , h ? $ $ Y* W Y, M *N 9'W WWW
$kq lifY 4- ,
Y T,1
% 1,e 4 Q D^ <
DETAILS N
s N - 1. -' Individuals Contacted 3 4" d b*' Phwer Authnity of the State of New York (PASNY) $n F' - "R. Pasternak, Resident ~ Manager "V2 Childs',; Assistant-to the. Resident-Manager d
7
- RZ Baker, superintendent of Power g
- R. Burns,iAssistant to-the Superintendent of Power
, 3
, M.,Cosgrove, Site-QA Engineer
- D. Tall, Training Coordinator- ;
t *R.1 ConverseV 0perations Superintendent ~;
- BE Gorman,' Environmental Supervisor
- A.;McKeen Assistantito Radiological and Environmental Services (RES) u
' Superintendent y K. Szeluga,-RES'"B" Technician b R. Liseno, Shift Supervisor :l*
D. Johnson, Control Room Shift Operator H. Keith, ILC Supervisor Niagara Mohawk Power Corporation (NMPC)
M. Silliman, Acting General Superintendent ,
T.' Roman, Station Superintendent. J E. Leach, Superintendent Chemical / Radiation Management H. Flanagan, Environmental Protection Coordinator B. Taylor, Site I&C Supervisor .
R. Coon Unit I&C Supervisor "
D. Palmer, Surervisor, QC Operations G. Leskiw, nsistant Supervisor, QC Operations D. Regan, "B" Technician N. Sereno, "C" Technician J. Coates, "D" Technician ,
" denotes those present t.t the exit interview.
- 2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (333/77-21-01): Fish kill contingency plan.
The licensee provided the inspector with a copy of the contingency plan which was submitted to the New York State Department of Environmental Conservation in February 1977, and which has been implemented through the PORC approved procedure, " Ecological Monitoring Program Standard Operating Procedure for J., A. FitzPatrick", and was part of the submittal to the NRC which resulted in the current Environmental Technical Specifications
( ET S ).. The inspector had no further questions in this area.
(Closed) Unresolved Item (333/77-21-07): Environmental Analytical Laboratory and procedures. The inspector reviewed the current laboratory facilities which are located in the Auxiliary Access Point Building on the J. A.
peny, p Wph+w * ~ % *y W y5g **- + e
- x- 2 ,
, . og - i g
i Fit: Patrick site and noted that the necessary equipment was calibrated d and operating at the time of the inspection, and that operations were !
conducted according to approved procedures. The inspector had no further i questions regarding this item.
~
l (Closed) Unresolved Item (333/78-17-01): TLD positioning. The inspector i reviewed selected TLD stations and noted that TLDs appeared to be appro- ,
priately located at the stations to minimize siting effects. Those TLDs i observed were counted on the plant side of support posts. The inspector :
had r.o further questions regarding this item. ;.
(Closed) Deficiency (333/78-17-08): Solutes discharge. The inspector :
noted that Amendment 46 to the ETS deleted the requirement for solutes monitoring on May 17, 1979. The inspector had no further questicas regarding this item.
(Closed) Deficiency (333/78-17-09): Failure to submit LERs as required.
The inspector reviewed selected records in the environmental area completed since the last inspection of the area and determined that for those records reviewed, all LERs had been submitted as required. The inspector had no further questions regarding this item, 6
(Closed) Deficiency (333/78-17-10): Failure to maintain analydical records. The inspector reviewed selected records of solutes analyses and verified that these records were complete up until May, 1979, at which time these analyses were no longer required. The inspector had no further questions regarding this ittm.
- 3. Manacem, ant Controls _
The inspector reviewed the licensee's management controls for the environ-mental monitoring programs. Areas reviewed included: assignment of responsibility; program audits; corrective action for identified inadequacies and problem areas in the program; and the reporting, analysis, and evaluation ;
of program data.
- a. Assianment of Rescensibility The inspector reviewed the organi:ation and administration of the environmental monitoring programs. The program is run by the site Environmental Supervisor who reports to the site Radiological and and Environmental Services Superintendent (RESS). The RESS reports to the Resident Manager through the Superintendent of Power. .
The licensee stated that as of January, 1981, the biological moni-toring programs are no longer conducted by Texas Instruments, Inc.,
but are now contracted to Ecological Analysts. Inc.
- b. procram Review and Audits j The inspector reviewed the following audits as part of the inspection.
l l
f
/d !
9 s 1
Audit Dates Program Area Covered l 4
4
' June 5, 1978 Environmental Station Inspection and P Sample Collection -
1
.. {
October 16-17, 1979 Texas Instruments, Incorporated b !
(biological programs) j u
December 18-19, 1979 Radiation Management Corp. (RMC)
(radiological analyses contractor) { ] '
2 June 24-25, 1980 Hiagara Mohawk Surveillance Report SR- 4 i 80-013, " Environmental Station Inspection !
L and Sample Collection" @j October 14, 1980 Texas Instruments, Inc. (TI) ]@
/
December 10-19, 1980 PASNY Standard Audit No. 347-ETS 4 J Sections 2.1, 2.2, 2.3, 3.4, 4.1, and 4.3. (To determine if. procedures @J and schedules existed to satisfy ETS J requirements) j Februa ry 2-6, 1981 RMC $E h
The inspector noted that the audits of TI covered sample collection, 1 processing, analyses, and data reduction and reporting. Audits of T RMC covered sample processing, analyses, and data reduction and II{g reporting. The inspector-noted that the licensee, during-the December i 18-19, 1979 audit of RMC, had questioned the' discrepancy between RMC i results and EPA values for Cs-137 in EPA Crosscheck Program milk I samples. RMC's response to'the licensee, dated January 10, 1980, i stated that the discrepancy was due to the methodology used in RMC's .g analysis of tne milk and that an alternative method was under inves- M tigation which would better assure the preservation of any cesium in "
the sample. The inspector discussed with the licensee the methodology still being used by the contractor and the possible effects of this methodology on radioactive cesium results reported for milk. The licensee stated that the contractor would perform a complete evalu-ation of the methodology used for gamma spectral analysis of milk and its effect on cesium results. The inspector stated that the adequacy of gamma spectral cesium results would be considered unresolved pending completion of this study and subsequent review by the NRC (333/81-05-01).
The inspector noted that Standard Audit No. 347 (December 10-19, 1950) was limited to a determination that procedures and schedules existed in the ETS program areas, but did not cover implementation or adequacy of these procedures (except in ETS Section 2.3). The licensee stated that audits similar to No. 347 were scheduled to cover appropriate areas every two years, and that program areas such as instrument calibrations, sample collection (other than those a
A
k .
h Y fbbb / MNb' Y ( k[ # "
NJ ' ,
[
.Jg + w - - ~
3 rv u.
5 >
6%
g .
4) collectedbyTI),sampleanalysesperformedbylPASNYpersonnel,and data reduction and reporting'were not_ covered by regular PASNY N
audits every 12 months.. The' inspector stated that failure to perform:
audits of conformance of~ facility operations;to provisions contained M
M in Sections 2.1,'2.2, 3.4, 4.1p and 4.3 of.the?ETS at least once-per 9 !
12 months was an item of noncompliance withlSection 6.5.2.8'of 1 )
-AppendixiA and 5.3.1 of Appendix'B (333/81-05-02).
$s Licensee program for Ouality Conte 1:of Radio 1'gical Analyses
~
4, o 4
The' inspector reviewed the licensee's program for quality control (QC) of laboratory radiological measurements.and noted that the analytical con- ('
tractor (RMC) had its own QC program,9 and that:the ltcensee conducted a >
QC program which included the contractor and those^ analyses performed by 4
-PASNYLpersennel.. The analytical: contractor'in this area ~and the licensee 8 had:both: prepared detailed written procedures for their respective QC M programs.J Environmental samples were also split with the New York State Department of Environmental Conservation. The' licensee stated that the $j contractor QC data was reviewed and evaluated on a routine basis. M ex TheIlicenseestatedthattheJAFQCprogramwasbeing-upgraded,andpro-vided the inspector with a copy of the " Draft Environmental Surveillance @%
Program QA/QC Program" description. The inspector reviewed the draft 5 program document and noted that there were clear provisions for: 3 Assignment of responsibility to manage and conduct the program; f4 k Numbers and types of samples to be included; T A
-- Acceptance criteria; and Q
k Followup action on identified discrepancies. M g i
The draf t program also contained provisions for detailed periodic checks of environmental monitoring stations and equipment. '
The licensee stated that this upgraded version of the QA/QC program would .
be implemented by May 1981. The inspector stated that this program would '
be reviewed during the next inspection of the area.
No items of noncompliance were identified in this area.
- 5. Implementation of the Environmental Monitorino Program - Radiological
- a. Direct Observation The inspector toured the site environmental analytical laborstory and reviewed the associated procedures, legs, and instrument cali-brations.
l L
l.
yug fk '
khf?YW f $ $ j 4
g
< " 6 'E y
Theinsoectorexaminedselectedendronmental'airsamplingand direct, radiation monitoring stations, sand observed the changing of [
the air particulate and air iodine" collection media, measurement of "'
sanple: flow rates, the recording of:the1 required information for (L ;
ler as it was returned fl each sample, to service. and the checks Thelinspector made"on noted.that each'samp? tit stations-(with the at most M
4
, exceptions of stations H,1I,W andLK)ithe charcoal! cartridge holder did not contain sealst so~that!the"cartrfdges were therefore loose 4
in thel holders. This would' allow'some;of the air from the' sampling cd c
~ ~ '
stream to bypass the cartridge. The inspector stated that this $
sampling arrangement did not provide adequate sampling of airborne %
todine because the air flow;through the charcoal; cartridge was reduced by an indeterminate amount. The inspector stated that W;
Vi inadequate' sampling.of airborne todineLwas~an item of. noncompliance with regulatory requirements. The inspector noted that prior to the
$l conclusion of the inspection the ~ licensee had provided adequate seals at those sampler stations where they were lacking, thereby 3
correcting the problem. Q 2
The inspector discussed with the Itcensee other aspects of environ-mental air sampling and noted that the air sampler inlet tubes each W9 contained a 90 degree bend through which inlet air was deflected j before reaching the particulate fil.ter. The inspector discussed %
with the licensee the advantages of having the inlet air first pass j through the particulate filter, thereby eliminating the possibility j of line effects on air particulate sampling. The licensee stated $
that the elbow had been incorporated to keep precipitation from the %
filter. The licensee stated that the inlet design would be modified R to eliminate any possible line effects ard that precipitation protec- @
tion would be provided by an alternate means. This area will be dj re-examined during a subsuquent inspection of the area (333/81-05-03). %
- b. Review of Reports .
(1) Routine The inspector reviewed the following reports as part of this inspection.
Radiological Environmental Surveillance Report, January 1-December 31, 1978 Radiological Environmental Surveillance Report, January 1-December 31, 1979 RMC Environmental TLD System: Evaluation of Compliance ,
with USNRC Regulatory Guide 4.13-August, 1973 '
The inspector determined through discussions with the licensee, review of these reports, and review of data that the licensee had reported all required information.
7 b *b N ib NNNr WN/\ NNfd h f MN '
?' OMQb' '*
e.
y x s .
s 3 i n \
(2) Non-routine 3
f l l
The inspectr.,r reviewed the circumstances and licensee's evalu- 4 ations of the following anomalous measurements reports, d LER No. Date' Subject Area y I
78-072 8/29/78 Co-60 in sediment y 78-077/04T 9/11/78 Ce-144 in periphyton 3 4 78-087/04T 10/18/78 Co-60 in periphyton j 78-099/04T 12/20/78 Mn-54, Co-60 in mollusks 3 79-051/04T 8/29/79 Mn-54 in mollusks ]
79-114/04T 12/21/79 Co-60 in sediment 3 80-064/04T 8/4/80 Co-60 in periphyton i 80-076/04T 10/2/80- Co-60 in periphyton
'}
The inspector noted that the'. levels of radioactivity cited in the above reports appeared to represent a negligible environmental impact based on the Icw levels of activity measured and the dose consequences to man are insignificant 4 based on the low levels of radioactivity and indirect dose e pathways to man involved.
The inspector reviewed the potential environmental consequences of LER 80-041/04T-0 and 80-041/04T-Revision 1 concerning a May &
13, 1980 release of I-131 and noted that there had been no i' measured offsite levels associated with the release.
{
The inspector reviewec a report prepared for the licensee by )
NUS Corporation titled, "An Evaluation of the Cesium Concen- t l
trations in Environmental Milk Samples and Their Significance at the Nine Mile Point ' James A. Fit: Patrick Sita". This report was prepared in response to an elevated Cs-137 level .,
reported for a September 1979 milk analysis at Station No. 25. E The inspector stated that based on the above report, it did not appear possible to rule out the Nine Mile point - J. A. Fit:- l Patrick plants as a source of the measured Cs-137 in milk I although neither did it appear likely that the plants were the only source. It is important to note that regardless of source, the reported 53 pCi/l of Cs-137 in milk would produce a I whole body exposure of 0.10 mrem / month to an adult (critical l l
individual), and of 0.89 mrom/ month to an infant liver (critical organ), calculated using methodology presented in Regulatory Guide 1.109 for maximum exposed individuals. The measured -
level of pCi/l did not appear to persist for more than one i month an s not identified at any other sampling stations. I I
These d .re a small fraction of the 25 mrem / year limit of I f a0 CFR 190 ter members of the general public. The inspector l hac no further questions regarcing this item at this time. I l
i
- ___ _ _ _ _ . i
NN?njyp i& -
k +^
^
~
,s!
fl ~ '
2 H
i IThe? inspector.condudedaEindependentevaluationofI-131 M e
detected in' milk lin! November,/1980 as: described in LER 80-91/04T and reviewed all: pertinent!availableidata..-Based on peak I-131 7
gy Latrborne release rates 1from both)plantsMust? prior to;and -
- duringithe'periodiin!which?I-131 wasr detecteditn milkt using
@9 4
$ i' theipathway modelsldescribedlin! Regulatory Gu. ides)1.109 and ji 9 ,
1.111.-it was:not possiblef to? identify as,thersole source (~
h 'either plant. releases or"the-October 16, 1980 Peoples Republic (_
g of, China weapons test and resulting fallout.- g q
- a. The attachment'to this' report ill'ustrates the airborne iodine-131 i releases from both the-NMP and JAF' sites during' the interval W September through November 1980.' Also shownton the same plot are the date of the weapons test'by the Peoples Republic of f
Chir.a on October:16, 1980p and;the-dates, locations;and the d* o '
I-131 results of all' milk samples with positive values. The 7 maximum airborne release rate (from JAF) for I-131 occurred lj t during the week in which the weapons test occurred.- Because of ,6 the near. proximity of the JAF-NMp source to the sampled milk 3 farms, any deposition from this source should have taken place 4;
within hours of the release. Deposition from the. weapons test, j;L e on the other hand, would first be expected to occur approximately t
- two weeks after the test because of the atmospheric diffusion M
< and transport time. The deposition from the latter would also 9 be distributed in time over several weeks. 3
.9 Review of the milk data (as as' depicted in the attachment) has fj indicated that the first positive todine measurements in milk n occurred approximately two weeks following the weapons test at 3 which time the iodine release rates from both NMP and JAF plants had decreased by a factor of 'about 10. These positive milk-I-131 samples were collected from several locations including the control farm. Subsequent to th1C date (November 3, 1981), 0 all sampled milk cattle in the area (with the exception of Sampling M ation No. 25) were removed from pasture for the winter. Sample Station tao. 25 showed an increase in I-131 levels in milk to 10 pct /l and remained at about that level (about 8 pCi/1) until the end of November, whil. the NMp-JAF releases continued at about a factor of 20 below the peak release rate.
Consequently, while one cannot easily rule out that the NMP-JAF releases contributed to the I-131 activities measured in three milk samples, it appears at least highly unlikely that these releases were the sole source of the measured activity. Regard-less of the source of the I-131 the expected dose consequences would be minor. Only one cow was present at Station No. 25 where the elevated levels were detected, and consumption of this cow's milk with 10 pC1/1 of I-131 for the one month period
. .D$N IN Ekhj $I f
,. 9,,.j,,..
_... ,wg
,y ,
k}{ ...
, p
-w s.
g,a.y,c g.
f >%7 - e n. ,
..j4 , gg
,.u.
];
, .g =
j(-% [Q,i Q y, ,, . [ ' ' J.7 ' .
tl w Q -:y; '
gi-* g ~ ~-n h7
- s. ,
a.
sF 6 : 2@ lq: Q W.
l @ l '.e=*
y , St, : ,)
g.
>, . [s ; . gf, .
~ ; E,, mcw -
, 9y, y< , My
'* y. ' '
. ,Qd ' *
[Q Q:-
-e ,p '
?
tg. .. ,,A- at .
tv N -.
, <yeM
, . , ::Q wi_- nt9-<1 1
-Q.m:
s p- -
. .,, O :L t
$Q. .*L "L.._ 6 o~t
.;8. f./#[ nc: ,n, it/ 1 I' .,
w
- ?
. M, i..J?;$. w;. +e Mi
" . m.
m qt- eau . -
%/l , . . 'j.
Q , k: > ,; ', " - *= .. /& ,M. , (M W4-Z .' =$ l l.
O i on
- l
- Inme I yTa
.m%q 2 '
24 j-; f . {, y u
.- Q 7: *C w,y 1c 3
ot ' - (gg'.16
. l,
,gg)gfg)gg.g &,m;A] p ;4 '
mm-A' c - -
Q. g, ($3 *tt$ = 81t45)y~ ,
O ..~ L/53CS*8 ; p;
' 6(, . ..== t,@y.QE ,. "'
l w -
- 4 P' =": > e IW,
,h:l g(' La= *Q* * *""
- l .
b.; Q, ti.. .
l 3.
'a.
Q
- g
- .r p .O ,
J .
5[.d's - ,S n-O O '. -(/) :o I. . ;gG T"" ** - '~ *$ )
.C-o !1(tl't15)'t/13dC*0 1 O
I g .e e u) "' ' (L" Sues-ci tss) inser t-i -
- ..(t't45)L/lDCt'O m%!
pd..
.C. .
- c .I
. - #r o.g al g "O .-.J ,g ., . . "p ,
o - - - -
- , m.
6 S '.'
- ~ o .
.=
.e , &r 3 g . - 4-4
_ _ a C C . g 2 h e emme . mens *
.' > y' qp ' ' " '
f!3h'i y l p -[ '!;g;. 0
- I tss[asauly3 q 2 u- .y Q[
. . C q7 2>
'.I .
~
=
,h i )M{.O
, ; ; ; e.se e e ==m 1 g;,. .
t> l . w $ ag g se e 3 {,aq :
. j-
.,* - @tv -
j.- l> e r 1 {w _. o 9
.-.. .-.-.- -..J l
y g g
-.-.-.-. "p.-.
1 G W G '9 w g w S o - m
^
, 4 2
.c
- o
- 4f
&4 i
=== s e=
4 ' g g ag em. IP l 4> I I o , e 8 g C O o ces /lon 4
,t
.M
n 3i j~Tc 9 p v v , g involved would produce 3.8 mrem to an infant thyroid, although no infant consumed milk-from this farm (an adult would receive a thyroid dose of 0.5 mrem). The inspector'had no further questions regarding the above releases and their consequences - at this time. No items of noncompliance were identified in the [ above areas. 1 J
- c. Other Records The inspector reviewed selected results of analyses of the radio-logical monitoring program, especially the 1980 data for which the annual report was issued subsequent to the inspection, and discussed with.the licensee the methodologies used to calculate error and to calculate lower limits of detection (LLD). The inspector determined that the required samples and analyses had been collected and analyzed in accord with the ETS.
No items of noncompliance were identified relative to th!s area. 3 i
- d. Meteorological Monitoring f The inspector examined the site meteorological instrumentation, ,'
including the meteorological tower which was maintained by Niagara Mohawk Power Corporation (NMPC) and the recorders in the J. A. FitzPatrick Control Room. The Itcensee stated that the control room recorders displaying data from the NMPC tower are calibrated on a semiannual basis concurrently with the tower instruments, although no records of these calibrations were maintained by PASNY. The inspector pointed out that records of meteorological instrument calibrations, including control room recorders, could be important in determining the reliability of dose calculations based on control room recorder outputs. The licensee stated that records of future calibrations would be maintained by PASNY at the plant. The inspector stated that records of future calibrations will be reviewed during a subsequent inspection of the area (333/81-05-04). The inspector observed that the licensee also had control room recorders displaying real-time data from an auxiliary 96 foot meteorological tower. The licensee stated that instruments on this tower and the associated control room recorders were not calibrated on a regular basis. The inspector stated that if data from the j auxiliary tower is to be used in the event that data is unavailable from the main tower then these instruments should be maintained and calibrated on a regular basis (along with completion of appropriate j records). The licensee concurred and the inspector stated that this ' area would also be reexamined during the next inspection of the area. No items of noncompliance were identified in this area, l i I _ - - - - - - - - - _ - - _ J
ij W ,.f15 *
/ '
-% L- k - 4
'9 y; y .. ;1g g' '
y-h ,
- 6. Implementation of the Environmental Monitoring program -
Biological / Ecological E y .The inspector examined the impingement sampling apparatus at the plant 4 side of the intake tunnel and reviewed selected sampling and analytical procedures. Also reviewed was the 1979 annual report of the aquatic } ecology studies and selected records and data completed ;ince the last f NRC inspection of this area in-September 1978 (50-333/78-17). s# No items of noncompliance were identified in this area,
- 7. Nonradioactive Effluent Release Rates and Limits
- a. Thermal The inspector reviewed selected records of the thermal monitoring system since the last inspection of this area, including thermal discharge records, calibration records and related procedures. The inspector also reviewed the circumstances and licensee's evaluations relative te LERs 78-110/04L, 79-052/04L and 79-077/04L concerning thermal discharges and the thermal monitoring system, and noted that any associated environmental impacts appeared to be minimal.
No items of noncompliance were identified in this area.
- b. Chemical The inspector examined selected results of waste neutralization tank pH and conductivity analyses, records of monthly pH meter checks, and related procedures. The inspector reviewed and discussed the circumstances and Itcensee's evaluations relative to LERs 78-079/04L, 78-088/04L, 78-092/04L, 78-108/04L, and 79-005/04L concerning solutes discharges. This review included the licensee's evaluation of the method of determination of solute concentration. The inspector noted that limits on solutes discharges had been deleted from the ETS by Amendment No. a6 on May 17, 1979. These discharge limits are now contained in the site SPDES permit.
No items of noncompliance were identified in the above area,
- 8. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain wnether they are acceptable items. ;tems of noncom-pitance, or deviations. One unresolved item was disclosed during tnis ;
inspection and is discussed in Detail 3.b. l
me u g a,
- fl y
- 9. Exit Interview g On February 27, 1981, at the conclusion of the inspection, the inspector j met with those individuals denoted in Detail 1. During this meeting the 'j purpose and scope of the inspection were summarized arid the inspection 4 findings, including the items of noncompliance and the unresolved item 4 were discussed. The inspector also contacted the licensee by telephone 3 on March 5 and 9, 1981 to discuss one. item of noncompliance. i,,
j 1s T k 9 L e a i ok a
'l
- g. . . . . _ . . . . . - .
I}}