IR 05000277/1986023

Insp Repts 50-277/86-23 & 50-278/86-24 on 861103-07.No Violations Noted.Major Areas Inspected:Environ Monitoring Programs for Operations,Including Mgt Controls & Licensee Program for QC of Analytical Measurements

ML20214X209
Person / Time
Site:	Peach Bottom
Issue date:	12/03/1986
From:	Jang J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214X199	List: IR 05000277/1986023 ML20214X196
References
50-277-86-23, 50-278-86-24, NUDOCS 8612110011
Download: ML20214X209 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-277/86-23 50-278/86-24 Docket Nos. 50-277 50-278 __

License Nos. DPR-44 Priority -

Category _C_,

DPR-56 -

C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania -19101 Facility Name: Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Inspection At: Delta, Pennsylvania and Philadelphia, Pen'nsylvania Inspection Conducted: November 3 - 7, 1986 Inspector: *

. Jhng, Radiation Y metry Specialist / /

date-ai '3/ f ,

Approved by: - \hin .i / N ul<L' ) N3 bb W. J. fasciak, Chief, Effluent Radiation / date Protection Section ; '

Inspection Summary: Inspection on November 3 - 7, 1986 (Combined Inspection Report Nos. 50-277/86-23 and 50-278/86-24).

Areas Inspected: Routine, announced inspection of environmental monitoring programs for operations,- including:, management controls for these programs; the licensee's program for quality control of analytical measurements; implemer..ation of the radiological environmental monitoring program and the meteorological monitoring program; and, followup on the licensee's actions on previour inspection findin Results: Within the areas inspected, no violations were foun PDR ADOCK 05000277 C6b G PDR

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DETAILS Individuals Contacted J. Ballantine, Engineer, Environmental Branch, Nuclear and Environ-

mental Section

• Bird, Quality Assurance, Electrical Production J. Evans, Branch Head, Quality Assurance, Engineering and Research

• L. Ferrero, Quality Assurance, Engineering and Research G. Hutt, Office Section Head, Quality Assurance, Engineering and Research A. Marie, Senior Engineer, Nuclear and Environmental Section

• R. Mulford, Engineer in Charge, Nuclear and Environmental Section

• G. Rombold,-Engineer, Environmental Branch, Nuclear and Environmental Section J. Toon, Supervising Engineering Technician, PBAPS i *D. Wahl, Consultant, RMC/ CANBERRA Encironmental Service

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• Denotes those present at the exit interview on November 7, 1986 at PEco Corporate Office.

l Licensee Action on Previous Inspection Findings (Closed) Followup Item (277/83-21-01, 278/83-21-01): Review Records of Licensee Audit of Contractor. The inspector reviewed audit records and found them satisfactory (Detail 3.b). Management Controls

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The inspector raviewed the licensee's management controls for the environ-mental monitoring programs, including assignment of responsibility, program audits, and corrective actions for identified inadequacies and problem areas in the progra Assignment of Responsibility The inspector determined that management of the environmental moni-toring programs remains essentially the same as it was at the time of the last inspection in this area. The licensee stated that radiological analyses are contracted to Teledyne Isotopes and Clean Harbor of Natick (formerly Chemical Waste Management Corporation). Audits The inspector reviewed audits of the Radiological Environmental Monitoring Program (REMP), including corporate activities and contractor activities. Audits of the corporate REMP oversight are performed by the Quality Assurance Division of tne Electrical

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Production Department. Audits of the contractor REMP are performed by the Quality Assurance Division of the Engineering and Research Department. Each Department reports to a different Vice Presiden m .

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The inspector reviewed the' following audit reports conducted'by the QA Division of the Electric Production Department and the Engineering and Research Department: '.

AP 86-43 PL "PBAPS Offsite Radiological Environmental Monitoring Program", May 27, 1986 - June 20, 1986

AC 85-34 PR " Engineering and Research QA Division Activities in Support of Operations", July 24, 1985

QUAC 1-3-9 (OP-273) "Teledyne Isotopes",

February 22-24, 1984

QUAL 1-3-1 (0-091) "Teledyne Isotopes",

September 23-26, 1986

QUAL 1-3-1 (OP-325) " Clean Harbors of Natick",

August 27-29, 1985

QUAL 1-3-1 (0-090) " Clean Harbors of Natick",

September 16 - 18, 198 The inspector noted the above referenced audits to be very thorough, and audit-identified deficiency followups were excellent. The audit was performed by a qualified lead auditor, and appeared to be quite thorough and.of sufficient technical depth to adequately assess the contractors' capabilities and performanc . Licensee Program for Quality Control of Analytical Measurements The licensee described the QC programs conducted by its contractors, Teledyne Isotopes and Clean Haroors of Natick. Both contractors parti-cipate in the EPA QC crosscheck progra The inspector reviewed selected samples of quality control data submitted to the licensee by its two contractors. These data indicated, with few exceptions, agreement between EPA spike samples and the contractors'

results. Where discrepancies were found, reasons for the differences were investigated and satisfactorily resolve . Implementation of the Radiological Environmental Monitoring Program The inspector examined selected environmental monitoring stations including air samplers for iodines and particulates, and TLDs for direct radiation measurement. All equipment at these stations was operational l

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at the time of the inspection. The inspector reviewed calibration of the air sampler and vacuum gauges, and found that these calibrations were performed regularly and on schedule.

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The inspector reviewed the annual reports for 1984 and 1985, prepared by the contractors for the licensee. These annual reports provided ,

thorough summaries of the environmental sampling and analyses. Also the '

inspector noted that these reports cover a greater number and variety of enviror. mental samples than is required by the Technical Specification. No

.significant problems were identifie . Environmental TLD Quality Assurance The inspector reviewed the licensee's environmental TLD program, including contractor's (Teledyne Isotopes) QA manual. The quality of environmental TLDs is supported by two programs: A study to demonstrate compliance with Regulatory Guide 4.13 (Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Application) and periodic participation in the International Environmental Dosimeter Intercomparison The results of the sixth (1982) and seventh (1984) International Environ-mental Dosimeter Intercomparisons indicated reasonable agreement between Teledyne Isotope's results and the known field and laboratory exposure The eighth (1986) Intercomparison results were not available at the time of the inspectio The environmental TLD study performed by Teledyne Isotopes to demonstrate compliance with Regulatory Guide 4.13 resulted in agreement in six out of eight test categories. Ta tests are described in ANSI N545-1975, which is referenced by Regulatory Guide 4.13. Section 4.3.3 of ANSI N545-1975 requires the test for " dependence of exposure interpretation on the length of the field cycle". This test is to be performed under both the minimum and the maximum temperature conditions expected in the field. Teledyne Isotopes performed this test at -7 C for the minimum temperature and 50'C for the maximum temperature. The inspector stated that the expected mini-mum temperature should be lower than -7 C (-20*C is not uncommon around PBAPS), and the licensee agreed to perform the test around -20 C. The inspector noted, however, that this test currently is being conducted by the contracto Section 4.3.5 of ANSI N545-1975 requires a test for the directional dependence in which "the response averaged over all directions shall not differ from the response obtained in the standard calibration position by more than 10%". The inspector noted that the response obtained in the standard calibration position was included to calculate the response averaged over all directions and allow this value to be compared to the standard calibration positio Teledyne Isotopes concluded that the requirement was satisfied (8.9%). If the response obtained for the standard calibration position does not include <the calculated response averaged over all directions then this test wouldn't be satisfied. The inspector was not able to complete the review because raw data were not attached to the test result .-. .. _

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The inspector stated that the results of the contractor's evaluation for Sections 4.3.3 and 4.3.5 of ANSI N545-1975 will be reviewed in a subse-quent inspection (277/86-23-01, 278/86-24-01).

7. Environmental Dosimetry The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitoring Network is operated by the NRC (Region I) to provide continuous measure-ment of the ambient radiation levels around nuclear power plants, (71 sites) throughout the United States. Each site is monitored by arranging approximately 30 to 50 thermoluminescent dosimeter (TLD) stations in two concentric rings extending to about five miles from the power plant. The monitoring results are published in NUREG-0837 quarterl One of the purposes of this program is to serve as a basis of comparison with similar programs co.nducted by individual utilities which operate nuclear power plants. Therefore, four NRC TLDs are collocated with each licensee's TLD station During this inspection the monitoring results of collocated TLDs were compared and the results are listed in Table All NRC exposures are

normalized to a 90-day quarte The licensee monitors the environmental radiation levels monthly and quarterly (2 TLDs each station) using a Teledyne TLD System (CaS0 :Dy),

t and reports both results in its annual reports. The inspector stated that comparisons between monthly and quarterly results for each station would be of benefit in evaluating the TLD system. The licensee agreed to review these results in the futur One colle:ated TLD station (NRC station 5 and Peach Bottom Station 42)

was evaluated during this inspection and deleted from the collocated TLD station lists. The monitoring results of Peach Bottom Station 42 were approximately 35% higher than NRC Station 5 results. The inspector toured these TLD stations with the licensee during this inspec-tion. The NRC Station 5 was placed above the road pavement and the licensee Station 42 was placed above the ground. Even though these TLDs are approximately one tenth mile apart, the inspector determined that they are not collocated due to ground conditions. The monitoring results of these stations, therefore, were not compare Although there are some differences between the NRC and the licensee's programs, results are generally in good agreemen <

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8. Meteorological Monitoring The inspector examined the licensee's meteorological monitoring system, including the primary and backup meteorological towers' digital readouts, charts, and computerized printout for wind speed, wind direction and temperature in the control roo The inspector also reviewed the Surveillance Test Procedures for calibra-tion of the wind speed, wind direction, and wind translator. The inspector reviewed calibration records (1985 and 1986) and found that procedures were thorough and calibrations were performed as schedule . Exit Interview The inspector met with licensee representatives denoted in Detail 1 at the conclusion of the inspection at the PECo corporate office on November 7, 1986. The inspector summarized the purpose and scope of the inspection, and discussed the findings. At no time during this inspection was written material provided to the licensee by the inspecto .

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Table 1 Envi ronmen ta l Monitorina Resna ts for Collocated TLos inR/90 davsl Collocated Collocated Collocated NRC TLD ( 1 ) F3 TLD (2) NRC TLD P8 TLD MRC TLD PB TLD Y Qt Station 10 Station 33A Station 11 Station 14 Station 14 Statiost 31 1984 1 16.61 .21 .52 .41 .42 .41 .32 .41 .61 .51 .420.7 (3) 20.11 .81 .21 .51 .01 .42 .61 .11 .11 .11 .41 .11 .91 .11 .32 .41 .61 .31 .11 .71 .41 .22 .41 .21 .71 .41 .01 .11 .3110 20.41 .21 .71 .31 .71 .52 .31 i 20.01 .21 .22 .61 .62 .51 .11 .41 .91 .41 .61 .41 .41 (1) NRC :mRt Panasonic TLD (CaSO4:Tm)

(2) PS ( Peach Botton) :mRt Telodyne TLD (CaSO4:Dy)

(3) Low result was due to the high transit, dose (about 22% of the result).

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