ML17037C209

Letter Responding to the May 30, 1974 Letter Informing the Commission of the Corrective and Preventive Actions in Response to a May 15, 1974 Letter

ML17037C209
Person / Time
Site:	Nine Mile Point, FitzPatrick
Issue date:	06/13/1974
From:	Nelson P US Atomic Energy Commission (AEC)
To:	Schneider R Niagara Mohawk Power Corp
References
IR 1974006, IR 1974017
Download: ML17037C209 (14)

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>IflII OI JUN 131974 Niagara Mohawk Power Corporation License Nos. DPR-17/CPPR-70 Attention: Hr. R. R. Schneider Inspection Nos. 50-220/74-06 Vice President, Operations 50-333/74-17 300 Erie Boulevard, Hest Syracuse, New York 13202

Reference:

Your letter dated May 30, 1974

-Inmes'pons'o our"letter dated Hay 15, 1974 Gentlemen:

Th;Ink you for informing us of the corrective and preventive actions you. documented in response to our correspondence. These actions will be examined during our next inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, Paul R. Nelson, Chief Radiological and Environmental Protection Branch cc: T. J. Perkins, Station Superintendent Mr. A.Z. Roisman, Counsel for C'itizens Committee for Protection of the Environment Berlin, Roisman and Kessler 1712 N Street, Northwest Ilashington, D.C. 20036

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NIAGARA MOHAWK POWER CORPORATION NIAGARA Q MOHAWK 300 EBIE OOVLEVABD %VEST SYBACUSE. N. Y. 13202 May 30, 1974 hir. Paul R. Nelson, Chief Radological and Environmental Protection Branch United States Atomic Energy Commission Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406

Dear Mr. Nelson:

Following a thorough review of your hfay 1S, 1974 letter, regarding the inspection conducted by Mr. Bores of. your office on April 22-26, 1974 at Nine Mile Point Nuclear Station llnit 1 and .Iames A. FitzPatrick Nuclear Power Plant, we conclude that there is no information in the report to be withheld from public disclosure.

Concerning the alleged violations of AEC requirements as numerated in your report the following information pursuant to provision of Section 2.201 of the AEC's "Rules of Practice", Part 2, Title 10, Code of Federal Regulations is submitted:

Section 4.6.1 and Table 4.6.18 of the Technical Specifications require that air particulates be sampled on a weekly basis at five on-site and six oFf-site stations.

Contrary to this requirement, air particulates >>ere not sampled at one of these stations, Dl On-Site, for 31 of 47 sampling periods from November 9, 1972 through September 29, 1973.

RESPONDS It should be pointed out that during. this period sampling was

.required for only 23 of the 47 periods because of the Fact that >>e >>ere in Grade A of the environmental program (i.e.,

stack release rate <1/30Q).

0 ~ g her. Paul R. Nelson, hiay 30, 1974 Atomic, Energy Commission }

h An investigation oF the operation of Dl on-site air sampler shows the Following:

History on Station Dl On-Site:

No oF Samples Required No of Sample Dates Land Pro ram Grade Prom Di On-Site Collected 4/1/72 w 11/1/72 None 27 1.1/1/72 -}. 3/1/73 17 3/1/73 ~ 4/15/73 ~ 3 4/15/73 ~ll/1/73 None 12 11/1/73 ~ 4/1/74 20 20 Total samples required from Sample Station Total samples collected as required 31 Required samples missing 13 Along with this sampler we also operated 10 other samplers as part of the survey program. During the year 1973 a total of 544 environmental air samples were collected while 28 were reported as missing samples. This is an overall recovery rate of approximately 95'~.

The required samples were not collected because of mal-functions of the sampling equipment. These included:

l. Burned out motor in sample pump.

2. 1:aulty fan on housing cooling system resulting in overheated motor and blown fuses.

3. Pump motor - faulty switch.

4. Pump piston freeze up.

5. Faulty thermostat on housing resulting in improper fan operation and subsequent over-heating of pump motor.

The major problem was discovered to be a faulty thermostat (see item 5. above); once this was replaced, November 14, 1973, the sampler operated satisfactorily.

h)r. )'aul R. Nelson, hfa~x0, 1974 Atomic Energy Commissio>~

The new Environmental Technical Specification which will go into efFect when the commission issues the NhiP-1 per-manent operating license >>ill allow an air sample station to be taken out of service on occasion (i.e., at least 10 out of 1S samplers shall be. operateil) .. This snccification

'recognizes the Fact that these sample stations are not continuousl> attended <<nd that if a pum)i trips>>hi le a technician is not in attendance a whole >>eek's sample is lost'n the future >>e will make every effort to maintain the environmental sampling equipment so t)iat required samples are collected. h'ith the increased work load due to the new ETS requirements we have recently added to the site staff >>'ho >>ill be responsible For the implementation of the environmental survey program.

2. Section 4.6.1 and Table 4.6.18 of the ')'echnical Specifications require that air particulate samples be analyzed monthly from five on-site and six off-site stations.

Contrary to this requi~'ement, the weekly air particulate filters were composited prior to analysis. In some instances, the five on-site samples were composit'ed into one sample and the six off-site samples were composited as a second sample prior to analysis. At other times all of the filters were composited into a single sample prior. to gamma spectral analysis.

RESPONDS A beta count was performed on each environmental air particulate sample on a low background beta counter. This is the most mean-ingful way to count these samples. Gamma spectral analysis using our present equipment is not sensitive enough to measure the low level of activity encountered in environmental samples.

The particulate air samples >>ere composited .to be counted on a 3 x 3 NaI gamma ray analyzer crystal because of the'low activity of the individual samples, the high background inherent in an in-plant Nal system and the low sensitivity of an in-plant NaI system.

If a significant difference bet>>een on-site and oFF-site gross beta analysis appears gamma analysis on a sensitive system is one wa> of isolating and examining these differences. To be

e h/r. Paul R. Nelson, l1a~30, 1974 Atomic Energy Commissio~

The ne>> Environmental Technical Speci Fication which will go into effect when the commission issues the Ni~lp-1 per-manent operating license will allow an air samnle station to be taken out of service on occasion '(i.e., at least 10 out of 15 samplers shall be operated) . This speciFication

'recognizes the Fact that these sample stations are not continuousl> attended and that iF a pump trips >>hile a technician is not in attendance a whole >>eck's sample is lost.

In the future we >>ill make every eFFort to maintain the environmental sampling equipment so that required samples are collected. b'ith the increased >>ork load due to the new ETS requirements we have recently added to the site staff >>'ho will be responsible for the implementation of the environmental survey program.

2. Section 4.6.1 and Table 4.6.1B of the Technical Specifications require that air particulate samples be analyzed monthly from five on-site and six off-site stations.

Contrary to this requirement, the weekl>'ir particulate filters >>ere composited prior to analysis. In some inst inces, the five on-site samples >>ere composited into one sample and the six off-site samples >>ere composited as a second sample prior to analysis. At other times all of, the filters were composited into a single sample prior to gamma spectral analysis.

RESPONDS A beta count was performed on each environmental air particulate sample on a low background beta counter. This is the most mean-ingful way to count these samples. Gamma spectral analysis using our present equipment is not sensitive enough to measure the low level of activity encountered in environmental samples.

The particulate air samples were composited to be counted on a 3 x 3 NaI gamma ray analyzer crystal because of the low activity of the individual samples, the high background inherent in an in-plant NaI system and the lo>> sensitivity of an in-plant NaI system.

If a significant difference between on-site and off-site gross beta analysis appears gamma analysis on a sensitive system is one wa> of isolating and examining these diFFerences. To be

" 'fr. Paul R. Nelson, Ma0, 1974 Atomic Energy Commission meaningful, however, the samples would have to be sent to a contractor for special analysis. On-site and off-sitc samples at Nine llile Point do not sho<< any significant differences. A review of thc gross beta data of air part-iculates for the second half of 1973 shows that the on-site samples averaged .042 pci/m while the off-site samples averaged 0.045 pci/m~. Even during periods oF high off-gas activity (i.e., >>hen release rates are greater than 1/10Q) the on-site and off-site samples do not sho>>

significant diFferences.

The new Environmental Tcchnical Specifications will allo>>"

compositing of the on-site samples and the off-site samples.

Until these specifications tako effect we will perform a gamma spectral analysis on each air particulate sample individually. Ne will also perform some of the analysis at the James A. FitzPatrick laboratory in an attempt to see if gxeater sensitivity can be obtained using the Geli counting system there.

Section 4.6.1 and Table 4 .6.1A of the Technical Specifications require that fish, clams and gammarus be- sampled at two locations each Spring and Fall and analyzed for gross beta activity.

Contrary to this requirement, gxoss beta analyzes <<'ere not performed on thc above media since 1971.

RESPONDS 4'hen our environmental lake program was fixst instituted because of the complexity of the analysis we were required to send all of our aquatic biota samples to a contractor for analysis. li'e requested that he run gross beta analysis, gamma scans and specific radiochemical analysis on Co Zn65, Sr and Cs' After a fe>> years oF analyzing the samples in this manner we realized that gross beta analysis was n'ot meaningful (it only accounted for natural K'ctivity),

that gamma scans >>ere not meaningful (all samples were reported as "not detectable" ) and oF the 4 isotopes which were being radiochemical 1> analyzed only Co6 was significant.

In 1972 we felt that the state of the <>ould get much morc meaningful isotopes information >>hiIc at thc same time accounting For all the significant beta emitters.

~ lv 0 0 her. Paul R. Nelson, May 30, 1974 Atomic Energy Commission The ne>>'nvironmental Technical SpeciFications list GeLi analysis and Sr ~, Sr as the method of analysis For aquatic biota. Until these ne>> specifications go into

.effect >>e >>ill request that in addition our contractor perform a gross beta analysis on all biota samples.

h Very truly yours, Original Signed by R.R. Schneider R.R. Schneidel Vice President - Electric Onerations RRS/bar