ML20138P266

Insp Repts 50-277/97-03 & 50-278/97-03 on 961209-970131. Violations Noted.Major Areas Inspected:Areas Involving Radiological Environ Monitoring Programs

ML20138P266
Person / Time
Site:	Peach Bottom
Issue date:	02/10/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135C595	List: IR 05000277/1997003 ML20135C592 ML20138P257 ML20138P266
References
50-277-97-03, 50-277-97-3, 50-278-97-03, 50-278-97-3, NUDOCS 9703040154
Download: ML20138P266 (14)

See also: IR 05000277/1997003

Text

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION l

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Docket Nos.:

50-277; 50-278

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Report Nos.:

50-277/97-03; 50-278/97-03

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Licensee:

Philadelphia Electric Company

Facility:

Peach Bottom Atomic Power Station

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Location:

P.O. Box 195

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Wayne, Pennsylvania 19087-0195

Dates:

December 9,1996 - January 24,1997

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Inspector:

Laurie A. Peluso, Health Physicist

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Radiation Safety Branch, DRS

Approved by:

John R. White, Chief

Radiation Safety Branch

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Division of Reactor Safety

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Report Details

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IV. Plant Support

R1

Radiological Protection and Chemistry (RP&C) Controls

R1.1 Imolementation of the Radioloaical Environmental Monitorina Proara_rn

a.

Insoection Scope (84750)

The inspector observed and assessed the licensee's capability to implement the

radiological environmental monitoring program (REMP). The program was inspected

against ODCM Sections 3.8.E.1 and 3.8.E.2, Regulatory Guide 4.1, " Programs for

Monitoring Radioactivity in the Environs of Nuclear Power Plants," and the Updated

Final Safety Analysis Report (UFSAR).

b.

Observations and Findinas

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The inspector examined selected sampling stations to determine whether samples

were being obtained from the locations designated in the ODCM and whether air

samplers were operable and calibrated. Air sampling equipment was calibrated at

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the frequency specified in the associated procedure. The sampling stations included

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air samplers for iodines and particulates, composite water sampling stations located

at the plant intake and discharge, milk farms, vegetation locations, and

thermoluminescent dosimeter (TLD) stations for measurement of direct ambient

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radiation. All air sampling equipment and water compositors at the selected

locations were functioning as designed. The sampling equipment, as evidenced by

the sample log books and analysis results, had operated continuously through the

year with few exceptions. The above environmental sampling media were available

at the locations designated in the ODCM, and TLDs were placed at locations

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designated in the ODCM. Analytical results did not indicate any anomalous trends.

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Sampling and analysis was performed as required. Compensatory sampling

(suriace, drinking water) was performed as required when applicable. Although the

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number of samples taken had been reduced, the licensee continued to collect and

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analyze more samples than required by the ODCM. Program changes were made in

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1995 and were documented in the annual Radiological Environmental Operating

Report (REOR). The changes made have not reduced the original intent of the

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REMP.

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Review of the land use census, required yearly by the ODCM, revealed that the

licensee performed the census in 1994,1995 and 1996. During the 1994 census,

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the licensee noted that a milk farm close to the plant had been reestablished.

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During the 1995 census, completed in September 1995, the licensee calculated the

D/O values for all the sectors and determined that the "new" farm has a D/O value

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(a calculated dose or dose commitment) that is at least 20% greater than the

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location from which samples were currently being obtained in accordance with

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ODCM Section 3.8.E.1. The licensee added the new location to the REMP and

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included the reew milk location to the ODCM. (The licensee expects the next

revision, Rev.10, to be published by the end of December 1996.) Changes made in

1995 will be documented in the 1996 REOR.

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The inspector also reviewed the wind direction (wind roses) and D/O values from

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the past five (5) years and compared them to the preoperational wind roses,

documented in the UFSAR Section 2.3.26, to detect changes, if any, in the

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prevalent and least prevalent wind direction. No significant changes were found.

The environmental monitoring control stations are still located in the lean prevalent

wind direction.

The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitoring

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Network is operated by the NRC (Region l} to provide continuous measurements of

the ambient radiation levels around nuclear power plants throughout the United

States. Each site is monitored by approximately 30 to 50 thermoluminescent

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dosimeter stat:ons in two concentric rings extending to about 5 miles from the

power plant. The monitoring results are published quarterly in NUREG-0837.

During the period covered by this inspection, three of the NRC TLDs were

collocated v,ith licensee TLDs at the Peach Bottom plant site as indicated in

Table 1. Yhe licensee's dosimeters, as of January 1995, are the same model

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dosimeter used by the NRC. Previously, the licensee used dosimeters which

contain cs!cium sulfate activated with dysprosium (CaSO.:Dy), which were supplied

and analyzed by Teledyne isotopes, Inc. The NRC uses the Panasonic Model 801

dosimeter, which contains two elements of lithium borate activated with copper,

(Li,BO,:Cu) and two elements of calcium sulfate activated with thulium (CaSO,:Tm).

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The licensee quarterly monitoring periods correlate well with the quarterly periods of

the NRC. During this inspection, the monitoring results of collocated TLDs were

compared, and the results are listed in Table 2. These reported values are the mean

+/-1 standard deviation for all quarters for which net data were available. The

relatively small standard deviations indicate that the NRC results have remained

consistent over the 10-year period. The NRC " historical average" data are reported

in NUREG-0837. The licensee results, generally, are somewhat below those of the

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NRC, and, for example, may be due to different methods of calibration of the two

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systems or differences in transit doses.

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c.

Conclusion

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Overallimplementation of the radiological environmental monitoring program was

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very good. Based on the above program review, discussions with the responsible

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individuals, and review of the ODCM and UFSAR, the program was well

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implemented, results were valid, and equipment was functioning as designed and

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was well maintained.

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Table 1

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Collocated Environmental TLDs at Peach Bottom

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Peach Bottom

NRC No.

Distance *

Azimuth * *

Loc. No.

Distance *

Azimuth * '

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1.9

96

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2.1

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4.6

85

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4.8

84

31

9.9

261

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9.7

261

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• Distance measured in miles

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• * Azimuth measured in degrees

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NOTE:

Distances and azimuths were measured independently and do not necessarily agree; however, collocation of

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these TLDs has been confirmed.

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Table 2

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Environmental TLD Monitoring Results (mR/ quarter)*

Comparison of NRC TLDs Collocated with Peach Bottom TLDs

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NRC no.:

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Monitoring Period

PBAPS no.:

14

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18

1995/1st Quarter

NRC

19.8 i O.7

18.9 i O.7

21.9 i O.8

PBAPS

15.7 i 1.2

15.1 i 1.0

17.5

0.6

2nd Quarter

NRC

19.6 i O.7

19.3 i O.7

21.9 i O.8

PBAPS

15.7

0.7

15.7 i O.2

16.6 i O.6

3rd Quarter

NRC

19.6 i O.7

20.5 i O.7

21.7 i O.7

PBAPS

15.4 i O.2

16.0 i O.6

16.9

0.7

4th Quarter

NRC

19.7 i 1.0

20.4 i 1.0

21.7 i 1.0

PBAPS

14.2 i O.6

15.7 i 1.2

17.8 i 1.0

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1996/1st Quarter

NRC

17.9 i O.6

18.2 i O.6

19.9 i O.7

PBAPS

14.7 i O.6

16.1 i O.9

18.0 i O.4

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2nd Quarter

NRC

18.5 i O.7

18.5 i O.7

21.6 i O.7

PBAPS

15.7 i O.2

15.7 i O.4

17.9 i O.4

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All results are in milliroentgens and are normalized to a 90-day quarter.

All data are shown as Result i 1 standard deviation.

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R1.2 Meteoroloaical Monitorina Proaram (MMP)

a.

_In_spection Scone (84750)

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The MMP was evaluated to determine whether the instruments and equipment were

operable, calibrated, and maintained. The MMP was inspected against UFSAR

Section 2.3 and Regulatory Guide 1.23.

The following associated procedures were reviewed:

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IC-11-00807,

Loop Calibration of the Climatronics Model F460 Wind

Direction and Wind Speed Transmitters

IC-11 -00811,

Loop Calibration of the Bendix-Friez Model 120 Wind speed -

wind Direction system

IC-C-11 -00806,

Loop Calibration of the Climatronics 1000HM Platinum

Temperature System

IC-C-11-00808,

Calibration of the Esterline Angus Model MS 424C Recorder

IC-C-11 -00809,

Calibration of the Esterline Angus Model MS 1124S Speed

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Servo 11 Multi Point Recorder

IC-C-11 -00810,

Calibration of the SUMX Model SX-410 Data Acquisition

System

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RT-0-094-800-2,

Meteorology Equipment Functional Test

b.

Observations and Findinas

Calibration and functional tests of the meteorological instrumentation were

performed using the above IC procedures. Calibration results from January 1995 -

December 1996 were reviewed. The licensee calibrated the instruments every 6

months as required by the UFSAR commitments and the RG 1.23 recommendations.

Functional checks from October - December 1996 were reviewed. The functional

checks were performed weekly as required in the UFSAR and the procedure, RT-0-

094-800-2. Results of the calibrations were within the established acceptance

criteria recommended by the vendor. Instrumentation was well maintained. The

inspector noted that the licensee had recently drafted a procedure to ensure paper

from the recorders would be changed every 2 weeks.

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Log books and records of maintenance were also reviewed. The books were kept

at the tower and the control room and used to record maintenance, surveillance,

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and calibration activities. The logs were up-to-date and coincided with maintenance

and calibration records.

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c.

Conclusions

Based on the above review of procedures, direct observations, and discussions with

personnel, the inspector concluded that calibration and maintenance of the

equipment were performed according to procedures, the meteorological monitoring

instrumentation was operable and sufficiently maintained, and the licensee

continued to effectively implement the meteorological monitoring program in

accordance with UFSAR and RG 1.23 commitments.

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R6

RP&C Organization and Administration

R6.1 Manaaement Controls

a.

insoection Scope (84570)

The inspector reviewed organization changes and the responsibilities relative to

oversight of the REMP and MMP, and reviewed the annual Radiological

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Environmental Operating Report and Dose Assessmer:t Report to verify the

implementation of ODCM Sections 3.8.E, 3.10.1 and 3.10.2.

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b.

Observations and Findinas

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The organization and responsibilities at the corporate office, located in

Chesterbrook, PA, essentially have remained the same since the previous inspection

conducted in March 1995. The responsibility to implement the REMP was with the

Program Manager, Programs Branch, Programs / Procedures Section, Nuclear

Engineering Division. Responsibility to perform calibrations of the meteorological

monitoring tower was with the Instrument and Controls Department at the site.

The annual REORs for 1994 and 1995 provided a comprehensive summary of the

observed impacts of plant operation on the environment surrounding the Peach

Bottorn sites. The results met the ODCM reporting requirements. The reports also

provided a summary of the land use census and interlaboratory comparison

program. The analytical data from 1996 were reviewed for sample frequency and

analysis requirements specified in the ODCM. No omissions, mistakes, obvious

anomalous results or trends were noted. Program deviations and/or changes in

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sampling locations were reported. The Dose Assessment Report for the period

January 1,1995, through December 31,1995, was reviewed. The report included

a summary of the radiation doses due to radioactive effluent releases from the sites

and annual summaries of hourly meteorological data joint frequency distributions of

wind speed, wind direction and atmospheric stability.

c.

Conclusion

Based on the above review, the inspector determined that the licensee implemented

very good management control and oversight of the REMP and MMP and effectively

implemented Sections 3.8.E, 3.10.1 and 3.10.2 of the ODCM.

R7

Quality Assurance in RP&C Activities

R7.1 Quality Assurance Audit Proaram

a.

Insoection Scoce (84750)

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Quality Assurance (QA) audit and surveillance programs were inspected against

criteria contained in the licensee's procedures and TS requirements. Audits of the

REMP and MMP were reviewed and follow up was performed to ensure the 1994

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NUPIC audit findings had been closed by the licensee.

b.

Observations and Findinas

The inspector reviewed the following Quality Assurance Audit Report as part of the

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evaluation of the implementation of the TS audit requirement:

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A0956206, Emergency Plan and Procedures Assessment and

10CFR50.54.(t) Review, dated 1/10/96

A0903756, NQA Audit at the GPU Nuclear Corporation Environmental

Radioactivity Laboratory (EML), dated

A0919170, Radiological and Environmental Monitoring, dated 5/26/95

The audits were performed by qualified personnel and were of sufficient technical

depth to assess the implementation of the programs. The audits were performed

within the 'requency in TS.

Licensee follow up of the NUPIC audit showed that all 5 items were closed in 1995.

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c.

Conclusion

Based on the above review, the inspector determined that the audits were sufficient

to assess the REMP and MMP and that the licensee implemented the TS audit

requirements.

R7.2 Quality Control Proarem of Analvtical Measurements

a.

Insoection Scoce (84750)

The inspector reviewed the quality control (OC) program of analytical measurements

against recommendation of Regulatory Guide 4.15, " Quality Assurance for

Radiological Monitoring Prograrr.s (Normal Operations) - Effluent Streams and the

Environment" to determine whether the licensee had adequate r,ontrol with respect

to sampling, analyzing, and evaluating data for the implementation of the REMP.

Included was a review of the intercomparison program required by ODCM Section

3.8.E.3.

b.

Observations and Findinas

The licensee uses the GPU Environmental Radioactivity Laboratory (ERL) as the

primary lab to analyze the environmental samples. The lab maintains an extensive

QC program including participation in the EPA cross check program (1995). Results

of this program were within the EPA acceptance criteria. With the exception of

drinking water, the EPA terminated the cross check program in December 1995.

Therefore, the licensee was tasked with finding another laboratory to provide an

independent intercomparison program. The EPA program was replaced using

Analytics, Inc. and the results were within the GPU laboratory criteria. Periodic

reports of QC results are suppbed to the licensee. The data, with few exceptions,

indicate agreement between the primary contractor laboratory and the QC

laboratory. ~Where discrepsncies were found, reasons for the differences were

investigated and resolved.

c.

Conclusion

Based on the above review, the inspector determined that the licensee continued to

implement a good quality control program in accordance with regulatory

requirements and recommendations. The licensee maintained good control with

respect to sampling, analyzing, and evaluating data for the implementation of the

REMP based on the data reviewed.

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R1.2 Desian Modifications involvina the North Wall of the Unit 3 Turbine Buildina

a.

laspection Scope (84750)

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The inspection scope, regarding Modification P00248, was to: (1) verify that

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gaseous effluents were processed as specified in the ODCM (Section 3.8.C.5) or

that compensatory measures had been taken: (2) ensure that an adequate safety

evaluation was conducted in accordance with 10 CFR 50.59; and (3) determine if

the turbine building atmosphere was processed consistent with the UFSAR

description (Section 10.15).

b.

Observations and Findinas

During the previous inspection, an inspector reviewed a PECO-identified event

involving a low level unmonitored release from the Unit 3 turbine building (TB)

which began on July 18 and ended on July 25,1996. (See Section R2 of the

Routine Integrated inspection Report 50-277/96-06 and 50-278/96-06, dated

October 10,1996, for details.)

During this inspection, a review of the licensee's 10 CFR 50.59 evaluation for

Modification P00248 (Mod) involving the construction of the new Plant Entrance

and Radiochemistry Laboratory (PEARL) Building (including the associated

penetration of the north wall of the Unit 3 Turbine Building to support the Mod) was

conducted by the inspector. According to the Mod, the licensee planned to breach

the north wall of the Unit 3 Turbine Building on July 18,1996. Five out of seven

holes (3'x 5') were initially cut into the turbine building wall to install ventilation

duct supports for the new Plant Entrance and Radiochemistry Laboratory (PEARL)

building exhaust systems. The exhaust duct traveled along the outside of the

turbine building, across the roof and entered the reactor building vent stack. After

cutting holes in the TB, a worker on the job was identified with short lived activity

(< 100 cpm) on his hand. The licensee reviewed the work conditions and collected

an air sample from the 195 foot elevation, which identified short-lived activity of

SE-10 Ci/cc Cs-138. The licensee calculated doses to the public using a

conservative assumption that the release through the holes was 10% of the total

reactor building vent flow (2E4 CFM). The offsite doses for the release were

calculated to be 3.2E-5 mrem / year total body and 5.1E-5 mrem / year skin. The

ODCM limit is 500 mrem / year total body and 3000 mrem / year skin. The licensee

stated that a full report of this event will be documented in the 1997 Annual

Radioactive Effluent Release Report as required by ODCM Section 3.10.2.

The inspector determined that the proper processing and monitoring of turbine

building atmosphere was not adequately performed. The UFSAR (Section 10.15)

states that exhaust ventilation air from the turbine building and radwaste building is

discharged to atmosphere from the ventilation stack above the reactor building roof

(a monitored release point). The licensee, on July 22,1996, stated in the

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Performance Evaluation Program (PEP) that, "After checking the covered openings

that flat sheeting on the corrugated outs:de wallleft wide gaps through which there

was very noticeable outward air flow. This air flow is a potential release path for

radioactive material." With regard to this statement, the inspector noted that the

licensee was aware of the potential for release of radioactive material after the holes

had been cut. Since the licensee could not ensure a negative pressure had been

maintained, the holes became a pathway for a potential unmonitored release. (See

observations and findings of Section R2 of the previous inspection report, noted

above, for details.)

Based on the licensee's "10 CFR 50.59 Review for Modification P00248," the

inspector determined that no evaluation of the gaseous waste processing,

monitoring, nor dose assessment was addressed. The licensee stated that they

assumed the turbine building was slightly negative and would remain slightly

negative as specified in UFSAR during the Mod and, therefore, no further evaluation

was performed. The evaluation did not consider the creation of a potential

unmonitored release pathway. No monitoring of the turbine building (continuous or

grab sampling) was planned. The actual modification resulted in an outward flow of

air from turbine building contrary to the licensee's assumptions of the maintenance

of negative pressure. With the exception of the sample previously noted, no

monitoring had been performed to evaluate this release pathway in a timely manner.

Failure of the licensee's safety evaluation record to provide the bases for the

determination that the penetration did not involve an unreviewed safety question

constitutos a violation of 10 CFR 50.59(b)(1). (VIO 50-278/97-03-01)

ODCM 3.8.C.S. states, in part, that gaseous effluents shall be processed through

the turbine Gaseous Waste Treatment System. The turbine building atmospheres

shall be processed through permanently or temporarily installed equipment in the

appropriate building ventilation system and the vent stack. The inspector noted

that, in the existing condition, the licensee could not assure that the turbine building

atmosphere was processed through the turbine building gaseous waste treatment

system, using either permanently or temporarily installed equipment. Failure to

assure that the turbine building atmosphere was processed and monitored in

accordance with the applicable plant design and regulatory requirements,

constitutes a violation of ODCM 3.8.C.5. (VIO 50-278/97-03-02)

c.

Conclusion

Based on the above findings, the inspector concluded the following. During the

Mod, a small portion of the turbine building atmosphere was unmonitored and

released through the holes cut into the turbine building. The safety evaluation

performed in accordance with 10 CFR 50.59 failed to address changes to the

Turbine Building that could result in unmonitored releases. The licensee identified

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these issues after the holes were cut. Overall, the immediate corrective actions to

ameliorate the condition were adequate, however, corrective actions relative to

assuring comprehensive evaluation of all elements of a facility change was not

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evident during this inspection. No actual safety consequence was evident as a

result of in this occurrence.

R8

Miscellaneous RP&C lasues

R8.1 UFSAR

A recent discovery of a licensee operating their facility in a manner contrary to the

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Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a

special focused review that compares plant practices, procedures and/or parameters

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to the UFSAR description. While performing the inspection discussed in this report,

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the inspectors reviewed the applicable portions of the UFSAR that related to the

areas inspected. The inspectors verified that the UFSAR wording was consistent

with the observed plant practices and procedures and/or parameters, except as

noted in Section R1.2 of this report.

V. Manaaement Meetinas

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Exit Meeting Summary

The inspector presented the inspection results to members of the licensee management at

the conclusion of the onsite inspection on December 13,1996. Subsequently, the

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inspector continued to review information relative to the onsite findings until a conclusion

was reached on January 24,1997. Following the conclusion, the inspection results were

discussed by telephone with licensee representatives on January 31,1997.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee Personnel

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E. Anderson, System Manager, Plant Engineering Division

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• T. Baxter, Nuclear Quality Assurance

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• G. Beck, Manager Programs / Procedures Section

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D. Chase, Radiochemist, Chemistry

• G. Lengylle, Experience Assessment Manager

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• T. Loomis, Licensing

J. Moore, Lead Responsible Engineer, Nuclear Engineering Division

• T. Mscisz, Engineer, Meteorology

' R. Nagle, l&C Technician

• A. O' Dell, Chemistry Manager

• D. Wahl, Physicist, Programs Branch

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Contractor Personnel

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C. Reid, Sampling Contractor, Radiation Management Corporation, Inc.

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' Denotes those present at the exit meeting on December 13,1996.

The inspector also interviewed other licensee personnel.

LIST OF INSPECTION PROCEDURES USED

84750:

Radioactive Waste Treatment, and Effluent and Environmental Monitoring

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

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Opened

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50-278/97-03-01

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Failure to perform and adequate safety evaluation according to

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10 CFR 50.59(b)(1)

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50-278/97-03-02

VIO

Failure to assure that the turbine building atmosphere was

processed through the turbine building gaseous waste

treatment system.

Closed

None

Discussed

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PARTIAL LIST OF ACRONYMS

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EPA.

Environmental Protection Agency

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MMP

Meteorological Monitoring Program

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NCV

Non-Cited Violation

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NRC

Nuclear Regulatory Commission

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ODCM

Offsite Dose Calculation Manual

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QA

Quality Assurance

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OC

Quality Control

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REMP

Radiological Environmental Monitoring Program

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REOR

Radiological Environmental Operating Report

TLD

Thermoluminescent Dosimeter

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TS

Technical Specifications

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UFSAR

Updated Final Safety Analysis Report

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