IR 05000206/1982036

IE Insp Rept 50-206/82-36 on 821129-1203.Noncompliance Noted:Effluent Monitor Calibr Not Performed Since Oct 1981

ML20028C936
Person / Time
Site:	San Onofre
Issue date:	12/28/1982
From:	Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20028C932	List: IR 05000206/1982036 ML20028C931 ML20028C933
References
50-206-82-36, NUDOCS 8301140325
Download: ML20028C936 (15)

Text

.

..

_-._

...-

U. S. NUCLEAR REGULATORY C01: MISSION

.

'

REGION V

Report No.

50-206/82-36

.

Docket No.

50-206 License No.

DPR-13

_ Safeguards croup Licensee:

Southern California Edison Company P. O. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770

-

Facility Name: San Onofre Unit 1

.

Inspection at: San Clemente, California

.

Inspection conduc ed:

November 29 - December.3, 1982 Inspectors:

/AM4/# 2 G. 'P.' Yuhas,' Ra61ation Specialist Date Signed

~'~

,

-

Date Signed Approved:

/3/J8/82-F. A. Wenslawski, Chief, eactor R iatio Dat'e Signed Protection Section u. E. Book, Chief, Radiological Safety Branch

' Date Signed

_

~~

Date Signed Summary:

"

Inspection on November 29 - December 3,1982 (Report No. 50-206/82-36)

Areas Inspected:

Routine unannounced inspection of the radioactive waste systems, including review of semi-annual operating reports, effluent monitoring instrumentation, radioactive effluent release procedures and practices, tests of the control room emergency air treatment systems and reactor coolant chemistry sampling and analysis.

The licensee's actions with regard to Licensee Event Reports 82-13,

.

82-18 and environmental reports dated Febuary 12, and June 1,1982 were also reviewed. The inspection included an unannounced tour of Unit 1 on the evening of November 29, 1982.

The inspection involved 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> on site by one regionally based inspector.

Results: Of the areas inspected one apparent item of noncompliance (failure to perform effluent monitor calibrations, TS 4.6E. paragraph 3)

.was identified.

RV Form 219 (2)

.-

8301140325 821229 DRADOCK05000g Y' :..

,

..

a..--

..

.; F %.

.,-

-

_

%;s

~

.. '

'

.

'

.

-

,

,-.

,

'"pf_ 4 ',

J

'

<

e e

-

3.,

~

-

,

'

'

u,

n

.

.

.,

'

'u,

'

.

m i

,

.,

,

"

'

e

-

,

,

,

,

,__

^

@

f

'

.I

'

'

DETAILS

-

. ;~

v

+

+-

,

,

,

..

~

,

-

1.. Pe'rsons-Contacted

. - '

-

,

4:y

-

.

.

<f!: - e

" License Representatives

,

y

' *W.1 Moody, '. Deputy,S ta ti ori l Mana ge r.

.

'

-

'

• P.R Croy, Configuration Control; and Compliance, Manager

-

~

_ *B./Katz, Technical Manager

'

~

,

,

.

• P. Knapp. Health Physics Man'ager;

~

'

• D. Schone,. Quality. Assurance Manager

,

• J. Wambold, Maintenan u Manager /

'

. L. Brevig, Supervisor of Plant Chemistry

,

.

D.. Duran, Radwaste Supervisor '

-

,

• P. Chang, Effluent Engineer-

,

[-

B.. Graham, Environmental.Engineeri

'

J. Heflin,: Chemistry Foreman -

Contractor Representatives

'

.

G. Eggers, General l Atomic' Company

'

B. Pullian, Quadrex Corporation J. Trimble, General Atomic Comapny-

• Indicates.those individuals attending the exit interview on December.3,

j 1982.-

<

.

.

'

In a'ddition to the jndividuals noted above~, the inspector met with and' held discussions'with other members of the licensee's and

'

contr, actor's, staffs.

'

2.

Licenses Event Reports

,g

,

~

u

.

l (Closed) (82-04-T0; 82-04 T1)b,

Excessive chlorination of the circulating

.

.

water system. The Environmental-Engineer discussed the licensees.

,

actions' to prevent further problems'of this nature. The inspector

'

L had no additional question ~s tregarding this matter.

.

.

,

y

,

,

I (Close'd) (LER 82-13)l Failure.to collect'and analyze mid and endpoint samples of a-Reheater Pit Sump discharge. The licensee's

'

-

,

actions.as described in letters dated June 1,1982 and August 6, i

j

- 1982 were 'reviewedt -Item 3 of the corrective actions presented in

,

the June 1, letter'had not bee _n completed by September 1,1982 in that the Effluent Engineers had not taken the test required by zStation Procedure'S01-IIIa5.5, " Effluent Monitori9g Training Program."

'

- On December 2,. the inspector confirmed that all four. Effluent

.

Engineers passed the required. examination on Decemb'er.1,1982. The

'

-

-inspector had'no additional l questions regarding this matter.

!

t. -

h

r

%%

N'

I

.. A [. ~,...

~..,

....

_

.

.

..... -.

-,.,,.

.

_.. _, _. _., _. _.... _..... _.. -..

v'--

--

<

-2-

'

.

(Closed)'(LER 82-18) Loss ~ of Stack particulate samples intended P

for strontium-89 and 90 analysis. The licensee's actions as described in a letter dated August 6, 1982 were reviewed and implementation confirmed. The inspector'had no additional questions regarding this matter.

No-items'of noncompliance were identified in review of these matters.

-

3.-

Radioactive Waste System

~

-In October 1981', ~an NRC inspection of this functional area determined that several significant deficiencies. existed.

These findings were documented in. Inspection Report No.. 50-206/81-36'.

In reply to the problems identified the Station Manager documented the licensee's in.itial response to each finding in a October 27, 1981 letter to Region V.

An Enforcement conference was held on November 25, 1981 and documented in Inspection > Report No.' 50-206/81-39. The-licensee's

.

January 15, 1982 response to the Notice of Violation, dated December 16, 1981 described those corrective steps to be taken to avoid further items of noncompliance. The focus of.this inspection was to review

'

implementation of;the long-term improvements in the radwaste area.

.

,

A.

Effluent Organization, Staffing, Qualification, and Training

'

'

Station Orde'r 123-C-1,'" Organization and Responsibilities of the Chemistry Section," Revision 0, dated July 22, 1981 places responsibility for management of radioactive liquid and.

gaseous effluents within the Chemistry Section.

S0123-HP-1,

" Organization and Responsibilties of the Health Physics Section," places responsibility for management of solid radioactive wastes within the Health Physics Department.

Since the last inspection of this functional area the " Supervisor of Plant Chemistry" position has changed hands twice.

The responsible " Effluent Engineer" position changed hands in July 1982. The " Health Physics Manager" position changed in January 1982 and again April 1982 leaving the Radwaste Supervisor as the only direct management representative unchanged since October 1981.

Chemical Procedure S0123-III-5.0, " Effluent Monitoring Program,"

Revision 0, dated February 11, 1982 defines the scope, authority, and method of program implementation for this area. The Effluent subsection is ' staffed by four engineers and one engineering aid. To supplement this staff the licensee has had four individuals from the General Atomics Company and two individuals from Quadrex Corporation on site during most of 1982. The licensee representative stated that they expect continued support from these contractors during 1983.

.

.

--

,

. _.

-

-

-

,

-3.

-

,.

t From discussions with the individuals involved the inspector concluded that the qualifications required by S0123-C-1 and -

S0123-HP-1 have been achieved.

Training requirements for individuals involved in aspects of effluent releases have been defined in' Chemistry Procedure S0123-III-5.5, " Effluent Monitoring Training Program," Revision 0,-

dated March 24, 1982.

In Paragraph A.4. of the licensee's January 15, 1982 letter the following statement was made: "The training procedure will list the type and frequency of training and the category of personnel to be trained. This program will be fully implemented by July 1, 1982." ' Review of the procedure indicates that the type and frequency of training for several. categories of personnel (Nuclear Chemical Technicians, Huclear Chemical Foreman, Engineer 'in Charge of Efiluent Monitoring, Operators,andNuclearInstrument. Technicians)have-

-

.been clearly stated. The training records for the Nuclear

_

Chemical Foreman, four Nuclear Chemical Technicians, the Effluent Engineers, and three Nuclear Instrument Technicians were reviewed.

The Nuclear Chemical Technicians and Foreman

. had. attended the required training and passed the written

,

examination with an average" score of 89 percent. The Effluent Engineers had attended the training on September 28, 1982 but

.had not taken'the examination. The four engineers took the examination on December 1 and ' achieved an average score of

-

93 percent. The Unit 1 Nuclear Instrument Technicians had not received the formal effluent training stipulated by S0123-III-5.5.

'

Discussions with the Unit 1 Instrument and Control Foreman

indicated.that no-formalized training had yet been provided for his technician's. area of responsibility. The Inspector

' discussed 'the ~ referenced training with two control operators and_a Shift Supervisor. The Shift Supervisor stated that he-expects the training to be provided prior to Unit l's return to power.

'

~

Completion'of the effluent' training described by S0123-III-5.5 prior to operation of Unit 1, is in the inspector.'s opinion, necessary-to' fulfill the Licensee's commitment (50-206/82-36-01).

)

B.

Evaluation of The Effluent Monitoring System i

Scientists and engineers from General Atomics Company (GA)

!

under the direction of the Effluent Engineer have during the

I last year conducted exhaustive testing of the Operational

[

Radiation Monitoring System (ORMS). - Specific components l'

evaluated included:

i

--

-

_ - - -, -,., - -

, - -.. - - -,

.y,-

-

-

_,.

,,,w-

.

,.-

.

,-_

_.

,

,

'

.

-

-4-

.

.

I.D. Number.

Monitored Stream'

R-1211 Containment Particulate 1R-1212 Containment Gas.

R-1214 StackGas~(inline)

'

R-1215

. Main-Condenser Air Ejector R-1216 Steam Generator Blowdown

,

R-1217 Component Cooling Water R'1218 Liquid Radwaste

,

R-1219

'

Stack Gas (off-line)

-

'

~

'R-1220 Stack' Particulate (off-line)

,

Stack Radiciodine (off-line)

R-1221

<

-

The inspector met with-licensee and contractor representatives

'to determine the scope of the evaluation; status of completion;

'

recommendations for= improvement; and to discuss the. inspector's

-

review of the technical data.

-

-

,

.;

The scope ofithd evaluation included a review of: system design; calibration of. ancillary equipment including electronics

-

and multipoint recorders, radioactive recalibration of the detection systems,_and evaluation of reliability and consistenancy

'

with ' contemporary. effluent ' monitoring standards.

With the exception of source and transfer calibrations of R-1211 and R-1214'the technical evaluation of the system has been

<

completed.

From this review of licensee efforts the following observations are worthy of note.

,

'

R-1211 calibration has not been completed. The linearity

-

check was performed on March 11, 1982. Mechanical design of the system's counting chamber is conducive to in i

i leak' age and buildup of internal contamination.

R-1212 was calibrated'using NBS traceable Xe-133 and Kr-85 gas.

-

,.

l This calibration found a factor of about 2 difference j.

from the original Xe-133 and 10 difference from the l

original Kr-85 calibration factors. A linearity experiment i

found the unit begins to saturate at IES counts per j

minutes (cpm), fully saturates at IE6 cpm and begins to l

paralyze at about 1.3E6. cpm. This would correspond to a l

-

radiation level of about 18 R/hr.

R-1212 is fed from R-1211

'

and is therefore susceptible to the inleakage condition.

l-

,

a..

'y

.

-

'

..

~

J

. wm 3:

'

,

.

'

-

c.

.

l

" ~

'

' '

'

.

,

='

'

..'

.,

,

s

,

,,

.w<

,

,

,o

.,

,

,

'

~

,

, g{[

,

}'

'T

- [

Y

~

'

'

s,

-

> -

,

s

,

.

-

-

-

_,

,

.

,v

,

+

a

.

.

--

,

ja,

,,

,..,.

_, s

>

v

.*

,

'R-1214'is; an iinline' monitor incapable 'of. discriminating

_

,

_

-

' - '

'

-

>

a.

'

- [p Although the' total system has yet to be. calibrated,.. tests:

'

"

'

between particulate. iodine and inert gasfactivity.

.

f

'

-

j?

Y~,(

X of individual. tubes

found that they;should.beEoperated at

'.

L K850_ volts rather;than thel 110 volts previously used. The

-

<

,

. GM tubes' used iridividually saturate.at about11ES cpm and

%;'

.

c

,

C paralyze fat about;4E5 Lcpm..

~

,

/

=

. '

'.

.

o,. s

...

- i *Th se GM: tubes'are prone.to mechanical failure'duelto.

.

'

'W" their inline location. They; are relatively insensitive

~

to beta-enbrgy (7:percerit tran5 mission for the' 364; Kev

~

'

t

' '

'

'

(beta from*Xe-133 and '25; percent' transmission for the '.

,

-

,..

W' _ g 650; Kev beta fp Kr185) an'd lowcenergy gansna. rays due to -

l N" their 30 mg/cm wall' thickness. The system reliability

~

e

+

'

, is:questionab,1e at high > count rates.

,

,

~

'

-

.

.

,,

,

...

~I,n an October-13, 1982> Memorandum from the GA representative

e to'the; Effluent Engineer,.the following recommendation was.

made:

. ' '

c

'

-

.

s

!

"The entire-system needs to be replaced with-an~ appropriate off-line monitor and the SV-99 valve function transferred

.

to that ~ monitor.'.This ~ intent was started in about,1975

!,

when ORMS channels 1219, 1220 and 1221'were installed but-it the effort was not completed"

!

-

R-1215 is identical to R-1212. The design suffers from l

~

the same problems as R-1212.

For example a steam generator rupture with 1 percent failed fuel will likely' result in t

'down scale failure of this channel.

.

-

.R-1216 and R-1217 were found acceptable.from a design standpoint, however, the system electronics were considered

[

. antiquated.

-

R-1218 suffers from a persistent background radiation

~

buildup problem. This is primarily due to -leakage from

'

s

.the stainless steel sample chamber into the surrounding

'

,.

housing. The unit was successfully decontaminated to

-

l

.less'than 8000 cpm at the initial calibration.

With'

t

. repeated additional decontamination the background has

'

still increased to about 50,000 cpm as observed by the

.

j inspector on~ November 29, 1982.-

In addition, due to the

'

detectors location in the lower level Auxiliary Building

,

the ambient radiation level is a source of concern.

In l

.

short, although the channel was sucessfully calibrated,-

!

-

l it is no easier to maintain now, than it was one year h

ago.

l l

,

y

~

!

.

,

,

,

,,

-

h

-i

n

.

,

_

-

,

'r

-

~

-

6-

.

_

-

-

,

.s

-

x -

The GA' contractor recommended to the licensee that "0RMS.

' '

-channel 1218_should be planned to be replaced as soon as possible."

'

,.,

-

R-1219'is 'an offline noble gas channel that uses a plastic

~ '

_

' scintillator. This unit did not saturate at count rates-up to 9.3 E6' cpm. 'Some difficulty with the checksource-

' design was identified.

. R-1220's paper tape drive presents = several problems which.

-

have resulted'in decreased reliability of the channel.

.R-1221 in addition to. the _ checksource p'roblems had a very

.--

complex magnetic interference situation which was corrected by GA.

~

,

,

a+

-

-

'In review of the source calibrations for R-1212, R-1215

.and R-1219 ittis' observed that an evaluation of the

~

~

.

. effect of a lower ' pressure in the sample chamber due to line losses 'and filter' differential -pressure was not

made. The licensee' representative agreed to evaluate.the

. magnitude of this effect!

No items of noncompliance.were identified in review of this area.

.

C.

Implementation of' Improvements

~

As previously note'd the licensee has established and implemented several procedures to improve man _agement of radioactive effluents.

The inspector reviewed the following procedures:

-

Chemical Procedure S0123-III-5.0, Effluent Monitoring l

Progre l

, ca ' 'rocedure S0123-III-5.1, Calibration Schedule

'

-

.

l at 4 3

. eewnt for the ORMS

-

-

cnemical Procedures 50123-III-5.1.1, 5.1.3, 5.1.4, 5.1.5, 5.1.8 and 5.1.9, Calibration of P.-1211, R-1212, R-1214,

,l'

R-1215, R-1218, and R-1219.

.

-

Chemical Procedure S0123-III-5.2.0, Effluent Sampling and Analysis Chemical Procedure S0123-III-5.3.0, Effluent Reports and l

-

l Records

Chemistry Procedure 50123-III-5.5, Effluent Monitoring

-

-Training Program

'

t

.,

y.

-

.-

a.--

g-

--n-rp.

a-,

r-e-

.}[1 ' ylQy. 3

-,

g,

-

-

~.' ',,

..f..

.

Q.

'V

~-

,

,

,.

y

a n.: ;

-

.

-

.

.

J;G7'-< l; y. _

[

._

' Q

^

. W r l&[x. f Q

$

"'

~

-

p

,

-

r

.p yy y 7w,

< - w.s-

.

.

.

>s

.

,s.~

w _w n,

_

,

..

.>s'

/.y

.e'

~

-

b '.,,.

y

-

y,

.'y,.

.

>

l ~~

-

'?

^

t n

' _.

-

,;

,

3_.

y

.

,

,

,

,

,

,

'

_

D dhemicaliProced0re S0123-II'I-Si3.1', Unii:1l Radioactive

'?

' '

~

<

% ; Gas. Sampling'and Analysis'Prncedure

-

'

>.

e

-

v

,

s-

,A-t

,m w,

_

f4-

.

-

,

. _

,s N-I i pe' rations S01-1.3-1,$igh Radiation,' Operational: Radiation?

,'"

'

'

Monitoring System; Rev. 3 -

~

'

'

-

.

,

c: - n

., - -

_ c1r s

fOperationsS01-5-1,RadwasteGasSystem,Rev.~7.1'

~

-

-

'

i1

..

'

"

f

-

,

-

Operations;S01-12.2-2,; 0RMS ; Test'

..

,,

,

-

s y

,

,

.

Instrument and Test-Procedure JS01-II-IL7, Unit l',- Operational.

'

'

'

Radiation Monitoring -Syst'em Calibration, Rev. =.6 a:

S01-XV-3.0, Surveillance Program Implementatihn,-'Rev. 0

'

-

-

'

~

'

LBased on' this} review;the following observations are'noted:

-

.

1.

In the licensee's -January 15, 1982 letter, Page 7,

_

+ Paragraph D.4.

The following. commitment was'made:

-

" Station-procedures S01-III-5.3.0, ' Effluent. Reports and-

~

'

,

,

,

--Records;' cand S01-III-5.3.1, "' Semi-Annual ; Report, are

• -

fin final stagesof-preparation and will be; implemented by ',

,

g Jebruary. 28, ~ 1982;" -

'

,

,,

,

,

S01-III-5.3.1 was drafted but never approved or; implemented.

i:

In an October 20, 1982,-Memorandum from'the Supervisor of

,

. Plant Chemistry the dacision~not to implement this. procedure

-

twas' documented.

-

On Page 2, in'pragraph~A.4 theilicensee stated in part

<

that' a procedure (S01-III-5.4.0, Inspection and Surveillance),"

will, listicompensatory actions and methods to be employed '

in the event of unacceptable differences-between monitor i

'

readings and sample data or failure of-operability checks."

It was also stated that: "S01-III-5.4.0, ' Inspection and

.

-e,

. Surveillance,' will identify the methods for assembly 'of

'

.

data and will list the requirements for. routine review of

data." The letter went on.to'say that: "This program p'

will be fully implemented by July-1, 1982."

Contrary to this commitment, a procedureLS01-III-5.4.0 i

has not been implemented.

'

NRC.was not informed of the licensee's intent not to

% implement S01-III-5.3.1 and 5.4.0.

Therefore, this

. matter'will remain-open pending a licensee response

,'(50-206/.82-36-02).

f

,,,

s

.

,

-

'# 2:

AttachmenF 8.1,'" System Alarm Setpoints, Operational i-

' Radiation Monitoring, System"-to S01-12.2-2, Rev.-4 does

.

-v

-

tv-not address monitors.R-1219, R-1220 and R-1221.

-.

,

,

'

i *

,,

p -

.

~

'

,

e i

,

.

.

,

-

-L.

.

'

'v, p

'

,

-

e

.<

,

.

-

.

i

.

-

-L8 -

-

'

- -

,

?

.

f

.

t

,

3.

S01-XV-3.0, Rev.'O delineates the requirement to calibrate.

' effluent monitors every six' months-by referencing S01-II-1.7.

'S01-II-1.7 is an electronic calibration followed by an

.

installed source check.

S0123-III-5.1 and'its'~ ancillary

,

procedures,S0123-III-5.1.1 through 5.1.13 describe the

-

. transfer calibration using radioactive material necessary

^~

,

to meet the Technical Specification requirements, however,

,

'S01-XV-3.0'does not reference these procedures.

_

4.

LIn an August 10, 1982, Memorandum to the I&C Supervisor-from the~ Technical Manager, I&C was requested-to incorporate.

the 501-III-5.1 Unit 1 effluent monitor isotopic calibration procedure series into.the.I&C procedures.-

As of December 3,'1982, none of these procedures had:been incorporated into the I&C procedures.

'5.

During the last inspection of this-functional area the licensee was cited for failure to evaluate continuous

'

releases.

The inspector understood paragraphs A.3, A.4,-

B.3 and B.4 of the licensees January 15, 1982 letter to mean

.

that administrative controls (procedure revisions) would

.be implemented to assure sthat operators would inform the Chemistry Technicians or Effluent Engineer of the need to take a' propriate. measures anytime an unusual release of. activity

~

l

~

p

'

was'noted on the ORMS system.

Based on discussions with

.0perators and the Effluent Engineer it does not appear

~

-

that this has been accomplished.

.

<

No' items'of noncompliance wer'e identified in this area.

'

'

'

~~

Electronic and isotopic calibration of-0RMS monitors have been accomplished'as shown below:

Channel Initial' Calibrations Six Month Calibration

'

.:

.

R-1211 Not Complete

. R-1212 3/11/82 Not Done l

l

'

R-1214 Not. Complete

.

!

R-1215 2/9/82 Not Done R-1216 3/2/82 Not Done R-1217_

2/25/82 11/1/82 R-1218 3/18/82-10/20/82 R-1219.

1/26/82 9/20/82 o

i

'

R-1220 2/17/82~

Not Done-R-1221

.5/12/82 Not Done

l

!

"

,

.

,-.

.

.

...,.

- -.

. - -.

~

y, u m m, mg..,

m

,

,

A; p s,,

,

J.

.

h. -

- ;

,

,

,,

.

_.

,,

.

,.ms-

, y; <,,. -

g

.y

.

_3

,

.

_

s'

V

• ?

,

s e.

_

c

..j ;

y, s

.

,

.- %

y

,

'TechnicaliSpecifihntion'4'6 E.~ states:

'

.

,

i a

~

.

.

-

"The stack' gas and particulate monitors shall be calibrated

.at a; min'imum frequency of'once every six months, and

,

normal l response of each monitor shall be tested weekly."

-Procedure S01-II-1.7 describes ~the electronic and' flow sensor

^

portion of the calibration. The radioactive material transfer calibration is described-in the S0123-III-5.1 series-procedures.

Channels R-1212, R-1214 or R-1219 when calibrated can be used

'

V to monitor the-stack for gaseous activity.

Channels R-1211 or R-1220-can be used to monitor the stack for particulate activity.

Review of data sheets maintained pursuant to~S01-II-1.7 indicated the electronic and flow calibrations were performed as required during 1982.

As noted above,.R-1214 has not yet been calibrated.

R-1212 was calibrated on March 11, 1982 but was not recalibrated within six months as required.

R-1219 was-calibrated on January 26, 1982 and recalibrated on September. 20, 1982, pursuant to S0123-III-5.1.9. Unit 1, Environmental Technical Specification, paragraph 1.3 defines " Semiannually" as "once every six months + one. month'."

Unit 1, Technical Specifications, Table'1.1 allows, "For.each frequency, the allowable extension is 25 percent." although R-1219 was recalibrated, it was not done within either time allowed.

R-1211 has not been calibrated per S0123-III-5.1.1 during 1982..R-1220 was calibrated on.Febuary 17, 1982 but has not yet been recalibrated.

As noted above only one channel-(R-1218) was calibrated within the six month criteria of S0123-III-5.1.

-Failure to calibrate the stack gas and particulate monitors at six months intervals represents noncompliance with Technical Specification 4.6.E (50-206/82-36-03).

It is fair to observe that since Unit I was shut down on february 27, 1982 a minimum potential for an airborne effluents exist.

In addition, the licensee ~ collects daily' noble gas samples and weekly particulate 'and iodine' samples from the

- s tack.

However, no relaxation from the calibration requirements

' exists since 'the detectors would be called on to identify and evaluate an. inadvertent or unplanned release.

~

/

e 3.Y

!

>

,

y

,

,

,

y.<

,

,

g r,

.-

,

<

,

,

y

_

-

. _

-.

-,

,..

,

u

.

,[

.p1

.,

,

,

"

/

"

dCO-

k

'

I

.

,

'

~

'

y

?

,

c

.

,

_

"-[ Y

.

t

>

-A t

~ Ah a result of the licensee evaluation 1tLwas determined that~

~

several effluent channels saturate and' paralyze at high count o

rates..A May 25,~ 1982,lMemorandumyfrom-GA to the Effluent

'

.

.

m iEngineer documented a design change which if implemented would

>-

. prevent the ORMS channels from pegging-downscale. A June 4,

-

,

,

~ 1982,: Memorandum' from the Chemistry Supervisor requested.

processing of a design modification.~ Another-memorandum from -

-the Supervisor of Plant Chemistry dated November 9, 1982,-

'

again addressed the ORMS downscale failure problem. On December 1, 1982 the inspector requested information on the' status of

. actions'to correct the problem. The' licensee representative L.

-

stated that the proposed ' design modification initiated in June

- 1982, had.been. lost and that a new one would be initiated.

.

~

Licensee action to correct downscale failure of ORMS channels

,

A-will be reviewed Lin:a, subsequent inspection,(50-206/82-36-04).

. Paragraph: A.4. of the licensee's January 15, 1982 letter y

stated that: "when satisfactory operation is_ demonstrated, a

'

' facility modification will ~be completed enabling.this monitor

~

!(R-1219) to control' the Waste Gas Discharge. Valve SV99, thus

-

' replacing R-1214.'"; As of this-inspection - the _ described

>

iactionhasnot-beencompJeted..

-

Control of SV99 will>be reviewed in a subsequent. inspection

!

(50-206/82i36-05).

'

'

'

~

27, 1981 letter-i

_ Item 7 on page:6 ofithe licensee's October

-

stated in reference to channel 11218, (liquid radwaste monitor)

a i' ~

.that: "This1 monitoring system will.be evaluated during the.

engineering calibration program and will be upgraded to a

' system designed to be 'easidr to maintain in the future." As j

of this inspection, R-1218 still suffers' from a-leaking bowl

.

seal-which continues, to decrease -its sensitivity. No action t

i l.

has been complet'ed which would' result in this channel being

' easisr' to maintain.

~

'

.

Actiontake[$oimproveR-1218willbereviewedinasubsequent-p V

inspection (50-206/82-36-06).

During a tour of Unit 1 on November 29, 1982 the inspector noted that the new 0RMS multipoint-recorder RLR1200 was working

-

.

'

properly and producing a readable record.

~

.

0ne_ item of noncompliance (50-206/82-36-03) and three outstanding '

items were -identified in this subparagraph.

-

'

-

<

,

=

...

J

.

_

.

..

.

.

..

.

n1

.

.

.

,

,

'%,

'

L f

,x I

.

-

'

11 _

-

.

.

..

,

.

, w

.

'

i

'.n. y,

,

D.

Effluent Reisases

'

'

%

~

~Two effluent releases, Gaseous' Radio ~ active. Release Permit-No. 3831,< Liquid. Radioactive Release Permit No. 1212, in

-

sprogress on November 29,.1982 were reviewed to-determine compliance with. Technical. Specification 4.5 and 4.6 requirements.

'

'

.

t

.

>

.

Records of gaseous radioactive releases, Permit Nos: 3457,

_

..

l3458, 3459, 3460,'3461, and'3463 made in February and March 1982 were~also reviewed.

'

~

Records of two liquid' radioactive relea'ses~, Permit Nos: 1181,

.

~

1182 made in August?1982 were also inspected.

-

'

'

^

'

No' items of no'ncompliance or' deviations were identified.

~

E.

. Review of Reports The licensee's " Semi-annual" reports for the period July 1981'

through June 1982 were reviewed to determine compliance with

- +

Technical Specifications 4.5, 4.6 and 5.6.2.

Raw data and preliminary calculations used in preparation of-t the January-June 1982 report were discussed with the licensee representatives and found to be consistent with,the data

. reported.

The licensee's " Annual" report dated March 31, 1982 and

supplement dated July 1, 1982 were reviewed in terms of'

Technical Specification 5.6.1.

No items of noncompliance or deviations were identified.

,

F.

Reactor Coolant / Steam Generator Chemistry -

'

The inspector reviewed selected records to determine compliance with Technica1 Specifications 3.1, " Maximum Reactor Coolant

Activity;" 3.42, " Maximum Secondary Coolant Activity;" Table t

4.1.2, " Minimum Equipment Check and Sampling Frequency" and

~

,

Station Order S01-E-2, " Water Chemistry Control," Revision 13.

Specific records reviewed included the " Daily Reactor Coolant Summary Sheets" and " Weekly Reactor Coolant Summary Sheets"

for February and October 1982. The " Weekly Turbine Plant Summary Sheets" for February and October 1982 and the " Steam Generator Summary Sheets" for October 1982 were also reviewed.

The inspector noted that S01-E-2, does not address specifications or sampling frequencies in shutdown or wet-layup conditions.

i No' items of noncompliance were identified in this area.

L

-

!

^

~

c

.,.

.. -.,, -,.

.,.

-

'

-

'

% ; m g;gl % y y [ %.4 ; Q f f:?? %

v.

,

,p,q y,f y_,;g i g, 3., mg. -

j

... <

,-

+

a.

-;

.~

q fw -

,

.

a

.x-

,. c

.

a e

. s _;.

w-31

, n ;y,

.

1m >

>

, _ - ' >

..

..

<

c -

w f.

-

,

,

-o

.

"

y_. m ;

wy,,;,

gy. - 12. b.

t-

'

'

'

-

'

"'

an.

?'

s?

.,1 W V,

r.

T.

'

s e

K ; +-

r

"

.

a_

>

p r--

_, _ -

,_

" :* ?

%

,

,

,

E'

t'

"'

.~ f

.

.s s

i _

.Gl iSol'id Ra'dioactivs Wa'ste:,

,-

'~

,

.

-

-

<

~

-

- % y _

.,.

,;

.

.

_

._

'

DThe ^ inspector! discussed with Lthe. Health _ Physics - Manager the -

,

,

,.

clicensee's plans 'to. increase storage capacity of solid 1radioactiveL

_

<

'

', ; wastes onsite.-- - At this' time a date to begin implementation of'

'

y

',

' ndesign changesihas not been established..The licensee ~isy

'

L

,"

_

_

presently' planning to decrease the inventory of-contaminated 1 resins"onsite by initiation'of a solidification.and shipping.. s

-

'

-

. program., :In-connection with thisl effort the inspector reviewed l t

y

the followingLdocuments.

,

t

-

-

-

s

, >

s

.

n_-

.

...

?

. Health Physics Procedure:501-VII-1.7-Spent Resin' Shipment, i-

{Rev.i8'

"

,.

,

. Heal'th Physics Procedure S0123-VII-8.5, Radwaste Solidification,.

~

Rev. 0

.

>

-

.

S0123-c/s-c-0250, Assembly and Disassembly Procedure for CNSI-:

Portable' Cement Solidification; Unit.

'

i

.s

'

'

r.

-

' S0123-c/s-c-0251; Operating Procedure for 'CNSI, Portable

.

Cement Solidification Unit

-,

<S0123-c/s-c-0252,-Process Control Program for CNSI Cement l -

Solidification' Units

,

Temporary Mobile Cement Solidification System Nuclear Safety' -

,

Evaluation, by D. D. Duran, dated November '17,1982.

.

-

Based on this: review the inspector concluded that the licensee has throughly planne'd the solidification program.

Two procedures which deal more generically with solid radioactive

or~ contaminated material.were also reviewed.

,

Health Physics Procedure S123-VII-8.1.3, Handling and Storage of Radioactive Waste Packages, Rev. 0

,

J ealtih Physics Procedure S0123-VII-7.3.1, Release'of Tools,

'

H Material,'and Equipment from Controlled Areas.

'

,. y

..

.

.

DuYingtour's'oftheUnit'the:inspectornotedthatsolid i

~

i

~

!

radioactive wastes were being controlled inaccordance with these procedures.

'

,

From review of the August and October -1982, " Station Exposure '

~

>

and Solid Radwaste. Processing Totals" and the December 1,

'1982, " SONGS ~ Health Physics. Information Notice," Number. 3-82 thelinspector observed:an'agressive effort to stimulats a

'

-

volume reduction in the amount' solid' radioactive waste-generated.

'

t t

,

,

.

'

s

,~

,

i

'

,

i :,,

( -.

t i

m.

.

.

~..

...

_ -, _.. _. _ _ _. _. _ _.. _ _. _ _ _ _ _. _

'

't'

,:

-

,

,+

'

,

,

[A

~

'

13 -

1. -

,

-

'

_.

.g-

.'4

'

'

-r

,

g g ^

"A., 'i.

.

f

,

-"

,

,

e

,

,

' These'communicati.on: tools should enhance the :licen' sees efforts in this' area.

.

'

'

.+

. No item'of noncompliance or. deviations were noted in this'

,

M,

.

,

area.

-

,

.

'H.

. Test of Air Cleaning Systems?

.

- a,

,

• Technical Specification 4.11. " Control Room Emergency Air.

. Treatment' System," requires periodic testing of that system in

~

accordance' with ANSI 'N510-1975.

The, inspector.. reviewed:

-

. Maintenance' Procedure 501-I-2.43, " Yearly /720 hr/ Post Maintenance Control Room Emergency Air Treatment System

~

Testing" Rev. 0

-

Maintenance Procedure 501-I-6.72,," Control Room Emergency Air Treatment System Filter Replacement,": Rev. O The HEPA and charcoal-filters were' replaced on September 10, 1982 and the system tested ~as described in these procedures Review of the " Maintenance Data Record Forms" for this work

-

(M.0. 20057) indicated the procedure-(S01-I-2.43).was not followed exactly by the performer (Flanders Filters Inc.).

The licensee representative informed the inspector that Quality Assurance had identified the same anomaly and issued a Corrective Action Request, (CAR) S01-P-581.

,

Review of S01-P-581 issued September 16, 1982, indicated that

,

Quality Assurance also noted the apparent failure to take a

charcoal sample and excessive test gas concentration. The

" Reply Due Date" to this CAR was initially October 18, 1982.

l On September 29, 1982 an extension was granted to October 15, i

1982. On October 15, 1982 an extension to November 10, 1982

was granted.

On November 15, 1982 Quality Assurance declared

!

the response to S01-P-581 delinquent.

l l

As of December 3, 1982 a response to this CAR has not been

'

submitted to Quality Assurance.

Failure to resolve S01-P-581 could result in noncompliance.

This matter will be reviewed in a subsequent in~spection (50-206/82-36-07).

j

_

_

$

i

,

+ -

w..

.

--

e w

-

~

,v-

-

+,-c-+

,

--, -

~g,-w, w<g

s

..,

,

_4

< se

=

..

.

<

- :-

f.

. ;g7

"'

~ '

~

.

,

,

.

W

.g.,

,

'

. i y.

.

s.

,

-

g__

,

e

'#

,

I.- : Audits

~

i

'

• .

'

-

,

_

. -,.

?Three Quality Assurance' Audits 1(501-39-82, S01-40-82, 501-41-82)

- '

of the Effluent / Chemistry area have been performed since the

"

'

last inspection. No CAR's resulted from these audits.

L

.The Quality Assurance Engineer responsible for this area Linformed the inspector that he was-just begining an audit of '

-

Chemistry to followup 501-41-82 during the week of November 29 -

December 3, 1982.

,

.

No items'of noncompliance were identified in this' area.

'

4.

Exit Interview.

~

The inspector met with the; licensee representatives (denoted in

'

paragraph 1) at the_ conclusion of the inspection on December 3,

.1982. 'The inspector summarized the scope and findings of the. '

i

- inspection. The inspector complemented the licensee on their

_

effective utilization of contractors during the past* year.- The

' inspector complemented the contractors for their scientific evaluation

. of the ORMS system and the dramatic improvement in the " Semi-annual Operating Report."

The inspector expressed concern that implementation of'some commitments contained in letters dated October'27, 1981' and January 15, 1982 had not been achieved. The Deputy Station Manager assured the inspector that the licensee takes each commitment seriously and.is presently developing a " Commitment Register" to minimize the possibility-of a failure to respond.

The inspector again expressed his displeasure with respect to timely resolution of Corrective Action Requests. The licensee responded by indicating that the backlog of delinquent CARS is being diminished.

,

'

,

,

'

,

.

-

,

'

.

b d

- '

~

,

1

.

-,

t

,-

_. - - -

- -, - -

,

,,

-

- - _,

. ~..

,

,..n...

.

...