IR 05000213/1997002

Insp Rept 50-213/97-02 on 970207-07 & 0224-26.Violation Noted.Major Area Inspected:Programs for Radioactive Liquid & Gaseous Effluent Control,Including Organization & Effectiveness of Program Implementation

ML20137E627
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137E624	List: IR 05000213/1997002 ML20137E619
References
50-213-97-02, 50-213-97-2, NUDOCS 9703280122
Download: ML20137E627 (17)

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U.S. NUCLEAR REGULATORY COMMISSION j REGION I <

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Docket No.: 50-213 l

License No.: DPR-61 i

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Report No.: 50-213/97-02

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1 l l l Licensee: Connecticut Yankee Atomic Power Company Hartford, CT 06141-0270 i

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l Facility: Haddam Neck Station  !

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i Location: Haddam, Connecticut  !

l b Dates: February 3-7 and February 24-26,1997

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- Inspectors: Dr. Jason Jang, Senior Radiation Specialist  !'

Lonny Eckert, Radiation Specialist l

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Approved by: John R. White, Chief, Radiation Safety Branch j L Division of Reactor Safety j i

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9703280122 970321 PDR ADOCK 05000213 G PDR

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< Report Details

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I Summarv of Plant Status l

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I Haddam Neck remained shutdown in a defueled condition. No major NRC-regulated i

activities were conducted during the inspection perio IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls R Imolementation of the Radioactive Liauid and Gaseous Effluent Control Proarams i

i Inspection Scope (84750-01)

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The inspection consisted of

(1) touring radioactive liquid and gaseous effluent j pathways and process facilities; (2) reviewing of radioactive liquid and gaseous l effluent release permits; and <(3) reviewing of Licensee Event Report (LER) 96-23.

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' Observations and Findinas

, The inspectors reviewed selected radioactive liquid and gas processing facilities and equipment including effluent radiation monitors and air cleaning systems. All

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equipment was considered by the licensee to be operable at the time of the review, with the exception of the steam generator blowdown radiation monitors (R-16 A&B). The licensee had installed and calibrated R-16 A&B, but had not placed this

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! RMS m service.

I l j During the review of selected radioactive liquid and gaseous effluent discharge l permits, the inspectors determined that the discharge permits were complete and

, met the TS requirements for sampling and analyses at the frequencies and lower I

] limits of detection established in the TS.

The inspectors reviewed LER 96-23 (containment air recirculation). This is

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discussed in greater detail in Section R2.3.

i i The inspectors also noted that the licensee routinely performed trending analyses i for radioactive liquid and gaseous effluent releases in order to manage and monitor the total amount of releases each year.

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, Conclusions l

Based on the above review, the inspectors concluded that the licensee maintained and implemented the radioactive liquid and gaseous effluent control programs effectivel .

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R2 Status of RP&C Facilities and Equipment i

R2.1 Calibration of Effluent / Process Radiation Monitorina Systems (RMS) Inspection Scoce (84750-01)

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The inspectors reviewed the most recent calibration results for the following j selected effluent / process RMS. The inspectors conducted interviews with licensee chemistry and l&C staff and the system engineer. The inspectors also reviewed the

licensee's RMS self-assessment and RMS work order * Main Stack Noble Gas Radiation Monitor (R-14A);

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j * Main Stack Wide Range Noble Gas Radiation Monitor (R-148); i e Steam Generator Blowdown Radiation Monitors (R-16 A&B);

• Radioactive Liquid Effluent Radiation Monitor (R-18);

* Spent Fuel Pool Radiation Monitor (R-19); and

• Test Tank Effluent Radiation Monitor (R-22).

! The inspectors reviewed the following licensee's I&C calibration procedures:

i e SUR 5.2-8 Radiation Monitoring System Calibration (R-14A 4 Main Stack);

4 * SUR 5.2-69 Calibration and Functional Test of the Stack

Wide Range Noble Gas Monitor; (R-14B),

) * SUR 5.2-8 Radiation Monitoring System Calibration (R-16A l Steam Generator Blowdown);

• SUR 5.2.8 Ra-diation Monitoring System Calibration (R-16B

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4 Steam Generator Blowdown);

• SUR 5.2-8 Radiation Monitoring System Calibration (R-18 i

River Effluent);

• PMP 9.2-19 Radiation Monitoring System Calibration (R-19

Spent Fuel Pool); and l * SUR 5.2.8 Radiation Monitoring System Calibration (R-22 Recycle and Waste Test Tank Discharge.

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The inspectors utilized the following documents as a basis to determine whether the above procedures contained sufficient calibration steps to verify conversion factors (calibration factors):

• Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity

in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light Water Cooled Nuclear Power Plants, February 1979";

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• Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations)- Effluent Streams and the Environment, February 1979";

• ANSI N42.18,1980, " Specification and Performance of On-Site instrumentation for Continuously Monitoring Radioactivity in Effluents"; and 0 EPRI TR-102644, " Calibration of Radiation Monitors at Nuclear Power Plants, March 1994".  ;

The above noted standerds consist of the primary and secondary calibration methodologies, and quality control, and monitoring guidance. The recommended manner of calibration of the RMS consists of two parts - an electronic and a radiological calibration. Electronic calibration is performed for all electronic components without a radiation detector. One of the most important steps for the electronic calibration is to verify the linear response between pulses (Hz) and count l rates (cpm). These pulses correspond to signals originated from a radiation detector, i.e., the high pulse will respond to the high count rate. The pulse l generator is usually calibrated by the National Institute of Standards and Technology '

(NIST). On completion of the electronic calibration, the radiation detector is reconnected to perform a radiological calibration. The radiological calibration l consists of: (1) construction of the plateau curve to set the operating high voltage, '

(2) construction of either the primary or the secondary calibration curves using multiple source strengths to determine conversion factors ( Ci/cc/ cpm for the primary calibration and pCi/ cpm for the secondary calibration), and (3) comparison of the calibration factor to the previous factor to determine the precision and accurac Observations and Findinos b-1. Adeauacy of Licensee RMS Calibration Techniaues R-14A, R-16A&B. R-18 The licensee installed the following new RMS, as part of an RMS upgrade project in early 1996. (See inspection Report No. 50-213/95-08 for detail):

• Main Stack Noble Gas Radiation Monitor (R-14A);

• Steam Generator Blowdown Radiation Monitors (R-16 A&B); and

• Radioactive Liquid Effluent Radiation Monitor (R-18).

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As these new RMS were installed, the responsibility for conducting radiological calibrations was transferred from the Chemistry Department to the l&C Department, although the I&C Department lacked experience and procedures for performing radiological calibrations. When developing procedural guidance in conducting radiological calibrations, the I&C Department did not use the techniques which had

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previously been established by Chemistry Department procedures, but rather develop a more cursory calibration process. The inspectors reviewed the most recent calibration results, as determined by the l&C Department, and found the following weaknesses:

• No electronic calibration data was documented:

• No in-situ primary calibrations were performed;

• No plateaus curves were constructed to determine the optimum operating high voltage;

• Secondary calibration methodology was inadequate because during

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radiological calibration, the licensee changed the high voltage in order to obtain the expected count rate;

• Conversion factors were not calculated; and

• Linearity for the intended monitoring range was not calculate The inspectors discussed radiological calibration methodology with the licensee's l&C and Chemistry personnel. The inspectors determined that the licensee's calibration procedures were not sufficiently comprehensive or detailed to assure adequate and verifiable calibratio The inspectors noted that prior to the installation of the new R-14A, radiological calibration was performed by the Chemistry Department. The inspectors reviewed the last radiological calibration conducted by the Chmistry Department on the previously installed R-14A and found that the Chemistry Department performed an excellent radiological calibratio R-14B The inspectors reviewed the 1996 calibration results for R-148, main stack wide range noble gas radiation monitor, as shown in the following table. The l&C Department had responsibility to perform electronic and radiological calibrations for this RMS. Quarterly calibrations are required by the T . _ _ _ __

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1st Otr 2nd Qtr 3rd Qtr 4th Qtr 2-7-96 5-7-96 8-23-96 11-27-96 (1) High Voltage 950 Vdc 925 Vdc 923 Vdc 922 Vdc L Desired, cpm 78,400 78,400 78,400 78,400 Measured, cpm 80,400 80,490 81,080 75,780 Cl-36, ID 92-1515 92-1515 92-1515 92-1515 (2) Desired, cpm 8,044 7,912 7,783 7,655 M Measured, cpm 7,720 7,332 7,184 10,900/7600 Ba-133, ID 84-122-3 10578-46 84-122-3 10578-46 (3) Desired, cpm 8,044 7,812 7,783 7,655 H Measured, cpm 7,990 7,960 7,248 7,520 Ba-133, ID 84-122-3 10578-46 84-122-3 10578-46 (1) L = Low Range Noble Gas Monitor (2) M = Mid Range Noble Gas Monitor (3) H = High Range Noble C:s Monitor During a review of the above calibration results, the inspectors identified the following weaknesses:

• A 1-point calibration method was used and the high voltage was changed to meet a specified count rate for the radiological calibration;

• Because the licensee had modified the high voltage to meet a specified count rate, the high range noble gas monitor calibration was particularly questionable because the source used was the same as that used for the mid range noble gas monitor; e l&C supervisory oversight of RMS calibration was inadequate. As noted above, there was no apparent count rate difference despite the large detector volume differences between the mid and high noble gas detector This was an indication of the inadequacy of the RMS calibration technique used for R-14B;

• Because the licensee had conducted a one point calibration, it was not possible to calculate conversion factors for low, mid, and high range monitors or establish linearity; and

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e A plateau curve was not generated to determine the optimum high voltage setpoin R-19 and R-22 The inspectors reviewed the most recent calibration results for RMS-19 and RMS-22. The l&C and Chemistry Departments had the responsibility to perform electronic and radiological calibrations, respectively. The inspectors identified similar weaknesses for the electronic calibre.;on listed above. The inspectors also identified that the previous radiological calibrations performed by the Chemistry Department were very goo b-2. System Enoineerina The inspectors noted a lack of continuity in system engineer oversight regarding the RMS in a critical period (RMS upgrade project). Both the senior NRC resident inspector and the chemistry manager had noted to the inspectors that the control room RMS panel (SCANRAD) did not appear to be reliable. The most recent licensee audit of the effluents control program, licensee audit No. 96-A10-02, noted that "RMS reliability was not easily evaluated. There is a great deal of concern with the amount of time the RMS is out of service. The SCANRAD system has been inoperable for greater than 30 days." When directly questioned by the inspectors, 3 the system engineer was not able to provide insight into overall system reliability, b-3. Enforcement lmolications

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Section 6.8 of the TS requires, in part, that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33 (RG 1.33), February 1978. Appendix A of the RG 1.33, j

" Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," !

describes typical procedures for the control of radioactivity, including procedures l involving radiation monitoring system l Contrary to the Section 6.8 TS requirement, as of February 7,1997, the licensee had failed to establish and implement procedures sufficient to test the above RMS as evidenced by: (1) no documentation or poor documentation of the electronic calibration data, (2) no performance of in-situ primary calibration, (3) no plateau curve to determine optimum operating high voltage, (4) incorrect performance of the secondary calibration, and (5) no determinations cf conversion factors and linearity for the intended monitoring ranges. This item is considered an apparent violation and will be addressed in separate documentation. (eel 50-213/97-02-01)

I b-4. Interim Corrective Actions 1,1itiated by the Licensee Based on the above reviews and discussions with the licensee representatives, on February 7,1996, the licensee declared the RMS, noted in the inspection scope, to be out-of-service. The licensee initiated compensatory sampling as required by the TS until recalibration was accomplishe .

b-5. Safety Sianificance R-14A

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For R-14A, the change of responsibilities and the new procedures were ,

implemented after shutdown. The new R-14A was installed, calibrated, and placed in service on August 4,1996. The inspector reviewed selected gaseous releasu -

permits from August 1996 to January 1997. The licensee took grab samples (e.g.,

, containment purge an gas decay tank samples) and analyzed them before release The licensee also performed projected dose calculations based upon sample results before releases as required by TS. These projected dose calculatiori results were well below TS limit ;

The inspectors also attempted to make a comparison between analytical results of grab samples and monitoring results. The inspectors noted that meaningful comparisons were not possible because of: (1) the massive dilution around the sampling probe and (2) the non-isokinetic probe. This can affect the projected dose calculation results to the public for iodine and particulate releases. Projected doses could be either in a conservative or non-conservative direction because a compensation method was used for line losses. However, the inspectors concluded that public health and safety was not impacted and that the TS limits were not exceeded because the possible error was not sufficient to have exceeded the TS limits (sete Section R3 of this inspection report for detail).

R14B For R-148, the safety significance of this issue is higher relative to other monitors -

due to the fact that the monitor was calibrated inadequately and was in this condition during power operations. Because this is an accident monitor, licensee reporting of norrnal effluent releases is not impacte l The inspectors stated to the licensee that the inadequate calibration of this monitor would result in questioning the accuracy of accident off-site dose projections that were based upon readings from RMS R-14B per Emergency Plan 6.2.3.1.(a), " Noble Gas Release Rate Estimates." Notwithstanding, the inspector noted that the licensee could still project accident doses using field monitoring results as described in the emergency pla R-16 A&B For R16A&B, the change of responsibilities and the new procedures were implemented after shutdown. These RMS monitor steam generator blowdown are

! important during operations. Therefore, there was no impact of the improper calibration because the new calibration technique was implemented after shutdow l l

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8 R-18. R19. and R-22 i For R18, the change of responsibilities and the new procedures were implemented ;

after shutdown. For R-19 and R-22, the new procedures were implemented in !

January of 1995. The chemistry department continued to perform radiological calibrations which provide some measure of RMS accurac The chemistry staff calculated the 1996 projected doses to the public using the !

" Method I" code. The Method I code was developed for radioactive gaseous and ;

liquid release assessments. There is a considerable amount of conservatism in the Method I code so as to avoid unusual releases. The Method 11 code was developed I to be more accurate and uses actual meteorological data. Doses projected by the l Method I are och higher than by Method ll. The licensee published the projected '

doses to the alic, using Method il in the Annual Report. The 1996 projected j doses (by Memod l} of the whole body were well below regulatory limits (e.g.,

whole body doses by airborne was calculated to be 0.92 mrem while the TS limit is !

5.0 mrem).

c. Conclusions The inspectors made the following conclusions based on the above findings:

• Poor safety focus was noted when the responsibility for conducting the !

radiological calibration was transferred from the Chemistry Department to l&C without assuring that proper procedures and technique would be utilize This was the first breakdown of quality verification to assure the operability I

. of the effluent monitors. A second breakdown in quality verification ;

occurred when the Plant Operations Review Committee (PORC) failed to identify the weaknesses in the new l&C procedures used to calibrate certain RMS;

• The licensee's calibration procedures did not contain necessary steps, recommended by Regulatory Guides, ANSI, and EPRI guidance to perform meaningful calibrations of the RMS;

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• The l&C Department was not prepared to take over full management of the RMS calibration program;

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• System engineering oversight of the RMS does not appear to be adequate; and

• The radiolog cal calibration techniques utilized by the Chemistry Department remained excclien l l

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R2.2 Calibration of Area Radiation Monitorino Systems (ARMS) Insoectico Scope (83750)

The inspectors reviewed the most recent calibration results for the following 1 selected ARMS:

• Containment Manipulator Crane Radiation Monitor (R-31);

• Containment Floor Radiation Monitor (R-32);

1 * Spent Fuel Building New Fuel Storage Radiation Monitor (R-33); and

• Spent Fuel Pool Bridge Radiation Monitor (R-34).

The inspectors also reviewed the following I&C and Health Physics (HP) procedures

• PMP 9.2-141 Calibration of Radiation Monitoring System (Area Monitors),

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• PMP 9.6-1 Calibration of the ARM Observations and Findinas The l&C and HP Departments had the responsibility to perform electronic and radiological calibrations, respectively. All calibration results were within the licensee's acceptance criteria. Calibration procedures were good and easy to j follo j The inspectors discussed radiological calibration methodology with HP Department personnel. The inspector noted that the responsible individual had good knowledge of the calibration technique ; Conclusions Based on the above review and discussion, tne inspectors determined that the

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licensee had a good calibration program for ARMS, R2.3 Air Cleanina (Handlina) Systems

Insoection Scoce (84750-01)

The inspector reviewed the licensee's: (1) most recent surveillance test results, and (2) performance summaries to determine the implementation of TS requirements for the following systems: j

• Primary Auxiliary Building (PAB) exhaust; and  ;

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e Containment Air Recirculation (CAR) fan ,

i b. Observations and Findinos The inspectors reviewed the following v .veillance test re:alts: ,

t e Visual Inspection; e in Place HEPA Leak Tests; '

e in-Place Charcoal Leak Tests;

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e Pressure Drop Tests; and  :

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e Laboratory Tests for the lodine Cc!!9ctinr. Efficiencie >

i Test results for the PAB were within the licensee's TS acceptance criteria. Three of four CAR fans failed their surveillance. The licensee has written an ACR and an LER !

(96-23) on this matter. At the time of the inspection, the licensee had not determined how to disposition this ACR and LER now that the decision to l decommission the station has been made, i t

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The inspectors noted that the system engineers were tracking system status, i NRC findings regarding the spent fuel pool air cleaning system were noted in NRC Inspection Report 50-213/96-11 and are pending final resolutio c. Conclusion The inspectors found no discrepancies concerning air cleaning system testing methodology regarding the PAB or the CAR fan R3 RP&C Procedures and Documentation 1

R3.1 Radioactive Effluent Release Procedures I

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l a. Insoection Scope (84570-01)

The inspectors reviewed the following selected chemistry procedures and Annual Effluent Report to determine whether the licensee could implement the radioactive liquid and gaseous effluent control programs effectively:

• SUR 5.4-13 Liquid Radwaste Release Surveillance; and e SUR 5.4-14 Gaseous Radwaste Release Surveillanc . __ . __ _ _ _ ..___ _ _ . __ _

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inspection of the ODCM consisted of: (1) review of setpoint calculation i methodologies; (2) review of selected parameters for calculating projected doses; l and (3) review of radioactive liquid and gaseous discharge pathway b. Observations and Findinos The inspectors determined that the reviewed effluent control procedures were l sufficiently detailed to facilitate performance of all necessary step This report provided data indicating total released radioactivity for liquid and gaseous effluents. This annual report also summarized the assessment of the projected maximum individual and population doses resulting from routine radioactive airborne and liquid effluents. Projected doses to the maximum individual were well below the TS limits as shown in the following tabl .

t Whole Body Thyroid i

Airborne Liquid Airborne liquid TS Limits 5 mrem 3 mrem 15 mrem 10 mrem 1995 Report 0.466 mrem 0.176 mrem 0.081 mrem 0.017 mrem The inspectors determined that there were no anomalous measurements, omissions or adverse trends in the 1995 report and raw data for the 1996 repor !

c. Conclusions ,

Based on the above reviews, the inspectors determined that the licensee effectively !

implemented the TS requirement for reporting effluent releases and projected doses to tiie publi !

R6 RP&C Organization and Administration i a. Inspection Scope (84570-01)

The inspector reviewed the organization and administration of the radioactive liquid and gaseous effluent control programs and discussed with the licensee changes made since the last inspection, conducted in March 1995, b. Observations and Findinos Since the last inspection of this program area, the chemistry organization was reduced by two positions. A new system engineer has been assigned to the RM '

Another major change, impacting the effluents control program, was in consolidating the responsibilities of RMS oversight to the l&C departmen )

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i The inspectors reviewed Connecticut Yankee (CY) Interim Organization dated 3 November 16,1996. The licensee stated that the Interim Organization will be

replaced by the Decommissioning Organization in 1997. The inspectors discussed i chemistry staffing levels during the interim and decommissioning phases with the licensee. The Interim Chemistry Organization consists of two CY technicians, six'

4 contractors (technicians), three CY chemists, one contractor chemist, and the Chemistry Manager. The inspectors also reviewed the licensee's planned chemistry organization for the decommissioning phase. The licensee stated that the number i of decommissioning chemistry staff was not finalized and was still under review.

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! The inspectors determined that the chemistry organization was adequately staffed 1 for the interim phase.

i R7 Quality Assurance (QA)in RP&C Activities

, a. Inspection Scope (84750-01)

The inspection consisted of review of the 1996 audit and laboratory quality control j (OC).

, b. Observations and Findinas

The inspectors noted that the 1996 audit was thorough and was conducted by -

individuals with backgrounds in chemistry and effluents. Some items with significance to the effluents control program were noted and corrected (main stack flow rate meter calibration frequency). QA had also identified problems with the SCANRAD computer (see Section 2.1, b-2). As a result of these findings, the QA Department had decided to increase their surveillances of the RM The inspectors noted that QC for chemistry measurements was very good and included blind, spike, and duplicate samplin c. Conclusions Based on the above reviews, the inspectors determined that the licensee met the QA audit requirement .

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R8 Miscellaneous issues ,

R8.1 Review of Uodated Final Safety Analysis Report (UFSAR) Commitments A recent discovery of a licensee operating their facility in a manner contrary to the I Updated Final Safety Analysis Report (UFSAR) description h!ahlighted the need for a special focused review that compares plant practices, procedures and/or parameters j to the UFSAR descriptio ,

e While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected. The i following inconsistency was noted between the wording of the UFSAR and the plant practices, procedures and/or parameters observed by the inspector ,

• The 10 CFR 50.59 implications regarding RMS calibration discrepancies are {

unresolved pending further review as described in Section 2.1 of this report. l (URI 50-213/97-02-02)

V. Manaaement Meetinas  !

X1 Exit Meeting Summary l The inspectors presented the inspection results to members of licensee management at the ,

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conclusion of the inspection on February 7 and 26,1997. The licensee acknowledged the findings presente !

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Licensee representatives emphasized that the effluent monitors detailed in Section 2.1 of this report were considered to be inoperable; compensatory sampling for these same RMS .

was initiated; and indication remained available in the control room for trending purpose l l

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PARTIAL LIST OF PERSONS CONTACTED ,

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Licensee '

i D. Bazinet, Supervisor, I&C

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G. Bouchard, Services Director S. Carnesi, System Engineer M. Deney, Performance Engineer J. LaPlatney, Unit Director {

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i NRC i M. Conner, Project Engineer, DRP Branch 8 W. Raymond, Senior Resident inspector {

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INSPECTION PROCEDURES USED IP 84750-01: Occupational Exposure i

l ITEMS OPEN, CLOSED, AND DISCUSSED Open 97-02-01 eel Failure to Establish Adequate RMS Calibration Procedures 97-02-02 URI UFSAR Calibration Discrepancies Closed

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NONE Discussed LER 96-23 CAR fan surveillance failure I

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[ LIST OF ACRONYMS USED ACR Adverse Condition Report

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ALARA As Low As is Reasonably Achievable l CY Connecticut Yankee

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LER Licensee Event Report NOV Notice of Violation

NRC Nuclear Regulatory Commission i NUSCO Northeast Utilities Service Company

, PDR Public Document Room

] PORC Plant Operations Review Committee

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PWR Pressurized Water Reactor a

QC Ouality Control

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RPM Radiation Protection Manager i RWPs Radiation Work Permits TLD Thermoluminescent Dosimeter UFSAR Updated Final Safety Analysis Report

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