IR 05000213/1997012

Insp Rept 50-213/97-12 on 970812-13 & 1006-09.No Violations Noted.Major Areas Inspected:Status of Rp&C Facilities & Equipment

ML20198Q623
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	01/15/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198Q621	List: IR 05000213/1997012 ML20198Q616
References
50-213-97-12, NUDOCS 9801230100
Download: ML20198Q623 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Docket No:

'50 213'

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t Ucense No:

~ DPR-61 -

Report No:

50 213/97 17

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- Licensee:

Connecticut Yankee Atomic Power Company

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Hartford, CT 061410270

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Facility: ;

Haddam Neck Station

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- Location: -

Haddam, Connecticut

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.-Dates:-'

- August 1213 und October 6-9,1997 Inspector: -

Dr. Jason C. Jang, Senior Radiation Specialist t'

Approved by:.

-John R. White, Chief

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• Radiation Safety Branch Division of Reactor Safety

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Report Detallg

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R2 Status of RP&C Facilities and Equipment R2.1 Corrective Actions for Effluent / Process Radiation Monitorino Systems (RMS)-

Calibration Methodoloov f(Closed) Aooarent Violation. eel 50 213/97-02-011

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Insoection Scope (92904)

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During the previous inspection of the radioactive liquid and gaseous effluent control pr grams conducted on February 3 7 and February 24 26,1997, an apparent

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violation (EEI 50 213/97 02-01)and an unresolved item (URI 50 213/97-02 02)

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were identified relative to the RMS calibration methodology (See inspection Report No. 50 213/97 02for detail). The licensee submitted to the NRC the " Revised Commitments and Corrective Actions" for the apparent violation on August 7, 1997. During these inspections (August 1213 and October 6 9,1997), the e

inspector reviewed the licensee's corrective sctions to determine their

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effectiveness, b.

Observations and Findinas f

Adeauacy of Revised RMS Calibration Procedures and Technioues The inspector reviewed the following revised calibration procedures and calibration results of effluent / process RMS to determine the adequacy of the corrective actions:

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

e Main Stack Wide Range Noble Gas Radiation Monitor (R 148);

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

o Spent Fuel Pool Radiation Monitor (R 19); and e

Test Tank Effluent Radiation Monitor (R 22).

Revised eleuronic and radiological calibration procedures associated with the above RMS were well developed and incorporated applicable industry specifications and

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guidance (e.g., Regulatory Guide, ANSI, and EPRI) Calibration results were within the licensee's acceptance criteria, including linearity tests and conversion factor determination. The inspector noted that the licensee's data reduction techniques were sufficient to demonstrate the validity of the calibration results. The inspector

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noted that the licensee purchased new calibration sources and used correct geometry for the liquid RMS calibration. The inspector also noted that the above RMS were operable during this inspection.

The licensee stated that the electronic and radiological calibration procedures will be combined as one procedure in the near future to avoid multiple work orders. The inspector stated that one procedure for the' electronic and radiological calibration was a common practice and was acceptable to the NRC. The licensee's decision to delete the steam generator blowdown radiation monitors (R-16 A&B) from the TS/ODCM requirements was acceptable since this monitor is no longer used, sirice cessation of plant operations.

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Elowmeters, Isokinetic Nozzle, and ScanRad Comoutge System The licensee ordered identical flowmeters for R 18 and R 14A 1hese flowmeters were scheduled to be installed and calibrated for use by Septernber 30,1997. The inspector reviewed calibration results and the results were acceptable.

The licensee identified that the sampling station for the main stack noble gas radiation monitor (R 14A) was not provided with the isokinetic nozzle, however, the main stack wide range noble gas radiation monitor (R-14B) was connected to an isokinette sampling device. A redundant sampling pathway was installed, using the R14Bisokinetic nozzle, to permit isokinetic sampling with the R-14A monitor. The inspector verified that the corrective action for this issue was complete and acceptably performed.

The licensee used the ScanRad computer system for RMS data acquisition, however, the system had malfunctioned about one moath after installation.

Subsequently, a new ScanRad computer system was installed with upgraded software. The inspector confirmed that the system has operated reliably since June 20,1997.

UFSAR and Technical Specification (TS) Adeauacv HClosed) URI 50 213/97-02-021 The licensee reviewed the UFSAR and TS requirements for the effluent / process RMS as part of the investigation of unresolved item, URI 50-213/97-02 02.

On August 13,1997, during review of tha UFSAR/TS requirements, the licensee identified a discrepancy involving the channel functional test relative to the table notation [ Tables 4.3 7, Radioactive Liquid Effluent RMS; and 4.3-8, Radioactive Gaseous Effluent RMS) of the TS and the 1S definition. Tables 4.3-7 and 4.3 8 of the TS requires the performance of a quarterly channel functional test for the subject effluont RMS channels. This maarterly requirement refers to the channel functional test as an Analog Chann.. Werational Test (ACOT) in the Table Notations. The notation described that the ACOT shall also demonstrate that control room alarm annunciation occurs if any of the following conditions exist:

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Instrument indicates measured level above the alarm / trip setpoint; 2.

Instrument indicates a downsca;e failure or circuit failure; and 3.

Instrument controls not set in operate mode.

However, Section 1.2 of the TS defines that "An ACOT shall be the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITY of alarm, interlock and/or trip functions. The ACOT shallinclude adjustments, as necessary, of the alarm, interlock and/or Trip Setpoints such that the Setpoints are within the required range and accuracy." The licensee did not use a simulated signal to perform the ACOT as described in Section 1.2 of the TS. The setpoints were lowered to the point below the current detected levels to actuate the sub%ct ularms and verify operability, but the installed detectors were utilized in lieu of a simulated signal. Subsequently, the licensee initiated an Adverse Cor iition

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Report to establah corrective actions and track deposition of this item.

The inspector was informed that the review of the UFSAR/TS was ongoing. As a result of this review, the licensee committed to update the UFSAR/TS as appropriate by September 30,1997. Accordingly, the licensee submitted the

"Defueling TS" change to NRR. The inspector reviewed the Defueling TS with respect to the RMS. The final updated UFSAR, with associated documentation, was reviewed during the inspection conducted on October 6 9,1997. The inspector did not identify any discrepancies with the Defueling TS or UFSAR.

The licensee was requested by the NRC to evaluate the impact of any potential inaccuracy on past operation by comparing past surveillance results with the results obtained using new calibrction sources and improved procedures. An independent historical operability assessment was performed by a contractor. The contractor identified several weaknesses which resulted in reduced sensitivities and increased the uncertainties for effluent RMS over the years. Although these weaknesses existed, the calibration data suggested that all effluent monitors reviewed were adequate to preclude the release of a significant amount of radioactive material, with the exception of R-22, the waste test tank monitor. This monitor had several significant weaknesses which affected the operability and accuracy of the monitor for many years. Notwithstanding, the inspector noted that the final discharge water was monitored by the radioact ve liquid effluent radiation monitor (R-18),

i downstream of R-22. The NRC concluded that no violation of regulatory requiremen" e ccurred.

Root Cause Evaluation The licensee submitted the root cause evaluation results of the previously identified RMS deficiencies to the NRC (Revised Commitments and Corrective Actions dated August 7,1997). The inspector reviewed the root cause evaluation results. The licensee identified that the RMS inaccuracies were introduced during a major revision to calibration procedures which inadvertently changed the calibration methodology end the responsibility (from the Chemistry Group to the l&C Group).

The following causes were identified by the licensee:

inadequate management oversight of the work transition process;

weak engineering input during procedure revisions; e

lack of follow-up on previously identified problems with the ScanRad computer; and e

inadequate Plant Operations Review Committee (PORC) review of the procedure revisions.

The licensee evaluated the effectiveness of the PROC review process and made improvements through: (1) changes in membership; (2) process changes in the administrative controls; (3) clarification of expectations; and (4) training PORC members in thc associated responsibilities and performance expectation.

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The Oversight Department participated in several elements of the RMS improvements including: (1) review of calibration procedures; (2) review of documentation for calibration source traceability; (3) observation of the work activity; (4) review of system modification documentation and irnplementation; (5) program enhancements; and (6) oversight of engineering input during procedure

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revisions.

The licensee's corrective actions pertaining to the ScanRad Computer were described in Section b.2 of this inspection report.

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Conclusions Tne licensee's corrective actions described in the " Revised Commitments and Corrective Actions" were considered v 'c well conceived and executed. The inspectors made the following conuusw o based on the above reviews arH findings:

Revised calibration procedures contained necessary steps, as recommended

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by Regulatory Guides, ANSI, and EPRI guidance to perform meaningful calibration of the effluent / process RMS;

Calibration results were within the licensee's acceptance criteria and were well defined in the revised calibration procedures; s

Calibration data reduction technique was sufficient to demonstrate the validity and reliability of the RMS;

Subject effluent / process RMS were operable at the time of this inspection;

The licensee commitments for installation of flowmeters and the isokinetic nozzle described in Section b.2 were complete;

The review process for the UFSAR/TS adequacy was appropriate and effective;

The evaluation of the historical calibration results (evaluation for the impact of any potentialinaccuracy on past operation by comparing past surveillance results with the ret.uua obtained using new calibration sources and improved procedures) did not indicate that any significant release occurred as the result of less than optimum instrument sensitivities.

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The licensee performed good root cause evaluations, including improvement of the PORC review process; and

Functions and responsibilities of the Oversight Department appeared appropriate to detect an early sign of the program breakdown or safety focus

neglect.

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Effluent / process radiation monitoring systems (RMS) had been improperly calibrateo because procedural guidance was inadequate: (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 of conversion factors and linearity for the intended monitoring ranges. This was a violation of Section 6.8 of Technical Specification requirements, in accordance with NRC Enforcement Policy, Section Vll.B.2, no additional enforcement action is planned in this matter since the violation was based on events that took place before plant shutdown and escalated enforcement action has already been taken for events of similar nature (i.e., $650,000 civil penaliy on May-12,1997 (NRC Inspection Report Nos. 50 213/96-201;50-213/96-80).

X1 Exit Meeting Summary The inspector presented the inspection results to the licensee at the conclusion of the inspection on August 13, and October 9,1997. The licensee acknowledged the findings.

PARTIAL LIST OF PERSONS CONTACTED Licensee

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G. Bouchard, Services Director

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J. Bourassa, QA Supervisor S. Carnesi, System Engineer

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J. Hasettine, Engineering Director

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S. Herd, Chemistry Manager

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B. van Nieuwenhuise, Chemistry Supervisor

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G. van Noordenner, Licensing Manager

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. R. Mellor, Director Site Operation & Decommissioning

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J. Tarzia, HP/ Chemistry Technical Support NB.C

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W. Raymond, Sr. Resident inspector M. Fairtile, Project Manager, NRR

• Denotes those present at the exit meeting on August 13,1997.

+ Denotes those present at the exit meeting on C ctober 13,1997.

The inspectors also interviewed other licensee personnel.

l ITEMS OPENED, CLOSED, AND DISCUSSED Opened None i

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I Closed (Closed) Anoarent Violation. eel 50-213/97-02-01: Effluent / process radiation monitoring systems (RMS) had been improperly calibrated because.

procedural guidance was inadequate.

(Closed) URI 50 213/97-02 02): The 10 CFR 50.59 implications regarding RMS calibration discrepancies.

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None LIST OF ACRONYMS USED ODCM Offsite Dose Calculation Manual NRR Nuclear Reactor Regulation RMS Radiation Monitoring System UFSAR Updated Final Safety Analysis Report TS Technical Specifications EPRI Electric Power Research Institute ANSI American National Standards institute I

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