IR 05000219/1988022

Insp Rept 50-219/88-22 on 880718-22.No Violations Noted. Major Areas Inspected:Gaseous & Liquid Radioactive Effluent Control Programs,Licensee Action on Previous Insp Findings, Effluents,Instrumentation,Audits & Air Cleaning Sys

ML20207G762
Person / Time
Site:	Oyster Creek
Issue date:	08/12/1988
From:	Kottan J, Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207G752	List: IR 05000219/1988022 ML20207G750
References
50-219-88-22, NUDOCS 8808240227
Download: ML20207G762 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-22 Docket N License N DPR-16 Priority --

Category C Licensee: GPU Nuclear Corporation 1 l}pper Pond Road Parsippany, New Jersel 07"A4 Facility Name: Oyster Creek Nucle,. qyny atinq Station Inspection At: Forked River, New versey Inspection Conducted: July 18-22,1938 Inspectors: kmh P. V. O'Cor.nell, RadiatioTipecialist F n- PV date (- //

3X Ka#d%

J. J. Kotta6,"Laboratory Specialist e-tt-u date Approved by: )

~ 1ak, Chipf, Effluents Radiation

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rotection Section  :

Inspection Summary: Inspection on July 18-22,1988 (Report No. 50-219/88-22)

Areas Inspect e_ed: Routine unannounced inspection of the licensee's gaseous and liquid radioactive effluent control programs, and licensee action on previous i inspection findings. Areas reviewed included: licensee action on previous ,

findings, effluents, instrumentation, audits, and air cleaning systems, ,

Results: Of the areas inspected, no violations were identifie l

@808240227 080012 PDR ADOCK 05000219 O PNV

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DETAILS Irdividuals Contacted Princioal Licensee Employees

• K. Barnes. Licensing Engineer

• C. Hager, Senior Engineer, Chemistry /Radwaste

"R. Stoudnour, Senior Engineer, Chemistry

• M. Slobodien, Radiological Controls Director

• R.'Hillaan, Manager, Plant Chemistry

• J. Barton, Deputy Director, Oyster Creek

• R. Barrett, Plant Operations Director

• D. Ranft, Manager, Plant Engineering

• R. Fenti, Manager, QA Mod / Ops

• D. MacFarlane, Si'.e Audit Manager T. Washburn, Radiological Controls B. DeMerchant, Licensing Engineer K. Smith, Supervisor, I&C 0 Perez, Plant Engineer K. Brown, Lead Auditor J. Christian, Lead Auditor P. Thompson, Lead Auditor The inspector also talked with and interviewed other licensee personnel including members of the Plant Material departmen *D2 notes those present at the exit intervie . Licensee Action On Previous Findings (Closed) Inspector Followup Item (219/86-01-01)- Improvements of Post Accident Sampling System (PASS). This item consists of the following subitems: Verify the volumetric delivery of the ball talve for a diluted sample. The licensee compared radiciodine results from a routine reactor water sample to a sample taken using the PASS system in order to verify the volumetric delivery of the ball valve. This data was documented in a memo from the Senior Chemist to the Manager

- Plant Chemistry dated April 16, 1987. This sub-item is closed.

! An appropri.te caution against contact with the needle should be'

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added to the procedure for the drawing of a sample of dissolved ga The licensee has modified Procedure 831.10, Operation of the GE Post-Accident Sampling System, to incorporate this caution. This sub-item is close .

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3 Clearly visible guidance should be provided and described-in the procedure for the positioning of the large cart for undiluted samples. The licensee has modified Procedure 831.10, Operation of the GE Post-Accident Sampling System, to incorporate this suggested guidance. This sub-item is close The indications of the radiation detectors installed adjacent to the liquid sample and particulate / iodine sampling cartridge should be utilized to alert the operator to the collection of high activity samples. Procedure 831.10, Operation of the GE Post-Accident Sampling System, has been modified by the licensee to include this recommendation. This sub-item is close The procedures for the determination of the flow in collection of particulate / iodine samples should be based on the flow through the critical orifice, with an appropriate precaution that the appropriate pressure differential .(approximately 0.5 cfm) is observed. The licensee has' modified Procedure 831.10, Operation of the GE Post-Accident Sampling System, to include the recommendation with the appropriate precaution. This sub-item is close The use of 0 rings between the canisters in the iodine sampling cartridge should be considered unless it can otherwise be demonstrated that bypass leakage cannot occu The licensee ha committed to install the 0 ring Stock initiation data sheet n S002228 was initiated on December 1, 1986 to purchase the 0 ring This item is close (Closed) Inspector Followup Item (219/86-01-02): Improvements in PASS sample anal /ses capability. This item consisted of the following sub-itens: Revise Procedure 824-9 to address the lower limit of detection capabilit This sub-item refers to the analysis of a PASS sample for chloride. The licensee has modified Procedure 824.9 to remove the reference to the lower limit of detection which was apparently a typographical error. This sub-item is close Ensure PASS cask has been maintained in accordance with Quality Assurance Program for transport packages prior to use. The licensee presented to tht inspector documentation indicating that the PASS cask warehouse responsibility was entrusted to Southern Electric Mternational . This documentation also included procedures for and i che results of the 1980 yearly maintenance testing and inspection of the PASS casks. This sub-item is close _ _

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4 Complete site specific core damage estimate procedure Procedure 6430-IMP-1300.33, Core-Damage Estimation,.has been' completed and was approved on August 29, 1986. This sub-item is close A defined calibration and maintenance schedule should be devise The licensee has placed the PASS operating procedure on the Master Surveillance Schedule to ensure the system is checked for operability at least once per yea If the system is' inoperable, any required maintenance will be performed. In addition three radiation monitors and two pressure elements / switches have been:

added to the routine surveillance schedule for annual calibration This sub-item is close A spare parts inventory should be documented. -The inspector reviewed a six page list of spare parts available for the PASS at the site. The list was provided by the spare parts engineering supervisor. This sub-item is close The basis for the alarm and warning set points of the PASS radiation monitors should be documented. 'Also, the procedures for the PASS should specify that the operator observe that they are operational when the PASS is initially energized. The licensee has modified Proc u re 831.10, Operati of the GE Post-Accident Sampling System, to incorporate the above .ommendation. In addition, Field Questionnaire No. C025792 scuments the alarm and warning set points of the PASS radiatio onitor This sub-item is closed.

< To aid operators, the proper indications of the lights on the PASS control panel logic diagrams should be called to the operator's attention at appropriate procedural steps where they should be energized and de-energized. The licensee has modified Procedure 831.10, Operation of the GE Post-Accident Sampling System,-to incorporate the above reccamendation. This sub-item is close (0 pen) Inspector Followup Item (219/86-01-03): Improvements to high range noble gas monitoring system. This item consists of eight sub-items. Sub-items A and G were closed in a previous inspection report (Repo,tNo. 50-219/87-10 performed March 31 -' April 3,1987). Calibration over multiple decades using transfer sources of varying energy should be performed. The results should-be incorporated into the dose assessment function. The licensee provided documentation of calibration of the stack noble gas monitor (RAGMS) indicating that the Xe-133 respose is lower than that of other noble gases in the effluent steam by a factor of 2.4 This sub-item is close '

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5 A low range capability should be installed on the turbine building'

monitor or it should be demonstrated that it is not required. The installation of this radiation monitor is expected to bn completed by the end of the next refueling outage. Therefore this sub-item remains ope D., The overlap of the high and low range monitors should be demon-strated. The licensee demonstrated the overlap of _the monitors by a factor of 10 as documented on data sheets dated November 18, 1987. This sub-item is close A r.1ethod to deactiviate the low range monitor _ near the upper bound of its dynamic range and to reactivate it when the high range monitor returns to the low end.of its range should be devise Discussions with licensee personnel indicated that this sub-item would be completed concurrently with sub-item C above. Therefore, this item remains ope A study on the effects of othar nearby radiation sources on the response of the low range mor.itor should be made. This sub-item was reviewed during a previous inspection (Report No. 87-10, performed March 31 - April 13, 1987) and was left open pending additional details to be supplied by the licensee. No additional data was supplied during this inspection. Therefore, this sub-item remains ope Routine calibration and maintenance procedures should be provided and training of the cperational personnel be' accomplished, such that normal surveillance of the P.AGEMS will be performed. The licensee has committed to routine calibration and maintenance of the xAGEMS systems upon final completion and installation of the system. This sub-item is close .

(Closed) Inspector Followup Item (219/86-01-04): Required improvements to- 1 plant effluents sampling and analysis capabilities. This item consists of seven sub-items. Sub-items A, B, C, E, F, and G were closed in a ,

previous inspection report (Report No. 50-219/87-10 performed March 31 - I April 3, 1987) leaving only sub-item D ope ! Heat tracing of the sample lines on vital power should be extended to the sample flow paths within the sampling shack. The licensee has extended the vital power heat tracing of the sample lines into the sampling shack. This sub-item is close (Closed) Inspector Followup Item (219/86-01-06): Airborne iodine sampling -i during an accident. This item consists of two sub-items: 1 i

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6 The ability to count the air samples collected should be demonstrate Questions in this area relate to the availability of sufficient counting systems to handle the expected large volume of samples as well as the susceptibility of such systems to being disabled by high ambient radiation fields. The inspectors reviewed documentation dated November 9, 1987 indicating that the licensee has set a limit on the amount of radioactivity on a charcoal cartridge and would not count cartridges above this limit. In addition, the licensee has purchased a shield for the gama spectrometry system located in the training center in order to provide shielding so that samples can be counted in the expected radiation field;. This sub-item is close The exact lines of authority during an accident should be designated, including the mechanisms that would be used to initiate sample collection and the assignment of priorities in counting those samples during an accident. The licensee has ordered air sampling equipment for the TSC, OSC, and ECC. The lead Radiological Controls representative in each center would direct sample collection from that center. This sub-iter.: is close (Closed) Unresolved Item (219/88-09-02): Compliance with Technical Specifications for airborne effluent sampling. The licensee is meeting ;

the Technical Specification requirements with respect to sampling every 48 hot rs when effluent monitors are declared inoperabl (SeeSection 3) This item is close . Effluents The responsibility for control of radioactive effluents from the site rests primarily with the Chemistry Department. Other groups have involvement in this area, such as I&C, which is responsible for process and effluent radiation monitor surveillance testin .1 Gaseous Radioactive Effluents The inspector reviewed the licensee's most recent submittal of the semi-annual effluent release report with respect to gaseous radioactive effluents. The report covered the period July 1 to December 31, 1987. No anomalies in the data were noted. The report appeared to be thorough and complete. In addition the inspector reviewed selected gaseous effluent data for the period January -

June, 1988. The following procedures in this area were also reviewed by the inspector:

820 Operation of the EFFECTS Computer Program 82 RETS Dose Assessment 82 Air Ejector Off Gas: Analysis 82 Stack Gas: Monitor Filter Change 82 Stack Gas: Monitor Filter Analysis

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829.4- Stack Gas:-Noble Gas Collection and Analysis 82 Stack Gas Tritium Analysis 82 A0G Gas: Monitor Filter Change and Analysis 82 A0G Gas: Ventilation' System. Monitoring for Noble Gases 82 A0G Gas: Ventilation Duct Monitor Calibration

,329.11- Turbine Building Ventilation System: Manual Sampling 83 Chemistry Surveillance Test Program 83 Surveillance / Compliance with 40 CFR 190 Off Site Dose Calculation Manual (00CM)

The data and procedures review indicated that the licensee has in place an adequate program for gaseous effluent sampling, analysis, surveillance, and reporting requirement The licensee uses the computer program EFFECTS to perform offsite dose assessment in order to demonstrate compliance with Technical Specification requirements using'0DCM methodology. The inspector using the gaseous effluent data for the period January 1,1988 to June 1,1988 performed hand calculations in order.to verify the dose calculations obtained by the licensee using the EFFECTS software. The results are:

Gamma Air Dose Stack Augmented Offgas Vent Licensee Result 4.5E-2 mrad 1.0E-2 mrad 1 NRC Result 4.4E-2 mrad 1.1E-2 mrad J Child Thyroid for Augmented Offgas Vent (Inhalation)

Licensee Result 5.4E-6 mrem NRC Result 5.7E-6 mrem l

The comparisons indicate good agreement. A review of the licensee's Jose calculations for 1988 to date indicate that the licensee is within Technical Specification Limit i

The inspector toured the facility and inspected the gaseous effluent monitors, selected ventilation systems and gaseous release pathways, and effluent monitor displays in the control room including the current monitor conversion factors. Presently the licensee is taking grab samples once every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> at the Turbine Building Vent due to the lack of an effluent radiation monitor at the location. The licensee stated ;

that the monitor would be installed during the next refueling outage. No '

violations were identified in this are .2 Liquid Radioactive Effluents The inspector reviewed the licensee's most recent submittal of the semi-annual effluent release report with respect to liquid radioactive effluents. The report covered the period July 1 to

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December 31, 1987.- No anomalies in the data were noted. .The report-appeared to be thorough and complete in this arer. In reviewing current data the inspector noted that no radioactive liquid releases had been made from the site for the period January 1 1 May 31, 1988. The following procedures in this area were also reviewed by the inspector:

82 Radiochemical Instrumentation: Liquid Radiation Monitoring 83 Radwaste System: Liquid Sampling 83 Radwaste System: Liquid Analysis and Disposition The data and procedures review-indicated that the licensee has in place an adequate program for liquid effluent sampling, analysis, surveillance and reporting requirements. The licensee is attempting to minimize routine liquid radioactive waste releases from the sit No routine liquid releases were-made during the third quarter of 1987 and, as noted above, no routine releases have been made through Ma for the year 1988. This is a noted strength of the licensee's progra The inspector noted that the licensee was effectively implementing the ODCM methodology for controlling ef fluent releases from the site, including trending of offsite doses and dose rate . Instrumentation The inspector toured the facility and examined the licensee's effluent radiation monitoring systems. Currently the liquid radwaste effluent monitor, the reactor building service water effident line monitor, and the turbine building ventilation monitor are not in service and are being operated under Tecnnical Specifications conditions which permit grab or additional sampling to meet the Technical Specification requirements. The licensee stated that the reactor building service water effluent line monitor and the turbine building ventilation noble gas monitor would be operable at the completion of the next refueling outag The inspector also reviewed the following procedures with respect to Technical Specification requirements for radioactive effluent and process radiation monitor checks, calibrations, and functional tests:

621.3.002 AE0G Radiation Monitor Test 621.3.003 Main Steam Line Radiation Monitor Test and Calibration 621.3.004 Process Radiation Monitors Test 621.3.009 MSL Radiation Monitor Front Panel Calibration 621.3.019 ARM / Process Radiation Monitoring Front Panel Test 621.3.021 A0G Ventilation Radiation Monitoring System Channel -

Calibration 621.4.006 Stack Gas Radiation Monitor Front Panel Test 621.4.008 Main Steam Line Radiation Monitor Front Panel Test

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9-The inspector reviewed in detail the checks, calibrations, and functional tests of the main steam line and stack noble gas radiation monitors performed in 1987 and 1988 to date. The licensee is meeting the Technical Specification requirements with respect to these monitors and, in fact, is performing many of the surveillance tests more frequently than required by the Technic 1 Specification The inspector also reviewed the determination of the stack noble' gas conversion factor in which an actual stack gas sample is used to determine the effluent radiation monitor release rate. In addition the inspector reviewed selected effluent radiation monitor alarm set point These set points were determined in accordance with the methodolog specified in the ODCM. The inspector had no further questions in this are . Audits The inspector reviewed Quality Assurance audits of the gaseous and liquid radioactive effluent areas. The Technical Specifications require a audit of conformance to Technical Specification requirements at least once per 12 months and the ODCM and implementing procedures at least once per 24 months. The following audits of the chemistry department were reviewed:

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Audit No. S-0C-86-10 performed 8-1-86 to 10-17-86

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Audit No. S-0C-87-08 performed 7-13-87 to 10-7-87 These audits included the gaseous and liquid radioactive effluents areas. The ODCM has yet to be completely audited, although parts of the ODCM have been included in audits of the chemistry and radiological environmental monitoring areas. Discussions with. licensee personnel indicated that auditors were aware of the ODCM contents and bad incorporated various sections of the ODCM-into planned future audits, The inspector noted that the ODCM had not yet been in use for two year The inspector reviewed the master audit schedule and it appeared that the licensee would meet the Technical Specification requirements in this are The inspector noted that the audits which were conducted by a lead auditor appeared to be both quite thorough and of sufficient technical depth to adequately assess capabilities and performance-in the areas being audited. However, the inspector discussed with the licensee the inclusion of a technical specialist in the audit. The licensee stated that future audits would include a technicel specialis The inspector also reviewed activities performed by the Operational QA grou Periodic in-depth surveillances of Chemistry Department activities are performed by this group. Again, these Operational QA activities appeared to be quite good and of excellent technical depth, and were conducted by an individual with technical expertise in this are . -

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The' inspector had no further questions in this are . Air Cleaning Systems The inspector reviewed the licensee's surveillance tests of the Standby

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Gas Treatment System (SGTS) with respect to Technical Specification requirements. The following procedures were. reviewed: ,

651.1.006 Standby Gas Treatment System - Charcoal Filter Radioactive Monthly Iodide Removal Efficiency. Test 651.3.002 SGTS Particulate Filter In-Place-Leak Test 651.3.003 SGTS Charcoal Filter In-Place Leak' Test In addition data from previous tests performed in.1986, 1987 and-1988 to date of the SGTS were reviewed. The procedure and data review indicated that the licensee is meeting the testing frequencies required by the Technical Specifications and the tests are being performed in accordance with the appropriate ANSI and ASTM standard The inspector noted that the licensee is now using single point sampling for DOP testing of HEPA filters and freon testing of charcoal adsorber Previously the licensee had used multipoint sampling for the test Discussions with the licensee indicated that an aerosol mixing uniformity test had been performed to permit single point sampling. The inspector reviewed documentation indicating that'the mixing test had been performed in accordance with Section 9 of ANSI-N510-1975, thus permitting single point samplin . Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on July 22, 1988. The inspector summarized the purpose, scope and findings of the inspectio l l

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