IR 05000237/1990025
| ML17202U867 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/24/1990 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202U866 | List: |
| References | |
| 50-237-90-25-EC, 50-249-90-24, NUDOCS 9011070280 | |
| Download: ML17202U867 (29) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION II I Report No /90025 (DRP); 50*249/9q024.(DRP}*
Docket No~.
50-237~ 50~249 L ictn ste:. -Commonwea rth *-Edi-son** Compdny Opus West.I II-1400 Opus Place Downers Grove, IL 60515 Fo.cility Ndme:.
Dresden Station - Units 2 and 3 M~~ting At:
- U. S. Nuc.lear Regulatory Commission Region III Office
. Gltn Ellyn, IL 60137*.*
~eeiing Conducted:
October 12, 1990 Typ~ of Meeting:
Enforc~ment tonfeferice
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rnspector:
- . D. E.. Hills Approved By:_,
Meeting. Summary: *
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OCT 2 4 199C Date Meeting on October 12, 1990 (Report Nos. 50-237/90025.(DRP);
50-249/90024 (DRP))*
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Matters Discussed:
Apparent Violatfon of 10 CFR 50.59:
~ailure ~o seek or obtain NRC approval prior to performing a change in the facility as described*
in the Final Safety. Analysis Report *(FSAR) which involved a change in Technical Specifications and an unreviewed safety questio This temporary modification, involving a temporary sample pump connected to the drywell manifold sampling system, was performed on numerous occasions since at least
- 1978.* *When utilized to obtain drywell air-samples, an additional primary containment *leakage of 4.73 percent by weight-of.the cont_pinment air per day 901107*0280 901029 PDR ADOCK 05000237 G *
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PNU
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wriuld have exi$ted if the design basis loss of coolant accident (LOCA) had occurre This exceeded both the Technical Specification allowable prtmary
. containment leakage (lnd nullified the margin of safety as defined in Technical Specification The specific deficienc,y is described in detail in NRC Inspection Reports No. 50-237/90022(DRP) and No *. 50-249/90022(D~P). *.
Information pertinent to the.causes, significance and-co.rrective acti.ons were
. discussed. *Disposition of the apparent violations will be presented in subsequent communi cat i_ons*.
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DETAILS Enforcement Confererice Attendees Commonwealth Edison Company (CECo)
D. G~lle, Vi~e-Pre~ident, BWR Operations L. DelGeorge, Assistant Vice President, Engineering and Construction G. Wagner, Nuclear Engineering-Mdnager T. tovach~ Nuclear Lit~hsi~g Manager M. Richter, Nucl~ar Licensing Administrator E. Eenigenburg, Station Manager -
L. Gerner, Technical Superintendent H. Massin, BWR Systems Design Superintendent K. Peterman, Regulatory Assurance Supervisor K. Brennan, Engineeririg And Constructibn Assurance Supervisor P. Barnes, Compliance Supervisor P. Manning, Desig~ and Cons*truction Program SpeciC:1list
~. Radtke, Compliance Engineer L. Wright, BWR Systems De5ign Engineer Sidley and Austin S. Trubatch, ~ttorney NUS *corporation D;- Studley, System Eri'gineer U. S. Nuclear Regulatory Commission (U.S. N-RC)
C. Paperiello, Deputy Regional Administrator, Region III w. Forney, Deputy Director, Division of Reactor Projects, Region III C. Pederson, Director, Enforcement and Investigation Coordinator Staff,
-Region III _
J. Hinds, Chief, Projetts Section 18, Region III S. Du Pont, Senior Resident Ins~ector, Re~ion III Hill~, Resident Inspector, Region III P. Lougheed, Enforcement Specialist, Region III R~ Lerch, Project Engineer, Region III M. Kunowski, Senior Radiation Specialist, Regton III J. Monninger, Project Engineer, Region III R. Pederson, Office of Enforcement, Nuclear Reactor Regulation HQS L. Olshdn, Project Manager, NucleC:1r Reactor Regulatio~ HQS
- By te 1 ephoni:
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Enforcement Conference As a result of the apparent_ violation of NRC requirements, an Enforcement Conference was held at the Region Ill Office in Glen Ellyn, Illinois, on October 12, 1990~ The preliminary findings which were the bases for thes~ apparent violation~ of NRC requirements were documented in NRC Inspection Reports N ~237/90022(DRP) and 50-249/90022(DRP).
The attendeei of this enforcement* conference are denoted in Paragt~ph l:of-this repor ____
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In opening the conference, the NRC stated the purpose of ttie conference, presented a brief description of the apparent violation-, and summarized the inspection finding (See Attachment 1)
The licensee did not *.-
contest the information presented_ by the NR The purposes of the-conference were:
(1) to discuss the apparent viol~tions,.th~
significance, cause, and the licensee's corrective actions; (2) to
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determine whether there were any mitigating circumstances; and* (3) to*
obtain other itiformation which would help det~rmine th~ appro~riate enforcement actiOr The licensee* was requested by the NRC to disclJSS the -
following:.
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. The temporary_ sample pump issue roof caus~- and related corrective actions status.. *
Any actions being taken to ensure 10 CFR 50.59 safety evaluation reflect the current plant licensing basi Contiols to ensure that ~dministra~ive prog~am~hanges are implemented-for previously existing prattice~. *
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The* licensee presented.th£;? results of their review concerning the apparent violation and presented their ~nalysis of the discus~ion *
topi In their analysis, the licensee described the corrective actions initiated to preclude repetition of the apparent violatio These included actions to ensure that changes in the_ facility _which required prior NRC approval were not made prior to obtaining th~t
~pproval. (See Attachment 2)
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- co-nclusion *
The e~aluation ind disposition of the apparent violations will be presented in subsequent communications.
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- PURPOSE OF MEETING ATTACHMENT 1 DRESDEN 2 & 3 ENFORCEMENT CONFERENCE OCTOBER.12, 1990
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Carl Paperiello A.*
Review the Issues Involved ii1 -the Use of a Temporary Pump for*
Conto.inmtr1t Sampling which Provide:d an Unattended Leak.Path froin *
Containmen Discuss the Concerns A~soci~ted with this lssu Review the Circumstances Surrounding the Issue and the Associated Violatio *Rt:view and Discuss.the Licensee's Perspective and.Corrective Actipn * 1 INTRODUCTION -OF NRC SIAFF
.. 111. NRC CONCERNS*
Carl Pdp_eriello,.Deputy Regiona Administrato William Forney, Deputy Director*,
Division of Reactor Project~ LaCk of. a lOCFR 50.59 Review for an Unreviewed Safety Questio Lack of Licen~ing Basis Documentation.on Site that is Essential fo~
Making _Safety Evaluations.. Application of Administrative Program.Changes to Existing Practice I SUMMARY OF FINDINGS *
David Hills, Resident Inspector LICENSEE'S PRESENTATION AND DISCUSSION VI~
CLOSING REMARKS Carl Paperiello
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ATTACHMENT 2
.. OCTOBER 12, 1990 *
DRESDEN ENFORCEMENT CONFERENCE.
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TEMPORARY MODIFICATION WITHOUT SAFETY EVALUATION AGENDA**
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- * INTRODUCTION D.GALLE
- OVERVIEW
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L.GERNER
. * * SAFETY SIGNIFICANCE H.MASSIN*
- CONCLUSIONS/CORRECTIVE ACTIONS L. GERNER
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- OVERALL CONCLUSIONS D.GALLE
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INTRODUCTION
INTERMITTENT OPERATION OF A PORTABLE SAMPLE PUMP RESULTED -_**
IN EXCEEDING THE TECHNICAL SPECIFICATION LIMIT.FOR.
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- *.. '.* CONTAINMENT. LEAK'RA IB:. -FURTHE-RMORE--'trrfLIZINGt>ESfG N BASIS.
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- ASSUMPTIONS, THERE WAS A REDUCTION IN THE MARGIN OF SAFETY.. *
. P°R:IOR NRC APPROVAL SHOULD HA VE BEEN OBTAINED, OR*TH.
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.* INSTALLATION NEVER MAD * CALCULATIONS, BAS~D ON ACTUAL TEST DATA, SHOW THE SAFETY.
SIGNIFICANCE OF THE PUMP OPERATION WAS MINIMAL. THE PERIODS
. OF TIME 'l'HAT THE "PuMP WAS QPERATED wERE MINIMAL, THEREBY FURTaER REDUCING THE SAFETY SIGNIFICANCE. ' '
- : THE* 10 CFR 50:59 FORMAT USED TO DESCRIBE A PAST SAFETY. *.*
s.1GNIFICANCE ANALYSIS OF rim AS FOUND DEFICIENT CONDITION wAS*. *
INAPPROPRIAT.
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. * - CORRECTIVE ACTIONS TAKEN IN RESPONSE TO THIS EVENT HA VE BEEN
- *PROMPT AND EXTENSIVE TO ENSURE NO OTHER SIMILAR OP_ERATIONS
. EXIST AND THAT CURRENT PROtj~S WOULD NOT ALLOW THE ERRORS.
- .. IDENTIFIED TO REOCCU * * IN PREPARING FOR THE ENFORCEMENT CONFERENCE CECo IDENTIFIED THAT THERE WAS AN FSAR REQUIREMENT FOR A CONTINUOUS AIR MONITOR (CAM). THAT COMMITMENT WAS APPARENTLY OVERLOOKED :
AND HAS NOT BEEN MET SINCE THE EARLY 1980's WHEN THE CAM WAS DISCONNECTED. REVIEWS PERFORMED TO DATE HAVE NOT IDENTIFIED THAT A 10 CFR 50.59 REVIEW HAD BEEN COMPLETE /scl:ID315:2
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SYSTEM BACKGROUND.
- * TECHNICAL SPECIFICATIONS REQUIRE THAT REACTOR COOLANT
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.. SYSTEM LEAKAGE BE CHECKED BY THE SUMP FLOW MONITORING AND
- ** -*AiR 8M\\if,iiNasYsTi:Ms~* 'AiR~sAMi>Lii~friis iiEQffiR:Et>> oNcE PErrnAY~-*.
- . VARIOUS AIR SAMPLING METHODS HAVE BEEN USE * * THE.ORIGINAL PRIMARY METHOD WAS A DAILY ANALYSIS OF..
. FILTERS FROM A CONTINUOUS AIR MONITQR.(CAM) INSTALLED ON THE NON-SAFETY RELATED PRIMARY CONTAINMENT DRYWELL *
MAfllFOLD AIR SAMPLE SYSTEM (SEE FIGURE 1).. USE OF nus.
.. SYSTEM WAS DISCONTINUED AND THE CAM REMOVED IN THE
.**.EARLY 1980~ *
A BACKUP METHOD-WAS THE DRYWELL MANIFOLD AIR SAMPL.... * ~YSTEM WHICH BECAME THE PRIMARY SAMPLING METHOD 'WHEN..
THE CAM WAS DISCONNECTE *
A SECOND BACKUP METHOD WAS A PORTABLE AIR SA.MPI.,E PUMP THAT COULD BE TEMPORARILY CONNECTED TO THE DRYWELL
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MANIFOLD AIR SAMPLE SYSTEM (SEE FIGURE 2). THIS PUMP WAS USED AS EARLY AS 1978~.
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TYP. OF. TYP. OF
ORIGINAL CONSTRUCTION SAMPLING CONFIGURATION WITH CONTINOUS AIR MONITOR ICAMl AUTOMATIC PRIMARY CONT. ISOL. VALVES MANUAL PRIMARY CONT. ISOL. VALVES
- AUTOMATIC PRIMARY CONT. ISOL: VALVES
.ET AIR SAMPLE VACUUM PUMP ORYWELL P -
PARTICULATE FILTER 1 - ' IODINE FILTER
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- FI -. FLOW METER
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TYP. OF
TYP.. OF
11 USED FOR RADE CO>
RAOECO SAMP!-E PUMP OPEH/\\ TJON.
AUTOMATIC PRIMARY
.CONT. *ISOL. VALVES*
MANUAL PRIMARY CONT. ISOL. *VALVES OXYGEN ANALYZER AUTOMATIC PRIMARY CONJ'. ISOL. VALVES RAOECO AIR PUMP ET AIR SAMPLE VACUUM PUMP DRY\\.JELL P -.PARTICULATE FILTER I -
IODINE. FILTER Fl -
FLOW METER
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F 1\\,1 JRF
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OVERVIEW OF EVENT PRE~*
1986 PROCEDURE DAP 7-4 CONTROLLED TEMPORARY ELECTRIC~,
JUMPERS OR LIITED LEADR TEMPORARY MECHANICAL ACTMTIES WERE NOT COVERED BY AN ADMINISTRATIVE PROGRAM OR PROCEDURE. CONNECTION OF THE PUMP (A MECHANICAL ACTIVITY) WOULD NOT HAVE BEEN CONSIDERED FOR EVALUATION.
. * * ~.. ;._AS.A_'fEMPORARY ALTERATION/MODIFICATION TO THE SYSTEM. * *.
OPERATION OF THE PORTABLE SAMPLECPUMP-'GONNEC.~D Tb TH DRYWELL MANIFOLD AIR SAMPLE SYSTEM WAS NOT CONTROLLE BY A FORMAL PROCEDUR PROCEDuRE.DAP 7-4 WAs REVISED. *SPECIFICALLY, A TEMPORARY.
- ALTERAT.ION WAS REDEFINED TO INCLUDE BOTH ELECTRICAL AND.
. *MECHANICAL CHANGES(I.E., JUMPERS, LIF1'ED LEADS, TEMPORARY.
.. BLANK FLANGES,.HOSES OR SPOOL PIECES).
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.A MEMORANDUM WAS ISSUED TO STATION DEPARTMENTS
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INFORMING THEM OF THIS CHANGE AND TO REVIEW FUTURE INSTALLATIONS PER THE REVISED.PROCEDURE..
- * DURING THIS PERIOD OF TIME THE CONTAINMENT AIR SAMPLES WERE BEING DRAWN BY THE INSTALLED VACUUM PUMP.. THE PORTABLE.SAMPLE PUMP WAS NOT INSTALLED DURING IMPLEMENTATION OF THE REVISED TEMPORARY ALTERATION PROCEDUR *
SUB.SEQUEl.'fT PORTABLE PUMP INSTALLATIONS WERE
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PERFORMED BY RADIATION PROTECTION TECHNICIAN$.
DURING THEIR SHIF'TL Y ROUNDS. THESE TECHNICIANS ARE NOT GIVEN TRAINING ON THE TEMPORARY ALTERATION.
PROGRA..
. 5/89 OVERVIEW (continued) *
IN RESPONSE TO AN INPO EVALUATION COMMENT, THE PROCESS FOR SAMPLING THE CONTAINMENT USING A PORTABLE PUMP WAS
. FORMALIZED INTO A NEW STATION PROCEDURE DRP 1350* *
AL THOUGH AN -ADMINISTRATIVE PROCEDURE w AS IN.
PLACE THAT REQUmED.ASAFETY EVALUATION ~E COMPLETED FOR NEW PROCEDURES, ONE WAS NOT *
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PERFORME *
IN DEVELOPING THE DRP 1350-3 PROCEDURE PACKAGE, THE FORM F~R A PROCEDURE REVISION, RATHER THAN*.
A NEW PROCEDURE; WAS COMPLETED. THIS FORM ALLOWED FOR SCREENING THE PROCEDURE TO DETERMINE WHETHER A SAFETY EVALUATION SHO.ULD'
BE PERFORMED. *.THE SCREENING PROCESS DETERMINED THAT NO/SAFETY EVALU~TION WAS
.. REQUIRED FOR THIS PROCEDUR~.
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- OVERVIEW (continued)
6/90 A PROPOSED REVISION TO PROCEDURE DRP 1350-3 WAS IN
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PROCESS. DURING THE TECHNICAL REVIEW IT WAS IDENTIFIED THAT UNATTENDED OPERATION OF THE PORTABLE SAMPLE.PUMP,.
- -~ _-,-WITllJ'f_Q AUTOMATIC ISOLATION CAPABILITY, COULD INCREASE THE PRiMAfiy**coNTAIN°MENT LEAKAGE BEYOND THE TECHNICAL'
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SPECIFICATION LIMI :;...... --
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- *A TEMPORARY PROCEDURE CHANGE WAS IMMEDIATELY IMPLEMENTED THE SAME DAY REQUIRING.THAT A RAP IA TION PROTECTION
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- .. :TECHNICIAN, IN COMMUNICATION WITH THE CONTROL ROOM, BE.IN ATTENDANCE AT THE PORTABLE SAMPLE.
PUMP DURING OPERATION IN ORDER TO CLOSE THE
- .MANUALPRIMARYCONTAINMENTISOLATIONVALVES, **
IF NECESSARY..
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A TEMPORARY SYSTEM ALTERATION WAS PERFORME RELOCATING THE PORTABLE SAMPLE ptJMp TO A
'SAMPLE LINE THAT HAD AUTOMATIC ISOLATION
. CAPABILITY (SEE FIGURE 3). -
- 6/30/90 COMPLETED FOR UNIT 2 WHICH WAS
._. OPERATIN /03/90 COMPLETED-FOR UNIT 3 PRIOR TO STARTU *
TYP. OF
IJ. USED FOR RADECOl TYP. OF
CORRECTED RAOECO SAMPLE PUMP CONFIGURATION AUTOMA l IC PRIMARY CONT. ISOL. VALVES MANUAL PRIMARY CON.T. ISOL. VALVES *
OXYGEN ANALYZER AU TOMA TIC PRIMARY'
CONT. ISOL. VALVES RADECO AIR PUMP*
ETC.'
AIR SAMPLE VACUUM PUMP'
DRYWELL P - PARTICULATE' F IL,TER I -
IODINE FILTER FI -. FLOW METER i
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OVERVIEW (continued)
. 7/90 THE STATION INITIATED A REVIEW OF THE SAFETY SIGNIFICANC OF THE PORTABLE SAMPLE PU'MP INSTALLATION AND OPERATION..
CORPORATE ENGINEERING ASSISTANCE WAS SOUGHT IN ESTABLISHING THE SAFETY SIGNIFICANC ::'.":.-.-.
ONGOING DISCUSSIONS BETWEEN--THE$T~1'!0N.AND THE NRC RESIDENT INSPECTORS FOCUSSED ON WHETHER THE SAMPLE PUMP OPERATION CONSTITUTED AN UNREVIEWED SAFETY QUESTION. THE STATION REQUESTED FROM ENGINEERING A 10 CFR 50.59 EVALUATION OF THE SAMPLE PUMP INSTALLATION. THE
- STATION SUBSEQUENTLY REQUESTED THAT THE EVALUATION BE PERFORMED UTILIZING KNOWN SBGT EFFICIENC.
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. THE ORIGINAL REQUEST FOR A 10 CFR 50.59 EVALUATION FOR THE INSTALLATION HAD BEEN PARTIALLY COMPLETED BUT NEVER
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. REVIEWED AND APPROVED. THIS EVALUATION, TO THE EXTENT IT.
. ~AS CO~LETED, WOULD HAVE LED To THE CONCLUSION THAr...
- THIS PORTABLE PUMP COULD NOT HA VE BEEN INSTALLED UNDER. *
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THE CURRENT TECHNICAL SPECIFICATIONS. *
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. OVERVIEW (continued).*
9/90 THE SAFETY SIGNIFICANCE EVALUATION WAS COMPLETED AND TRANSMITTED TO THE NRC BY A SEPTEMBER 17, 1990 EENIGENBURG 'l'O DUPONT LETIER.. ENCLOSURE 8, THE SAFETY
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. EVALUATION, SPECIFICALLY STATED THAT:
. "THIS SAFETY SIGNIFICANCE EVALUATION IS NOT BEING PERFORMED~TO EVALUATE IF THE CHANGE CAN BE MADE WITHIN THE PRoVisioNs*,oF~io_crR 50.59. THIS SAFETY EVALUATION IS BEING PERFORMED.TCfESTABLISH.. THE PAST. '
SAFETY SIGNIFICANCE OF THE PROCEDURE. THIS DISTINCTION *
IS IMPORTANT BECAUSE THE EVALUATION BOUNDS THE.
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CO~SEQUENCES BY CREDITING ACTITAL... SBGTS.:..
EFFICIENCIES IN LIEU OF UTILIZING THE LOWER LIMIT....
ALLOWED BY PLANT TECHNICAL SPECIFICATIONS... "
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. THE CALCULATIONS AND ASSUMPTIONS USED WERE FOR A SAFETY
- SIGNIFICANCE EVALUATION OF WHAT EXISTED UNTIL JUNE 1990 *
liQT A 10.CFR 50~59 SAFETY EVALUATION FOR A CHANGE TO niE *
PLANT SYSTE *
IF WE HAD PERFORMED A 10 CFR 50.59 REVIEW IN SEPTEMBER 1986 OR MAY 1989, DESIGN BASiS ASSUMPI'IONS WOULD HAVE BEEN USED AND A CONCLUSION REACHED THAT AN UNREVIEWED SAFETY QUESTION DID EXIS WE CONFUSED THE APPLICATION OF A 10 CFR 50.59 REVIEW
. FOR PAST ACTMTIES WHEN ACTUAL DATA, AS COMPARED TO.
DESIGN BASIS ASSUMPTIONS, WAS AVA.ll.ABLE. OUR EVALUATION USED CURRENT METHODOLOGIES AND KNOWN..
DATA TO DETERMINE THAT NO UNREVIEWED SAFETY QUESTION HAD EXISTED.*
10/90 ADDITIONAL CALCULATIONS WERE PERFORMED USING THE CONTROL ROOM HABITABILITY (CRH) STUDY AND PLANT OPERATING DATA TO DEFINE THE SAFETY SIGNIFICANCE OF THE SAMPLE PUMP OPERATION WITH RESPECT TO THESE ASSUMPTION....
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SAFETY SIGNIFICANCE
- CONTROL ROOM, SITE BOUNDARYAND LOW POPULATION ZONE (LYl).
DOSES WERE CALCULATE.
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- . CALCULATI.ONS WERE PERFORMED USING CURRENTLY ACCEPTED.
- _METHODOLOGIES (I~E. REGULATORY GUIDE 1.3 AND STANDARD REVIEW PLAN SECTION 6.5:.5) AND*KNowN STATION OPERATING DAT *. THE SAFETY SIGNIFICANCE OF ESSENTIALLY EL'INATING.THE
- ., -NON-SAFETYRELATED FISSION PRODUCT BARRIER WAS MITIGATED B ' - ACTUAL SBGTS FILTER EFFICIENC * *'THE RESULTS.INDICATE THAT DOSES, WHICH RESULT FROM A DESIGN*
. BASIS LOCA CONCµRRENT WITH sAMJ>L~.PUMP OPERATION, ARE SIGNIFICANTLY BELOW GDC-19 AND iO CFR 100 LIMIT /scl:ID315:9
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SAFETY SIGNIFICANCE (continued)
CASE 1: FOR CONTROL ROOM HABITABILITY USING DESIGN BASIS. *
METHODOLOGIES AND ACTUAL SBGTS EFFICIENCY, GDC 19 LIMITS.
ARE NOT EXCEEDE CASE 2: FOR THE SITE BOUNDARY AND LPZ USING DESIGN BASIS METHODOLOGIES ANI> ACTUAL SBGTS EFFICIENCY, 10 CFR 100 LIMITS ARE NOT EXCEEDE CASE 3: FOR CONTROL ROOM HABITABILITY USING DESIGN.BASIS
. METHODQLOGIES AND TECH SPEC SBGTS _EFFICIENCY, THE 9DC 19.
LIMIT FOR THYROID DOSE IS EXCEEDED.. THE OTHER.DOSES ARE
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. BELOW GDc* 19 LIMIT CASE*4:: FOR THE SITE BOUNDARY AND°LPZ USING DESIGN BASIS METHODOLOGIES AND TECH SPEC SBGTS EFFICIENCY, THE 30 DAY THYROID DOSE AT THE LPZ IS EXCEEDED. THE. OTHER DOSES ARE
- BELOW 10CFR100 LIMIT /scl:ID316:10
SAFETY SIGNIFICANCE Ccontmued) *
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CASE I - CONTROL ROOM BABITABU,ITY THYROID <REM> *. SKIN <BEM> wB <REMl
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GDC*l9 LIMIT..
30
CONTROL RM *oosE 2.6" 0.6 '
CONTROL RM DOSE W/SRP 6...6 0.62
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INPUT PARAMETERS
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. CONTAINMENT LEAKAGE@ 1.6%/DAY FOR 30 DAYS (5/ll/83 SER)
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SAMPLE LEAKAGE'@ 4. 73%/DA y DECA YIN a CFSAR)'
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- .. HOLD*uP OF ACTIVITY IN SECONDARY (5/li/83 SER).
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- * 97.8% SBGTS EFFICIENCY (TEST RESULTS)
.263 CFM UNFILTERED INLEAKAGE (REANALYSIS, FSAR) *,
- * * 40 MINUTE ISOLATION (RE.ANALYSIS, FSAR) *
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SAFETY SIGNIFICANCE (continued>
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CASE ll * SITE BOUNDARY AND LOW POPULATION ZONE THYROID <REMl WB <REM>.
10 CFR 100 LIMIT 300
. 25 SITE BOl]NDARY DOSE 2.7 SITE BOUNDARY DOSE.7 W/SRP6. '..
LOW POPULATION ZONE DOSE. 104.. *
9.4.
LOW POPULATION ZONE DOSE 24*
' W/SRP 6.5.5.
INPUT PARAMETERS
CONTAINMENT LEAKAGE @.2.0%/DAY FOR 30 DAYS (1982 SEP)
NO HOLD-UP OF ACTMTY IN SECONDARY (1982 SEP)
- . SAMPLE LEAKAGE AT 4. 73%/DAY DECAYING (FSAR)
97.8% SBGTS EFFICIENCY (TEST RESULTS)
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SAFETY SIGNIFICANCE (continued>
CASE m - ~ONTROL ROOM HABITABD,ITY
- THYROID <REM>
SKIN <BE Ml WB <REM>.
.. GDC-19 LIMIT
30
CONTROL RM DOSE
- 6.6 0.62
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INPUT PARAMETERS **
SAME AS CASE*I, EXCEPT USED SBGTS EFFICIENCY OF 90% (TECHNICAL
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SPECIFICATION VALUE)
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. SAFETY SIGNIFICANCE (continued)
CASE IV* SITE BOUNDARY ANJ> LOW POPULATION THYROID <REM>
WB <REM>.
10 CFR 100 LIMIT 300
SITE BOUNDARY DOSE..
11.7
- LOW POPULATION ZONE 474. INPUT PARAMETERS SAME AS CASE II, EXCEPT USED SBGTS EFFICIENCY OF 90% (TECHNiCAL
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SPECIFICATION VALUE)
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CONCLUSIONS
- * ADMINISTRATIVE CONTROLS OF MECHANICAL TEMPORARY *
ALTERATIONS WERE ESTABLISHED IN 1986. ALTHOUGH NOT*INSTALLED AT THE TIME, SUBSEQUENT iNSTALLATION* OF THE PORTABLE PUMP WAS PERFORMED BY TECHNICIANS NOT TRAINED ON THE TEMPORARY*..
. ALTERATION PROGRAM. ADDITIONALLY, DUE TO ITS LONGSTANDING
. PRES~NCE, THE PORTABLE AIR SAMPLE PUMP WAS NOT RECOGNIZED AS A TEMPORARY ALTERATION AND NO SAFETY EVALUATION WAS PERFORME.
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- IN DEVELOPING A PROCEDURE PACKAGE TO FORMALIZE OPERATION OF THE. PORTABLE~ SAMPLER, PROPER STEPS IN AN ADMINISTRATIVE
- PROCEDURE WERE NOT FOLLOWED. AS A RESULT, NO SAFETY*
. *:.EVALUATION WAS PERFORME *. **, HAI) THE SAMPLE PUMP INSTALUTION BEEN RECOGNIZED AS A
- , 'TEMPORARYALTERATION.PRIOR TO JUNE 1990., THE NEED FOR PRIO : :NRC'APPROV AL WOULD HA VE BEEN RECOGNizED AlID AN ALTERNAT~
SAMPLING PROCESS WOULD HAVE BEEN ADOPTE *. ALTHOUGH WRITl'EN IN A CECo lO CFR 50.59 FORMAT, THE S~r.
SIGNIFICANCE EVALUATION PERFORMED WAS NOT INTENDED TO BE io* *
CFR 50.59 EVALUATION FOR A PLANT SYSTEM.CHANGE.
. *DURING DEVELOPMENT OF THE SAFETY Sl(JNIFICANCE *
EVALUATION AND THE 10 CFR 50.59 EVALUATION CECo ERRONEOUSLY USED THE TE*RM UNREVIEWED SAFETY QUESTION *
TO ADDRESS SAFETY SIGNIFICANCE.
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.CONCLUSIONS (continued)
- DETAILED DOSE CALCULATIONS USING CURRENTLY ACCEPTED METHODOLOGIES AND OPERATIONAL DATA DEMONSTRATE THAT THE SAFETY SIGNIFICANCE OF THE PORTABLE SAMPLE PUMP OPERATION
- WAS WITHiN THE BOUNDS OF GDC 19 AND 10 CFR 100 LIMIT * THE CONTINUOUS AIR MONITOR SHOULD NOT HA VE BEEN DISCONNECTED FROM THE DRYWELL MANIFOLD AIR SAMPLING SYSTEM IF NO SAFETY EVALUATION WAS PERFORMED..
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-~
- CORRECTIVE ACTIONS COMPLETED -
UPON IDENTIFICATION, A TEMPORARY PROCEDURE CHANGE WAS MADE TO REQUIRE THAT A RADIATION PROTECTION TECHNICIAN REMAIN AT _
- THE SAMPLE PUMP AND IN COMMUNICATION WITH THE CONTROL ROOM DURING THE SAMPLING PROCESS TO PROVIDE A MEANS TO
_ I~OLATE TIIE SAMPLE LINE QUICKLY, IF REQUIR.E *
A TEMPORARY ALTERATION WAS MADE TO DRAW THE SAMPLE_
__ THROUGH A LINE WHICH CONTAINED AUTOMATIC ISOLATION. _ -
'
- - THE 10 CFR 50.59 SAFETY EV ALUATIQN PROCEDURE CDAP 10-02) HAD * :
BEEN REVISED'IN JANUARY 1990 TO PROVIDE MORE DEFINITIVE
- *
GUIDANCE ON _THE PERFORMANCE OF 10 -CFR 50.59 SCREENING AND 10
_ CFR 50.59 SAFETY EVALUATION *
OTHER CHEMISTRY AND RAD PROTECTION PROCEDURES AND -
--- - SURVEILLANCES WERE EXAMINED TO IDENTIFY IF ADDITIONAL CONTAINMENT 1NraGRITY VIOLATIONS EXISTED. NO ADDITIONAL
.
',
.
.
-_VIOLATIONS OF INTEGRITY WERE IDENTIFIE *
NEW CHEMISTRY AND RAD PROTECTION PROCEDURES THAT COULD HAVE BEEN ERRONEOUSLY SCREENED OUT OF A 10 CFR 50,:69
. EVALUATION WERE REVIEWED. THE REVIEWED PROCEDURES WERE _
-VERIFIED TO HAYE THE-REQUIRED 10 CFR 50.59 EVALUATIO * THE INSTALLATION AND OPERATION OF THE CONTAINMENT SAMPLING
'
'
_SYSTEM WAS REVIEWED AT QUAD CiTIES STATION. NO PORTABLE SAMPLE PUMP IS USED AT QUAD CITIES FOR CONTAINMENT SAMPLING.
/scl:ID315:17
- .
'\\
~~~ *-*
- ..
...
CORRECTIVE ACTIONS (continued)
IN PROGRESS
- . NUCLEAR OPERATIONS DIRECTIVE NOD-TS.11 "10 CFR 50.59 SAFETY EVALU~TION PROCESS" HAS BEEN APPROVED AND WAS ISSUED TO THE STATIONS ON OCTOBER 9, 1990.. IMPLEMENTATION OF THE DIRECTIVE
.. BY BOTH CORPORATE AND STATION ORGANIZATIONS WILL BEGIN.
JANUARY 1, 199 *
ENHANCED TRAINING OF ENGINEERING PERSONNEL FOR IMPLEMENTATION OF NOD-TS.11 WILL BE PROVIDED ON AN EXPEDITED BASIS, EXPECTED TO BE COMPLETED BY*.
- DECEMBER 31, 1990..
A DISCUSSION OF THIS EVENT WIL~ BE INCLUDED IN THE TRAINING
. *PROGRAM FOR IMPLEMENTATION OF NOD-TS:1 *
ENGINEERING WILL PERFORM A ROOT CAUSE EVALUATION OF RECENT.
NRC VIOLATIONS RELATED TO PERFORMANCE OF 10 CFR 50.59 EVALUATIONS IN ORDER TO CONFIRM. OUR BELIEF THAT.THE NEW NOD.
. *. TS.11 ADDRESSES THOSE *coNCERNS. COMPLETION IS EXPECTED BY
.
'
..
.
.
..
.
. DECEMBER 31, 199Q. *.
- A SAMPLE OF MORE 'fHAN 200 NEW STATION PROCEDURES IS BEING
.
.
REVIEWED TO VERIFY THAT THE ArPROPRIATE EVALUATIONS WERE
.
.
.
.
.
PERFORMED. THIS REVIEW WILL BE COMPLETED BY OCTOBER 15, 199 APPROPRIATE ACTIONS WILL BE TAKEN AS NECESSAR /ecl:ID315:18
...
.. ~..
- CORRECTIVE ACTIONS (continued)
IN PROGRESS
THE CHECKLIST FOR INITIATING NEW PROCEDURES OR REVISING PROCEDURES WILL BE ENHANCED TO INCLUDE A VERIFICATION THAT THE APPROPRIATE PAPERWORK IS INCLUDED IN THE PROCEDURE
- PACKAGE PRIOR TO ONSITE REVIEW, THIS WILL BE COMPLETED BY DECEMBER 1, 199.
.
- THE ONGOING TRAINING PROGRAM FOR STATION PERSONNEL IS BEING.*
- EV ALU~TED TO IDENTIFY THOSE INDMDUALS WHO MAY REQtJIRE....
~ING ON THE TEMPORARY ALTERATION PROGRAM. THIS REVIEW * -
WILL BE COMPLETED BY DECEMBER 1, 1990 AND APP~OPRIATE*:
CHANGES-MADE TO THE ONGOING TRAINING PR()GRAM.BY-JAfWARY 31, 199..,.
-
- _PROCEDURE DOS 010-6 PROVIDES FOR A QUARTERLY INSPECTION FOR
.**
UNAUTHORIZED AL'rERATiONS IN AREAS OF HIGH ACTMTIES. THESE *.
AREAS ARE DETERMINED BY THE OPERATING ENGINEER._ THE EXTENT.
TO WHiCH AREAS OF THE PLANT ARE INSPECTED WILL BE. REVIEWE THIS REVIEW AND ANY NECESSARY PROCEDURE CHANGE WILL B COMPLETED BY DECEMBER 1, 199.
.
.
...
.
.
.
.
'
- AN EXPANDED WALKDOWN WILL BE PERFORMED TO INSPECT FOR...
UNAUTHORIZED ALTERATIONS. SPECIFIC PLANT AREAS WILL BE TARGETED (I.E. PROCESS SAMPLING).. THIS INSPECTION PLAN WILL BE.
DEVELOPED AND W ALKDOWNS wiLL BEGIN BY JANUARY:* 1, 199 * AN ENGINEERING EVALUATION OF THE CONTAINMENT AIR SAMPLE -. *
SYSTEM IS ONGOING. ONE RECOMMENDATION FROM THIS EVALUATION, TO IMMEDIATELY REINSTALL THE CAM, WAS COMPLETED ON OCTOBER 12, 1990. THE COMPLETED EVALUATION AND PROPOSED ACTIONS WILL BE PROVIDED TO THE STATION BY OCTOBER 31, 1990. -. *
/scl:ID315:19
.
.
ci,
..
'. j'
-
CORRECTIVE ACTIONS (continued)
IN PROGRESS *..
- MEASURES ARE PLANNED OR IN PLACE TO ADDRESS THE LIMITATION'
.
.
OF THE UFSAR WHE,N PERFORMING DESIGN CHANGE ACTMTIES THE CORRECTIVE ACTIONS CITED ABOVE (*)
-
- NOD-TS.ll ON.10 CFR 50.59 EVALUATIONS (PLANNED)
. COVERS ALL CHANGE.MECHANISMS (PROCEDURE CHANGES, TEMPORARY ALTERATIONS, SETPOINT CHANGES, ETC.) WHICH COULD REQUIRE EVALUATION * * PROVIDES-IMPROVED SCREENING CRITERIA TO*DETERMINE
-
.
.
.
.
WHICH ACTMTIES"REQUIRE EVALUATIO : *
SOME CHANGES WILL ALWAYS.RECEIVE AN EVALUATION REGARDLE.SS OF COVERAGE IN THE UFSA *
EVALUATION REQUIRES AN ANALYSIS OF l:IOW CHANGES *
AFFECT SYSTEM OPERATION AND INTERACTIONS.*
,
.
.
-*
.
..
MANDATORY ELEMENTS OF THE MOD PROCESS (IN PLACE)
DESIGNERS WALKDOWN
..
.
.
.
.
PROJECT PLAN - DOCUMENTS ASSUMPrIONS
STATION OPERATING DEPARTMENT INPUT
ALL SAFETY-RELATED MODS RECEIVE_A 10 CFR 60.69 EVALUATION wffETHER ITEM IS DESCRIBED IN UFSAR OR NOT. *
/ecl:ID315:20.
.,-
...
- '.....
.
.
.
CORRECTIVE ACTIONS (continued)
IN PROGRESS
PROCEDURE ASKS BROAD-BASED QUESTIONS ABOUT ALL *
SAFETY ASPECTS OF MODs
- * 'PROCEDURES AND.TRAINING DIRECT THE EVALUATOR TO
.
.
.
CONSULT ALL APPLICABLE REFERENCES (TECH SPEC BASES, *
FIRE.PROTECTION REPORT, ETC.).
,.
/scl:ID315:21