IR 05000245/1986008
| ML20198E399 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/16/1986 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198E390 | List: |
| References | |
| 50-245-86-08, 50-245-86-8, 50-336-86-08, 50-336-86-8, NUDOCS 8605270368 | |
| Download: ML20198E399 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Combined Report Nos.
50-245/86-08; 50-336/86-08
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l Docket Nos.
50-245 and 50-336 l
License Nos.
OPR-21 and OPR-65 Priority Category C
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l Licensee:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101
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Facility Name:
Millstone Nuclear Power Station, Units 1 and 2 Inspection At:
Waterford, Connecticut Inspection Conducted:
April 14-18, 1986 p
Inspector:
)l. O. dd'i hijf96 H. Bic'ehouse, Radiation Specialist date Approved by:
lA.
s'J u < O h $b W. J.V asciak, Chief, Effluents Radiation date Protection Section, ORSS l
Injs ection Summary:
Ins ection on April 14-18, 1986 (Combined Report Nos.
50-245/86-08 and 50-33 6-08 Areas Inspected:
Routine, unannounced inspection of the licensee's liquid and gaseous radioactive waste control program. Areas reviewed included audits, changes, liquid effluents, gaseous effluents, instrumentation, chemistry and air cleaning systems.
Reruits: Within the scope of this review, no violations were noted.
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DETAILS 1.
Persons Contacted 1.1 Northeast Nuclear Energy Company (NNECo)
J. Flannagan, Unit 1 Operations Technician
- J. Heg, Unit 2 Operations Assistant T. Ittellag, Unit 2 Chemistry Supervisor
- J. Kangley, Radiological Services Supervisor J. Parillo, Assistant Engineering Supervisor / Reactor Engineer
- S. Seace, Unit 2 Superintendent
- J. Stetz, Unit 1 Superintendent
- J. Waters, Chemistry Supervisor
- 0. Wilkens, Unit 1 Chemistry Supervisor Other NNECo employees were also contacted or interviewed.
1.2 Northeast Utilities Service Company (NUSCo)
C. Libby, Operations Quality Assurance Supervisor Other NUSCo employees were also contacted or interviewed.
1.3 USNRC T. Rebelowski, Senior Resident Inspector, Units 1 and 2 T. Shediosky, Senior Resident Inspector, Unit 3
- Attended the exit interview on April 18, 1986.
2.
Purpose The purpose of this routine inspection was to review the licensee's Unit 1 and Unit 2 gaseous and liquid radioactive waste (radwaste) control program with respect to the following elements:
Audits
Changes
Effluents
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Instrumentation
Chemistry / Radiochemistry
Air Cleaning Systems
Special emphasis was placed on reviews of procedural and other changes to the licensee's program implementing Amendment No.106 to License No.
OPR-21 (Unit 1) and Amendment 104 to License No. DPR-65 (Unit 2).
The amendments incorporated Radiological Effluent Technical Specifications (RETS) into the licensee's Appendix A Technical Specifications for both units. The amendments took effect on January 1,1986.
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3.
Audits The performance of audits of each unit's activities under the cognizance of the Nuclear Review Board (NRB) is required under Technical Specift-cation 6.5.
In addition, the licensee's quality assurance (QA) program'
under 10 CFR 50, Appendix B, Criterion XVIII, (" Audits") requires periodic, planned audits of all aspects of the QA program. The licensee's perform-ance relative to these requirements was determined by interviews of the Operations QA Supervisor and members of his staff and examination of planned and completed audits of the gaseous and liquid radwaste control program.
Within the scope of this review, no violations were noted. However, audits of the following aspects of the changes to the licensee's Technical Specifications had not been completed:
Unit 1 Technical Specification No. 6.15, " Radiological Effluent Monitoring
and Offsite Dose Calculation Manual (REMODCM)";
Technical Specification No. 6.16, " Radioactive Waste Treatment";
Technical Specification No. 3/4.8A, " Radioactive Liquid Effluent
Instrumentation";
Technical Specification No. 3/4.8B, " Radioactive Gaseous Ef fluent
Monitoring Instrumentation";
Unit 2 Technical Specification 6.15, " Radiological Effluent Monitoring and
Offsite Dose Calculation Manual (REM 00CM)";
Technical Specification 6.16, " Radioactive Waste Treatment";
Technical Specification 3/4.3.9, " Radioactive Liquid Effluent
Monitoring Instrumentation"; and Technical Specification 3/4.3.10, " Radioactive Gaseous Effluent
Monitoring Instrumentation."
At the exit interview on April 18, 1986, the inspector stated that audits of the areas above would be reviewed during a subsequent inspection.
50-245/86-08-01; 50-336/86-08-01 4.
Changes Changes to the licensee's equipment and procedures by Amendment No. 106 to License No. OpR-21 and Amendment No. 104 to License No. OPR-65 were reviewed. Those amendments deleted the respective Appendices B from the two licenses and provided new Appendices A Technical Specifications sections defining limiting conditions for operation and surveillance requirements for radioactive liquid and gaseous effluent monitoring, concentration, dose, treatment of liquid and gaseous wastes and total
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dose. The procedures to be followed and the bases supporting the opera-tion and surveillance requirements were identified in the licensee's Radiological Effluent Monitoring and Offsite Dose Calculation Manual
{REMODCM).
Fifteen revised procedures were reviewed against revised technical specification requirements and discussed with the licensee's Chemistry Supervisor and members of his staff, Instrumentation and Control personnel and Operations personnel.
4.1 Administrative Control Procedures The licensee identifies periodic surveillance tests to be performed, the appropriate test procedures, intervals for test performance and technical specification requirements in two Administrative Control Procedures (ACP):
ACP-QA-9.02A, " Unit 1 Sury tillance Master Test Control List";
and ACP-QA-9.02B, " Unit 2 Surveillance Master Test Control List."
- The inspector noted that the ACP3 had not been revised to include technical specification changes to tne surveillance requirements for radioactive liquid and gaseous effluent monitoring. The approved and controlled revisions to the procedure, (i.e., Revision 11 to ACP-QA-9.02A and Revision 10 to ACP-QA-9.028) still retained references to the deleted Appendix B Technical Specifications.
In response to this observation, the licensee provided a draft revision to ACP-QA-9.02B which appeared to address the deficiencies in Revision 10.
However, a similar draft of ACP-QA-9.02A was not available for review during the inspection.
At the exit interview on April 18, 1986, the inspector stated that revisions to ACP-QA-9.02A and ACP-QA-9.02B would be reviewed during a subsequent inspection.
50-245/86-08-02; 50-336/86-08-02 4.2 Surveillance Procedures Surveillance procedures implementing the following technical speci-
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fications were reviewed relative to Technical Specification No. 6.8,
" Procedures," Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," and 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":
Unit 1 Technical Specification 3/4.8, " Radioactive Materials";
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Technical Specification 3/4.3.3.9, " Radioactive Liquid Effluent
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Monitoring Instrumentation";
Technical Specification 3/4.3.3.10, " Radioactive Gaseous Effluent
- Monitoring Instrumentation"; and Technical Specification 3/4.11, " Radioactive Effluents."
- Within the scope of this review, the following item was noted:
Unit 1 Surveillance Procedures for calibration and functional
testing of the Liquid Radwaste Effluent Line, Service Water j
Effluent Line, Steam Jet Air Ejector (SJAE) Off gas and Main l
Stack Noble Gas Activity monitors referenced incorrect sections i
of the Technical Specifications (following the numbering changes
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inAmendment106).
Portions of the calibration procedures for the SJAE Off gas and Main Stack Noble Gas Activity monitors were contained in routine chemical procedures, (e.g., Chemistry Procedure (CP) 806J, " Stack Gas Sampling and Counting," for obtaining a gas sample, counting it and providing a countrate
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to noble gas concentration calibration factor).
Surveillance
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Procedure (SP)-831, "Radwaste/ Service Water Effluent Radiation
Monitor (Scintillation Detector) Calibration," Revision 2
(4/24/84), was undergoing revision to include calibration with radioactive liquid sources.
SP-836, " Stack Gas Monitoring System Functional Test and Calibration," Revision 4 (10/4/85),
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was undergoing revision to include calibration with radioactive gaseous sources.
SP-406T, " Air Ejector Off gas Isolation Radi-
i ation Monitor Detector Calibration Test," Revision 6 (5/11/83),
was being revised to cover more of the instrument's range. These
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changes to the licensee's Unit 1 Surveillance Procedures will be j
reviewed during a subsequent inspection.
50-245/86-08-03
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4.3 Dose Projection Procedures
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Procedures implementing the following Technical Specifications were i
reviewed for consistency with the licensee's REM 00CM:
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Unit 1
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Technical Specification 3/4.8.C.2, " Liquid Effluents - Dose";
Technical Specification 3/4.8.D.2, " Gaseous Effluents - Dose,
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Noble Gases";
Technical Specification 3/4.8.D.3, " Gaseous Effluents - Dose
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Radiolodines; Radioactive Material in Particulate Form, and
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Radionuclides Other Than Noble Gases";
Technical Specification 3/4.8.0.4, " Radioactive Effluents -
Total Dose";
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Unit 2 Technical Specification 3/4.11.1.2, " Dose, Liquids";
Technical Specification 3/4.11.2, " Gaseous Effluents"; and
Technical Specification 3/4.11.3, " Total Dose."
- Within the scope of this review, no violations were identified. The licensee's procedures for dose projection appeared to be consistent with the REM 0DCM.
5.
Effluents The licensee's gaseous and liquid effluent releases from July 1,1985 through April 15, 1986 were reviewed relative to Appendices B, " Environ-mental Technical Specification" (July 1-December 31, 1985) and amended Appendices A (January 1-April 15, 1986). The licensee's " Semi-annual Radioactive Effluent Release Report (July-December 1985)" was reviewed and discussed with chemistry personnel. The Millstone site was toured to identify release points for both gaseous and liquid effluents.
5.1 Liquid Effluent Releases Unit 1 The activities and isotopic mixes for 44 liquid discharge permits from January 1-April 14,1986 were reviewed relative to Technical Specification 3/4.8.C.1, " Liquid Effluents-Concentrations." Dose projections under Technical Specification 3/4.8.C.2, " Liquid Efflu-ents - Dose," for a 8.466E2 microcurie discharge on February 3,1986 and a 3.238E1 microcurie discharge on February 24, 1986 were reviewed.
Unit 2 The activities and isotopic mixes for 136 liquid discharge permits from January 1-April 14, 1986 were reviewed against requirements in Technical Specification 3/4.11.1, " Liquid Effluents." First Quarter 1986 dose projections based on a total release of 4.32E-1 curies were reviewed relative to Technical Specification 3/4.11.1.2, " Dose, Liquids."
Unmonitored Pathways (Site)
Under licensee's Surveillance Procedure (SP) 821/2821/3821, "Unmoni-tored Liquid Release Paths," Revision 6 (3/11/86), the following release pathways are sampled and analyzed monthly:
Catch basins (1-3, 1-5, 1-7, 1-13, 1-14, 1-22, and 2-9);
NPDES Otscharge No. 006;
Unit 2 Condenser Sump - East;
Unit 2 Condenser Sump - West;
Radwaste Storage Building;
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Refueling Outage Building Yard Drain;
Unit 3 Sewer Manhole No. 14; and
Radwaste Reduction Facility Sump.
- Results of the sampling / analyses for January, February and March 1986 were reviewed.
Within the scope of this review of the licensee's liquid effluent releases, no violations were identified.
5.2 Gaseous Effluent Releases Unit 1 The results of noble gas, radioiodine and radioactive particulate monitoring for the first quarter of 1986 were reviewed relative to Technical Specification 3/4.80, " Radioactive Gaseous Effluents."
Stack gas isotopic analyses, weekly stack iodine measurements and monthly composite particulate analyses were reviewed.
Dose projec-tions for quarterly thyroid and other organ doses based on monitoring results were made and compared with licensee estimates under Techni-cal Specification 3/4.8.D.3, " Gaseous Effluents - Dose Radiciodines, Radioactive Material in Particulate Form, and Radionuclides Other Than Noble Gases."
Unit 2 Batch gaseous releases from the following Waste Gas Discharge Tanks (WGOT) were reviewed relative to Environmental Technical Specifica-tion 2.4, (Appendix B to License No. DPR-65 since replaced by Amendment No. 104):
Discharge WGOT Date Permit No.
"D" November 8, 1985 2050
"D" November 12, 1985 2051
"A" November 19, 1985 2052
"B" November 21, 1985 2053
"C" November 27, 1985 2054 No batch gaseous discharges had been recorded since January 1986.
Radioiodine and radioactive particulate sampling at Unit 2 " stack",
(vent), was reviewed relative to Technical Specification 3/4.11.2.3,
" Dose, Radiotodines, Radioactive Material in Particulate Form, and Radionuclides Other Than Noble Gases." Calculations of projected dose made by the inspector were compared with the licensee's projections for the first quarter 1986.
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Within the scope of this review of the licensee's gaseous effluent releases, no violations were noted.
6.
Instrumentation The licensee's liquid and gaseous process and effluent monitors were reviewed for operability and calibration. Alarm and control setpoint determinations were reviewed for consistency with Technical Specification requirements. Maintenance of the monitors was also reviewed.
6.1 Liquid Monitors Unit 1 The liquid radwaste effluent line and service water effluent line monitors were reviewed against criteria provided in Technical Speci-fication 3/4.8. A, " Radioactive Liquid Effluent Instrumentation."
Instrument checks, calibrations, functional tests and source checks were reviewed for the line monitors.
Flow rate measurement instrumentation was also reviewed.
Within the scope of this review, the following items were noted:
The radwaste effluent line and service water effluent line
monitors were calibrated quarterly during 1985 under SP-831,
"Radwaste/ Service Water Effluent Radiation Monitor (Scintilla-tion Detector) Calibration." The calibrations included the use of cesium-137 sources traceable to NBS in a known, reproducible geometry. The calibration appeared to be acceptable under the amended Technical Specification 3/4.8.A.
The service water effluent line monitor was inoperative
January 21-22, February 10-11, and February 19-21, 1986.
During those periods, the licensee provided grab sampling and analysis of the Reactor Building Service Water effluent.
The acceptance criteria in SP-831 permitted 13/16 inch on a
logarithmic scale recorder readout. As noted during Combined Inspection No. 50-245/83-20; 50-336/83-28, the acceptance criteria allowed an uneven error bracketing on the logarithmic scale readout resulting in an error up to 32% low recorder response.
The licensee was revising SP-831 (see related item in Detail 4.2).
The inspector stated that acceptance criteria in the revised SP-831 would be reviewed in conjunction with review of the licensee's action regarding item 50-245/86-08-03.
Within the scope of this review of the licensee's Unit I liquid effluent monitors, no violations were noted.
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Unit 2 The following liquid effluent monitoring instruments were reviewed against criteria in Technical Specification 3/4.3.3.9, " Radioactive Liquid Effluent Monitoring Instrumentation":
Clean liquid radwaste effluent line monitor;
Aerated liquid radwaste effluent line monitor;
Steam generator blowdown monitor;
Condenser air ejector monitor;
Condensate Polishing Facility waste sump monitor; and
Reactor Building Closed Cooling Water monitor.
- Surveillance test results for the monitors including channel checks, source checks, calibrations and functional tests were reviewed on a sampling basis.
The inspector noted that the Reactor Building Closed Cooling Water monitor was inoperative February 8-13, 1986 and reviewed grab sampling and analysis frequencies and results for that period.
Within the scope of this review of the licensee's Unit 2 liquid ef fluent monitors, no violations were identified.
6.2 Gaseous Effluent Monitors Unit 1 The SJAE Off gas and Main Stack Noble Gas. Activity monitors, and the Main Stack Iodine and Particulate Samplers were reviewed against criteria in Technical Specification 3/4.8.B, " Radioactive Gaseous Effluent Monitoring Instrumentation." Alarm setpoints, instrument checks, calibrations, functional tests and source checks were reviewed. Stack and sampler flow rate instrumentation checks and calibration and sampler flow rate functional tests were also reviewed.
Within the scope of this review, the following items were noted:
The calibration test of the SJAE Off gas monitor did not cover
the monitor's full range. As noted in Detail 4.2, the licensee was revising calibration test procedures to address the concern.
Unit 1 personnel were unable to discuss the full scope of the
monitors' calibration procedures.
Each monitoring channel was calibrated by a series of sequential, overlapping channel steps including functional tests of alarm / trip functions, detector response to solid check sources and isotopic analysis of actual noble gas mixtures on NBS-traceable calibrated gamma spectrometers. However, no one at the site appeared to be fully versed on how the overall calibration was actually accomplishe.
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The licensee's corporate staff appeared to be the only indi-viduals fully cognizant of how Technical Specification 3/4.8.B (i.e., Surveillance Requirement 4.8.B.1)' calibrations were accomplished at Unit 1.
This apparent weakness in the licensee's program was discussed with the licensee and will be reviewed during a subsequent inspection.
50-245/86-08-04 Unit 2 The Unit 2 Stack Noble Gas Activity Monitor, Stack Iodine and Par-ticulate Sampler, Stack Flow Rate Monitor, Stack Sampler Flow Rate Monitor and Waste Gas Holdup System Noble Gas Monitor were reviewed against criteria provided in Technical Specification 3/4.3.3.10,
" Radioactive Gaseous Effluent Monitoring Instrumentation." Alarm setpoints, channel and source checks, channel calibrations and functional tests were reviewed.
Stack and sampler flow rate instrumentation checks and calibrations and sampler flow rate functional tests were also reviewed. The inspector noted that the Unit 1 Main Stack Noble Gas Activity Monitor, Stack Iodine and Par-ticulate Samplers and flow instrumentation were included in Technical Specification 3/4.3.3.10 requirements as well as Unit 1 Technical Speci fication 3/4.8.B.
The Unit 2 Stack (Vent) Noble Gas Activity Monitor was out of service on June 15, 1985, March 13, 1986 and March 17-18, 1986. Vent gas grab sampling and analyses were reviewed for those periods.
Within the scope of this review, no violations were noted.
7.
Chemistry The licensee's chemical and radiochemical analyses of reactor coolant water for both units and secondary water chemistry for Unit 2 were reviewed relative to each unit's technical specifications.
7.1 Unit 1 Chemical and radiochemical analytical records for the Unit's reactor coolant were reviewed against requirements in Technical Specification
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3/4.6.C, " Coolant Chemistry." Results of the following parameter measurements were reviewed from January 1-April 16, 1986:
pH
Conductivity
Dose-equivalent Iodine-131
100/ average Energy (E)
Within the scope of this review, no violations were identifie _.
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7.2 Unit 2
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Chemical and radiochemical analytical records for the Unit's reactor
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coolant and secondary water were reviewed relative to requirements
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in Technical Specification 3/4.4.7, Chemistry," and Technical Speci fication 3/4.4.8, "Speci fic Activity." Records relating to measurements of dissolved oxygen, chloride, fluoride iodine-131, gross radioactivity and average energy (2) dose-equivalent
P E in the primary reactor coolant water and gross radioactivity and dose-equivalent iodine-131 in the secondary water from July 1,1985 through April 16, 1986 were reviewed and discussed with Chemistry personnel,
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j Within the scope of this review, no violations were identified.
8.
Air Cleaning Systems Records of tests of air cleaning systems including the Standby Gas Treat-ment System (SBGT) in Unit 1 and the Enclosure Building Filtration System and Control Room Emergency Ventilation System in Unit 2 were reviewed j
relative to criteria provided in:
Technical Specification 3/4.7.B " Standby Gas Treatment System";
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Technical Specification 3/4.6.5, " Secondary Containment Enclosure
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i Building Filtration System";
Technical Specification 3/4.7.6, " Control Room Emergency Ventilation
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j System"; and ANSI /ASME N510-1980, " Testing of Nuclear Air-Cleaning Systems."
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In place tests of High Efficiency Particulate Activity (HEPA) filters and iodine adsorber units and laboratory tests of activated carbon (including visual inspections, leak tests, flow rate measurements, canister tests, relative humidity and pressure drop measurements) were made by contractors for the Itcensee.
Functional tests by the licensee were also reviewed.
Within the scope of this review, no violations were identified.
9.
Exit Interview
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i The inspector met with the licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on April 18, 1986, and summarized the scope and findings of the inspection. At no time during this inspection was written material provided to the licensee by the
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inspector. No information exempt from disclosure under 10 CFR 2.790 is I
discussed in this report.
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