IR 05000259/1991001
| ML18033B657 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/19/1991 |
| From: | Decker T, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033B656 | List: |
| References | |
| 50-259-91-01, 50-259-91-1, 50-260-91-01, 50-260-91-1, 50-296-91-01, 50-296-91-1, NUDOCS 9103120322 | |
| Download: ML18033B657 (16) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
.Report Nos.:
50-259/91-01, 50-260/91-01, and 50-296/91-01 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-259, 50-260, and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility-Name:
Browns Ferry 1, 2, and
Inspection Conducted:
January 14-18, 22-23, and 29, 1991 Inspector:
.
R. Marston Date Signed Accompanied by P.
G. Stoddart Approved by:
T.
R. Decker, Chief Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards Z r7 Date Signed SUMMARY Scope:
This routine, unannounced inspection was in the areas of normal and accident level effluent monitoring instrumentation, the Post Accident Sampling System (PASS),
gaseous effluent cleaning systems, audits of the programs in these areas, and changes to the chemistry and radwaste programs.
Results:
No violations or deviations were identified.
Based on the scope of the
.
inspection, audit and radwaste handling and release programs were adequate.
The Wide Range Gaseous Effluent Radiation Monitor had passed the Post Modification Test (with resulting closure of the associated IFI), but required calibration and functional testing to close out the corresponding TYiI Action Items.
The Post Accident Sampling System (PASS)
was not yet complete.
Completion was estimated to take place on or about the end of January.
Required testing at operating pressure remained to be done.
Successful completion of the construction and operational testing could result in closeout of the IFI and the TYII Action Item.
The Constant Air Yionitor Systems used to measure the effluent from the Refueling Floor Ventilation Exhaust, the Reactor Building Ventilation Exhaust, and the 9103120322 910304 PDR ADOCK 05000259 FDR
Il Turbine. Building Ventilation Exhaust had been installed, calibrated, and functional'ly tested.
The inspector observed that each of the incoming sample lines to 'each of the three units had two right angle bends near the monitor.
It appeared that this might impact the ability to take a representative sample to make an adequate survey of releases.
The licensee provided an analysis of this system that intended to show that adequate sampling could be performed even with such bends in sample lines.
This item was identified as an Unresolved Item (50-259, 260, 296/91-01-01)
pending further review of this analysis by the NR REPORT DETAILS Persons Contacted Licensee Employees J. Bratcher, Operations Mater Processing Yianager
- S. Bugg, Radwaste Group Manager, Radiation Control R. Grumpier, System Engineer (Offgas Treatment System)
D. Curths, Nuclear Chemist H. Goldman, System Engineer (Standby Gas Treatment System)
- D. Gruber, Yiaintenance Program Manager T. Haney, System Engineer (Primary Containment Purge System
- N. Herrell, Plant Operations Yianager H. Hodges, System Engineer (Control Room Emergency Ventilation System)
J.
Johnson, System Engineer (System 90)
- S. NcDaniel, guality Assurance/guality Evaluation Evaluator Yi. Yiorrison, Nuclear Engineer, Compliance Licensing
- L. Nyers, Plant Manager
.
T. Nesmith, System Engineer, Chemistry (PASS)
- J. Sabados, Chemistry Technical Support Supervisor
- P. Salas, Compliance Licensing Supervisor
- K. Schaus, guality Assurance Specialist
- M. Thompson, Technical Support Manager
- J. Mallace, Compliance Engineer, Site Licensing
- 0. Zeringue, Site Director Other licensee employees contacted during this inspection included technicians, operators, security force members, and office personnel.
Nuclear Regulatory Commission M. Bearden, RI E. Christnot, RI
"G. Humphrey, RI K. Ivey, RI
- Attended exit interview Audits (84750)
Technical Specification (TS) 6.5.2.8 states the requirements for the frequencies and subjects of guality Assurance audits.
The inspector discussed the most recent audit conducted with a licensee guality Assurance Specialist to verify compliance and assess quality.
The audit was designated as Audit Report No.
SSA90103, Audit Report of Radiological Environmental and Effluent Monitoring, dated January 18, 1991.
The audit had been conducted from November 19 to December 19, 1990.
The audit had not been published during the week of the onsite part of this inspection, but was discussed with the guality Assurance Specialist,, then was reviewed in
I
the Region II Office upon receipt of a copy in the mail.
The inspector determined that the audit provided a detailed, comprehensive review of the subject programs for Sequoyah, Browns Ferry, and the Western Area Regional Laboratory.
No significant findings were identified for Browns Ferry.
The audit checklist was.
reviewed and showed in detail how the audit was conducted.
No violations or deviations were identified.
Changes to the Programs (84750)
Changes to the licensee's Chemistry and Liquid Radwaste programs were reviewed by the inspectors to assess capability and to evaluate quality.
The inspectors reviewed these programs through discussions with the Chemistry and Environmental Superintendent and the Operations Water Processing Yianager.
The Chemistry and Environmental Superintendent stated that the unit was fully manned with 55 personnel and that authorization had been received to hire three trainees.
The organization had been working on decreasing Offgas Treatment System and Condenser inleakages.
During the period when the CAYiS used for gaseous effluent monitoring where being changed over and checked out, Chemistry and Environmental conducted compensate.ory sampling.
The Operations Mater Processing Manager stated that since the previous inspection in this area, the plant had installed a "steam jenny" to provide steam for periodic cleaning of Floor Drain filters, and that the Laundry Drain system was made operable again.
This system is used for water from the decon showers and the decon cask located on the Refuel Floor.
During the refueling outage in May 1990, the plant started using a body feed system on the condensate filters and on the Waste Collector filters.
Total Organic Carbon (TOC) had caused problems in the Floor Drain system.
The Floor Drain water could not be reused when TOC levels were too high.
The vendor who provided water-to the plants started using a Reverse Osmosis (RO} system to reduce TOC levels.
The licensee had started using methods to reduce groundwater inleakage into the Floor Drain system.
Crews were on site plugging leaks.
The Operations Mater Processing organization consisted of the Yianager, five Unit Operators assigned to the Radwaste Building, six Assistant Unit Operators who had been assigned elsewhere, then were released back to Operations Water Processing, two Assistant Unit Operators assigned to resin and dewatering, one Nuclear Engineer (assigned to Chem Nuclear),
one Assistant Unit Operator assigned to inleakage reduction, one Chemist assigned to monitor trends, records, and maintenance tracking.
The Nanager stated that Floor Drain inleakage was down to seven to seven and one half gallons per minute, with the target to be below 10 gallons per minute.
The changes to the two programs were implemented to improve operations, no adverse effects were noted.
No violations or deviations were identifie Air Cleaning Systems (84750, 84524)
TSs 3/4.7B, 3/4.7E, and 3/4.7.F state operability and surveillance requirements for the Standby Gas Treatment Systems (SBGT), Control Room Emergency Ventilation Systems (CREVS),
and Primary Containment Purge Systems (PCPs),
respectively.
The inspector reviewed test records and discussed the testing programs with cognizant Systems Engineers to verify compliance.
The inspector checked results of current laboratory testing of charcoal samples for Iodine-131 removal efficiency.
Test results were available for the CREVS, Train A, passed on June 4,
1990; and SBGT, Train C, which passed on April 4, 1990.
The other SBGT samples were at the vendor laboratory, but results were not yet available.
The System Engineer stated that the in-place leak tests of the CREVS were being done the week of the inspection, and that results would be provided at a later date.
Information was subsequently received
.which showed that the CREVS charcoal beds were successfully tested on January 17, 1991.
The System Engineer for the PCP systems stated that the systems were not considered operable at'he time of the inspection.
The charcoal beds had been removed, and the fans*were being run to assist in ventilation for ongoing work.
Prior to fuel load it was planned to install new charcoal beds and conduct testing.
The SBGT system was undergoing work at the time of the inspection.
The inspector stated that the status of these systems would be evaluated during a subsequent inspection, The inspector discussed the condition of the charcoal beds in the Offgas Treatment System (OGTS)
with the cognizant System Engineer to assess capability.
The Engineer stated that the beds had been placed in layup during the extended shutdown.
The beds were taken out of layup during June or July 1989 for the condenser vacuum pull, and had not been placed back into layup due to imminent restart.
A vendor expert on the system stated that charcoal beds would retain their effectiveness during long idle periods.
The only concern would be a buildup of moisture.
The moisture content was checked in October 1990, and was found to be 12.3 percent by weight.
The vendor recommendation was for moisture to be maintained to two to five percent by weight.
The licensee planned to recheck this prior to startup.
No violations or deviations were identified.
Process and Effluent Yionitors (84750, 84524)
TS 3/4.2.0 states the operability and surveillance requirements for radioactive liquid effluent monitoring instrumentation, and TS 3/4.2.K states the operability and surveillance requirements for radioactive gaseous effluent monitoring instrumentation.
TYiI Action Plan Items II.F.1.2.A and II.F. 1.2.B state requirements for accident monitoring instrumentation.
a.
Radioactive Vent Gaseous Effluent Yionitoring and Sampling Prior to the Browns Ferry Nuclear Plant (BFNP)
shutdown of 1986, in-plant atmospheric air and effluent vent monitors consisted of
t
continuous air monitors (CANs) manufactured by Nuclear Measurements Corporation (NNC).
During the extended shutdown, most or all of the pre-existing CAYis were replaced by Eberline CANs.
The Eberline CAYis consisted of a
noble gas continuous monitoring channel and provisions for the collecting of radioiodines and particulates.
The inspectors noted that, in several instances, the sample procurement lines were long (greater than. 100 feet), that certain of the lines contained one or more sharp right-angle bends (considered to induce particle losses through impingement),
and that none of the sample procurement lines were heat-traced to minimize radioiodine plate-out.
The inspector questioned whether such sampling configurations would result in representative sampling to perform an adequate survey in accordance with 10 CFR 20.201(b)..
ANSI N13. 1-1969, relative to particulates in air sampling lines, indicated that a
high percentage of particles would impinge on the sampling line walls at locations of sharp right-angle bends or other acute-angle bends and would be lost (would not appear-on the downstream sample collection media).
The same reference also held that turbulent flow in sample lines longer than about 5 meters would result in loss of a high percentage of particl,es by deposition on the 'sample line walls.
Mhile ANSI N13. 1-1969 did not specifically address iodine sampling line losses in detail, it has been generally acknowledged within the industry that sampling line plateout of -radioiodines would be minimized by the use of non-reactive sample line materials such as stainless steel and by use of electric heat-tracing to minimize temperature transitions.
The BFNP vent CANs used stainless steel lines, but did not incorpor'ate heat tracing.
The rationale for not heat tracing was that since all of the sampling line was within the Turbine Building main hall, temperature transitions would be minimal.
The inspector questioned licensee representatives and systems engineers about the right angle bends and the lack of electrical heat tracing.
The inspectors were provided with a copy of documentation of a computer program for modelling of sample line transmission of particulates,,as developed by Dr. Birney Fish of the TVA corporate technical staff and others, and with copies of computer printouts of calculations, using Dr. Fish's modelling program, of sample line transmission as prepared by the plant staff.
Based on measured plant parameters for particulates of the size and density anticipated (by the licensee) for airborne gases and particulates at BFNP, particulate sample transmission from the sampling points to the sample collection media ranged from a low of about 73 percent to a high of about 99 percent.
The inspector notified the licensee, on January 29, 1991, that the matter of representative sampling to assure performance of an adequate survey in lioht of potential sample line losses and the adequacy of, the line loss modelling program used in calculating line losses at BFNP would be referred to NRR for evaluation and that this had been
identified as an Unresolved Item:
URI 91-01-01:
Adequacy of calculation of sampling line losses.
High Range Gaseous Effluent Monitoring System The high range gaseous effluent monitor which was installed at BFNP to meet the requirements of NUREG-0737, items II.F. 1-1 and II.F.1-2 and which was designed to service the principal release point for all three BFNP units, was located in a building adjacent to the 600-foot site stack.
The licensee's designation for this monitor was
"Wide Range Gaseous Effluent Radioactivity Monitor," or "WRGERN."
The MRGERYi was custom-built to BFNP specifications, but was the subject of a number of major problems during fabrication and installation.
A licensee representative stated that the original vendor, Gull Electronics, declared bankruptcy after delivery of most of the contracted WRGERYi components, but prior to completion of final assembly and testing.
It was further stated that a licensee evaluation of the Gull-supplied WRGERYi components and of system design and fabrication concluded that substantial modification of the MRGERYi would have to be done to assure that the system would perform its required functions.
Subsequently, a
second vendor, RCI, was contracted to make the necessary modificationns and to complete the MRGERM installation and preoperational testing.
After a substantial effort had been expended by the licensee in working through RCI in the redesign and rebuilding of the MRGERM, RCI also declared bankruptcy prior to the final completion and preoperational testing of the MRGERN.
The licensee then undertook the remaining portions of the task of completing the WRGERY>
'installation and had completed the installation and post-modification testing prior to the start of this inspection.
The inspector reviewed the licensee's completed post-modification procedures and found them to be satisfactory.
On the basis of this review, IFI 90-02-02, post-modification testing of the MRGERYi, was considered closed; however, the licensee's surveillance and operability testing and radioactivity testing procedures had not been completed.
Licensee representatives stated that these procedures would be completed prior to startup of BFNP, Unit 2.
In a deficiency report, Form SSDSP-36,
"Deficiencies and Exceptions,"
dated December 2, 1990, it was reported that a check source intended to be used as a radioactivity check source on one channel of the VRGERN had been incorrectly identified.
What had been believed to be a Cl-36 source was determined by the licensee to be a Tl-204 source.
The discrepancy was identified while investigating what had initially been thought to have been a leaking radioactive source.
When 'the source nuclide was properly identified, and the anticipated radioactivity level corrected for half-life, the discrepancy was resolved.
In discussions between the systems engineer and the inspectors, it was indicated that the confusion originated from incomplete documentation on the MRGERYi resulting from the bankruptcy of the initial vendor (Gull
Electronics).
The followup vendor (RCI) had used and documented Cl-36 sources for two other sections of the WRGERYi, but had not documented the source installed by the initial vendor.
Since all three detector sections were essentially identical, BFNP engineers and technicians initially assumed that the built-in check sources were identical.
It should be noted that it is the usual industry practice to provide check sources with half-lives on the order of 30 years to minimize the need for periodically recalibrating the strength of the check sources over the anticipated 10 to 15 year useful life of systems of this type.
After review of the deficiency reports and of the corrective measures taken, the inspectors considered that the licensee had acted promptly and efficiently in identifying and resolving the discrepancy.
this incident did, however, emphasize to the licensee the inadequacy of the existing WRGERYi documentation as supplied by the vendor, with the result that the licensee, at the time of the inspection, was preparing adequate documentation through the system procedures.
The licensee was informed that NUREG-0737, items II.F. 1-1 and II.F. 1-2 concerning post-accident effluent monitoring for radioactive noble gases, radioiodines, a'nd particulates would not be closed until inspectors had reviewed the completed preoperational surveillances and radioactive calibration procedures and the system was fully operational.
No violations or deviations were identified.
6.
Post Accident Sampling System (PASS)
(S4750, 84524)
NUREG-0737, Item II.B.3 states the requirements for a
PASS.
The PASS at Browns Ferry was supplied by General Electric Company (GE).
During the period of this inspection, the PASS was in the final stages of installation, with a
licensee-estimated completion date of January 31, 1991.
The installed PASS was essentially identical to PASSs previously supplied by GE to other Boiling Water Reactors (BWRs) and which have been found acceptable in meeting the requirements.
The inspector, accompanied by licensee representatives, visited the Unit 2 PASS installation.
Based on the inspectors'bservations, the licensee's estimated completion date appeared to be reasonable.
The installation of the PASS at the time of this inspection appeared to have been conducted in a satisfactory manner with no significant problems being observed by the inspector or reported by the licensee's representatives.
The inspector reviewed the vendor's two-volume manual on the operation and maintenance of the PASS, the licensee's proposed operating procedures for the PASS, the licensee's proposed procedures for the preoperational testing and calibration of the PASS, and the proposed training program for
'perational personnel.
The licensee's procedures appeared to be consistent with the vendor's recommended operating and preoperational procedures and the proposed training program appeared to be adequate to permit personnel to
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operate the system and take the required samples with minimal exposure to the operators.
The inspector's review of'he vendor manual and piping and instrumentation diagrams (PSIDs)
indicated that the PASS would be capable of sampling post-accident liquids and gases consistent with the requirements of NUREG-0737, item II.B.3.
Verification of the operability of the PASS and of the capability of the PASS to meet the requirements of NUREG-0737, will be accomplished at a later date through an NRC onsite evaluation which will include review of the results of preoperational testing, of PASS calibration, and witness the taking and analysis of actual samples of reactor coolant and coolant system noble gas taken by PASS operators using the PASS under full reactor power operating conditions.
The evaluation w'ill consider correlations between results of PASS analyses and results of analyses of concurrent coolant and gaseous samples as taken and analyzed using the licensee's routine reactor coolant and gaseous sampling and analysis systems and procedures.
Training records of PASS operators will also be reviewed.
Training of licensee personnel in operation of the PASS was started during the period of this inspection and was to be completed for all appropriate personnel prior to the end of January 1991.
Six crews of operators'were to be trained during the 'current training cycle.
Sufficient numbers of personnel wer e to be trained to assure the availability of at least one qualified operator at all times.
Further training for new PASS operators and periodic refresher training for PASS operators would be performed as needed.
NUREG-0737, item II.B.3 and IFI 90-02-01, Conduct of operating test on PASS, remained open as of the closing date of this inspection.
No violations or deviations were identified.
Exit Interview (84750, 84524)
The inspectio'n scope and findings were summarized on January 18, 1991, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection findings.
IFI 90-02-02 was closed (Paragraph 5)
as a result of the successful completion of the post-modification test on the WRGERN.
NUREG-0737, items II.F. 1-1 and II.F.1-2 will remain open until the successful calibration of the MRGERN.
IFI 90-02-01 and NUREG-0737, item II.B.3 will remain open until the successful operational check of the PASS.
The licensee was subsequently notified on January 29, 1991, that the issue regarding the right-angle bends in the sample lines in the building vent were considered to be an Unresolved Item, 'and would be evaluated by NRR.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio )'
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