IR 05000261/1986014
| ML14175B400 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/19/1986 |
| From: | Adamovitz S, Gloersen W, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B399 | List: |
| References | |
| 50-261-86-14, NUDOCS 8607220719 | |
| Download: ML14175B400 (10) | |
Text
REGq UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 JUN 25 1986 Report No.:
50-261/86-14 Licensee:
Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DPR-23 Facility*Name:
H. B. Robinson Inspection Conducted:
June 2-6, 1986 Inspectors:
//Date S. S. Adamovitz C-,' Date Signed en Date Signed Approved by: Stoddar ing Section Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection covered the areas of liquid and gaseous radwaste managemen Results:
No violations or deviations were identifie PDR ADOCK 05000261 G
REPORT DETAILS 1. Persons Contacted Licensee Employees
- R. E. Morgan, General Manager
- J. M. Curley, Director, Regulatory Compliance
- H. G. Young, Director, Quality Assurance/Quality Control (QA/QC)
D. Smith, Manager, Environmental and Radiological Control
- S. A. Griggs, Aide, Regulatory Compliance
- P. C. Harding, Project Specialist, Regulatory Compliance
- J. L. Harrison, Project Specialist, Environmental and Chemistry
- D. H. Edwards, Senior Environmental Specialist
- S. Crocker, Supervisor, Regulatory Compliance J. A. Eaddy, Supervisor, Environmental and Chemistry H. F. Watkins, Foreman, Environmental and Chemistry R. Dayton, Project Engineer, Engineering Performance J. Taylor, Technician, Environmental and Chemistry NRC Resident Inspectors
- H. E. P. Krug, Senior Resident Inspector R. Latta, Resident Inspector
- Attended exit interview Exit Interview The inspection scope and findings were summarized on June 6, 1986, with those persons indicated in Paragraph 1 above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio. Audits and Appraisals (84723, 84724)
Technical Specification 6.5.3.2.d requires audits of plant activities including the Offsite Dose Calculation Manual (ODCM)
and implementing procedure at least once per 24 months, the conformance of facility operation to all provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months, and the performance of activities required by the Quality Assurance Program to meet
the criteria of Regulatory Guide 4.15, December 1977 at least once per 12 months. The inspectors reviewed the following audits conducted by licensee personnel:
QASR No.85-173, Chemistry and Radiochemistry, October 28, 1985 through November 5, 1985 QASR No.86-048, Radiological Effluent Technical Specifications March 3, 1986 through March 24, 1986 QASR No.86-067, Regulatory Guide 4.17 (December 1977), March 4, 1986 through May 9, 1986 QASR No.86-070, Offsite Dose Calculations Manual, May 12, 1986 through May 22, 1986 The inspectors noted that one nonconformance item and one item of concern identified in QASR No.86-067 had been assigned tracking number Both items had been evaluated, responses had been prepared by the appropriate department, and an estimated completion date was identifie A corporate audit QAA/0020-86-04, Quality Assurance Audit of H. B. Robinson Steam Electric Plant, Unit N Operations was conducted in May, 198 However, the audit report had not been received by plant personnel as of the date of this inspectio No violations or deviations were identifie.
Plant Radwaste Treatment Systems (84723, 84724)
a. Technical Specification 6.17.1 requires that licensee-initiated major changes to the radioactive waste systems be reported to the Commission in the Semiannual Radioactive Effluent Release Reports for the period in which the safety evaluation was reviewed by the Plant Nuclear Safety Committee. The inspectors reviewed the Semiannual Radioactive Effluent Release Reports for January-June 1985 and July-December 1985, and discussed radwaste systems with licensee personne b. Technical Specifications 3.9.1, 3.9.2, 3.16.1 and 3.16.2 define the operating requirements and radioactive effluent limits of the liquid radwaste treatment system. Technical Specification 4.10.1 defines the surveillance requirement The inspectors reviewed selected liquid effluent release permits for the period of January-May 1986 and discussed liquid radwaste operating and maintenance experience with licensee personne Licensee personnel indicated that no major problems had been encountered since the last inspectio Technical Specifications 3.9.3, 3.9.4, 3.9.5, 3.16.3, 3.16.4, and 3.16.5 define the operating requirements and radioactive effluent limits of the gaseous radwaste treatment systems, including ventilation
treatment systems. The inspectors reviewed selected gaseous effluent release permits for the period of January-May 198 The inspectors also discussed operational and maintenance experience with licensee personnel, who-indicated normal system operabilit No violations or deviations were identifie.
Procedure Reviews a. Technical Specification 6.5.1.1 requires the licensee to establish, implement, and maintain procedures including, per Appendix A of Regulatory Guide 1.33, Rev. 2, dated February 1978, procedures covering operations and activities relative to liquid and gaseous radwaste management. The inspectors reviewed selected portions of the following procedures:
RCP-101 Preparation of Effluent and Noneffluent Samples, Rev. 1, May 16, 1986 RCP-102 Sample Submission to the Radiochemistry Laboratory, Rev. 0, August 24, 1983 RCP-104 Instrument Nonconformance Reports, Rev. 0, August 24, 1985 RCP-105 Unsealed Source Accountability, Rev. 2, September 10, 1984 RCP-120 Tritium Sample Preparation and Analysis, Rev. 2, October 15, 1985 RCP-133 Determination of Radiochemistry, E bar, and Iodine-134 Dose Equivalent, Rev. 1, August 17, 1984 CP-001 Chemistry Monitoring Program, Rev. 9, May 30, 1986 CP-003 Systems Sampling.Procedure, Rev. 5, May 30, 1986 CP-008 Control Charts, Rev. 0, March 8, 1985 EMP-010 Effluent and Waste Disposal Report, Rev. 1, March 2, 1985 EMP-013 Operation and Calibration of RMS-34, Rev. 2, February 25, 1986 EMP-019 LRW/GRW Composite Preparation and Update, Rev. 1, March 12, 1986 EMP-022 Gaseous Waste Release Permits, Rev. 0, March 14, 1986 EMP-023 Liquid Waste Release and Sampling, Rev. 1, February 25, 1986 EMP-024 RETS Surveillance, Rev. 1, March 12, 1986
EMP-025 Gaseous Effluent Sampling and Analysis Requirements, Rev. 0, March 12, 1986 RST-010 Calibration of Radiation Monitoring System, Monitor R-11, Rev. 3, May 9, 1986 RST-011 Calibration of Radiation Monitoring System, Monitors R-12, R-20, and R-21, Rev. 2, May 9, 1986 RST-012 Calibration of Radiation Monitoring System, Monitor R-14, Rev. 2, May 9, 1986 RST-016 Calibration of Radiation Monitoring System, Monitor R-18, Rev. 2, May 9, 1986 b. The inspectors noted the procedure RCP-120, Tritium Sample Preparation and Analysis, did not contain an alternate preparation step for vapor tritium samples. Normally, the licensee utilized a boiling step to purge the noble gases from the sample. The inspectors discussed with licensee personnel the need for the procedure to reflect alternate methods of sample preparatio During the course of the inspection, licensee personnel provided the inspectors a copy of the procedure change form which included this boiling ste No violations or deviations were identifie.
Record Review a. Technical Specification 6.10 requires specified records to be retained for at least five years or for the duration of the Facility Operating License. The inspectors reviewed selected portions of the following records:
(1) Chemistry Plots January-December 1985, January-May 1986 (a) RCS (Reactor Coolant System) pH (b) RCS Chloride (c) RCS 15 Minute Activity (d) RCS 7 Day Activity (e) RCS Boron (f) 1-131 Dose Equivalent (g) RCS 1-131 (h) RCS Iodine 131/133 Ratio (i) RCS Cs-134 Activity (j) RCS Cs-137 Activity
(2) Chemistry Plots (computer-generated)
March-December 1985 (a) RCS Iodine Summary 1)
1-131/133 Ratio 2)
1-131, 1-133, Dose Equivalent (b) RCS Cesium Summary 1) Cs-134 2)
Cs-137 (3) Waste Gas Tank Decay Release Permits, including sample analysis sheet, 86-59, 86-88, 86-90, 86-91,86-122, and 86-160 (4) Liquid Waste Release Permits, including sample analysis sheet, 86-99,86-109, 86-114,86-115, 86-123,86-128 (5) Operating Chemistry Reports, CP-001, Attachment 11.1, File:
18-1051A/2, February 1985-January 1986 (6) Shutdown Chemistry Reports, CP-001, Attachment 11.2, File:
18-10510A/2, January 1985, February 1986, March 1986 (7) Technical Specification Surveillance, Results, CP-001, Attachment 11.6, File:
18-10510B/2 January, April, June, and October 1985, and January-June 1986 (8) Environmental and Chemistry RETS Surveillance Log, EMP-024, Attachment 11.1 and 11.5, File: 17-12510E January, March, May 1986 (9) Effluent Monitor Calibrations (a) Containment Vessel (via plant vent) radioparticulate monitor (RMS-11)
1. beta phosphor detector -
January 14, 1986 (last calibration)
2. NaI(T1) detector (replaced beta phosphor detector per engineering evaluation 86-031) - March 12, 1986 (initial calibration)
(b) Containment vessel (via plant vent) radionoble gas monitor (RMS-12) - January 24, 1986
(c)
Plant vent radionoble gas monitor (RMS-14)
- December 18, 1985 (d)
Plant vent gaseous effluent monitoring system (RMS-34)
-
Eberline Model PING 2A - April 12, 1986 1. Radionoble gas channel Radioiodine channel Radioparticulate channel (e) Plant vent midrange accident monitor (RMS-35) - May 15, 1986 (f) Plant vent hi-range accident monitor (RMS-36)
- November 1, 1984 (g) Liquid radwaste effluent line monitor (RMS-18)
- March 20, 1986 (10)
Nuclear Air-Cleaning Filter Tests (a) Containment Purge System (HVE-1) Laboratory analysis of charcoal adsorbent samples January 23, 1986 In-place DOP leak test for HEPA filters -
February 3, 1986 In-place halide test for charcoal adsorbers February 3, 1986 (b) Auxiliary Building Emergency Exhaust System (HVE-5) Laboratory analysis of charcoal adsorbent samples April 3, 1985 In-place DOP leak test for HEPA filters - April 3, 1985 3. In-place halide test for charcoal adsorbers - April 3, 1985 (c) Spent Fuel Pit Exhaust (HVE-15A)
1. Laboratory analysis of charcoal adsorbent samples January 23, 1986 2. In-place DOP leak test for HEPA filters - January 23, 1986 In-place halide test for charcoal adsorbers January 23, 1986 (d) Control Room Emergency Ventilation (HVE-19) Laboratory analysis of charcoal adsorbent samples March 28, 1986
8 In-place DOP leak test for HEPA filters - April 3, 1985 In-place halide test for charcoal adsorbers - April 13, 1985 b. The inspectors noted that RCS parameters were plotted, which allowed easy identification of abnormal values or general trend No violations or deviations were identifie.
Radioactive Liquid and Gaseous Effluent Monitoring Instrumentation (84723, 84724)
Technical Specifications 3.5.2, 3.5.3, and Technical Specification Tables 3.5-6 and 3.5-7 define the operating requirements for radioactive effluent monitoring and sampling of plant liquid and gaseous effluent stream Additionally, Technical Specifications 4.19.1, 4.1 and Technical Specification Tables 4.19-1 and 4.19-2 define the surveillance requirements for radioactive liquid and gaseous effluent monitoring and samplin The inspectors reviewed selected logs and records of instrumentation maintenance and calibration activities, reviewed procedures for instrument calibration and calibration source preparation, and discussed operating and maintenance experience with licensee personne The inspectors noted that on March 3, 1986, the containment vessel radioparticulate monitor (RMS-11), which used a phosphor beta detector, was replaced with a NaI(Tl) detector in accordance with engineering evaluation 86-43 No violations or deviations were identifie.
Effluents (84723, 84724)
a. Technical Specification 6.9.1.d requires the licensee to submit, within 60 days after January 1 and July 1 of each year, Routine Radioactive Effluent Release Reports covering the operation of the unit during the previous six months of operatio The inspectors reviewed the Semiannual Radiological Effluent Release Reports for the periods January 1 - June 30, 1985 and July 1 - December 31, 198 The review included an examination of the liquid and gaseous release data. Based on data obtained from the semiannual reports for calendar year 1985, the inspectors noted that 0.09 curies of fission and activation products and 309 curies of tritium were released in the form of liquid waste. For gaseous effluents, a total of 2.14 E+3 curies of fission and activation gases, 1.05 E+2 curies of tritium, 1.35 E-2 curies of 1-131, and 2.33 E-4 curies of particulates (with half lives greater than eight days) were released during 1985. The inspectors noted a typographical error in the July 1 -
December 31, 1985 semiannual repor The licensee re-verified the release information for the quarterly summary page where the error was identified and submitted a request to reissue the affected page. The inspectors also noted that the licensee estimated the total error associated with both liquid and gaseous effluent measurements to be +/-10%. The inspectors and licensee
representatives discussed how the 10% error estimate was derived and the licensee agreed to provide additional information to support the numerical error estimat Additionally, the inspectors noted the reporting of zero for several nuclides in the Semiannual Effluent Release Reports. The inspectors indicated that zero should not be used in the report and noted that Regulatory Guide 1.21 specifies that the term "not detected" should not be used in the report An acceptable means to manage this reporting problem would be to explain in the semiannual report that "zeros" denote that radioactivity was not present above detectable levels. If this method is chosen, a reference to a range of analytical lower limits of detection (LLD)
should be provided in the repor The inspectors and the licensee discussed effluent reporting and agreed that (1) whenever a nuclide is detected in an effluent sample, it should be reported even if the analysis results are below the Technical Specification LLD limits and (2)
whenever an analysis for a nuclide yields a "less than LLD," that "less than LLD" value should not be used in quantifying the release nor in calculating the dose contributions from the effluent To summarize, the correction of the typographical error in the second half 1985 Semiannual report, an evaluation of the error estimate in the semiannual report, and the definition of zero in the semiannual report were identified as one inspector followup item (50-261/86-14-01).
0 b. Additionally, the inspectors observed the sampling, analysis, and pre-release calculations that were involved prior to a waste gas decay tank (WGDT)
releas A WGDT sample was analyzed for noble gases, tritium, iodine, and particulates. The dose estimates due to the gas releases were based on 1977 averaged meteorological data from a site-specific study performed in 1979 by Dames and Moor This practice is in accordance with Appendix A of the ODC Technicians used this data to update the monthly dose projections before the gaseous releases were made. The licensee indicated to the inspectors that when the semiannual report is submitted to the Commission, that the meteorological data averaged for the year during which the releases were made is used to compute the doses due to gaseous effluent No violations or deviations were identifie.
Licensee Action on Previously Identified Inspector Followup Items (92701) (Open) IFI 50-261/85-15-01, Evaluate PASS shielding studies with respect to sample piping external to PASS panel, access areas, and operator location (NUREG-0737). The licensee stated that the study has been completed; however the recommendations of the study have not been implemented completely. This item remains ope O b. (Closed)
IFI 50-261/85-15-02, Resolve sampling errors in containment atmosphere sampling system for post-accident sampling (NUREG-0737).
During the NUREG-0737 appraisal of the licensee's post-accident sampling system (PASS) (see IE Report No. 85-15), the PASS containment
atmosphere sample radioisotope results were significantly below the result obtained for the normal containment atmosphere grab sample. The inspectors reviewed three additional PASS samples obtained on September 27, 1985 and October 17, 1985. The PASS containment air sample results compared favorably with those obtained for the normal containment air grab samples. The licensee speculated that the sample container used during inspection 50-261/85-15 had lost vacuum prior to sample injectio The licensee added a precaution step to gas sample procedures CP-081 and CP-083 to instruct technicians to verify that the gas sample vial will hold a vacuum prior to us This item is considered close (Closed) IFI 50-261/85-15-03, Resolve analytical problem in PASS chloride sample determination (NUREG-0737).
During the NUREG-0737 inspection of the licensee's PASS (IE Report No. 85-15)
high chloride results were obtained on the undiluted RCS sample ru During the operation of the "cask",
Kimwipes were used to remove liquid from the ends of the quick disconnect An analysis of the Kimwipes showed approximately 0.01% (-
100ppm)
chloride by weigh The Kimwipes appeared to be the source of the chloride contamination. The licensee added a precaution to the two PASS liquid sample procedures CP-082 and CP-081 to caution technicians about possible sources of chloride
<.
contamination. This item is considered close (Closed)
IFI 50-261/85-17-01, Evaluation of procedures to meet radiological technical specification (RETS) effluent measurement lower-limit-of-detection (LLD)
limit During the 50-261/85-17 inspection, the inspectors noted LLD calculations did not take into consideration isotopic decay time between sample collection and analysis. The inspectors also noted that procedures for liquid and gaseous effluent analyses did not specify a maximum time limit between sampling and analysi During the current inspection, inspectors reviewed procedures that addressed both items. RCP-101, Preparation of Effluent and Noneffluent Samples, Rev. 1, May 16, 1986, included decay corrections for LLD calculation EMP-019, LRW/GRW Composite Preparation and Update, Re, March 12, 1986, and EMP-025 Gaseous Effluent Sampling and Analysis Requirements Re, March 12, 1986, indicated maximum time limits between sampling and analysis. This item is considered closed.