IR 05000269/1977011
| ML19322B792 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 07/20/1977 |
| From: | Bangart R, Cunningham A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322B780 | List: |
| References | |
| 50-269-77-11, 50-270-77-11, 50-287-77-11, NUDOCS 7912050782 | |
| Download: ML19322B792 (9) | |
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9 "80f/q[o UNITED STATES NUCLEAR REGULATORY COMMISSION T 4 g
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t 230 PEACHTREE STREET, N.W. SUITE 1217
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Report Nos. :
50-269/77-11, 50-270/77-11 and 50-287/77-11 Docket Nos.:
50-269, 50-270 and 50-287 License Nos.: DPR-38, DPR-37 and DPR-55 Licensee: Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 Facility Name:
Oconee Nuclear Station, Units 1, 2 and 3
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Inspection at:
Oconee Nuclear Station Seneca, South Carolina Management Meeting at: NRC Region 2 Office Atlanta, Georgia Inspection conducted: June 20-21, 1977 Managasent Meeting conducted: July 15,1977 Inspectors:
A. L. Cunningham R. L. Bangart Reviewed by: b. bCvt c,a4 7[2e/77 7Dat'e R. L. BangartgChief Environmental and Special Projects Section J
Fuel Facility and Materials Safety Branch Inspection Summary Inspection on June 20-21, 1977 (Report Nos. 50-269/77-11, 50-270/77-11 50-287/77-11)
Areas Inspected:
Routine, unannounced followup inspection of nonradio-logical environmental reportable occurrences and their respective corrective actions; audit of scation waste water treatment system (%'b7S) discharge pH monitoring records and data; review of makeup water demineralizer regeneration procedures; status of operation of WTS and Units 1 and 2 control room WTS discharge pH alarm; followup on previously identified items; management meeting with licensee representatives. The l
inspection involved 16 inspector-hours on site by two NRC inspectors.
7912050f
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RII Rp t. Nos. 50-269/77-11, 50-270/77-11 and 50-287/77-11-2-
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Results: Of the five areas inspected, no apparent items of noncompliance or deviations were identified in four areas; one apparent item of noncompliance was identified in one area (infraction: exceeded maximum pH limit assigned to the WTS discharge, Details I, paragraph 4).
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RII Rpt. Nos. 50-269/77-11, 50-270/77-11 and 50-287/77-11 I-1 DETAILS I Prepared by:
[/. banom I
7 c/77 A. L. Cunninghag/, Environmental
~ Date Scientist Environmental and Special Projects Section Fuel Facility and Materials Safety Branch Dates of Inspection: June 20-21, 1977 Reviewed by: [ 4. Ndan4 7N: h ~1 R.'L.Bangart,ghief
' Da t'e Environmental and Special Projects Section Fuel Facility and tbterials Safety Branch 1.
Persons Contacted
- J.
E. Smith, Station Manager
- R. M. Koehler, Superintendent of Technical Services
- W. A Brown, Staff Chemist
- D. C. Smith, Station Chemist
- J. J. Johnson, Jr. Engineer
- R.
Knoerr, Associate Engineer
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-269/77-5; 50-270/77-5; 50-287/77-5):
Reporting Requirement.
The license submitted a written report to the NRC Region II Director on April 15, 1977, concerning the reportable occurrence of March 16, 1977, in which the Waste Water Treatment System discharge pH limit was exceeded.
The inspector reviewed the report. The report appeared to be adequate.
There were no further questions concerning this item.
(Open) Deviation (50-269/77-5; 50-270/77-5; 50-287/77-5):
Incomplete Corrective Action.
Corrective action involving installation of a control room Hi/Lo alarm for waste water treatment system discharge pH by April 1, 1977, had not been implemented.
Implementation of the corrective action requirement was rescheduled for June 1,1977.
This item remains open pending completion of installation of an effective control room Hi/Lo pH alarm (Details I, paragraph 5).
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m, RII Rpt. Nos. 50-269/77-11, 50-270/77-11 and 50-287/77-11 I-2 3.
Unresolved Items No unresolved items were disclosed during this inspection.
4.
Review of Reportable Occurrenc q a.
The inspector reviewed Reportable Occurrences of April 18, 1977, and May 1, 1977, in which the Waste Water Treatment System (WTS) discharge pH limit assigned by Appendix B Technical Specification 1.2 was exceeded. The action requirements of this specification stipulate that the written report which is
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submitted to the appropriate NRC Regional Director within one week j
following telephone notification of an occurrence involving
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chemical discharge limits, must include the following:
(1)
description, analysis and evaluation of the occurrence, includ-
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ing the extent and magnitude of the impact; (2) description of l
the cause of the occurrence; and (3) indication of the corrective action (including any significant changes made in procedure)
taken to preclude repetition of the occurrence and to prevent similar occurrences involving similar components or systems.
As part of the review, major emphasis was placed upon the respective corrective actions taken to preclude repetition of the occurrences.
Inspection revealed that the corrective actions actually implemented for both reported occurrences cited above did not assure that the WTS discharge would be maintained within the specified pH limits. The inspector informed licensee represen* ative that the subject occurrences constituted an item of nonevapliance because of their failure to implement adequate corrective actions necessary to preclude repetition of such occurrences.
b.
Corrective actions taken in each of the above cases to preclude their recurrence were considered inadequate based on the findings discussed below.
(1) The licensee f ailed to implement a previous corrective action commitment (Response dated November 16, 1976) to IE Inspection Report Nos. 50-269/76-10; 50-270/76-10 and
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50-287/76-10) requiring installation of a control room WTS discharge pH alarm. The alarm would be actuated at setpoints within the Hi/Lo pH range limit to allow the licensee to make necessary adjustments to the system to preclude exceeding the assigned pH limits. The alarm was to be installed in the control room by April 1, 1977.
The licensee later rescheduled installation for June 1, 1977 in response to inspection findings defined in IE Inspection Report Nos. 50-269/77-5, 50-270/77-5 and
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RII Rpt. Nos. 50-269/77-11, 50-270/77-11 and 50-287/77-11 I-3 50-287/77-5. At the time of this inspection, installa-tion of the control room pH alarm was not adequately completed.
Implementation of this commitment would provide greater assurance that the WWTS discharge would be maintained within the specified pH limits.
(2) The corrective action commitment implemented in response to the Reportable pH Occurrence of March 16, 1976 has not proven to be effective based on the number of pH incidents
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which have occurred following its implementation.
This commitment involved recording pH readings of the waste water collection basins and WWTS discharge every four hours and prior to and following demineralizer regeneration to effect improved surveillance of pH changes.
This commitment has been included in the licensee's responses to Reportable Occurrences of March 16, 1977, April 18, 1977 and May 1, 1977.
5.
Status of Waste Water Treatment System (WWTS) Discharge pH Alarm a.
The inspector toured selected areas of the plant and plant site to assess the status of operation cf the waste water treatment system (WWTS) and the WWTS discharge pH alarm.
Inspection included the following areas:
(1) upper and lower waste water collection basins and their respective recirculation and discharge pH monitoring probes; (2) oil collection pond and waste water discharge pH monitoring probe (yard drainage pH monitor); (3) water treatment room; (4) Units 1 and 2 control room.
During the tour, items identified by the inspec-tor were acknowledged by licensee representatives who initiated interim corrective actions in the case of the WWTS discharge pH alarm.
b.
Inspection revealed that the lower waste water basin was temporarily taken out of the system to provide holdup and removal of radioactivity previously released to the basin.
Recirculation and discharge pH probes in this basin were removed from service. All flow of demineralizer regeneration process waste water was diverted to the upper collection basin. The recirculation pH monitoring probe in this basin was in use.
The upper basin discharge pH monitor, however, was not in service.
During inspection, no known discharges from the upper basin were made.
The basin was maintained in the recirculation mode.
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q RII Rpt. Nos. 50-269/77-11,
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50-270/77-11 and 50-287/77-11 I-4 c.
During tour of the oil collection pond area, the inspector observed that the WWTS discharge pH probe (yard drainage pH probe), located in the pond spillway, was covered with algae and vegetative debris. Licensee representatives who were questioned concerning the frequency of both probe cleaning and calibration responded by stating that the subject probe was cleaned weekly. At time of inspection, however, they were not certain that any assigned p.
be calibration frequency had been followed. A licensee represcatative later contacted NRC Region II and stated that a procedural change would be imple-mented which requires weekly buffer checks and daily cleaning of the WWTS discharge pH monitor.
The licensee representative was informed that those actions appeared to address the points which had been raised during inspection and that it was expected that those commitments would be documented in reply to the NRC enforcement letter.
d.
Inspection of the water treatment room confirned that only two of the five pH monitoring probes, viz., upper waste water basin recirculation and WWTS discharge, were being recorded on the water treatment room strip chart recorder.
The inspector observed however, that the water treatment room annunciator panel indicated a continuous pH alarm condition.
It was determined that the visual alarm was actuated by removal of the three pH monitoring probes (lower basin discharge, lower basin recirculation, upper basin discharge) which were reading off-scale.
Inspection of Units 1 and 2 control room annunciator panel indicated no such alarm condition in that area since the alarm condition had been previously acknowledged in the Water Treatment Room.
In discussion of this finding with licensee representatives, the inspector was informed that pH alarm channels were provided with neither cut-out switches nor reflash capability. A licensee representative further stated that installation of pH alarms in accordance with the corrective action ccmmited to in response to IE Inspection Report Nos. 50-269/76-10, 50-270/76-10, 50-287/76-10, would require pulling of cables from the water treatment room recorder /
console to the control room annunciator panel.
Licensee representatives then stated that as an immediate, but temporary corrective action, channel alarm modules for those inline pH monitors taken out of service would be removed by June 21, 1977.
This action would provide alarm capabilities for the two pH monitors currently in service and other water treatment control parameters included in the alarm. The inspector verified by observation on June 21, 1977 that this action had been completed.
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NRC Region II was later informed by a licensee representative that a request has been submitted to station engineering
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RII Rpt. Nos. 50-269/77-11, 50-270/77-11 and 50-287/77-11 I-5
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seeking a commitment to install by August 31, 1977, a control room annunciator to alarm at specified Hi/Lo pH settings for each waste water collection basin recirculation probe and a separate alarm for the oil collection pond pH monitor.
Based on the findings discussed above, no automatic control room WWTS discharge pH alarm capability was available at the time of inspection on June 20, 1977.
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e.
Inspection of Units 1 and 2 control room annunciator panel ISA6 revealed that there was no alarm specifically provided for the WWTS inline pH monitors. An annunciator panel entitled,
" Treated Water Panel Trouble," was designed to be actuated by pH as well as other water treatment process parameter controls.
The inspector informed licensec representatives that the deviation disclosed in IE Inspection Report Nos. 50-269/77-5, 50-270/77-5 and 50-287/77-5 concerning the above discussed pH alarm would remain open, pending completion of its installation and effective operation.
6.
Procedures Inspection included a detailed review of procedures developed for regeneration of makeup demineralizers and response to Units 1 and 2 control room alarm indicating trouble in the water treatment room (WTR). Demineralizer regeneration procedures were audited to determine if specific procedural revisions concerning WTR sump pump operation were Laplemented in accordance with the corrective action commitment defined by the licensee following the reportable pH occurrence of April 18, 1977 and cited in their written report to the NRC dated April 25, 1977.
Inspection revealed that the subject correction (Procedure CP/0/B/200/2, Change No. 2) was implemented on April 20, 1977. During inspection, it was observed that a copy of the revised procedute was posted in the WTR.
Inspection of control room Operating Procedure No. 1706/45, dated October 10, 1972 -
Treated Water Panel Trouble, was consistent with the general WTR alarm discussed in the preceeding paragraph.
This procedure simply entails the operator contacting the shift chemist (upon receipt of the alarm) who is dispatched to the WTR to identify the source of the alarm and implement corrective action required to return the system to normal operation. The inspector discussed the procedure with licensee representatives. Upon completion of installation and operation of the control room Hi/Lo p3 alarm in compliance with the corrective action commitment, revisions to the subject procedure may be required.
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RII Rpt. Nos. 50-269/77-11, 50-270/77-11 and 50-287/77-11 I-6 7.
Audit of Station Discharge pH Records The inspector audited pH records of daily WWTS discharge grab samples and WTR strip charts collected during the period April 15,
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1977 through June 20, 1977.
The inspector also reviewed licensee Incident Reports B-595, B-615 and B-620 for pH Reportable Occurrences of March 16, 1977, April 18, 1977 and May 1, 1977, respectively.
In the case of pH records, no items of noncompliance were disclosed.
The records indicated only those reported incidents in which the pH limits of Appendix B Technical Specification 1.2 were exceeded.
The incident reports cited were consistent with the respective telephone and written reports submitted to the NRC.
There were no questions concerning this item.
8.
Management Meeting On July 15, 1977, a management meeting was held by the Region II Director at the Region II office with Duke Power Company's Vice President of Steam Production and Transmission, the Oconee Nuclear Station Manager, and members of their staffs.
The meeting was convened to appraise licensee management of NRC concern relative to the failure to implement corrective actions required to preclude recurrence of incidents in which the WWTS discharge pH limits are exceeded, as discussed in paragraph 4, above.
The five reportable occurrences involving WWTS discharge pH (February 12, 1976; March 16, 1976; March 16, 1977; April 18, 1977; and May 1, 1977) and the enforcement actions associated with these occurrences were discussed.
A licensee representative stated that they were aware of the facts presented by the NRC and that the circumstances were indicative of a need for additional management controls. A licensee representative also stated that measures would be taken to implement all pending corrective actions and that a review of both the hardware and procedural aspects of WWTS discharge pH control had been initiated.
Corrective actions would be directed toward preventing recurrence of reportable incidents.
It was stated that required improvements in management controls would be addressed in their response to the subject IE Report.
9.
Exit Interview The inspector met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on June 21, 1977. The inspector summarized the scope and findings of the inspection.
Licensee representatives made the following comments in response to certain items discussed by the inspector:
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RII Rpt. Nos. 50-269/77-11
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50-270/77-11 and 50-287/77-11 I-7 a.
Acknowledged statements by the inspector with respect to the item of noncompliance (paragraph 4).
I b.
Stated that an immediate, but temporary corrective action had been implemented by June 21, 1977, to restore operation of the control room treated water trouble alarm by removal of pH channel modules for the three inline pH monitors taken out of service during restricted use of the upper and lower vaste water collection basins.
c.
Stated that they would contact NRC Region II within one week concerning implementation of the outstanding corrective action commitment to install an effective control room WIS discharga pH alarm.
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