IR 05000269/1977016
| ML19322B641 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/02/1977 |
| From: | Gibson A, Kowalczuk A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322B638 | List: |
| References | |
| 50-269-77-16, 50-270-77-16, 50-287-77-16, NUDOCS 7912040669 | |
| Download: ML19322B641 (1) | |
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sP Mits UNITED STATES e
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NUCLEAR REGULATORY COMMISSION
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o REGION 11
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230 PEACHTREE STREET, N.W. SUITE 1217
ATLANTA, GEORGI A 30303 os.,.....J Report Nos.:
50-269/77-16, 50-270/77-16 and 50-287/77-16 Docket Nos.:
50-269, 50-270 and 50-287 License Nos.:
DPR-38, DPR-47 and DPR-55 Category:
C Licensee:
Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 Facility Name: Oconee Nuclear Station Inspection at: Oconee Site, Seneca, South Carolina Inspection conducted: August 2-5, 1977
Inspector 1:
A. D. Kowalczuk M. P. Car on N77 Reviewed by:
L A. F. dibson, Chief Date Radiation Support Section Fuel Facility and Materials Safety Branch Inspection Summary Inspection on August 2-5, 1977 (Report Nos. 50-269/77-16, 50-270/77-16 and 50-287/77-16)
Areas Insoected: Routine, unannounced, operational inspection of radioactiv0 effluent monitoring systems, air cleaning systems and radiation pretection program.
The inspection involved about 52 inspector-hours on site by two inspectors.
Results: No items of noncompliance were disclosed in the three areas inspected. One unresolved item related to air cleaning systems tests was closed and one unresolved item related to test prerequisites was opened. A deviation from licensee commitments was identified.
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RII Rpt. Nos. 50-269/77-16, I-l
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50-270/77-16 and 50-287/77-16
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DETAILS I Prepared by:
,e A.ff.KowalcK, Rad ~ on S'pecialist
/Da(e Radiation Support Sect on Fuel Facility and Materials Safety Branch Dates of Inspection:
Augu t 2-5, 1977
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A. F. Gibs'on, Shetion Chief Date Radiation Support Section Fuel Facility and Materials Safety Branch 1.
Individuals contacted J. E. Smith, Manager, ONS R. M. Koehler, Superintendent of Technical Services R. T. Bond, Technical Services Engineer T. S. Barr, Performance Engineer J. A. Long, Assistant Health Physics Supervisor L. A. Blue, Junior Health Physicist D. Patterson, Shift Supervisor R. Rogers, Performance Engineer 2.
Licensee Action on Previous Inspection Findings a.
Calibration of Effluent Monitors (Unresolved Item 73-12/1)
(1) The inspector reviewed radiation monitor correlation curves for RIA-45 (Unit Vent Gas), RIA-49 (Reactor Building Gas), RIA-53 (Interim Radwaste Building Gas),
3RIA-38 (Unit 3 Waste Gas-High), IRIA-38 (Unit 1 Waste Gas-High), and RIA-40 (Condenser Air Ejectors). These curves as well as those for other radiation monitors were included as enclosure 13.4 to PT/0/A/230/01, Radiation Monitor Check, and available in the control rooms and were checked as required by the " Procedure for Correlation of Effluent RIA Monitors".
(2)
Several weaknesses in the effluent monitor correlation program.were apparent to the inspector and are identified below:
(a) Operators contacted in the control rooms were not aware of which correlation curves were current and where the current curves were locate __
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(b) Operators were unable to read the radiation monitors and make a quick, rough estimate of effluent radio-activity release rates in relation to release limits, particularly as related to iodine and particulate monitors.
(c) Correlation curves were not dated or otherwise identified to indicate current applicability.
In some instances the applicable reactor unit (s) were not identified.
In one instance three undated
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curves were available for the same radiation monitor.
(d) Graphs having more than one curve for different radionuclides did not include guidance for applying the various curves to operating conditions.
(e)
Radiation background data indicating the lowest useful countrate and thus the concentration were not available. Background data are also needed to identify the net monitor response at low countrates.
(f)
Records of data supporting the correlation curves did not appear to include a curve showing the associated data points, the dates of measurements and the associated analytical results with monitor readings. Data in these records was not amenable to review and evaluation and the inspector questioned whether an adequate management review could be maintained.
(g)
Discussions with licensee representatives revealed that unit vent particulate monitors are still con-sidered inoperable.
The representatives stated that daily samples are analyzed in accordance with Technical Specification 3.10.7.
This item remains open.
b.
Process and Effluent Monitor Calibrations and Functional Checks (Unresolved Item 76-2/1)
(1)
PT/0/A/23 /01, Radiation Monitor Check, was reviewed.
Setpoints'specified in enclosure 13.2 are now based on acceptable criteria.
Setpoint settings were verified by the inspector.
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RII Rpt. Nos. 50-269/77-16, I-3
50-270/77-16 and 50-287/77-16 (2)
HP/0/B/1000/60/F, Correlation of Effluent Monitors, was reviewed. A program for correlating monitor response to radioactivity concentration determined by laboratory analyses has been established.
It was not apparent that monitor background data has been obtained to provide accurate correlations at low and moderate countrates.
(3) The operational status of radiation monitors in the two control rooms was observed by the inspectors. No monitors were in an alarmed condition without a satisfactory reason. In the one instance where an alarm existed indicating a higher than normal radioactivity concentra-tion, the cause of the alarm was agressively pursued and apparently identified.
This area showed substantial improvement.
(4) As stated in paragraph 2a(2)(b) the inspector was not satisfied that operators were able to interpret radiation monitor readings in relation to radioactive effluent release limits.
(5) A review of calibration and functional check procedures for the unit vent iodine monitors established that Barium-133 is being used for calibrations and checks.
(6) A review of calibration procedures for RIAs 43, 44, 45, 37 and 38 revealed that in some instances specified setpoints remain in conflict with PT/0/A/230/01 which licensee representatives have stated is the controlling document. While progress has been made in this area, the necessary procedural changes were not implemented by November 1, 1976, as stated in a Duke Power Company letter to Region II dated October 20, 1976.
This item remains open.
c.
Sampling Radioactive Materials in Cases (Unresolved 77-1/1)
(1) Discussions with licensee representatives and review rf an intrastation letter dated August 1, 1977 indicated that work' was progressing to evaluate and quantify collection efficiencies for iodine sampling media.
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RII Rpt. Nos. 50-269/77-16, I-4 50-270/77-16 and 50-287/77-16 (2)
Review of the above mentioned letter indicated that charcoal loaded filter paper has been eliminated as an iodine sample media at Oconee.
(3) The inspector observed that the right angle bend upstream of the Unit 2 vent particulate sampler had been removed.
This item has been corrected on all three units.
(4)
The inspector reviewed records indicating that effluent release values previously reported were being corrected.
This item remains open pending completion of iodine sampling media efficiency testing, d.
Updating Effluent Procedures (Unresolved Item 77-8/2)
The inspector reviewed an intrastation letter dated August 1, 1977, indicating that work was progressing on this item.
This item remains open.
e.
Air Cleaning System Tests (Unresolved Item 77-8/2)
This item is closed, see paragraph 4 for details.
3.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Item 77-16/1, In-Place Filter Testing Prerequisites Data on prerequisite tests required by ANSI-N510-1975 was not immediately available.
See paragraph 4.e of these details for additional information.
4.
In-Place Filter Testing a.
Reactor Building Purge Tij'_2;c and the Spent Fuel Pool Ventilation System (1) Technical Specification 4.14 requires annually, and af ter each complete or partial replacement of a HEPA bank or charcoal adsorber bank, or after any structural main-tenance on the system housing, leak tests using cold DOP
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RII Rpt. Nos. 50-26]/77-16, I-5 50-270/77-16 and 50-287/77-16
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for HEPA banks and a halogenated hydrocarbon for charcoal adsorber banks be performed on the reactor building purge filters for Units 2 and 3.
Results of the tests shall show > 99% DOP removal and > 99% halogenated hydrocarbon removal respectively for HEPA and charcoal filters when tested in accordance with ANSI-N510-1975. An annual laboratory carbon sample from the reactor building purge filter shall show > 90% radioactive methyl iodide removal when tested in accordance with ANSI-N510-1975.
(2) The inspector reviewed the following procedures and results completed June 22, 1977 for Unit 2 and June 14, 1977 for Unit 3; PT/0/A/0110/01 Spent Fuel Pool Ventilation Test, PT/0/A/0110/05C Reactor Building Purge Filter Test, and PT/0/A/0110/05F Reactor Building Purge Carbon Filter Test.
(3)
Section 4.14 of the Technical Specifications appeared to be adequately satisfied.
The inspector had no further questions on this matter.
b.
Penetration Room Ventilation System (1)
Section 4.5.3.2 of the Techical Specifications requires annually, and after each complete or partial replacement of a HEPA bank or charcoal adsorber bank, or after any structural maintenance on the system housing leak tests using cold DOP for HEPA banks and a halogenated hydro-carbon for charcoal adsorber banks to be performed on the penetration room ventilation system.
Results of the tests shall show > 99% DOP removal and > 99% halogenated hydrocarbon removal respectively for HEPA and charcoal filters when tested in accordance with ANSI-N510-1975.
An annual laborabory carbon sample from the penetration room ventilation system shall show > 90% radioactive methyl iodide removal when tested in accordance with ANSI-N510-1975.
(2)
The inspector reviewed the following procedures and results completed June 27, 1977 for Unit 3, June 28, 1977 for Unit 2, and June 30, 1977, July 1, 1977 for Unit 1; PT/0/A/0110/04 PVRS Operating Test, and PT/0/A/0110/05B PRVS Filter Tes.
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RII Rpt. Nos. 50-269/77-16, I-6 50-270/77-16 and 50-287/77-16 (3)
Section 4.5.3.2 of the Technical Specifications appeared to be adequately satisfied, the inspector had no further questions on this matter.
c.
Control Room Filtering System (1) Section 4.12.2 of the Technical Specifications requires annually, and after any maintenance which may affect the structural integrity of either the filtration system units or of the housing, an in-place leakage test using DOP on HEPA units and Freon-112 (or equivalent) on charcoal units at design flow on each filter train, to be performed on Units 1, 2 and 3.
Removal of 99.5% DOP by each entire HEPA filter unit and removal of 99.0% Freon-112 (or equivalent) by each entire charcoal adsorber unit shall constitute acceptable performance.
(2) The inspector reviewed the following procedures and results completed June 23, 1977 for Units 1 and 2, and June 27, 1977 for Unit 3; PT/0/A/0110/5A Control Room Filter System Test, PT/0/A/0110/05G Control Room Filter System HEPA Filter Test, and PT/0/A/0110/05H Control Room Filter System Carbon Filter Test.
(3)
Section 4.12.2 of the Technical Specifications appeared to be adequately satisfied, the inspector had no further questions on this matter.
d.
Hydrogen Purge System (1) Technical Specifications, section 4.4.3.2 requires
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annually, and af ter each complete or partial replacement of the HEPA filter bank or charcoal adsorber bank, and after any maintenance on the system housing, leakage tests using cold DOP shall be performed on HEPA banks and halogenated hydrocarbon on charcoal adsorber banks.
Results of the tests shall show > 99% removal of the DOP by HEPA banks and halogenated hydrocarbon respectively when tested in accordance with ANSI-N510-1975.
(2)
The inspector reviewed the procedure and results of PT/0/A/0110/05R Hydrogen Purge Filter Test, completed July 1, 1977.
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RII Rpt. Nos. 50-269/77-16, I-7 50-270/77-16 and 50-287/77-16 (3) Section 4.4.3.2 of Technical Specifications appeared to be adequately satisfied, the inspector had no further questions on this matter.
e.
In-Place Filter Testing Prerequisites (1) Technical Specifications 4.14 (Reactor Building Purge Filters and Spent Fuel Pool Ventilation System, Units 2 and 3), 4.5.3 (Penetration Room Ventilation System), and 4.4.3 (Hydrogen Purge System) require in-place leak tests of HEPA banks and charcoal adsorber banks to be conducted in accordance with the provisions of ANSI-N510-1975.
Included in the provisions of this standard are two pre-requisite tests; section 8, Airflow Capacity, Distribution, and Residence Time Tests, and section 9, Air-Aerosol Mixing Uniformity Test, as specified in paragraphs 10.3
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and 12.3, ANSI-N510-1975.
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(2) Since these tests are normally performed only once following initial installation of filter systems, records j
of the test were not immediately available to the inspec-tor.
The inspector discussed the purpose and method of section 8 and 9 of ANSI-N510-1975 with a licensee repre-sentative and it was concluded that if satisfactory results are produced for one system and identical systems exist at the plant, then the identical systems can be considered to adequately meet acceptable criteria.
The inspector emphasized the systems must be shown to be identical for the results of tests on one system to apply to another. Futher, since testing of one system may apply to another if systems are demonstrated to be identical, the prerequisite tests (sections 8 and 9 of ANSI-N510-1975) must be carried out in strict adherence to the methods, procedures, and standards set forth in ANSI-N510-1975.
j (3) This matter is considered unresolved.
f.
Gaseous Waste Disposal Filter System (1)
Section.3.10.4.b of the Technical Specifications requires waste gases and particulates to be passed through particu-late and charcoal filters except when under unsual conditions
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RII Rpt. Nos. 50-269/77-16, I-8 50-270/77-16 and 50-287/77-16 the filter system is inoperable, gaseous wastes shall be held up for the maximum period practicable prior to release. Every reasonable effort shall be made to return inoperable filters to the operable condition before releases to the environment are made. Bases "e" of Technical Specification 3.10 also assumes a charcoal filter decontamination factor of 10 for removal of iodine in the purge exhaust system.
(2)
The inspector reviewed procedure PT/0/A/0110/05E Gaseous Waste Disposal Filter Test, and the resulst of this procedure completed June 29, 1977, for units 1 and 3.
Both the HEPA and charcoal filter banks for unit 3 demonstrated acceptable removal criteria a defined in the procedure. Unit 1 HEPA filter banks also met accept-able removal criteria, however the charcoal filter bank failed to meet the acceptance criterion defined in the procedure. Completed procedure PT/0/A/0110/05E appro-priately reviewed and dated August 3,1977 stated the following:
"Before filter replacement, this test did not meet acceptance due to filter damage.
The charcoal absorption for Freon-112 was 95%. Acceptance is > 99%.
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The filter was replaced and the test rerun with acceptable results." The inspector requested the results of the rerun test and was informed by a licensee representative that the test had net been rerun, but was scheduled to be rerua and acceptable results had not been obtained by procedural re-testing, that acceptable results had been assumed based on the replacement of the damaged filter.
The inspector discussed with a licensee representative
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the necessity of accurate information on the completed test procedure to preclude the possibility of not re-testing the charcoal filter banks when it had not been demonstrated to meet appropriate acceptance criteria, and to substantiate the credit taken for removal of iodine by the filter banks in effluent release calculations.
(3) No items of noncompliance or deviations were identified.
S.
Radiation Protection a.
The inspectors made tours of the plant on August 2 and 3 while accompanied by management respresentatives.
Instruments and
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equipment used and observed during the tour were operable and
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RII Rpt. Nos. 50-269/77-16, I-9 50-270/77-16 and 50-287/77-16 properly calibrated.
Plant personnel observed by the inspec-tors were using appropriate personnel monitoring equipment and the inspectors observed that a whole body counting program was being actively pursued.
Radiation areas and high radiation areas were properly posted and survey data was current as verifed by measurements made during the tours.
Personnel exposure records were initiated by plant personnel on the inspectors prior to allowing entry into radiation control areas. A portion of the restricted area boundary was surveyed during the tour with satisfactory results. A rather extensive contamination survey made during the tours was satisfactory.
b.
Work requests were initiated by plant personnel to repair two high radiation area doors observed to be damaged. Temporary control measures were established.
, c.
The inspectors confirmed that followup action was taken to determine the exposure status of two workers who had left incomplete exposure time cards at the unit 2 spent fuel pool control station.
d.
The inspectors commented that general housekeeping appeared poor. Bags of clothing, trash and equipment as well as loose items including wood and paper were frequently observed to be lying about in a apparently disorganized fashion.
6.
Interim Radwaste Building Effluent Monitor On August 4, 1977, the inspector determined that the RIA-53 alarm in the Unit 3 control room had been intentionally disabled.
Control operators were informed that the alarm function had been committed to by Duke Power Company as a result of an enforcement action. The alarm was reactivated immediately and the inspectors observed an alarm test.
7.
An exit interview was held on August 5, 1977 with Mr. R. M. Koehler as Mr. J. E. Smith's designated alternate and members of the Oconee staff. A deviation from licensee commitments was discussed with l
Mr. J. E. Smith by telephone on September 7, 1977.
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