IR 05000272/1978030
| ML18078A920 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/28/1978 |
| From: | Crocker H, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18078A913 | List: |
| References | |
| 50-272-78-30, 50-311-78-52, NUDOCS 7903070181 | |
| Download: ML18078A920 (14) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 78-30 Report No. 78-52
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Do c ket No. 50-311
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Region i L i cens e No. CPPR-53
Priority -------
Category c
B
Licensee:
Public Service Electric and Gas Company 80 Park Place Newark, New Jersey Facility Name:
Salem Nuclear Generating Station, Units l and 2
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Inspection at:
Hancocks Bri.dge New Jersey Inspection conducted:
December 12-15, 1978 inspectors:
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J. WQ_~~te, Radiatiori'Specialist Approved by~~~
H. W. Crocker, Acting Chief, Fuel Fadlity Project Section, FF & MS Branch Inspection Summary:
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date 'signed date signed date signed
- date' signed Inspection on December 12-15. 1978 (Report Nos. 50-272/78-30; 50-311/78-52)
Areas Inspected:--Routine, unannounced inspection by one NRC regional based inspector of the Radiation Waste Systems necessary for Unit 2 operatio Areas included the verification that the installed Liquid, Gaseous, and Solid Waste System conform to FSAR commitments, Area and Process Radiation Monitor Systems, Procedures for the control and release of Radioactive Water, and Containment and Auxiliary Building Air Cleaning System In addition, the inspector also reviewed items that were identified in the previous inspectio The inspection involved 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> on-site by one NRC inspecto Results: Of the six areas inspected, three items of noncompliance were found in the following areas (Unit 1, Infraction - failure to evaluate concentrations of airborne
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ioactivity in accordance with 10 CFR 20. 103, Paragraph 4.c) (Unit 1, Deficiency -
lure to adhere to procedures in accordance with Technical Specification 6.8, agraph 4.b) (Unit 1, Infraction - failure to perform review in accordance with CFR 50.59 for change in a system described in the FSAR, Paragraph 4.a). Tours of both Unit 1 and Unit 2 were taken to review the implementation of the Radioactive
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DETAILS Persons Contacted
- H. J. Mtdura, Manager, Salem Nuclear Generating Station (SNGS)
- J. Gueller, Senior Performance Supervisor
- M. F. Metcalf, Resident Quality Assurance (QA) Engineer
- B. Leap, Station QA Supervisor
- L. K. Mi 11 er, Performance Engineer
- F. J. Robertson, Senior Maintenance Supervisor
- O. W. Lyons, QA Specialist
- J. R. Ronafalvy, Waste Co-ordinator, Operations Department E. A. Pierce, Start-up Engineer, Unit 2 J. Gagliardi, Corporate Sponsor Engineer, Radiati.on Monitoring System
- L. J. Norrholm, NRC Resident Inspector, SNGS
- denotes those present at the exit intervie The inspector also interviewed several other licensee employees including m~mbers of.the Maintenances Operations, and Performance Department.
Licensee Action on Previous Inspection Findings; Bulletins and Circulars References:
(a)
IE Bulletin 78-07, 11Protection Offered by Air-Line Respirators and Supplied Air Hoods,
dated June 12, 1978
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(b)
Licensees' Response to IE Bulletin 78-07, dated July 20, 1978
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(c)
IE Bulletin-78-08, 11Radiation Levels from Fuel Element Transfer Tubes, 11 dated June 12, 1978 (d)
Licensees' Response to IE Bulletin 78-08, dated August 7, 1978 (e)
IE Notice of V1olation, dated June 12, 1978
(f) Licensees' Response to IE Notice of Violation (dated June 12, 1978), dated August 11, 1978 (g)
Licensee Supplemental Information to IE Notice of Violation, (dated June 12, 1978), dated September 27, 1978 (h)
IE Circular 1a..:.03, 11Packaging Greater Than Type A Quantities of Low Specific Activity, 11 dated May 12, 1978 (Clos~d) IE Bulletin (272/78-BU-07): The inspector noted that at this time the licensee does not have a Respiratory Protection Program in accordance with 10 CFR 20.103, and is, ther~fdre, not taking credit for respiratory protective device However, the licensee is preparing procedures to include the information covered in Reference (a). to support the* expected development.'of a Respiratory Protection Program by April 197 The inspector noted that Reference (b) adequately responded to IE Bulletin 78-0.
(Closed) IE Bulletin (272/78-BU-08): The inspector reviewed Reference (d) in response to Reference. (e), and found that this item is being followed-up by the stations QA grou In addition, the inspector noted that the outage scheduled for the first refueling of Unit l has incorporated special survey requirements to evaluate radiation streaming from the fuel transfer tub (Closed) Noncompliance (272/78-18-01): Change in a procedure described in the FSAR without a review in accordance with 10 CFR 50.5 The inspector reviewed the licensees response, Refer-ence (f), to th~ Notice of Violation, Reference (e), and verified the procedure OQA-5, 11Auditing 11 had been amended as state The inspector also reviewed the licensee's supplemental information
[Reference (g)] concerning this area and noted that this item was, in fact, previously identified by the Quality Assurance Department - Corporate as early as March 13, 1978; but that the station had not taken timely corrective action. in that procedure OQA-5 was not amended until July 197 (Closed) Circular (272/78-CI-03): The inspector.noted that the licensee intends to incorporate the information contained in
- Reference (h) in procedure PD 15. 4. 007, 11 Shipments of Radioactive Material 11 which is currently undergoing revisio [ *
(Open) Inspector Follow-up Item (311/78-13-01): Descrepancies in Performance Department Manua The inspector reviewed this area and noted that the licensee is still in the p~ocess of amending the Performance Department Manua (Open) Inspector Follow-up Item (311/78-13-03): Development of Health Physics Procedure The inspector noted that the procedures previously identified in Inspection Report 311/78-13, are in-draft form but have not been reviewed or implemente (Open)- Inspector Follow-up Item (311/78-13-04): Resolve descre-pancies in current Health Physics Procedure The inspector noted that the procedures previously identified in Inspection Report 311/78-13, are currently undergoing revision but have not yet been implemente {Open) Inspector Follow-up Item (311/78-13-05): Health Physics (HP) Technician Training Program Development.. The inspector noted that the licensee has initiated a HP Technician retraining but has not yet developed a long term retraining program in accordance with Technical Specification 6.4, Training.
(Open) Inspector Follow-up Item (311/78-13-06): Development of a Respiratory Protection Progra The inspector noted that.the licensee is currently developing procedures, training programs, and acquiring the necessary equipment to support a Respiratory Protection Program in accordance with 10 CFR 20.10 Implemen-tation of such a program is expected by the licensee in April 197 (Open) Inspector Follow-up Item (311/78-13-07):. Design and Relo-cation of Health Physics (HP) Facilities. Initial movement of the HP facilities to the Service Building has been amended from January to March 197 The Design Change Request to support the design of the facilities has been approve.
Radiation Monitoring System The inspector reviewed the status of the Unit 2 Radioactive Mani~
taring (RM) System against the description presented in the Licensee's tinal Safety Analysis Report (FSAR), Chapter ll, 11Waste Disposal and Radiation Protection Systems.
The licensee is still awaiting delivery of several system compo-nents ( pri nci pally, the computer system. needed for support of the RM system and various process and area monitoring detectors.) At this time only 2-R9 (area monitor, Fuel Storage Area) was operationa The inspector reviewed the planned Unit 2 RM System installation against the description presented in the FSAR, and noted the following descrepancies:
FSAR Description Containment Fan Cooling Coil Water - 2 R-13, A, B, C, 0, E Waste Gas :EffTDent*2 R-14 Letdown Line 2 R-31A {_Gross)
2 R-318 (Iodine)
2 R-31C (Iodine/Gross)
Unit 2 Planned Installation 2 *R-13, A, B, C (Note -
These monitors are being used to replace the original five described in the FSAR)
2 R-41, A, B, C (Note - 2 R-41 replaced 2 R-14; the three channels independently monitored particulates, gross iodine, and noble
- gas)
2 R-31 (Note - 2 R-31 replaced the original three channel elements but is capable of providing the same information)
- Condensate Fflter Atea:
M&nitor - 2 R-40
- Steam Generator Blow-down Filter - 2 R-38
- Gas Decay Tanks Area Monitors - 2 R-42, A, B, C, D
- These morii tors.are 1.additions to the RM Sys:tem.and are beyond the description preserited"in**the *FSAR.
The inspector interviewed the Corporate Sponsor Engineer for this system who indicated that a amended system description was in process and would be incorporated as a change in the FSA The inspector indicated that this item would be reviewed in a subsequent. inspection to verify that the system is correctly described in the FSAR (311/78-52-01)
The inspector also indicated that since the RM system was not completely installed, a review of the operation and calibration of the system would be performed in a subsequent inspection (50-311/78-52-02).
Radioactive Waste System Components The inspector reviewed the following Radioactive Waste System Components against the description presented in the FSAR~ Chapter 11, 11Waste Disposal and Radiation Protection Systems.
Unit 2 Rad Waste System Components Name
~ Quantity Volume Reactor Coolant Drain Tank Hori Ga Waste Hold-up Tank Hori.
3300 Ft3;
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Sump Tank (and associated pumps)
Hori l
.1000 Ga Gas Decay Tanks Ver Ft Gas Compressors
Name Waste Evaporator Evaporator Mixing Tank Evaporator Condenser Absorption Tower Distillates Cooler Concentrates Pump Distillates Pump Drumming Station Waste Monitor Hold-up Tank Waste Monitor Tanks Spent Resin Storage Tank Nitrogen Mani fa l d Hydrogen Manifold
Quantity Volume
(Note - Due to the experience gained with the operation of the Unit 1 Evapor-ator of the same type, the licensee intends to replace this unit later during the opera ti on of the facility in order to reduce the effect of chloride stress corrosion._)
(Note - This unit is operational and is currently used to support Unit l operations)
Hori T 3300 Ft Ver Ga Ver l 300 Ft (Note - This system is i nsta 11 ed)
(Note - This system is construction)
still under
~11 of the listed components were verified to be in place as described, with the exception of the Hydrogen Manifold which is still undergoing constructio The installed ~omponents are currently in various stages of final construction and pre-operational testin The inspector indicated that this area wo~ld be reviewed in a
- subsequent inspection to verify completed installation of all system components (50-311/78-52-03).
Procedures The inspector noted that the following procedures effecting the central and operation of the Unit 2 Radioactive Waste System had been developed and approved in accord with Technfcal Specifications 6. 9 ~
11 Procedures, 11 and 6. 11,
11 Radiation Protection Progra Procedure Title M7A - 7E Solid Waste System - Baling, Drumming, and Shipping-.: *
PD-3.8.015 Use of Liquid Waste Release Form PD-3.8.016 Gaseous Rad Waste Release Calculations I I-11 WASTE DISPOSAL SYSTEM - LIQUID WL QI Il-11. 3. 1 Waste Ho 1 dup Tanks - Norma 1 Opera ti on QI rr-11. Release of Radioactive Liquid Waste to the Circulating Water System Or II-11. 3. 3 Waste Evaporator - Normal Operation OI II-11. Reactor Coolant Drain Tank - Normal Operation O.I II-11. Chemical Drain, Laundry and Hot Shower Tanks - Normal Operation Or rr-11. Discharge of Chlorided Water Or Ir-12. Gaseous Waste Disposal System - Normal Operation Or rr-12. Removal of Moisture from Gas Decay Tanks OI II-12. Discharge of Gaseous Waste to the Plant Vent OI If-12. Transfer of Waste Gas
A licensee representative indicated to the inspector that the Operating Instructions were about 70% completed as of December 12, 197 The inspector indicated that this area. would be reviewed in *a subsequent inspection to verify that all procedures* necessary for operation of the Unit 2 Rad Waste System were completed (50-311/78-52-04).
In-Place Testing, Air Cleaning Systems A licensee representative informed the inspector that though the containment and auxiliary building air cleaning system had been installed, the element had not been subject to in-place testing of the efficiencies of the High Efficiency Particulate Air Filters or the Charcoal Absorber Banks in accordance with ANSI-N510-1975,
"Testing of Nuclear Air Cleaning Systems. '
The inspector indicated that this area would be examined in a subsequent inspection to verify the testing had been accomplished (50-311/78-52-05). Unit 1 Radioactive Waste System The course of the reviewing the pre-operation status of the Unit 2, the inspector examined several elements of the Unit l system to verify control and implementation of the 1 i'censee' s Radioactive Waste Management and Radiation Protection Progra The following was noted: Regulation 10 CFR 50.59, "Changes, tests and experiments,"
states, in part:
11 (a)(l) The holder of a license authorizing operation of a production or utilization facility may... make changes in the facility as described in the safety analysis report... without prior Commission approval. unless the proposed change... involves a change in the technical specifications incorporated in the license or an unreviewed safety questio (2) A proposed change.. ~ shall be deemed to involve an unreviewed safety question (i) if the probability of occurrence or the.
consequences of an accident of malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased; or (ii) if a possibility for* an accident or malfunction of a safety analysis may be created; or (iii) if the margin of safety as defined in the basis for any technical specification is reduce (b) The licensee shall maintain records of changes in the facility... {including} a written safety evaluation which provides the basis for the determin-ation that the change... does not involve an unreviewed safety question."
The licensee's Final Safety Analysis Report, Chapter 11,
"Waste Disposal and Radiation Protection Systems" describes the Liquid Waste Disposal System in Figure 11. 1-1 (See
Simplified Drawing of the Chem-Nuclear/Liquid Waste System Interface, 11 Figure A).
- The licensee administrative procedure AP-8, "Station Design Changes, Tests and Experiments" requires that a Design Change Request be processed and reviewed in accordance with 10 CFR 50.59 for changes in facility involving the change in mode of operation of systems (or components) described in the FSA Through discussions with licensee personnel and a review of records, the inspector learned that on about August 2, 1978, the licensee modified the Unit l liquid waste disposal system in accordance with Work Authorization No. OD-9915 in order to make hose connections to a Chem-Nuclear Filtration and Demineralization Syste The licensee indicated that such connections were necessary to augment the Waste Evaporator system which was failing due to leakage caused by chloride
stress corrision; (The Waste Evaporator system was later removed from service entirely).
Hose connections were made-up to lWL-79, Evaporator Feed Pump Discharge Valve; and lWL-84, Evaporator Filter Outlet Valv The hose connections were made to these valves (1 T/2 11 Grinell-Saunders Disphragm Valves) by removing the valve bonnets and replacing them with hose adaptor device The inspector noted that such modification changed the mode of operation of the valves in that the valves were not able to be operated in the normal manner, but rather served only as a hose connectio The inspector noted that this modification to the liquid waste system, as described in the FSAR, was made in accord with Work Authorization No. OD-9915. The licensee represen-tative indicated that no evaluation or review was made tn accordance with AP-8 "Station Design Changes, Tests and Experiments" or 10 CFR 50.59, to support this change in the facilit The licensee representative also indicated that the hose conne~tions to the Chem~Nuclear System were expected to remain in place for at least a year; and, therefore, a station operating instruction was being developed in order to operate the Chem-Nuclear System as Normal Station Equipment.
- The inspector identified that failure to perform a review in accordance with 10 CFR 50.59 prior to changing the facility as described in the FSAR constituted noncompliance (50-272/ 78-30-01}.
. Technical Specification 6.8, "Procedures, states, in part that written procedures shall be established, implemented, and maintained covering the activities referenced in the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33,. November, 1972. This regulatory Guide identifies "Baling Machine Operation" in Appendix 11A
, Item G. In accordance with this requirement procedure M7A, "Solid Waste Compactor Operations" was develope This procedure requires that a radiation monitoring instrument (PIC-6) be installed, calibrated, and operating on the compacto~ in order to provide information concerning the activity contained in the drums of compacted radioactive materia Contrary to this requirement, on December 14, 1978, the inspector observed a waste compaction operation being per-formed in accordance with Extended Radiation Exposure Permit (EREP) No. 2E25, and noted that the PIC-6 survey meter required by procedure M7A was not installed; and there was no other radiation monitoring device being used to provide the monitoring functio The inspector noted that this item was previously identified in the licensee's audit of the March 31, 1978 (Audit #78-3-C.3-2)~
in which the immediate corrective action was to re-install the monitoring devic The inspector identified that failure to adhere to procedures
.in accordance with Technical Specification 6.8 constttutes an item of noncompliance (50-272/78-30-02). O CFR 20. 103, "Exposure of* i.ndivi dua l:s to concentrations of radioactive materials in air in restricted areas 11 states, in part: "No licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radi:oactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week of 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table I, Column 1... For purposes of determining compliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radioactive materials *in air for detecting and evaluati.ng airborne radioactivity in restricted areas."
- Contrary to this requirement,* on December 14, 1978, the inspector observed that a solid radioactive waste compacting operation was in progress in accordance with EREP No. 2E25, 11Waste Compaction...
Through discussion :with licensee per-sonnel, the inspector learned that breathing zone type air samples or grab air samples were not used to provide measure-ments of the concentrations of radioactive material in air to which the compactor operator was expose The licensee explained such measurements are made by use of a Continuous Air Monitoring (CAM) unit located outside of the compactor work tent, with the air suction hose located in the work tent; in the vicinity of the operato The inspector noted that the CAM unit used to support this operation was not energized, and;.therefore, had not been
- monitoring the operato Upon notification, the licensee representative initiated action to stop compactor operation The inspector observed that the compactor operator was wearing
- a respi*ratory protection device in accordance with the require-ments EREP 2E2 The inspector identified the failure to use suitable measure-ments of concentration :of radioactive material in air for detecting and evaluating airborne radioactivi'ty in restricted area constituted noncompliance with 10 CFR 20.103 (50-272/78-30-03).
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The inspector informed the licensee representative that use of a CAM as the sole method of monitoring personnel exposure to airborne radi oacti vi ty was not sati s'factory with out an evaluation based on direct measurement of the concentrations
- of radioactive material :in and to which personnel were expose The representative indicated that health physics procedures would be modified as necessary to assure that meaningful measurements of airborne radioactivity are utilized to support work activitie The inspector indicated that this item would be reviewed in a subsequent inspection (50-272/78-30-04) *
- 13 Exit Interview The inspector met with the licensee's representatives (denoted in paragraph 1) at the conclust6n of the inspecti-0n on Decembe~ 15~
197 The inspector summarized the scope and findings of the inspection as noted in this report.
Figure A, Simplified Drawing of the Chem-Nuclear/Liquid Waste System Interface To: I No. 1 Waste Evaporator Out of _$er.v.i-cc *.
' ' t 1WL90 1WL89 Chem-Nuclear
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Filtration and r
- HJL84 Hose./ n Connecti ans ~
Demineralization System (TEPS)
Hoses
~-J-----~ *1WL79 No. 1 Waste Evaporator Feed Pump
- Modified Grinnel"'."Saunders 1 1/2" valves (i.e., bonnets removed; adapter plates installed with pipes for hose connections)
To: Nos. 11 and 12 Waste Hold-up Tks; No. 1 Waste Monitor T From:
Nos. 11 and 12 Waste Hold-up Tks; No. 1 Waste Mani tor.
Hold;..up Tk.*