IR 05000272/1982028
| ML20028D662 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/07/1983 |
| From: | Shanbaky M, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028D640 | List: |
| References | |
| 50-272-82-28, NUDOCS 8301190344 | |
| Download: ML20028D662 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-272/82-28 Docket No.
50-272 License No. DPR-70 Priority Category C
Licensee:
Public Service Electric and Gas Company Mail Code T15A P.O. Box 570
@ wark,NewJersey 07101 Facility Name: Salem Nuclear Generating Station, Unit 1 Inspection At: Hancocks Bridge, New Jersey Inspection Conducted: Sgptemb m 982,7 /
Inspectors:
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S J. R.
e, 'fenioF Racriatilh S ecialist date 1(igned Approved by:
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M. M. Shpfbaky, Chief,' FaciMties Radiation crate' signed Protection Section Inspection Summary:
Inspection on September 3, 1982 (Report No. 50-272/82-28)
Arus Inspected:
Special, unannounced safety inspection by a region-based inspector of the monitoring capabilities of the licensee relative to radio-active gas effluent quantification.
The inspection was reactive to a licensee event involving the unplanned release of radioactive gaseous material on August 27-29 and September 3, 1982. The inspection involved 6 inspector-hours onsite by one region-based inspector.
Results: One violation was identified:
Failure to follow procedures in accordance with Technical Specification 6.8 (Paragraph 3.4).
8301190344 830107
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PDR ADOCK 05000272 G
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DETAILS 1.
Persons Contacted
- H. Midura, Manager - Salem Nuclear Generating Station (SNGS)
B. Dolan, Chemistry Engineer
- W. Jocher, Senior Chemistry Supervisor
- L. Miller, Technical Manager N. Allman, Senior Staff Engineer, Licensing and Environment
- denotes personnel attending the exit interview on September 3, 1982 2.
Inspection Purnose and Scope On August 27-29 and September 3, 1982, unplanned releases of radioactive noble gases occurred. While the releases were finally determined to be of minor sigificance relative to the SNGS technical specifications, the licensee did experience difficulty in timely quantification of the releases in terms of total release, comparison to technical specifications, and release rate.
The purpose of this inspection was to review the licensee's capability in this area, and to initiate actions as necessary to resolve problems involving the monitoring of gaseous effluer.ts.
3.
Gaseous Effluent Monitoring, Noble Gas 3.1 References NRC80 NRC Inspection Report 50-272/80-03 (dated June 13,1980)
which transmitted the findings of the NRC Health Physics Appraisal of SNGS on January 28 through February 8, 1980.
NRC81 NRC Inspection Report 50-272/81-20 (dated October 26, 1981)
for the inspection period June 29 through July 29, 1981.
SGS80 SNGS response letter to NRC Inspection Report 50-272/80-03 (Health Physics Appraisal), dated July 7, 1980.
SGS81 SNGS response letter to NRC Inspection Report 50-272/81-20, dated November 25, 1981.
NRC82 NRC Inspection Report 50-272/82-12 (dated June 14,1982)
for the inspection period May 12 through June 8, 1982.
3.2 Description The effluent monitor 1R16 (four inline G-M tubes) is the licensee's primary device for the monitoring of effluent noble gas through the Unit-1 plant vent.
In accordance with the SNGS Offsite Dose Calcula-tion Manual (00CM), 1R16 alarms at 500,000 cpm which indicates the
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Environmental Technical Specification (ETS) instantaneous release rate limit for noble gases (ETS Section 2.3.3.a.1).
Assumed in the 3 per minute and a 00CM is a plant vent flow rate of 1.25 E5 ft sensitivity to Xe-133 of 3.6E7 cpm /pCi/cc.
3.3 Background The NRC Health Physics Appraisal Report (NRC80) identified that the licensee did not systematically review the plant vent noble gas monitor recorder 1R16 for quantification of anamalous releases during periods between monthly grab samples. The 'icensee's response (SGS80) indicated that procedure PD-3.8.023, Chemistry Analysis Summary Forms, was amended to provide for daily review and documen-tation quantifying anomalous releases.
Further, the response stated that procedures PD-3.3.020, Plant Vent Sample Analysis, and PD-3.8.016, Gaseous Radwaste Release Calculations, were similarly amended to provide for additional review and control to assure that all gaseous releases were subject to evaluation. The response stated that all of these actions were completed as of July 7,1980.
In a followup inspection (NRC81) it was determined that none of the actions pertaining to 1R16 described in the licensee's responses had been implemented.
Review of procedures PD-3.8.023, PD-3.3.020 and PD-3.8.016 indicated that the procedures had not been amended or revised; and that there was still no system established to review and quantify anomalous noble gas releases.
In response (SGS81), the licensee identified that the procedural changes were implemented by August 1, 1981. This action was confirmed by a NRC inspection (NRC82) which verified that the procedures had been revised to evaluate and record the values provided by 1R16 on a daily bases sufficient to review and control anomalous releases.
3.4 Procedures The following procedures were reviewed in this inspection:
PD-3.8.023, Rev. 1, Chemistry Analysis Summary Forms PD-3.8.016, Rev. 4, Gaseous Radwaste Release Calculations PD-3.3.020, Rev. 2, Plant Vent Sample Analyses It was found that while the licensee did amend the procedures, actual practice (i.e., relying only on manthly grab samples to quantify and qualify releases in continuous mode) had not changed. The procedures, as amended, were not being followed. As a result, the basis of the concern expressed in the report (NRC80) had not been resolved.
Technical Specification 6.8 requires that written procedures be established, implemented and maintained for activities identified in Appendix "A" to Regulatory Guide 1.33, November 1972.
Regulatory Guide 1.33, November 1972, Appendix "A", Section G.3 identifies
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procedures for sampling and monitoring of gaseous effluents.
Proce-dure PD-3.8.016 wcs developed in accordance with this requirement.
Sections 3 through 5 of this procedure provide for quantification of gaseous radwaste releases by u:ing data derived from 1R16 (pending instrument efficiency determination from Johnson Comb grab samples).
This method is referenced in Procedures PD-3.8.023 and PD-3.3.020.
Contrary to Procedure PD-3.8.016, from the time of the implementation of Revision 4 on July 31, 1981, the licensee failed to use IR16 in accordance with the stated requirements.
Rather, the licensee used a technique involving monthly Johns n Bomb grab samples to quantify gaseous releases in the continuous mode.
It was noted that such technique was not specified as the method by which to quantify such releases in the applicable procedures.
Failure to follow the requirements of Procedure PD-3.8.016 constitutes a violation of Technical Specification 6.8 (272/82-28-01).
4.
Reports of Gaseous Activity References:
SNGS82 1982 Semiannual Radioactive Effluent Release Report (RERR-12), August 1982.
The report (SNGS82) specified the following releases of fission and activation gases for the first half of 1982 (Continuous and Batch Modes):
1st Quarter 0.295 Curies 2nd Quarter 0.250 Curies Total 0.545 Curies According to the Senior Staff Engineer-Licensing and Environment, this data was derived from Johnson Bomb grab samples for the period, and considered only those samples having activity greater than the Minimum Detectable Activity (MDA). Activities less than MDA were neglected from the report.
In contrast, the licensee's contractor for the evaluation of gaseous activity noted that if values less than MDA were not neglected, such Johnson Bomb grab samples would indicate an upper limit of approximately 245 Curies of activity released in the continuous mode for the period.
Further, it was noted that had 1R16 been used to quantify the release of gaseous activity, 1059 Curies of noble gas activity could have been indicated in the continuous mode for the first half of 1982.
The inspector noted that the incongruity of these values for this period, i.e., 0.545, 245 and 1056 Curies, was such that the veracity of the licensee's report (SNGS82) and previous reports was in question.
In response, on November 1, 1982, in a telephone discussion of this area, the Senior Staff Engineer-Licensing and Environment committed to review all reports submitted to the Commission since 1976 to determine the
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accuracy of gaseous release activity data submitted. The individual indicated that the results of this determin tion would be submitted to the Regional Administrator, NRC Region I by January 18, 1983.
This item is unresolved pending review of the licensee's submittal.
(272/82-28-02)
5.
Corrective Measures The following corrective actions to enhance the licensee's response to situations involving unplanned or anomalous gaseous releases were identi-fied by the Senior Chemistry Supervisor in a telephone discussion on September 2, 1982:
The specified sensitivity of 1R16 has been amended from 3.6E7 to
4.9E9 cpm /pCi/cc, Xe-133. This revision is due to a new determina-tion of instrument efficiency via correlation to actual measured activity.
Further evaluation of instrument sensitivity will be acomplished in the next outage. The Offsite Dose Calculation Manual will be amended to reflect this new instrument sensitivity value.
A new procedure has been implemented to evaluate and integrate the
IR16 recorder on a daily bases to determine actual released activity in both the continuous and batch mode.
The IR16 alarm set point has been changed from 500,000 cpm (the
instantaneous release rate limit for noble gases, Environmental Technical Specification 2.3.3.a.1) to 10,000 cpm.
The control room alarm response procedure, EI-416, has been amended
to require operators to record 1R16 values and plant vent flow rates, and calculate instantaneous release rate and activity discharged every half hour whenever 1R16 is in the alarm condition.
Data derived from 1R16 will be entered into the calculational program
daily to evaluate the noble gas release in regard to technical speci-fications, design criteria, operational performance off-site doses, and reports.
6.
Exit Interview The inspector met with the licensee's representatives (denoted in paragraph 1) at the conclusion of the inspection on September 3, 1982. The inspector summarized the purpose and scope of the inspection and identified findings as described in this report.
The licensee representative stated that corrective actions in the areas identified would be implemented, and that notification of actual plans would be made to the USNRC, Region I, following this inspection. Such notifications were made on September 19 and November 1, 1982 via telephone discussions with the inspector.
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