IR 05000282/1989009
| ML20245L178 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/27/1989 |
| From: | Gill C, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20245L175 | List: |
| References | |
| 50-282-89-09, 50-282-89-9, 50-306-89-09, 50-306-89-9, IEIN-88-008, IEIN-88-022, IEIN-88-101, IEIN-88-22, IEIN-88-8, NUDOCS 8905050309 | |
| Download: ML20245L178 (12) | |
Text
-- - -.
J ^
'
'
',
G, (
'
,
,
j
-
E
,
m.
U.S. NUCLEAR REGULATORY COMMISSION-j
'
REGION III
' Reports No. 50-282/89009(DRSS); 50-306/89009(DRSS)
Docket Nos. 50-282; 50-306 Licenses No. OPR-42; DPR-60 Licensee:. Northern States Power Company
'y 414'Nicollet Mall Minneapolis, MN 55401.
Facility Name:
Prairie Island Nuclear Generating Plant
i Inspection At:
Prairie Island Site, Red Wing, Minnesota
)
'
Inspection Conducted:
April 3-17, 1989 j
. Inspector:
LO. ( U 4/27/ fry C. F. Gill
Date
.
Approved By:
/A. G.M 4/zy/sj W. G. Snell, Chief Date Emergency Preparedness and Effluents Section i
~ Inspection Summary Inspection on April 3-17, 1989 (Reports No. 50-282/89009(DRSS); 50-306/89009(DRSS))
l Areas Inspected:
Routine, unannounced inspection of the radwaste/ transportation proCram, including:. organization and management controls (IP 83750, 84750),
training and qualifications (IP 83750,84750), gaseous radwaste (IP 84750,
,
84724), liquid radwaste (IP 84750,84723),. solid radwaste (IP 83750,84750),
- .
radioactive material shipping and transportation activities (IP 83750), audits and appraisals-(IP 83750,84750), effluent reports (IP 84750), primary coolant radiochemistry (IP 84750), air cleaning systems (IP 84750), and selected Information Notices (92701).
Results: The organizational structure, management controls, staffing levels, and upper management support for the radwaste/ transportation program appeared generally adequate.
One violation was identified (failure to report required
- information in the semiannual radioactive effluent release reports - Section 11);
however, because the provisions of Section V.A of Appendix C to 10 CFR Part 2
,
have been satisfied, a Notice of Violation will not be issued.
Also an unresolved item was identified regarding the apparently questionable acceptance criteria for HVAC system carbon adsorber surveillance tests (Section 14).
l l
l l
-
8905050309 890428
^
PDR ADOCK 0500
,
a
,
-
_i______L-._._.---_
._
. _.
-_ _
- - - - - __
__
t
,-
.
.
.'
,
l DETAILS 1.
Persons Contacted S. Derleth, Radiation Protection Specialist
J. Friedrick, Lead Production Engineer, Radiation Protection
- T. Gatten, Chemistry Coordinator
- M. Gruber, System Operations Engineer l
- A. Hunstad, Staff Engineer
- M. Klee', Superintendent, Quality Engineering
- D. Larimer, Radiochemistry Supervisor
- D. Mendele, General Superintendent, Plant Engineering
'
and Radiation Protection
- J. Delkers, Quality Specialist
!
- C. Propst, Quality Specialist
- D. Schuelke, Superintendent, Radiation Protection
- D. Stember, Radwaste Engineer
- E. Watzl, Plant Manager
- R. Greger, NRC/RIII, Chief, Reactor Programs Branch
- J. Hard, NRC Senior Resident Inspector
- T, O'Connor, NRC Resident Inspector The inspector also contacted several other licensee and contractor personnel.
- Denotes those present at the onsite exit meeting on April 7, 1989.
- Denotes those contacted by telephone during the period April 10-17, 1989.
2.
General This inspection was conducted to review the radwaste/ transportation program. The inspection included tours of the onsite facilities, observation of work in progress, review of records, and discussions with licensee personnel.
3.
Licensee Action on Inspection Findings (Closed) Open Item (282/89009-01; 306/89009-01):
Data corrections to the 1987 Semiannual Radioactive Effluent Release Reports need to be consolidated and resubmitted to the NRC.
The licensee's corrective action commitments appear appropriate and adequate; this matter is considered closed (see Section 11).
(Closed) Violation (282/89009-02; 306/89009-02):
Violation of T/S 6.7. A.5 (failure to report required information in the semiannual radioactive effluent release reports).
Because the provisions of Section V.A of Appendix C to 10 CFR Part 2 have been satisfied, no Notice of Violation was issued; this matter is considered closed (see Section 11).
L g.
J.)
.,
,
-
.
i
..
(Closed)OpenItem(282/89009-03;306/89009-03J:
Incorrect sample volumes were used to calculate primary coolant I-131 dose equivalent concentrations.
The licensee's corrective action commitments appear appropriate and adequate; this matter is considered closed (see
.I Section 13).
'4.
Organization and Management Controls (IP 83750, 84750)
The inspector reviewed the licensee's organization and management
controls for the radwaste/ transportation program, including:
-]
organizational. structure; staffing; effectiveness of procedures and other management techniques used to implement the program; and experience concerning self-identification and correction of program implementation weaknesses.
The overall management of the radwaste/ transportation program is the responsibility of the Superintendent, Radiation Protection, who reports to the Plant Manager via the General Superintendent, Plant-Engineering and Radiation Protection.
The implementation of the program is the responsibility of the Radwaste Engineer, who is supported by two j
radiation protection specialists and plant helpers, as needed.
The
'
radwaste systems are operated by the operations department.
The responsibility for the effluent radiation monitoring systems is shared between the functional areas of operations, radiation protection, instrumentation and control, and system engineering.
The organization and management controls for the radwaste/ transportation program appear adequate.
No violations or deviations were identified.
5.
Training and Qualifications (IP 83750, 84750)
The inspector reviewed the training and qualification aspects of the licensee's radwaste/ transportation program, including:
changes in responsibilities, policies, programs and methods; qualifications of newly-hired or promoted personnel; and provisions for appropriate radwaste/ transportation training of personnel.
The inspector reviewed the training and qualification requirements and selected qualification documentation for appropriate licensee personnel; no significant problems were noted.
The inspector also verified that the radwaste/ transportation technical staff and the program's primary QC inspectors (Quality Specialists) were continuing the practice of attending seminars and workshops concerning packaging and transportation of radioactive waste material.
No violations or deviations were identified.
6.
Gaseous Radioactive Radwaste (IP 84750, 84724)
The inspector reviewed the licensee's gaseous radwaste management program, including:
changes in equipment and procedures; gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and
)
_ _ _ _
_ _ _ - _ _
l
.-
..
.
effluent monitors for compliance with maintenance, calibration, and l
operational requirements; and experience concerning identification and correction of programmatic weaknesses.
,
l Sampling and release methods and procedures, records, ar.d reports appear generally adequate with some exceptions which are delineated in Section 11.
The inspector selectively reviewed gaseous batch release permit records for 1987 and 1988; no significant problems were noted.
There were 22 and 46 gaseous radioactive effluent batch releases for 1987 and 1988, respectively; corresponding 1985 and 1986 totals were
'
19 and 14, respectively.
The frequency of batch releases has increased primarily because the licensee began recording steam relief / safety valve releases as batch releases during 1987; anytime a steam relief / safety valve discharge timer indicates a release, a batch release estimation of offsite dose consequences is performed.
The other gaseous release pathways and the sampling program are discussed in Section 2 of Inspection Reports No. 50-282/85019(DRSS); 50-306/85018(DRSS).
Recently, the licensee significantly improved oversight of the gaseous and liquid radioactive effluent release program by the effective use of modern computer technology.
The inspector reviewed summary records of gaseous radioactive effluent releases for 1985-1988.
The 1988 noble gas activity release, gamma, and beta air dose (percent of T/S limit) totals were approximately 0.142 curies, 2.04 E-4%, and 2.72 E-3%, respectively; corresponding 1987 totals were 0.876 curies, 1.09 E-3%, and 1.71 E-2%, respectively.
The 1988 I-131, tritium, and particulate activity release and critical organ dose (percent of T/S limit) totals were approximately 1.20 E-6 curies, 150.4 curies, 2.67 E-5 curies, and 0.886%, respectively; corresponding 1987 totals were 0.0 curies (below lower limit of detection),
61.5 curies, 1.54 E-3 curies (based on questionable and apparently very conservative vendor analysis results), and 0.373%, respectively.
A comparison with 1985-1986 gaseous radioactive effluent release data indicates that the amount of noble gas released decreased dramatically in 1987 and 1988 (compared to 30.3 and 45.9 curies in 1986 and 1985, respectively), the amount of I-131 release also decreased dramatically in 1987 and 1988 (compared to 2.20 E-3 and 7.29 E-3 curies in 1986 and 1985, respectively), and the calculated organ dose decreased significantly in 1987 and 1988 (compared to 1.11% and 1.37% in 1986 and 1985, respectively).
The decrease in releases is indicative of very good performance and attributed by the licensee primarily to replacement of defective fuel assemblies.
Due to recurrence of fuel problems in Unit 1 during March 1989, the gaseous effluent releases for 1989 are expected to be higher than those for 1988.
The inspector identified only one abnormal (unplanned or uncontrolled)
i
'
gaseous radioactive effluent release during the 1985-1988 time period; this release was not identified by the licensee in the semiannual radioactive effluent release report (see Section 11).
This abnormal release occurred on February 19, 1985 when a personnel error regarding system configuration resulted in gases in the Unit 2 waste gas header being released into the auxiliary building.
At 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />, the high radiation trip function of monitors 2R-30 and 2R-37 initiated the Auxiliary Building Special Ventilation System.
The dose rate at
_ _ _ _ - _ _ _
. _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
'..
..
.'
.
the site boundary, as estimated by the licensee, was 1.12 mrem / year gamma and 1.96 mrem /yr beta.
The piping alignment was corrected in approximately two hours during which about 0.2 curies of Xe-133 equivalent were released to the environs.
Corrective action included special training and procedural revision.
Interviews with personnel and documentation review indicated that the corrective action was adequate to prevent recurrence.
No violations or deviations were identified by the inspector.
!
7.
Liquid Radioactive Waste (IP 84750, 84723)
The inspector reviewed the licensee's liquid radwaste management program, including:
changes in equipment and procedures; liquid radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesses.
Sampling and release methods and procedures, records, and reports appear generally adequate with some exceptions which are delineated in
{
Section 11.
The inspector selectively reviewed liquid batch release
!
permit records for 1987 and 1988; no significant problems were noted.
l'
There were 254 and 189 liquid radioactive effluent batch releases for 1987 and 1988, respectively; corresponding 1985 and 1986 totals were 231 and 200, respectively.
The liquid release pathways are discussed in Section 3 Inspection Reports No. 50-282/85019(DRSS); 50-306/85018(DRSS).
The inspector reviewed summary records of liquid radioactive effluent releases for 1985-1988.
The 1988 whole body and maximum organ dose totals were 0.019% and 0.027% of the T/S dose limits, respectively; the corresponding 1987 totals were 0.023% and 0.019%, respectively.
The total liquid tritium and fission / activation products (without tritium, gases, alpha) releases for 1988 were 404.5 and 0.035 curies, respectively; the 1987 totals were 446.3 and 0.071 curies, respectively.
The liquid release data for 1985 and 1986 also indicate dose totals which were significantly less than 0.1% of the T/S dose limits; these low doses are indicative of very good licensee performance.
The inspector identified only one abnormal (unplanned or uncontrolled)
liquid radioactive effluent release during the 1985-1988 time period; this release was not identified by the licensee in the semiannual radioactive effluent release report (see Section 11).
This abnormal I
release occurred on August 15, 1985 (see Section 3 of Inspection Reports No. 50-282/85019(DRSS); 50-306/85018(DRSS)).
No violations or deviations were identified.
8.
Solid Radwaste (IP 83750, 84750)
The inspector reviewed the licensee's solid radwaste management program, including:
changes to equipment and procedures; processing, control, and storage of solid wastes; adequacy of required records, reports,
__ _ _ - _ - _ _ _._
-
,
..
.
-
.
and notifications; implementation of procedures to properly classify and characterize waste, prepare manifests, and mark packages; and experience concerning identification and correction of programmatic weaknesses.
The inspector reviewed selected portions of the licensee's solid radwaste processing, storage, and shipping records for 1985-1988.
The licensee records indicate that approximately 9977.4, 7127.5, 8241.6, and 4329.9 cubic feet of solid radwaste was generated in 1985, 1986, 1987, and 1988, respectively.
Although the licensee showed a downward trend in solid radwaste generation, there are still areas where volume reduction i
techniques need improvement.
Licensee records indicate that about half i
!
of the radwaste generated is dry active waste (DAW), yet the licensee has not developed an effective program to segregate contaminated and uncontaminated trash collected from the radiologically controlled area (RCA).
Until recently, the licensee has been discarding all material placed in " clean" trash containers as radwaste.
The licensee is presently storing bags containing " clean" trash temporarily in LSA boxes until an acceptable segregation program can be developed.
Once the DAW segregation / sorting / compaction program becomes more effective, the licensee should realize a significant reduction in DAW generated.
The inspector toured the solid radwaste facilities, including the storage facility and the supercompaction facility; no problems were noted.
A
,
review of solid radwaste storage records for 1985-1988 showed that the
!
storage inventory generally has remained between 1000 and 3000 cubic feet with the exception of 52 gallon drums awaiting supercompaction.
The licensee stores 52 gallon drums of solid radwaste until the number of drums is determined to be sufficient to justify a supercompaction
" campai gn. "
Records of past supercompaction campaigns indicate that the average compaction ratio is about 2.1.
The compressed 52 gallon drums are placed in 55 gallon shipment drums along with other solid radwaste.
As of April 1, 1989, the licensee had 582 52 gallon drums of solid radwaste in storage; the next supercompaction campaign is expected to begin after the current outage.
The solid radwaste storage facility (barrel yard) is quite large and is also used to store some contaminated equipment and other items which are not classified as radwaste.
Revision 1 of the Prairie Island Process Control Program (PCP) for Solidification of Radioactive Waste from Liquid Systems was issued on September 10, 1987 to add a reference to T/S 3.9 and to allow the Radwaste Engineer the use of a plant procedure for certain types of manual solidification of waste liquids.
Revision 2 of the PCP for Solidification / Dewatering of Radioactive Waste from Liquid Systems was issued on April 15, 1988 to primarily change the title and scope of the PCP to include dewatering processes.
Although the licensee does not
,
presently use the installed radwaste solidification system, the PCP still
!
allows that option.
No violations or deviations were identified.
l 9.
Transportation Activities (IP 83750)
The inspector reviewed the licensee's transportation of radioactive materials program, including:
determination whether written implementing
. _ _ _ - _ _ _ _
'
.-
,.
.
procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses.
The inspector selectively reviewed portions of the radwaste shipment records for 1987 and 1988.
The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirements.
The licensee had 12 shipments in 1988 and 18 shipments in 1987 consisting of approximately 5026.4 and 2007.6 cubic feet, respectively.
The licensee records also showed there were 11 shipments in 1986 and 14 shipments in 1985 consisting of approximately 4503 and 6089 cubic feet, respectively.
No violations or deviations were identified.
10.
Audits and Appraisals (IP 83750, 84750)
The inspector reviewed reports of audits and appraisals conducted for or by the licensee including audits required by Technical Specifications.
Also reviewed were management techniques used to implement and audit the program, and experience concerning identification and correction of programmatic weaknesses.
The inspector selectively reviewed QC inspection reports and QA audit /
surveillance reports for 1987 and 1988.
Some of the relevant QA findings are delineated below.
QA Audit No. AG 87-45-15 (Prairie Island Process Control Program):
It was noted by the auditors that the plant uses both the Hittman and Chem-Nuclear dewatering processes for radwaste disposal; however, Revision 1 of the PCP did not contain a description of these processes.
As noted in Section 8 above, this discrepancy was corrected in Revision 2 of the PCP.
QA Audit No. AG 87-24-15 (Offsite Dose Calculation Manual):
Although the auditors issued a deficiency (DG 87-2) to document three relatively minor items, they concluded that the Prairie Island quality control for effluent monitoring and the ODCM effectively implemented the applicable T/S and QA requirements.
,
l QA Audit No. AG 88-42-15 (Radioactive Effluents):
The auditor noted
the poor operability history of the discharge canal radiation monitor (R-21) and encouraged the plant to rectify the situation.
The overall conclusion was that Prairie Island effectively controls and administrates radioactive effluents.
Interviews with appropriate personnel and documentation reviews indicate that the above auditor concerns prompted adequate corrective action in a timely manner.
In addition to the above QA audits, the inspector also selected several recent QA surveillance and QC inspections of the radwaste/ transportation program for a similar review; no problets were
..
- _
_ - _ _
_
_ _ _ _
_-_ -
_ _ _ _ - _ - _ _ - _ _ - - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ - - - _.
_ _ __ __
'
u'
'. -
-
.
,
,
noted.
A review of'the certification records of th'e two lead Quality Specialists assigned to review this program indicate they are well
.
qualified and trained in this technical area.
The inspector reviewed the schedules for'QA/QC oversight (inspections, audits, and surveillance),
of this technical area for the past few years and for future planned activities; no problems were identified.
The licensee's QC inspection and QA audit / surveillance program appear adequate to assess technical performance, regulatory and procedural compliance, and personnel qualification and training of the radwaste/ transportation program.
No violations or deviations were identified by the inspector.
11.
Effluent Reports (IP 84750)
The inspector selectively reviewed radiological effluent analysis results to determine accuracy of data reported in the Semiannual Radioactive Effluent Release Reports for 1985-1988.
It was noted that the addendum to the report for the last half of 1988 contained corrections for the 1987 reports; however, these corrections were maae on 1987 report pages which had'been superseded by corrections made to the same pages (for a different type of data correction) which were included in an addendum to the report for the first half of 1988.
Upon notification by the inspector, the licensee agreed to correct the oversight by supplying the NRC with the corrected 1987 report pages (with both types of data corrections present) in an addendum to the report for the first half of 1989.
The licensee also agreed to take corrective action to prevent recurrence by modifying the computer software which generates the reports, issuance of a memorandum to appropriate personnel to inform them of the error and steps to preclude recurrence, and procedural revisions.
The licensee's corrective action commitments appear appropriate and adequate; this open item is considered closed.
(0 pen Item 282/89009-01; 306/89009-01).
Technical Specification 6.7.A.5 requires, in part, that the Semiannual Radioactive Effluent Release Reports include the identification of unplanned releases from the site of radioactive materials in gaseous and liquid effluents and include a summary of radioactive gaseous and liquid effluents as specified in Appendix B to Regulatory Guide 1.21, Revision 1, June 1974.
Section A.6 of the aforementioned appendix specifies, in part, the identification of abnormal (unplanned or uncontrolled) gaseous and liquid releases.
The inspector identified an unplanned gaseous radioactive effluent release which occurred on February 19, 1985 (see Section 6 above) but was not reported by the licensee in the Semiannual Radioactive Effluents Release Report for the first half of 1985.
The inspector also identified an unplanned liquid radioactive effluent release which occurred on August 15, 1985 (see Section 3 of Inspection Reports No. 50-282/85019(DRSS); 50-306/85019(DRSS)) but was not reported by the licensee in.the Semiannual Radioactive Effluent Release Report for the last half of 1985.
These are two examples of a violation of Technical Specification 6.7.A.5; however, pursuant to Section V.A. of Appendix C to 10 CFR Part 2, a Notice of Violation will not be issued for this isolated Severity Level V violation because the licensee initiated appropriate corrective action before the inspection ended.
The licensee initiated a procedural revision to more clearly define abnormal effluent releases and
_ - _ _ _ _ _
-
- _.
-_
.
-_
_ _ _ _
- _- _-__ ___- - - _ _ _ - _ _ _ _ _ _ _ _ _
.
..
.
,
.
committed to report the above abnormal effluent releases in an addendum to the report for the first half of 1989; the licensee's initiated / planned corrective actions are deem appropriate and adequate.
(Violation 282/89009-02; 306/89009-02)
One violation was identified; however a Notice of Violation will not be. issued.
12.
Effluent Control Instrumentation-(Ib 84750, 92700, 93702)
The inspector reviewed the record:, for effluent control instrumentation surveillance / operability.
Because recent QA audit / surveillance and QC inspection reports., significant occurrence events reports (50ERs) and
- licensee eve % reports (LERs) made numerous and frequent references to operability /autenance/ reliability problems, the inspector reviewed the work request summary listings for-1987 present and interviewed appropriate licensee personnel to ascertain the extent of the licensee's apparent weaknesses in maintaining effluent radioactive monitoring system (RMS) operability.
The reviews and discussions confirmed that the licensee has a history of significant effluent control instrumentation operability problems; however, it appears that the work requests are given a high priority and completed generally within a few days, a preventive maintenance program addresses chronic problem areas, system modifications are used as appropriate, adequate spare and rebuilt parts are kept in stock, onsite expertise is generally adequate to correct recurrent system problems, and the staff appears knowledgeable of the systems and conscientious.
Thus, e'though the licensee has a preponderance of effluent RMS problems, the staff appears to be adequately coping with the situation.
No violations or deviations were identified by the inspector.
13.
Primary Coolant RadieAemistry (IP 84750)
Technical Specification 3.1.D.1(a) requires that the specific activity l
of the primary coolant not exceed one microcurie of I-131 dose equivalent per' gram except under certain limiting conditions of operation.
The inspector selectively reviewed the licensee's primary coolant radiochemistry results for the past two years to determine compliance with the Technical Specification requirements for the I-131 dose equivalent (DEI-131) concentration.
The selective review and discussion with licensee personnel indicated that the DEI-131 concentration for the primary system
remained less than the applicable Technical Specification limit throughout
the review period for both units.
'4owever, the review identified that in j
l early December 1987, the DEI-lil es :entration increased by a factor of five on both units at the same 'iet without apparent reason.
The
Radiochemistry Supcrvisor investigated the apparent anomalies and
informed the inspector that apparently a technician had used the incorrect
'
sample volumes to calculate the DEI-131 concentrations.
The inspector was
!
informed that the licensee's corrective action would include discussing i
the incident at the next weekly meeting with the technicians, including l
J j
9'
l
_ _ _ _ _ _
i
'
..
..
.'
.
the importance of verifying that the correct sample volume is used in all calculations.
The licensee's corrective action commitments appear appropriate and adequate; this open item is considered closed.
(0 pen Item 282/89009-03; 306/89009-03)
No violations or deviations were identified.
14.
Air Cleaning Systems (IP 84750)
Technical Specifications (T/S) require filter testing of the Emergency Air Treatment Systems (all trains of the Shield Building Ventilation System and the Auxiliary Building Special Ventilation System) as specified by T/S 3.6.E and T/S 4.4.B; the Spent Fuel Pool Special Ventilation System (two trains common to both units, also used as the In-Service Purge Ventilation System) as specified by T/S 3.8 and T/S 4.15; and the Control Room Air Treatment System (two trains common to both units) as specified by T/S 3.13 and T/S 4.14.
The inplace leakage test criterion specified both for D0P testing of HEPA filters and for freon testing of charcoal adsorbers is equal to or less than one percent penetration.
The laboratory test criterion for carbon sample removal efficiency for methyl iodide is equal to or greater than 90 percent.
A selective review of surveillance test data for 1986-1988 showed that the surveillance for the above ventilation systems had met test acceptance criteria.
Although the licensee has passed the surveillance test requir nents for all appropriate ventilation systems, the inspector noted that the test conditions did not appear to meet current NRC regulatory positions in that:
Laboratory test results were often not received in a timely manner.
(The standard industry criterion is for the methyl iodide test results to be received by the licensee within 31 day from the time the carbon sample is removed from the ventilation train).
The testing methodology specified by the licensee for the methyl
}
iodide test is RDT M16-1T (per Regulatory Guide 1.52 and ANSI /ASME N509-1976).
This methodology (testing protocol) has been shown to be inappropriate; the test protocol recommended to replace RDT M16-1T is specified by NRC Information Notice No. 87-32.
The licensee acceptance criterion of 90% efficiency for carbon
adsorbers tested with methyl iodide may not adequately reflect iodine removal credit assumed in the associated HVAC system design basis safety evaluations.
The NRC regulatory position is that carbon adsorbers should be tested with methyl iodide at acceptance criteria which requires a higher efficiency than that assumed in the HVAC system design basis safety evaluation to allow a margin of safety to account for potential degradation of the carbon adsorber between surveillance tests.
The methyl iodide test specified by the licensee's Technical
Specifications is at 130 C and 95% relative humidity (RH).
The test at 130 C has been shown to be inappropriate; the NRC recommended
_ _ - _ _ _.
,
_
,
. - -. -
-
- _ _ _ _ _ _
___
,.9 D,
,
<
testing temperature is 30 C.
References:
NUREG/CR-4960 (ANL-87-22)
and EGG-CS-7653 (prepared for the NRC under contract).
'
Because all the T/S ventilation systems except the Control Room
Air Treatment System have electrical heaters to reduce the relative humidity, the T/S requirement to test the carbon adsorbers at 95%
RH may be inappropriate.
'It appears the licensee should begin specifying the acceptance
criterion to the methyl iodide testing vendor so that earlier.
notifications of potential unacceptable results may be given to the licensee.
The inspector discussed the above concerns at the onsite exit meeting on April 7, 1989; on April 17, IJ89, the licensee informed the inspector
>
that the licensee's technical staff will evaluate their current testing program and revise the Technical Specifications and plant procedures, as appropriate.
The licensee plans to complete the evaluation, request all appropriate T/S amendments, and revise appropriate procedures by the end of July 1989.
The licensee expects to work closely with their testing vendor in resolving these 1egulatory concerns, including testing carbon samples from the Shielding Building Ventilation System by the current methyl iodide testing protocol (RDT M16-1T, 130 C, 95% RH) and by the NRC l
IN 87-32 recommended protocol (30 C, 95% RH and 30 C, 70% RH), for
'
comparison.
The carbon samples for this system are scheduled to be
' collected by the licensee's technical staff as specified by the testing vendor on April 24, 1989; previously entire trays of carbon were sent Lc the testing vendor who then extracted required samples.
Pending completion of the-licensee's evaluation, this matter is considering an unresolved item which will be reviewed further during a future inspection.
(Unresolved Item 282/89009-04; 306/89009-04)
No violations or deviations were identified; however, one unresolved item was identified.
15.
NRC Information Notices (IP 92701)
The inspector reviewed licensee actions in response to selected Information Notices (ins).
For the following ins, the inspector noted:
the licensee reviewed the IN for applicability; the IN was distributed to appropriate personnel; and if applicable, corrective actions were-scheduled / performed.
Chemical Reactions with Radioactive Waste Solidification Agents.
Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations.
IN No. 88-101:
Shipment of Contaminated Equipment Between Nuclear Power Stations.
l
_ _ _ _ _ _
I
_- _ _ _ _ _ _ _ _
- .
..
.
J
-
16.
Exit Meeting (IP 30703)
The inspector met with licensee representatives (denoted in Section 1)
i at the conclusion of the onsite inspection on April 7, 1989, and by telephone through April 17, 1989.
The inspector summarized the scope and findings of the inspection, including the apparent violation and the unresolved item.
The inspector also discussed the likely informational content of the inspection report with regard to documents and processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents or processes as proprietary.
l l
l
Iu
-
_ _ _ _ _ _ _ _ _ - - - - - - - - - - _ _ _ _ _ _