IR 05000287/1979033
| ML15222A063 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/05/1979 |
| From: | Ewald S, Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15222A059 | List: |
| References | |
| 50-287-79-33, NUDOCS 8002130434 | |
| Download: ML15222A063 (6) | |
Text
0 oUNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
V101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 3030 Report No. 50-287/79-33 Licensee:
Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 Facility Name:
Oconee, Unit 3 License No. DPR-55 Inspection at Oconee n ar Seneca, South Carolin Inspector:
/3
S. C. Swald D te Signed Approved by:__
_
_
,tA. F. Gibson, Seaon Chief, FFMS Branch Date Signed SUMMARY Inspection on October 15-16, 197 Areas Inspected This special, unannounced inspection involved 17 inspector-hours onsite reviewing the draining of contaminated liquids to the sewage treatment system using a temporary drain lin Results Three apparent items of noncompliance were found in this area (Infraction Radioactive liquid release in excess of Technical Specification limits (79-33-01) - Paragraph 7; Infraction -Failure to follow liquid waste procedures (79-33-02) - Paragraph 7; Infraction - Failure to review modification of steam generator sample line drain (79-33-03) - Paragraph 7).
8 0 0 213 0 1-*+
DETAILS Persons Contacted Licensee Employees
- T. B. Owen, Superintendent of Technical Services
- R. T. Bond, Licensing and Projects Engineer
- M. L. Birch, Health Physicist, *D. P. Rochester, Station Chemist
- C. Yongue, Station Health Physicist
- R. J. Brackett, Station Senior Q.A. Engineer
- T. D. Curtis, Reactor Engineer Other licensee employees contacted included-five technicians and four operator NRC Resident Inspector
- F. Jape
- Attended Exit Interview Exit Interview The inspection scope and findings were summarized on November 16, 1979 with those persons indicated in Paragraph 1 above. Items discussed included three items of noncompliance. With regard to the item concerning the release to an unrestricted area in excess of radioactivity concentration limits, licensee representatives stated it was their opinion that the sewage treatment sump was not an unrestricted area for liquid effluent The inspector acknowledged licensee comments that proposed "Appendix I" Technical Specifications will clearly define site restricted areas but stated that the 10 CFR 20 definition of restricted area would be applied until some other site specific definition is approved by the NRC. With regard to the practice of routing Steam Generator sample line drainage to the sewage treatment system, licensee representatives stated site personnel had been instructed that this practice was unacceptable and not to be repeate.
Licensee Action on Previous Inspection Findings Not inspecte.
Unresolved Items Unresolved items were not idenfitied during this inspectio.
Event Description From 10:00 p.m. on November 10, 1979 to 6:25 a.m. on November 11, 1979, approximately 176 gallons of water were drained from the A and B once through Steam Generators, OTSG, (secondary side) to the sewage treatment system. The flow path was from the steam generator liquid sample lines through temporary tubes to' a wash sink in a mens room near the sample sink. The tubes were labeled "3A Steam Generator" and
"3B Steam Generator" and were taped to the sink. Sample analyses for radioactivity and chemistry are summarized below. From the mens room sink, the liquid drained to the,sewage treatment system sump, was processed through the sewage treatment system, and discharged to the waste oil collection basin. This pond then overflows to the Keowee Dam tailrace and subsequently to Lake Hartwell. The pond overflow has a continuous composite sampler installed and composites are routinely analyzed for gamma emmitters daily. The sampler, however, had been out of service since October 2 In lieu of the sampler, daily grab samples were taken and analyzed. Trace amounts of cesium-137 were found, but no significance can be placed on these results due to the marginally detectable quantities and uncertainties in normally expected levels due to previous release Radioactivity Analyses Date 11/10 11/10 11/10 11/10 11/11 11/11 Time 1650 1750 2210 2210 1000 1000 OTSG 3A 3B 3A 3B 3A 3B Cs-134 (pCi/cc)
6.7E-6 1.5E-5 3.2E-6 2.4E-5 5.4E-7 X
Cs-137 (pCi/cc)
1.7E-5 4.8E-5 6.9E-6 6.9E-5 1.5E-6 9.4E-7 MPC Fraction.2.1 0.13
.05 NOTE:
The analysis at 1750 on 11/10 of OTSG-3B also indicated radioactive lodines totaling 7.5 times MPC. Licensee representatives stated the iodine activity was believed to have resulted from contamination of the sample. No other analyses showed iodine activit Chemistry Analyses Date 11/10 11/10 11/11 11/11 11/11 11/11 Time 2200 2200 0530 0530 0700 0700 OTSG 3A 3B 3A 3B 3A 3B Cations (ppm)
56.65 Sodium (ppm).8 0.05 7.12 0.14 1.22 Silica (ppm)
9200 27600 800 43000 880 7000 The inspector discussed the release and use of a temporary drain line with licensee representatives. Based on these discussions the inspec tor's understanding of the rationale behind the use of the temporary line is as discussed belo Following a plant trip or other event, if chemistry problems developed, the only means of reducing chemical concentrations was a "feed and bleed" dilution'operation. The only mechanism for bleeding the secon dary side of an OTSG with system temperatures above 300'F is through the sample line. Even though'the maximum flow rate is low (about 1 liter/min.) reductions in chemical concentrations had been observe The drainage from the secondary sample sink is piped to the liquid radioactive waste system, as described in the facility Final Safety Analysis Report (FSAR) (see paragraph 6).
Previous to 1976, when primary/secondary leakage first developed at the station, secondary activity was below detectable limits, so the liquid was drained to the sewage treatment system to avoid having to process the liquid through the radwaste system. Since the development of OTSG leaks and subse quent detectable secondary system radioactivity, this practice had stopped until the event on November 10, 1979. Licensee personnel decided the radioactivity concentrations were low enough in this case
.such that it was not necessary to process the liquid through the radwaste system, so the temporary drain line was installed and use Discussions with chemistry and operations personnel indicate the drain line was used without notification of the shift supervisor or develop ment of any special procedures or other control The release was accounted for as liquid release no. 79-2277 and 79-2278 using isotopic accountability forms associated with releases from the waste oil collection basin. These forms assure the activity released is accounted for in the-semiannual release report.
Procedure and System Review The inspector reviewed procedures relating to the handling and release of liquid radioactive wastes. Procedures addressing routine releases through the liquid radioactive waste system, while containing specific controls and administrative requirements, did not address general control criteria for liquid wastes. Station Directive 3.8.21, "Radio active Waste Disposal", dated June 8, 1979, addresses these general criteria. Section 4.1.1 states all radioactive liquids must be dis posed of only in sinks and drains that go to the liquid radioactive waste system. The inspector also reviewed procedures addressing sampling and accountability of liquids released from the waste oil collection basin. The inspector also reviewed Station Directive 4.4.2, "Processing Nuclear Station Modifications", which describes administrative procedures and controls to assure management review of plant modification The inspector reviewed the Final Safety Analysis Report (FSAR) sec tions 9 and 1 FSAR Figure 9-3 shows the Steam Generator Liquid Sample lines going to a sample sink. The drain from this sink is routed to the radioactive liquid waste system. In addition, FSAR section 11.1.2.2 states low radioactivity liquids are to be routed to the low activity waste tank. FSAR section 1A.70, design criterion for
'
control of releases of radioactivity to the environment, states liquid
-4 wastes will be monitored for activity level at all times during releas The use of the temporary drain line, as described in paragraph 5, constitutes a change in the facility from the above FSAR references in that radioactive liquid from the steam generators was drained to the sewage treatment system rather than the liquid waste system. In addition, the release path incorporating the sewage treatment system to the waste oil collection basin to the Keowee tailrace, while sampled, does not provide for continuous radioactivity monitorin The inspector toured various parts of the auxiliary building and the sewage treatment system. The secondary sample sink is in a controlled, contaminated area. The temporary hose used for the release was routed through an overhead pipe penetration and down to the sink in the adjacent mens room. The inspector examined the sewage treatment system sump, located near an employee parking area. The sump is a below grade pit with a metal grating cover. No posting, labeling, or other radiological controls existed. Access to this sump, while on licensee property, is not restricted in any manner by the license.
Inspection Findings Based on examination of the release path and tours of the sewage treatment sump and facility, the inspector determined access to the sump is not controlled for the purpose of protection of individuals from exposure to radiation or radioactive materials. The sump is, therefore, not in a restricted area, as defined by 10 CFR 20.3(14).
Based on analyses of samples taken-at 10:10 p.m. on November 10, the concentration of radioactive materials in the sink drain was approxi mately 3.45 times values listed in 10 CFR 20 Appendix B, Table II, column 2. Technical Specification 3.9.3 requires the instantaneous concentration of radioactive materials in liquid waste released from the restricted area not exceed these 10 CFR 20 values. The inspector stated the release to the sewage treatment sump was, therefore, in noncompliance with Technical Specification 3.9.3 (79-33-01). Technical Specification 6.4.1.h requires the liquid waste management system be operated in accordance with approved procedures. Station Directive 4.1.1 (discussed in paragraph 6) requires contaminated liquids be drained to the liquid waste treatment system. The inspector stated that use of the temporary drain line to the sewage treatment system was not in accordance with this Station Directive and was, therefore, in noncompliance with Technical Specification 6.4.1.h, The inspector reviewed the licensee's Administrative Policy Manual for Nuclear Stations and the Duke Power Company Topical Report -Quality
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Assurance Program (Duke-1). Based on this review, the inspector determined that the requirement of 10 CFR 50, Appendix B (III) providing controls for design modifications, is implemented in part by Station Directive 4.4.2 (discussed in paragraph 6).
This Directive requires facility changes be reviewed and controlled in accordance with procedures
-5 in section 6 of the Directive. The inspector noted that the use of the temporary drain line constituted a change from the facility as described in the FSAR (see paragraph 6).
The inspector stated that failure to review the use of the temporary drain line in accordance with Station Directive 4.4.2 was in noncompliance with 10 CFR 50, Appendix B (III) (79-33-03).