IR 05000293/1981004
| ML19350F120 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/05/1981 |
| From: | Knapp P, Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19350F114 | List: |
| References | |
| 50-293-81-04, 50-293-81-4, NUDOCS 8106240236 | |
| Download: ML19350F120 (15) | |
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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-293/81-04 Occket No.
50-293 C4cegory C
License No. OpR-35 Priority
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Licensee:
Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name. pilgrim Nuclear power Station Inspection at: Plymouth, Massachusetts Inspection conducted:
February 3-5, 1981 Inspectors:
R. L. N d 6I5 Bl
Nimitz, RaMation Specialist-date signed o
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Approved by datfe tigned Peter J. Knapp, Chief, Fadility Radiological
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Protection Section, Technical Inspection Branch Insoection Summary:
Inspection on Febru_ary 3-5, 1981 (Report No. 50-293/81-04)
Areas Insoected: Special, announced inspection by one regional based inspector of the circumstances and licensee actions taken following an event on January
17, 1981 during which radioactive spent resin leaked from a building to a driveway located outside the building. Areas inspected included:
adherence t l
procedures, procedure adequacy, surveys, releases to the environment, event l
circumstances, emergency plan implementation, personnel exposures and corrective actions. The inspection involved 20 inspector-hours onsite by one regional based inspector.
Results: Of the eight areas inspected, no items of noncompliance were identified
j in six areas. Two items of noncompliance were identified in two areas (Failure to perform surveys in accordance with 10 CFR 20.201(b) to ensure compliance with
l 10 CFR 20.101, Paragraph 5.a; Failure to prepare procedures in accordance with i
Section 5.3 of ANSI N18.7-1972 as required by Technical Specification 6.8, Paragraph 6 ).
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Region I-Form 12 (Rev. April 77)
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OETAILS
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1.
Persons Contacted
- R. Kuhn, Senior Radio 1cgical Engineer
- R. D. Machon, Nuclear Operations Manager
. C. J. Martin, Shift Technical Advisor C. J. Mathis, Deputy - Nuclear Operations Manager
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J. J. McCann, Watch Engineer T. McGlaughlin, Senior Compliance Engineer L. J. Olivier, Operations Supervisor W. F. Olsen, Senior Nuclear Training ' Specialist S. C. Powers, Nuclear Plant Operator P.-Smith, Chief Technical Engineer
- E. Zemanski, Management Services Group Leader
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- J. Johnson, USNRC Resident
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- denotes those persons attending the exit interview on February 4,1981.
The inspector also contacted other members of the licensee's radiological controls organization including supervisory and technical personnel.
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2.
Inspection purpose
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The purpose of this inspection was to reviqw the circumstances and licensee followup actions taken subsequent to an. event on January 17, 1981, during which radioactive spent resin leaked from the Pilgrim Unit 1 Resin Addition Room to a driveway located outsfde the room.
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3.
Event Description At about 11:30 a.m. on January 17, 1981, a nuclear plant operator, who
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was awaiting a delivery of fuel oil, noticed material seeping under the
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Resin Addition Room truck bay door (See Figure 1). The material was l
flowing and was approximately 2-3 feet from the door at the initial I
identification. Using a telephone on an outside building wall, the
operator notified the Reactor Control Room of the seepagt. Since a snow storm during the previous evening resulted in approximately 6 inches of accumulation, the operator also notified an onsite snow plow crew via the security radio system. The crew subsequently plowed a " snow dam" to prevent movement of the material.
Following receipt of the telephone call from the operator, the Operations Supervisor, notified the Watch Engineer of the seepage. The Watch Engineer immediately obtained the keys to the Resin Addition Room and, accompanied by a Shift Technical Advisor, proceeded from the Control Room to the area i
of the seepage. The Operations Supervisor also notified the shift radiation l
protection technician of the seepage and requested that he respond to the
area.
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Figure 1 Facility Layout A
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Upon arrival at the area, a period of less than several minutes from receipt of the initial call to the Control Room, the Watch Ergineer noted the seepage to be in progress and the material to have flowed out to approximately 6 feet from the truck bay door. The Watch Engineer, noting the material to have a high probability of flowing under the snow to a storm drain located approximately 30-40 feet from the door, decided to enter the Resin Addition Room to attempt to secure the leak causing the seepage. This decision was made based on the individual's knowledge that the storm drain flowed directly into the plant discharge canal and that the leak was possibly due to a valve being left open which resulted in a similar event in December of 1977. The Watch Engineer further believed that, based on his previous experience with spent resin and the amount of time he was to spend in the room, the radiological hazard associated with the entry'would not be significant.
Based on this knowledge, the Watch Engineer unlocked the door to the room, proceeded to the resin addition
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hopper (See Figure 2) and secured two condensate transfer valves through which spent resin was ' flowing into the hopper from the cation regeneration tank. The regeneration tank contained resin which was being backwashed.
The Watch Engineer spent an estimated 30 seconds in the room.
l Upon his exit from the Resin Addition Room, the Watch Engineer contacted the Control Room via the outside telephone and directed the Control Room to initiate the station Emergency plan. After the notification of the Control Room personnel, the Watch Engineer entered the Auxiliar Building
and encountered the responding shift radiation protection technician.
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The technician surveyed the Watch Engineer and found him to be radioactively contaminated. The Watch Engineer was requested to shower by the technician, however, the Watch Engineer indicated to the technician that, as the Emergency Director, he must wait to be relieved prior to showering. The
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Watch Engineer removed his contaminated clothing, dressed in protective clothing, and departed the area.
Discussions with the Watch Engineer l
indicated he d,id shower and check himself for contamination prior to l
going to the Control Room. The frisk indicated he was free of contamination.
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After completion of surveys of the Watch Engineer, the shift radiation l
protection technician went to the area of the seepage and found personnel
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shoveling the radioactive material into barrels. The technician did not immediately perform radiation surveys initially upon his arrival, but rather allowed personnel to continue shoveling. The surveys were not performed because the technician did not want to interrupt the shoveling operations. The Technician said that he allowed the shoveling to continue for at least five minutes before he performed any survey to evaluate the radiological conditions under which the personnel were working.
Subsequent surveys performed of the material indicated the resin was radioactive with contact gamma dose rates up to approximately 300 millirem /hr and beta dose rates up to approximately 1000 millirad /hr. The technician roped and barricaded the area and collected an air sample.
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In accordance with the Emergency Plan, additional personnel arrived onsite to assume.their respective emergency duties. The spent resin, contaminated water and snow were placed in radioactive waste liners and later moved to the turbine deck. The emergency was declared terminated at 3:00 p.m. that day (January 17,1981).
4.
Emergency Plan Implementation a.~
Notifications The inspector reviewed the notifications made by the licensee in accordance with Pilgrim Nuclear Power Station Procedure No. 3.1.1.3,
" Radiation Emergency", Revision 9.
Review of licensee documentation of the spill and discussions with
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personnel indicated that,'following the Watch Engineer's exit from the Resin Addition Room and his assessment of the spill, the Watch Engineer contacted the control room and directed that Control Room personnel implement tSe Emergency Plan. The Control Room personnel, based on information supplied by the Watch Engineer, declared a Category I Radiation Emergency Alert. Utilizing guidance provided in this procedure category, the control room personnel notified the NRC and those persons identified in the procedure.
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The review, indicated the licensee appeared to have adhered to the
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requirements for personnel notification.
No items of noncompliance were identified.
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b.
Restricted Area Surveys The inspector reviewed documentation of " rapid area surveys" performed by personnel following the iclaration of the alert. The surveys reviewed were performed in accordance with Pilgrim Nuclear Power Station Procedure No. 5.1.1.3 (discussed above) and Procedure No.
5.1.2.2, " Rapid Protected Area Survey," Revision 6.
Review of the survey data and discussions with personnel present during the event indicated that a rapid area survty was commenced and completed within approximately 10 minutes of declaration of the alert condition. All areas identified in Procedure 5.1.2.2 as required to be surveyed were documented as indicating less than 1 millirem / hour. Based on review of the data and discussions with personnel involved, the rapid area survey was performed in accordance with Procedure No. 5.1.2.2.
No items of noncompliance were identified.
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5.
Pre-Entry Surveys The inspector reviewed the event with respect to the requirements of 10 CFR 20.201, " Surveys".
10 CFR 20.201(b) requires that each licensee make or cause to be made surveys as may be necessary for him to comply with the requirements of 10 CFR 20. 10 CFR 20.201(a) defines a survey as an evaluation of the radiation hazards incident to the' production, use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of conditions. When appropriate,10 CFR 20.201(a) requires the evaluation to include a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material 'present.
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Radiation Surveys
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The inspector reviewed the extent of Resin Addition Room radiation surveys performed by the licensee to ensure compliance with 10 CFR 20.101, " Radiation Dose Standards for Individuals in Restricted Areas." 10 CFR 20.101(a) requires that no licensee possess, use or transfer licensed material in such a manner as to cause an individual to receive radiation exposures in excess of the limits specified therein.
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Inspector review of the event and discussions with personnel involved t
l in the emergency response indicated that during the-Watch Engineer's initial entry into the Resin Addition Room to secure the open valves, no physical survey of the radiation emanating from the spent resin was made to ensure compliance with 10 CFR 20.101. The discussions did indicate that the Watch Engineer had a general knowledge of the radiation, dose rates (approximately 400 mR/hr) emanting from a condensate demineralizer containing spent resin. However,-this
l knowledge was based on a resin bed which had been in-service for a normal period (1-2 weeks). The resin spilled during this event was, per discussions with the Watch Engineer, to have originated from a
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condensate demineralizer which had been in-service for a period of approximately 4 weeks. The discussions with the Watch Engineer indicated that although he did not know how much higher the radiation levels would be, he did not envision the dose rates to be much higher.
The inspector review of the Watch Enginer's knowledge of the radiation l
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l dose rates emanting from the spilled spent resin indicated thi.t, l
based on his previous knowledge of the contact radiation dose rates l
on the sides of the facility's condensate demineralizers, the Watch Erigineer did have a general idea of the anticipated gamma dose rates
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to be encountered during the entry. The review did indicate, however, that the Watch Engineer did not have any idea of the beta radiation dose rates to be encountered during his entry into the room. During
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' the entry, the Watch Ens neer sustained spent resin contamination of.
his hair and was noted to fisicate that his shoes became wet as a result of walking through the resin and water.
Radiation measurements made on spent resin iside the Resin Addition Room indicated contact stes of approximately 300 mR/hr and approximately gamma and beta dc
1000 mrad /hr, respectively.
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The inspector noted that the Watch Engineer's general knowledge of the gamma exposure rate, although limited, appeared adequate to ensure his whole body gamma exposure limit would not be exceeded. However, his i
knowledge of the beta radiation dose rates was insufficient to determine if the allowable dose to the skin of the whole body limit would be exceeded and therefore, a physical survey of beta radiation dose rates was appropriate for the entry.
The failure to perform a survey la accordance with 10 CFR 20.201(b) to ensure compliance with 10 CFR 20.101(a), prior to the entry of the Watch Engineer into the Resin Addition Room, is not cited; since (1)
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the timely actions of the Watch Engineer were necessary to protect the environment, and (2) the conclusions of the Watch Engineer's that the entry was not a hazard, although based on an incomplete analysis, has been determined to be correct by NRC analysis.
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Following the Watch Engineer's exit from the Resin Addition Room, and within approximately 5 minutes, personnel began to shovel the
radioactive spent resin, which had seeped under the Resin Addition Room door, into containers. This was to prevent it from flowing into the storm drain.
Inspector review of the cleanup indicated that during the initial cleanup and up to approximately several minutes after arrival of the responding radiation protection technician, no radiation surveys were performed by either the personnel performing the cleanup or by the responding radiation protection technician.
Discussions with the radiation protection technician involved indicated he did not perform radiation surveys immediately upon arrival but rather, allowed the personnel to continue shoveling the material into the containers. This again was to preclude the material from running into the storm drain.
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The inspector noted that, although the individuals were acting to prevent an offsite release, radiation surveys necessary to assure that the method chosen could be accomplished without personnel overexposure and to assure compliance with 10 CFR 20.101 were required to be performed. The inspector expressed concern with licensee representatives regarding the radiation protection technician's apparent failure to perform surveys upon his arrival at the seepage Rather, the technician apparently placed emphasis on barricading
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the area. The inspector noted the event occurred on a Saturday, a day which limited personnel traffic would be expected in the area.
As a result, the inspector indicated that failure to survey as required by 10 CFR 20.201(b) to ensure compliance with 10 CFR 20.101(a)
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constitutes noncompliance with 10 CFR 20.201(b). (50-293/81-04-01)
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b.
Airborne Radioactivity Surveys The inspector reviewed the airbor'.e radioactivity surveys performed by the licensee.in accordance with 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in
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restricted areas." Paragraph (a)(1) of 20.103 requires that no licensee possess, use or transfer licensed material in such a manner -
as oto permit, in a restricted area, any individual intake of a quantity of radioactive material in excess of the limits specified therein.
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As discussed above, a " survey" is defined as an evaluation of the l'
radiation hazards associated with radioactive materials or other sources of radiation. When appropriate, this evaluation includes a
. physical. survey of the meterial and measurement of radiation or concentrations of radiotutive material present.
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In reviewing the initial entry by the Watch Engineer into the Resin Addition Room to secure the leak, the inspector noted that the Watch Engineer did perform an evaluation of the airborne radioactivity hazards which would be encountered upon his entry into the room.
Based on the information tn at the leaking radioactive material was wet and estimating the duration of his entry was to be short, the Watch Engineer believed the radiological hazard 'due to the presence of airborne radioactive material would not be significant.
- The inspector roted that the knowledge that the material was wet would serve as an indication that airborne particulate radioactive material would not be a signi,ficant hazard.
The inspector noted, however, that this evaluation was inadequate with regard to airbor o
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gaseous radioactive material, particularly radiotodine. Discuss'sns with the Watch Engineer indicated he believed that airborne radiofodine would not,be a significant hazard due to the short amount of time that he was to be in the room.
Inspector analysis using primary coolant fodine-131 data from a sample taken on November 25, 1980, the Watch Engineer's reported staytime, and an assumed iodine partition coefficient of IE-2, indicated that this individual would not have sustained an airborne iodine-131 exposure in excess of 40 MPC-hours (i.e., less than 10% of the allowable exposure limit). The inspector further noted this estimate was conservative. A whole body count of this individual indicated no intake of radioactive material (See Section 7.b).
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The inspector also reviewed air samples collected during the cleanup of the resin on the driveway. No airborne radioactivity was detected
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in thase samples.
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6.
Procedures As discussed in Paragraph 3, the resin spill was apparently a result of
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valves being left open during new resin addition. Consequently, the inspector reviewed the event with respect to licensee adherence to, and i
the adequacy of, the existing procedures for addition of resin to the condensate demineralizer system.
Technical Specificatio.: 6.8, " Procedures," requires in Paragraph A that written procedures and administrative policies be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix "A" of USNRC Regulatory Guide 1.33.
Appendix "A" of USNRC Regulatory Guide 1.33, 1978, recommends in Paragraph 4 that procedures for startup, operation and shutdown of Safety-Related BWR Systems be prepared.
Included is the recommendation (Paragraph 4.n) that procedures for the condensate system, including demineralizer resin regen-eration, be prepared.
- ANSI N18.7-1972, " Administrative Controls for Nuclear Plants," requires in Section 5.3, "Openating and Maintenance Procedures," that nuclear power plants are to be ope, rated in accordance with written procedures that pro-i vide an approved, preplanned method of conducting operations to minimize reliance on memory.
Section 5.3.2 of ANSI N18.7-1972 lists the significant'
aspects of the content of procedures that are in accordance with common
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practices.
Section 5.3.1, Procedure Scope, of ANSI N18.7 requires that each procedure be sufficiently detailed for a qualified individual to perform the required function without direct supervision, but need not provide a complete description of the system or plant process.
Section 5.3.2.4, Prerequisites, of ANSI N18.7 recommends that each pro-l cedure identify those independent actions or procedures to be completed and plant conditions that exist prior to its use.
Section 5.3.2.5, Precautions, of ANSI N18.7 recommends that precautions be established to alert the individual performing the task to those situations in which important measures should be taken early or where extreme care should be used to i
l protect equipment, personnel, including the public, or to avoid an abnormal
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or emergency situation.
Included in these significant aspects of the content of procedures is the recommendation in Section 5.3.2.8 of ANSI N18.7 that, for complex procedures, checkoff lists be included in the procedure or appended to it.
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The licensee has established and implemented Procedure No. 2.2.97, " Condensate
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Demineralizer System," Ravision 13, dated December 17, 1980, for operation of the condensate domineralizer system.Section VII.J of this procedure provides guidance for replacing and loading resins.
Inspector review of the procedure with respect to the above Technical Specification requirements indicated that the procedure did have a section dealing with addition of new resin to the system. However, the guidance provided was limited in that details and prerequisites to ensure that all valves opened during the addition were identified and indicated as requiring closure upon completion of addition were not included in the procedure.
Specifically, the procedure did not identify or require closure of the condensate transfer valves which bypass the 2-inch block valve downstream of the resin hopper. These open transfer valves, as indicated by the Watch Engineer who closed them, allowed spent resin to run into the resin addition nopper and subsequently overflow during backwash of resins on January 17, 1981.
In addition, the procedure was noted to reference the " resin addition
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tank" and opening of sludge water thereto; however, the review of the
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process and instrumentation diagramt referenced in the procedure did not indicate the presence of a " resin addition tank". The inspector noted this may be a misnomer of the resin hopper.
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Further review of the procedure indicated it did not provide precaution to
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alert individuals implementing the procedure that failuras to close valves, such as the bypass. valves, opened during loading of the resin would result in a situation (i.e.
spilling of spent resin) that would affect personnel
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or public safety and result in an abnormal or emergency condition.
The inspector noted a similar event had occurred on December 7, 1977, during which spent resin spilled into the Resin Addition Room, seeped under the room door and flowed into a storm drain. During that event, the 2-
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inch block valve had been left open following a resin addition.
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The inspector noted that for the December 7 spill, the licensee had committed to training of the operators in the requirement for adherence to procedures as the corrective action for that event.
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Regarding valve checkoff lists, the inspector noted the condensate demin-eralizer system procedure to have checkoff lists attached. However, the lists did not identify the 2-inch block valve downstream of the resin hopper, or the condensate transfer valves which bypass the block valve, or the required position of these valves.
In addition, the procedure sect:on for loading resins identified a cation drain valve (S-30-101) to be opened
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and closed during the loading;- however, the checkoff list appeared to identify this. valve as a 3-inch hand operated valve and did not identify it
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by number as referenced in the procedure. The required position of this valve was presented in the checkoff list.
The inspector discussed the above findings with licensee representatives and expressed concern regarding the lack of adequate prerequisites and precautionary notes to ensure the procedures met the recommendations of ANSI N18.7, Section 5.3.
The inspector noted in discussing the previous resin spill with these individuals that no apparent action had been taken to review and correct the procedural inadequacies subsequent to the p-e-vious spill from the resin hopper (December 7,1977).
As a result, the inspector indicated that failure to establish, implement and maintain procedure's consistent with the requirements and recommendations of Section 5.3 of ANSI N18.7-1972 as required by Technical Specification 6.8.A, con-stitutes noncompliance. (50-293/81-04-02).
Following this spill, licensee representatives held a critique to identify the cause of the spill and to determine corrective actions to be implemented to preclude a similar event. These corrective actions included:
the updating of the procedure to identify the additional condensate transfer
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water piping and purpose of same, development of a checklist for loading resin, and updating of the process and instrumentation diagrams to reflect the additi,onal piping.
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7.
Personn'el Excosure
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a.
Radiation Exoosu.-e The inspector discussed the radiation exposures received by the per-sonnel during their response to the event with licensee radiation protection. representatives. Based on these discussions, personnel were noted to have received no significant radiation exposure.
b.
Airborne Radioactivity Exposure The inspector reviewed the licensee's followup to identify and deter-mir.s the amount of any airborne radioactivity intake sustained by the individuals responding to the event.
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Review of the. data of the Watch Engineer's whole body count performed approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after his entry into the Resin Addition Room to secure the resin leak indicated no radioactivity intake above mini-mum detectable occurred during his entry. The minimum detectable activities of the whole body counts when combined with the clearance which could take place in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> indicate that intake by the worker was well with regulatory limits for the radionuclides present.
Further review of the whole body counting of personnel involved in the cleanup of the spill indicated that the individuals who shoveled the material into drums were not whole body counted. These individuals were frisked with thin window GM tubes, found to be free of contamination, and subsequently permitted to re+frn to normal duties.
Inspector discussions with licensee representatives regarding the above indi-cated that, because the material shoveled was wet and because the individuals were found to be free-of contamination, the whole body counts did not appear to be necessary.
In addition, an air sample was collected during the cleanup, counted and found not to indicate any unusual airborne radioactivity concentrations. 'The inspector noted,
however, that this air sample was collected after the cleanup had l
j begun and may not have represented airborne radioactivity concentra-l tion during the initial cleanup. The inspector did acknowledge.that the probability of significant airborne radioactivity being present was low, however, whole body counts of selected individuals involved
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in the shoveling of the radioactive resin appeared to be warranted.
- l Licensee representatives acknowledged the above and indicated whole l
body counts would be performed on individuals involved in the initial l
cleanup (50-293/81-04-03).
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8.
Releases to Environment
!
The inspector reviewed the event to determine the amount, if any, of radioactive material which was released to the environment.
,
The review indicated that the licensee was able to contain the spill and l
did not release any material to the storm drain. This storm drain was l
checked for contamination and none was found. During the cleanup, the drain had been covered and sealed to prevent any contamination from flowing into i
it.
In addition, based on the air samples collected during the cleanup operations, no detectable airborne radioactive material had been released during the spill.
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9.
Corrective Actions The inspector met with those licensee representatives identified in Section l'
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.of this report to determine what corrective actions they had planned to esta-
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blish and implement to prevent a recurrent of this event.
In addition, the licensee's Nuclear Operations Manager and members of his staff were contacted by telephone on February 9, 1981, by the inspector and representatives of USNRC Region I.
Based on the results of the February 9,1981, telephone discussion, it was understood that the'following actions would be undertaken:
Condensate demineralizer resin additions would not be performed again
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until the condensate demineralizer system operating procedures had been reviewed and revised to include the appropriate prerequisites, precautions and checkoff lists as necessary to ensure consistency with Section 5.3 of ANSI N18.7-1972.
..
All operating personnel responsible for operation of the condensate de-
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mineralizer system would be instructed in the revised procedures, dis-cussed in paragraph 1 above, prior to their performing resin addition.
Documentation of this training would be available for NRC review.
Changes to the condensate demineralizer resin regeneration system piping
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and. instrumentation dr,awings to reflect the resin addition hopper
, piping would be initiated by March 1, 1981. ' Revision to system. piping
,
and instrumentation drawings reflecting a walk-down of all accessible portions of the system would be completed by September 1, 1981.
,
,
A policy statement would be issued to all station personnel by February
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13, 1981, to provide guidance on personnel protection when repair /cor-rective a,ction is performed during a radiation emergency.
In addition,
l a procedure change notice would be issued by February 13, 1981, to re-quire evaluation and appropriate action for personnel safety prior to taking actions which may be hazardous.
These understandings were documented in a letter dated February 10, 1981, to the licensee's Vice President - Nuclear from the Director, Region I.
Additional licensee corrective actions were identified to the inspector at the exit interview on February 5, 1981..These are-discussed in Section 10 l
of this report.
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10.
Exit Interview The inspector met with licensee representatives (denoted in Section 1 of this report) at the conclusion of the inspection on February 5,1981.
-The inspector summarized the purpose, scope and findings of the inspection.
Licensee. representatives stated the following:
The condensate demineralizer system operating procedures would be
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revised by March 1, 1981, to include the valves left open during and prior to the January 17, 1981 event.
Radioactive Waste System operators would be trained in the revised
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procedures discussed above by March 15, 1981.
A document change notice for rev'ision of the process and-instrumen-
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tation drawings to include the valves left open during the January 17, 1981, event would be initiated by March 1, 1981.
The Emergency Implementing Procedures would be revised by April 1,
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1981, to include the topic of radiological protection for personnel
. responding to emergencies.
The operation performed which resulted in the spillage of resin on
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January 17, 1981, was not anticipated to be performed prior to proced-ure revision and instruction of operations personnel in the revised procedure.
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