IR 05000302/1979035
| ML19250C441 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/20/1979 |
| From: | Ewald S, Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19250C436 | List: |
| References | |
| 50-302-79-35, NUDOCS 7911260129 | |
| Download: ML19250C441 (7) | |
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101 MARIETTA sT N.W SUITE 3100 ATLANTA, GEORGIA 30303 g***** e Report No. 50-302/79-35
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Licensee: Florida Power Corporation 3201 34th Street St. Petersburg, Florida 33733 Facility Name: Crystal River Unit 3 License No.
DPR-72 Inspection near Crys al Ri c, Florida Inspected ty:
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i A. F. ' Gibson, Section Chief, FF&'fS Branch Date Signell SUMMARY Inspected on August 28-31, 1979.
Areas Inspected This routine, unannounced inspection involved 34 inspector-hours onsite in the areas of liquid effluent controls and accountability for the secondary system.
Results Of the two areas inspected, no apparent items of noncompliance or deviations were identified... I area; Two apparent items of noncompliance were found in one area (Infraction - liquid release exceeding regulatory limits, Paragraph 5; Infraction - Inadequate procedure for releases from secondary system, Paragraph 7).
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s DETAILS 1.
Persons Contacted
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Licensee Employees
- G. P. Beatty, Jr., Nuclear Plant Manager
- T. C. Lutkehaus, Nuclear Technical Services Superintendent
- J. R. Wright, Chemical and Radiation Protection Engineer
- J. L. Harrisson, Assistant Chemical and Radiation Protection Engineer
- G. G. Ruszala, Supervisor, Radioactive Waste Management
- R. E. Fuller, Plant Engineer G. M. Williams, Nuclear Compliance Plant Engineer J. Cooper, Nuclear Compliance Engineer Other licensee employees contacted included six technicians and two operators
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on August 31, 1979, with those persons indicated in Paragrpah I above.
Items discussed included two items of noncompliance and two unresolved items. With regard to the controls for secondary system releases, facility management representatives stated the controls discussed in Paragraph 8 would be followed.
3.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (79-33-01) Unplanned Liquid Release. The inspector reviewed the events and records relating to unplanned liquid releases from the Turbine Building Sump that occurred on August 16 and 21, 1979. The inspector's review and findings are discussed in the remainder of this report.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviations. New unresolved items identified during this inspection are discussed in paragraphs 7 and 8.
5.
Unplanned Liquid Releases
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Liquid effluents from the Turbine Building Sump are normally routed to one of two waste percolation ponds onsite but outside the restricted This sump collects liquids from various secondary sources area.
including floor drainage, valve leakage, and condensate from auxiliary steam. The Turbine Building Sump effluent is sampled with an automatic composite sampler and analyzed for radioactivity on a daily schedule.
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-2-The Turbine Building can also be aligned to discharge to the Secondary Neutralizer Tank (SDT-1) for batch release.
b.
On August 17, analysis of a Turbine Building Sump composite sample, representative of 82,800 gallons discharged to the waste pond on August 16, indicated activities in excess of 10 CFR 20 Appendix B, Table II, Column 2 limits (MPC) by 22 percent.
Isotopes identified included radioiodines, cesiums, and cobalts. The activity apparently resulted from sluice water generated during the transfer of secondary demineralizer resins to a shipping liner for disposal. The resin liners were dewatered to the turbine building sump. The potential for activity being discharged to the sump via the sluice water had been recognized and piping modifications were in progress to install a dewatering line to SDT-1, however, the modifications were not yet complete. Procedural controls, detailed in Operating Procedure OP-601, Section 16 requires the Turbine Building Sump discharge be valved to SDT-1 as an initial condition for resin transfer operations.
This procedure is discussed further in Paragraph 7.
The licensee, in response to this release, temporarily stopped all secondary resin transfers.
Instructions to this affect were noted in the secondary plant operators log.
On August 22, analysis of the Turbine Building Sump composite sample, c.
representative of 25,540 gallons discharged on August 21, indicated radioactivity in concentrations totaling 76 percent of MPC. No resin transfers were in progress and the sump was discharged to the waste ponds. The source of the activity could not be isolated and is assumed to have resulted from various valve leaks, heater drains, etc.
The concentration increased to the observed level apparently as the result of a reduction in uncontaminated input volumes rather than an increase in contaminated volumes or concentrations. This assessment is justified in that Turbine Building Sump discharge volumes ranged typically from 70,000 to 190,000 gallons per day, thus the 25,540 gallons released on August 21 indicates a substantial reduction in inputs to the sump.
d.
Technical Specification 2.4.1.A requires the instantaneous concentration of radioactive materials in liquid waste effluents not exceed concentrations in 10 CFR 20 Appendix B, Table II, Column 2.
The inspector stated that the release of liquids on August 16, with concentrations exceeding the value,s, would be considered a noncompliance (50-302/79-35-01).
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6.
Temporary Controls of Secondary System Releases Various intermediate and long term corrective actions and controls a.
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were discussed in a telephone conversation on August 24 between the NRC Region II facility management and confirmed in a letter to the licensee dated August 27, 1979. The inspector reviewed the licensee's implementation of these corrective measures as discussed below.
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-3-s b.
The inspector verified that Turbine Building Sump discharges were being handled on a batch basis with isotopic analysis prior to release.
Due to processing limitations inherent in the existing system (pump and line capacities) licensee representatives stated tha_t batch processing of Turbine Building effluents would likely not be able to keep up with input volumes during plant startup, trip or shutdown.
The inspector and Region II were notified on August 31 that the facility expected to depart from the batch release mode over the next few days.
The controls and procedures necessary for this departure are discussed in paragraph 8.
In the telephone discussion August 24, and confirmed in the referenced c.
letter, the licensee stated installation of a continuous radiation monitor was being considered along with new procedural controls and operator training. The inspector reviewed temporary procedural changes and the Short Term Instruction requiring operations staff review of these changes. These procedural modifications appeared adequate as long as releases were made on a batch basis.
Procedural modifications for other modes of release, as discussed in paragraph 8, were under development. Facility management stated that alternate, continuous release modes, would not be implemented until the associated procedural modifications were complete.
In addition, on August 29, the Plant Manager informed the inspector that the decision to install an effluent radiation monitor had been made and work was in progress to install the monitor as soon as possible. Details relating to this monitor are discussed further in paragraph 8.
7.
Procedures and Documentation Technical Specification 6.8.1.a requires procedures referenced a.
in Regulatory Guide (R.G.) 1.33 (1972) must be established, implemented and maintained. Section G.I.c of R. G. 1.33 references procedures for limiting radioactive materials released to the environment in liquid effluents. The inspector reviewed the following plant procedures as they applied to the unplanned releases discussed above.
Operating Procedure OP-601, " Condensate Demineralizer System" Operating Procedure OP-407," Liquid Waste Disposal System" Administrative Instruction AI-500, " Conduct of Operations" Compliance Procedure CP-111, " Nonconforming Operations" b.
Section 16 of OP-601 contains procedural requirements for the transfer of exhausted resin to shipping liners.
Step 16.1.15 states that the Turbine Building Sump pumps are to be lined up to SDT-1 as a prerequisite to resin transfer operations. Section
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4.15 contains a precautionary statement that if primary-to-secondary leakage is suspected or known to exist, all secondary cycle waste releases need to be considered radioactive until determined otherwise. The inspector reviewed secondary plant operator log i394 244
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-4-s entries for the period August 15 thru August 24.
Based on log entries the Turbine Building Sump was apparently aligned to the waste ponds from 2:30 p.m. August 16 until 9:10 a.m. August 17.
However, discussions with several secondary plant operators indicated this log is not a complete record of all valve line-ups, and similar actions. The inspector reviewed daily surveillance records of SDT-1 level, performed on a shift basis, and noted that between 4:00 p.m. on August 16 and 8:00 a.m. on August 17, the tank level increased from 11.5 feet to 13.75 feet (approximately 10,000 gallons). Discussions with licensee representatives indicated no other routine inputs to SDT-1 are made, thus the 10,000 gallons was apparently from the Turbine Building Sump. Further review of OP-601 Section 16 indicated no guidance as to when to realign the sump back to the waste ponds after completion of resin transfer operations. Due to the operating cycle of the Turbine Building Sump pumps, based on sump level, aligning the sump effluent during transfer operations does not assure all or any of the sump inventory generated will be pumped to the SDT-1 tank.
Based on the above review and discussions, the inspector concluded that, while log entries may be incomplete, the was an indication that the procedural requirement of OP-601, Section 16 had been accomplished, but that these procedure precautions were inadequate to provide the level of control necessary to assure compliance with Technical Specification release limits. The inspector
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stated that this inadequacy in OP-601 would be considerd in noncompli-ance with Technical Specification 6.8.1.a (79-35-02).
In reviewing the releases from the Turbine Building Sump c.
the inspector examined the relevant Nonconforming Operation Reports (NCOR), Followup Reports (FUR), log entries, Short Term Instructions, and Temporary Procedure changes, as well as the procedures controlling the various types of documentation.
While the inspector found no items of noncompliance or examples of failure to follow procedures, the inspector expressed concern that 1.he documentation of these events lacked appropriate depth and detail. NCOR 79-310, generated in response to the release of August 16, describes the event as "Hi gross beta (activity) in Turbine Building Sump", with tin only documented corrective action being " Reported to Shift Supervisor".
The only documentation of corrective action was a log entry noting the restrictions on resin transfer operations.
The same concerns relative to documentation of operations related to effluents from the secondary system were also discussed.
The inspector noted no records of resin transfers or records of precautions, valve lineups, etc.
for turbine building sump releases are routinely kept. These procedural precautions normally documented with check lists or signoffs, are specifically
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exempted by AI-500, Section 2.7, which states that procedures not directly affecting the reactor, reactor ccalant system or engineered safeguards are written as operator guides and require no signoffs or approval. The inspector stated these concerns about documentation of events, corrective actions, and routine operations involving radio-active effluents would be unresolved (79-35-03) pending further 1394 245
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-5-s review by the inspector.
8.
Long Term Controls for Secondary System Releases During the inspection, various long term secondary system effluent a.
controls were discussed with licensee representatives.
License-representatives agreed that secondary system releases would be controlled within the following constraints (1) No contiraous releases will be made to the waste percolation ponds.
Continuous releases will be made to the discharge canal.
(2) Accountability for secondary system releases would be based on analyses of the automatic composite sampler.
(3) Releases would be made on a Batch Basis with activity-analysis prior to discharge OR a continuous basis with a continuous radiation monitor (RML-7) OR on a continuous basis with analysis of the automatic liquid composite sample every four hours.
With regard to Item 1 above, discharges will be made to the Nuclear Services Seawater effluent to provide dilution for the secondary system discharge.
The inspector verified the isolation valve (SDV-50) in the line from the Turbine Building Sump to the waste ponds had been tagged closed and locked. With regard to Item 2 above, the inspector stated the automatic composite sampler would be representative provided all other secondary system effluent paths were routed to the Turbine Building Sump, all other inputs to SDT-1 were positively controlled, and controls to assure the same sump effluent flow (one vs.two pump operation) were implemented.
With regard to Item 3 above, the inspector stated the four hour analyses for continuous /no monitor releases need not be isotopics but must demonstrate compliance with regulatory release limits.
b.
The specifications relating to the continuous radiation monitor were discussed with licensee representatives on several occasions during the inspection. The inspector stated the monitor would need to meet the following criteria to assure compliance with release limits (1) The monitor must alarm prior to concentratiens in the
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effluent to the unrestricted area exceeding'rechnical Specification 2.4.1.A limits.
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(2) Automatic termination of the release based on monitor alarm or equivalent alarm response procedures are required.
(3) The monitor will be subject to surveillance requirements similar to those specified in Technical Specification 2.4.1.N.
(4) The effluent flow rate shall be continuously monitored.
The licensee is continuing to review other long term controls c.
including installation of redundant equipment and additional batch tanks. The inspector stated these controls would be reviewed as they are implemented.
d.
The inspector noted several of the above controls are under development and installation. These controls will necessitate several procedure and system modifications.
Licensee representatives stated the continuous release modes would not be implemented until the procedural and other modifications were complete. The inspector stated completion and implementation of these controls would be unresolved (79-35-04) pending their completion and review.
9.
Sample Analyses On August 29, 1979, the inspector took liquid and sediment samples from the two waste percolation ponds. Licensee representatives also took and analyzed liquid samples and results indicated all activities were below minimum detectable levels.
The NRC analyzed the liquid and sediment samples verifying activity was below MPC for unrestricted areas.
While the NRC analyses did identify trace levels of several isotopes comparison with licensee values is not meaningful due to the very low levels and large associated errors in the analyses.
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