IR 05000321/1990021
| ML20058H850 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 11/01/1990 |
| From: | Hughey C, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058H847 | List: |
| References | |
| 50-321-90-21, 50-366-90-21, NUDOCS 9011260087 | |
| Download: ML20058H850 (11) | |
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UNITED STATES
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g NUCLEAR REGULATORY COMMISRION
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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!!0V 131990 Report Hos.:. 50-321/90-21 and 50-366/90-21-Licensee:
Georgia Power Company P.O. Box 1295
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Birmingham, AL 35201 Dohket Nos.-:
50-321 and 50-366 License Nos.: DPR-57 and NPF-5
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Facility Name: 'Hotch 1 and 2 Inspection Conducted: October 1-5, 1990 Inspector:
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d,_ d /,y.g-C.A. Hughey
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-Accompanying Perso ch P
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Facilities Radiation Protection Section.
Radiological Protection and Emergency Preparedness Branch.
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Division =of Radiat. ion Safety and Safeguards n
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- Scope
This routine unannounced inspection was conducted in" areas of whole body counter
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and radioanalytical laboratory quality control',; fuel quality, ALARA, hydrogen water chemistry,.and zinc oxide injection.
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s Results:
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In'the areas inspected no violations'or deviations were identified.
Two previously identified violations and three Inspector Followup Items were -
. closed (Paragraph 2).
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The licensee whole body: counting and radioanalytical quality contro1~ programs were considered adequate in ensuring accurate counting results (Paragraphs 3 and 4).
' Fuel' integrity in both Units appeared to be excellent based on dose equivalent iodine results, noble gas measuremenis from the condenser air ejector and cesium 1134/137 ratio calculations (Paragraph 5).
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Due to unexpectedly high dose rates in the Unit 1 drywell during the Spring 1990 outage, total site person-rem for 1990 was expected to be well in excess of the best estimate goal of 1050 person-rem.
As of the end of August 1990, collective site exposure was 1400 person-rem. Personnel contaminations were tracking toward the expected yearly goal (Paragraph 6).
Hydrogen injection rates had been significantly reduced and protection levels against intergranular stress corrosion cracking had significantly improved in Unit 1 since_the condenser tube replacement, in an attempt to reduce cobalt-60
[1 deposition in reactor coolant piping thereby reducing exposure source term, the
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licensee had begun zinc oxide injection 'n both Units during August 1990
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(Paragraph 7),
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REPORT DETAILS i
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Persons Contacted Licensee Employees
- J. Hamonds, Regulatory Compliance Supervisor W. Kirkley, Plant Engineering Supervisor T. Metzler, Acting Manager, Nuclear Safety and Compliance
- M. Link, Health Physics-Supervisor
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- D. Read, Assistant General Manager Operations
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- J. Reddick, Health Physics Supervisor M. Rigsby, Plant Health Physicist
- D. Smith, Health Physics Superintendent
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- L. Sumner, Plant General Manager
- S. Tipps, Manager, Nuclear Safety and Compliance i
- R. Zavadoski, Manager, Health Physics and Chemistry l
Other licensee employees contacted during this inspection iacluded-technicians, securi_ty and office personnel.
I Nuclear Regulatory Commission
- R. Musser, Resident inspector L. Wert, Senior Resident Inspector
- Attended exit meeting
i 2.
Licensee Action on Previously Indentified Items (92701)
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a.
(Closed)
Violation (VIO) 50-321, 366/89-28-01: Failure to maintain high i
radiation area door locked.
This violation was identified on account of an unlocked high radiation area door identified by the NRC Resident Inspector and several more
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identified by the licensee.
The unlocked door identified by the
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Resident Inspector was dragging on its frame and was repaired the same day it was identified.
A Health Physics Departmental Directive
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(HP-89-29) was issued emphasizing to departmental personnel-that all
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high radiation doors should be closed and locked after exiting the area.
A-detailed inspection of all high radiation area doors was conducted by health. physics personnel in July and November 1989, and maintenance s
work orders were initiated on deficient doors.
During the inspection, i
the licensee indicated that all repairs had been completed.
The inspector reviewed a revision to Procedure 62RP-RAD-016-0S and noted that the revision included requirements for a quarterly detailed check l
of the integrity and function of all high radiation area doors and a daily routine check of all doors.
During the inspection, random high
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radiation area doors were verified to be locked and in good repair by
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the inspector. This item is considered closed,
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b.
(Closed) -Inspector Followup Item (IFI) 50-321,366/89-28-03: Review licensee actions regarding guidance for information listed on " Caution Radioactive Material" labels affixed to dumpsters utilized for contaminated trash.
During tours of the Unit I radioactNe waste trash storage area in
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November 1989 (Report No. 89-28), the inspector noted several trash bins
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containing varying quantities of potentially contaminated material.
The area was posted appropriately, and -the bins were properly labeled as
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containing radioactive materials; however, some of the labels listed information designating the bins as being " empty" although they
contained various quantities of trash.
To insure that waste containers located in trash storage area were
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properly labeled, the licensee issued directive HPC-89-60 to all health
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physics foremen and technicians specifying detailed instructions for the
. labeling of laundry and waste bins.
The inspector reviewed this
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. instruction and found it to be adequate.
During tours of the radwaste facilities, the inspector also noted the proper labeling of the waste bins in accordance with the directive. This item is considered closed.
c.
(Closed) lF1 50-321,366/89-b 04: Review adequacy of licensee quality
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3rogram to resolve concerns for control of doors leading to potential Tigh radiation areas.
The quality program for the control of doors leading to potential high radiation areas was reviewed during the closure of violation 50-321, 361/89-28-01 and was discussed in Paragraph 2a above.
Based on that review, this item is considered closed,
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d.
(Closed) IFl 50-321,366/89-32-01: Modify procedures to specify the
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frequency of carrier standardization, to specify the frequency for generation of control limits, and to specify the acceptance criteria for efficiency determinations.
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During a review of laboratory quality control and-instrument operation procedures Inspection 89-32, the inspector noted that (1) the fregrency. to generate control limits for. instrument performance checks was not procedurally specified although actual laboratory practices were ace,eptable. (2) Procedure PS,-12450.703, " Calibration and Operation of
~ Ir.trinsic Germanium Spectroscopy System,"1 Revision 1, May 27,1987, required the comparison of currant efficiencies to previously determined efficiencies during calibration ht did not specify acceptance criteria for the compariscn, and (3) the potassium iodate carrier sMution used in iodine-131 determinations had not been standardized for an excessively
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long period of time.
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During the present inspection, a review of updated quality control and instrument quality control procedures noted that (1) PSL-12450.612
" Environmental Radiochemistry Section Quality Control," Revision 1, new control charts were generated, (2) pecify the conditions under which February 2,1990, had been updated to s Procedure PSL-12450.703 had been updated requiring that the calculated activity of a known standard determined from the new calibration curve be within 10 percent of the l
calculated activity determined from the previous calibration curve, and E
(3) Procedures ENV-628, " Determination of I-131 in Water" and ENV-629, " Determination of I-131 in Milk" had been revised to require the annual standardization of the potassium iodate carrier solution.
This item is considered closed.
e.
(Closed) VIO 50-321,366/90-02-01: Failure to conduct adequate pre-job L
surveys (evaluations) for resuspensien of surface contamination and failure to collect representative worker breathing air samples to e' valuate airborne radioactivity hazards with and adjacent to the refueling floor drywell separator pool.
This. violation was issued for failure to determine the potential airborne _ radiological hazards prior to and during work conducted in the dryer separator pool.
To' prevent recurrence, the licensee (1) issued Health Physics Department
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Directive HPC-90-015, dated. March 22, 1990, to all health physics foremen and technicians emphasizing the importance of collecting representative air samples before and during work activities and (2)L revised Procedure 60AC-HPX-009-0S to require increasing levels of
Health Physics supervisory review and approval for increasing levels of smearable contamination.
During - a tour of the refueling floor, the inspector verified compliance with the revised procedure by observing a job that was ultimately stopped by a health physics technician.- As i
a refueling pool; gate was being lifted out of the water for repairs, a smear obtained from_ the top of the gate-indicated over 50 millirad /100
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square' centimeters smearable contamination, which required the approval of the Health Physics Superintendent prior to proceeding with the job.
'The' job was properly halted as required by the procedure.
Th;s item is' considered closed.
3.
Internal Exposure Control (Whole Body Counting) (83750)
10 CFR 20.103(a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
The licensee's onsite whole body counting equipment consisted of one Nuclear Data standup counter normally used for one minute screening counts and a Nuclear Data whole body counting chair used as a backup for the standup
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4 counter and for diagnostic counting if internal contamination was suspected.
The standup counter and the chair counter both contained sodium iodide i
detectors.
The operation of both counters was described in Procedure 62HI-0CB-028-05, "Use and Calibration of Whole Body Counters," Revision 5 November 27, 1989.
The inspectors reviewed selected portions of the quality control program for the standup and chair counters and noted the following:
a.
A full efficiency calibration was performed semiannually.
The inspectors reviewed the documentation of the most recent calibration of the standup counter (June 90) and found it to be complete.
b.
Daily energy calibration checks (update energy calibration) were being performed with a europium-152 source to verify detector linearity.
During a review of September 1990 data, however, the inspectors noted that detector efficiency was not being tracked on a daily basis.
Prior to the end of the inspection, the licensee implemented a program for trending detector efficiency daily which included updating Procedure 62H1-0CB-028-0S.
c.
Daily background checks were being performed to monitor background radioactivity. Background count time was two minutes for both the standup and chair counters. During a review of the September 1990 data, the inspectors noted that the two minute background count time exceeded the one minute normal count time of_the standup counter but was less than the normal five minute count time of the chair counter. To insure that background radioactivity problems could be identified, the licensee updated Procedure 62H1-0CB-028-0S changing background count time of the chair detector from two minutes to five minutes (normal count time). This change was completed prior to the end of the inspection.
d.
The licensee participated in a quarterly cross check program administered by an outside vendor to help ensure accurate whole body-counting results.
The inspector reviewed the results from the third quarter of 1990 and noted that the licensee's results were within the predetermined acceptance criteria.
No violations or deviations were identified.
4.
Radioanalytical Laboratory (84750)
The inspectors toured the licensee's radioanalytical laboratory and found it clean and arranged for efficient _ operation, inservice equipment consisted of three high purity germanium detectors with Nuclear Data ND66 multichannel analyzers and two sodium iodide "well counters".
Selected portions of the quality control program for the germanium detectors were reviewed with the following items noted:
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a.
Daily checks for resolution and net counts at 122 and 1332 kev were
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performed with warning limits-at plus or minus 2 standards deviations and control limits at plus or minus 3 standards deviations from a
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pre-established mean.
The centroid of the 122 and 1332 kev peaks were also checked daily.
Control limits were set during the annual L
efficiency calibrations.
The results of these daily checks were plotted daily.
If control charts were recalculated between calibrations, the newly established means was required to be within one standard deviation of the original means.
The inspectors reviewed these control charts for the period January through October 1990 for all three detectors and noted stable detector performance.
b.
Full: energy and efficiency calibrations were performed annually on all
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detectors.
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The. licensee participated in a quarterly cross-check program administered by an outside vendor.
A review of the results from 1989 and the first and second quarters of 1990 indicated good agreement except for minor deviations.
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Weekly background checks were performed on all detectors.
A review of the checks for 1990 indicated no significant background control problems.
c.
All radioactive sources used during calibrations and calibration checks were traceable to the National _ Institute and Standards and Technology, f.
Tritium, strontium-89/90, and iron-55 analyses were performed by an offsite vendor.
The licensee periodically sent blind spiked samples to the vendor to verify the accuracy of their analyses.
The inspectors considered the licensee's radioanalytical laboratory quality control program to be adequate in insuring accurate counting l
results.
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No violations or deviations were identified.
5.
Reactor Coolant Chemistry / Fuel Performance (84750)
Section 3.6.F of ' Unit 1 Technical Specifications and Section 3.4.E of
. Units 2 Technical Specifications require that dose equivalent iodine-131 be limited to less than or equal to 0.2 microcuries per gram when the
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reactor is critical.
Section 3.15.2.7 of Units 1 and 2 Technical Specifications states that the gross gamma radioactivity rate of the noble gases Xe-133, Xe-135, Xe-138, Kr-85m, Kr-87, and Kr-88 measured at the main condenser evacuation system pretreatment monitor station shall be limited to less than or equal to 240,000 microcurier. aer second.
This measureme'it is comsronly referred to as the " sum of the sic noble gases.
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Since the beginning of the current fuel cycle in Unit 1 (June 1990), dose equivalent iodine-131 activity had averaged - about 7 E-4 microcuries per gram and the " sum of the six" noble gases activity had averaged about 3700 microcuries per second, both indicating good fuel integrity.
A trend plot o-these parameters over the current fuel cycle indicated that both of these parameters had also been steadily decreasing since the beginning of the fsel cycle.
This was attributed to the " burn out" of fuel released from leaking fuel cladding during previous fuel cycles.
Licensee reprosentatives indicated that current " sum of the six" offgas measurements were significantly lower than during previous fuel cycles.
A very low ces'um 134/137 ratio (basically undetectable) was another indicator of excallent fuel cladding integrity along with a calculation from the " sum of the six" noble gases that indicated 100% of fission products to be from recoil (tramp Uranium) and not from diffusion through the cladding.
Fuel integrity indicators from Unit 2 had been similar to Unit 1.
Since the beginning of the current fuel cycle, which began in December 1989, dose equivalent iodine-131 activity had averaged about 3 E-4 microcuries per gram, and the " sum of the six" noble gas measurements had averaged even better than Unit 1 at about 1400 microcuries per second.
As with Unit 1, a trend of-these Unit 2 parameters over the current fuel cycle indicated a t.reesing trend because of the " burn out" of previously released fuel.
There was also a nondetectable cesium 134/137 ratio and " sum of the six" talculations also indicated that 100 percent of the fission products messured in the reactor coolant system were from recoil mechanisms.
No v:olations or deviations were identified.
6.
Person-Rem and Personnel Contamination Report Status (83750)
10 CFR' 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures ALARA.
a.
Person-Rem Status The inspector reviewed site colicctive dose status and discussed current trends and future goals with cognizant plant personnel.
As discussed in Inspection Report No. 90-08- (April 25,1990) total site person-rem for 1990 was expected to be well in excess of the original best estimate goal of 1050 person-rem due to unexpectedly high dose rates in the Unit 1 drywell during the Spring 1990 outage. As of August 31, 1990, TLD verified site person-rem was about 1400 person-rem.
Since the end of the outage (June 1990), the licensee was averaging about 1 person-rem per day, b.
Personnel Contamination Reports (PCR's)
As of October 1, 1990, PCR's were trending toward the yearly goal of 22%
with 175 PCRs.
No adjustments had been made in the yearly goal. N no
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significant changes had been noted since the last inspection in this area (90-08).
7.
Hydrogen Water Chemistry and Zinc 0xide Injection (83750, 84750)
a.
Hydrogen Water Chemistry As discussed in inspection Report No. 90-08, hydrogen water chemistry control in Unit 1 had been achieved by injecting gaseous hydrogen into the reactor feedwater system to reduce the concentration of oxidizing species created during the radiolytic decomposition of water during power operations.
The reduction of these species (02, H202, etc.)
decreased the possibility of intergranular stress corrosion cracking (IGSCC) in the reactor coolant system piping and welds, General reduce the in order to effectively (ECp)
Electric had recommended thatelectrochemical potential of possibility. of.lGSCC, an-230 millivolts or less should be maintained between the bulk water and the stainless steel surfaces of the RCS piping.
Erosion of copper from the admiralty brass main condenser tubes, however, required excessive amounts of hydrogen to be injected to maintain the desired ECP.
This resulted in much higher than anticipated nitrogen-16
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carryover into the main steam lines and intolerabic radiation levels.
Copper was. also ' attributed to copper induced localized cracking (CILC)
of the zircaloy fuel cladding.
Inspection Report No. 90-08 discusses the phenomena associated with hydrogen water chemistry in more detail.
During the Unit 1 Spring 1990 outage, the licensee replaced the-admiralty brass main condenser tubes with titanium tubes.
This replacement was to-hopefully reduce incidences of condenser in-leakage and CILC of fuel cladding.
This replacement also reduced reactor water copper levels from erosion of the tubes, previous high copper levels 'in the reactor coolant system required higher than er.tMpted hydrogen injection rates into the feedwater system to neintain minimum protection against intergranular stress corror. ion cracking in the reactor recirculation-system and associated piping, lonic copper acts as an oxidizing agent similar to the hydrogen peroxides and dissolved oxygen created during the radiolysis of water.
As residual copper was depleted from the feedweer system oxide layers after the condenser-tube replacement, the hydracn became more effective in achieving the desired ECP in -the reactor colant system allowing a decrease in the
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hydrogen injection rate' required to maintain the desired ECP. Dissolved oxygen in the recirculation sysMm also decreased af ter the tube replacement because of the increa.ed hydrogen effectiveness.
The following chart summarizes the previously discussed parameters.
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J Main Stea,m Line Injection Dissolved I:
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Before tube 2.0 times back-22scfm 0 mV 15 ppb replacement ground After tube 1.8 times back-16scfm-450mV 0.3 ppb replacement ground Although the recirculation piping could most likely be protected at a
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lower injection rate and resu1Mtg higher ECP (-230mV), the licensee decided to maintain the 16 scfm injection rate to provide additional
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protection to the reactor internals.
Current test results from pre-cracked specimens located in an off-line autoclave showed no
'significant crack growth.
Licensee representatives also indicated that
periodic interruptions in hydrogen injection was of minimal significance
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because of a " memory effect" for several days after injection was stopped.
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During the last Unit 1 outage, unexpectedly high dose rates' were
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suspected as a result of a long fuel cycle under hydrogen water
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chemistry.
Since the beginning of the current fuel cycle (June 1990)..
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there had not been an opportunity to measure dose rates in the drywell.
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Hydrogen water chemistry control.was planned to begin in Unit 2 during
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the first part of 1991.
b.
Zinc 0xide Injection During August 1990, the licensee had begun zinc oxide injection in both Units -1 and 2 to help control radiation field buildup in recirculation-
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system piping.
Previous testing by industry sponsored research' groups
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had.shown that maintaining ionic zinc at about 5 to 10 parts per billion (ppb) in the reactor recirculation system could significantly reduce
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activated corrosion-product deposition, especially cobalt-60, on primary system piping wall.
Zinc oxide injection has been shown to be even more effective under the reducing environment of hydrogen water chemistry..
Since zinc oxide injection had only begun in August, it was too early to assess.its long term effectiveness on cobalt-60 deposition.
However, discussions with radwaste personnel did indicate an increase in the amount of zinc-65 in reactor water cleanup system spent resins and no significant change in cobalt-60 levels.
It is also important to note that prior to the Unit 1 Spring 1990 outage, the condenser tubes were constructed of admiralty brass which contained natural amounts of zinc contaminarts that were eroded into the feedwater system during power operations.
During the outage, they were replaced with titanium-tubes which contained no natural amounts oi zinc.
This unit had also been under-hydrogen water chemistry (HWC) control for the i
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Unit 2, however, had never been under HWC, and the
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i condenser tubes had been replaced with titanium tubes several fuel cycles
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ago. _ The effect that these differences have on the deposition of activated corrosion products should be more clear during the next long outages.
To help reduce dose rates and occupational radiation exposure during the next' Unit 1 outage, the licensee planned to chemically decontaminate the interior of the reactor coolant system surfaces using a low-oxidation-state metal-ion process.
There were no immediate plans for the
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chemical decontamination of Unit 2.
No-violations or deviations were identified,
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Exit Interview The inspection scope and results were summarized on October 5,1990, with
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those persons, indicated in Paragraph 1.
The inspector described the areas
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inspected and discussed in detail the inspection results.
Proprietary information is-not contained in this report.
Dissenting comments were not
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received from the licensee.
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Licensee management was informed. that two - violations and three IFis
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discussed in Paragraph 2 were closed during this inspection.
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