IR 05000327/1989028

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Insp Repts 50-327/89-28 & 50-328/89-28 on 891113-17. Violation Noted Re Failure to Source Check Effluent Gas Monitors Per Tech Specs.Major Areas Inspected:Radiological Effluents & Waste Treatment,Water Chemistry & QA
ML20006G087
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 01/26/1990
From: Decker T, Marston R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20006G086 List:
References
50-327-89-28, 50-328-89-28, NUDOCS 9003050002
Download: ML20006G087 (14)


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UNITED ST AT ES 0CECoq'o

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET,N.W.

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2-ATLANTA, GEORGI A 30323

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JAN 2 91990 Report Nos. - 50-327/89-28 and 50-328/89-28 T

Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801-Docket Nos.: 50-327 and 50-328 License Nos.:

D?R-77 and DPR-79

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Facility Name: Sequoyah 1 and 2 Inspection Conducted: November 13-17, 1989 Inspector:

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R. R. Marston Date Signed Approved by:'

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T. R. Decker, Chief Date Signed Radiological Effluents and Chemistry Section L

Emergency Preparedness and Radiological

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Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of radiological effluents and waste treatment, radiological monitoring end analysis, water chemistry, and quality assurance and control.

Results:

The licensee's chemistry program appeared to be acceptable. Documentation and close supervision and review by management enhanced this program. The Quality Surveillance program tracked chemistry activities closely and thoroughly.

One non-cited violation (NCV) was identified and reviewed during this

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inspection:

Failure to source check effluent gas monitors in accordance with

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Technical Specifications (Paragraph 11.b).

Three inspector follow-up items

'(IFIs) in the chemistry area were closed out.

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REPORT DETAILS 1.

Persons Contacted l

Licensee Employees-D. Adams, Primary Chemistry Manager

  • M. Cooper, Compliance Licensing Supervisor
  • D Craven. Technical Support (I&C) Systems Engineering Manager
  • S. Crowe, Nuclear Quality Audit (NQA) Site Quality Manager
  • A. Dyson, NQA (OTS) Evaluator
  • G. Fiser, Chemistry and Environmental Superintendent

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i J. Hereford, Systems (Instrumentation) Engineer

  • W. Lagergren, Operations Manager
  • J. LaPoint, Site Director D. Nix, Count Room Manager
  • J. Proffitt, Licensing Engineer R. Richie, Jr., Secondary Chemistry Manager
  • V. Shanks, TVA Chemistry Program Manager (Sequoyah)
  • J. Smith, Nuclear Experience Review Supervisor
  • W. Smith, NQA & Evaluation Audit Specialist D. Vanosdale, Manager, Operations Water Processing
  • C. Vondra, Plant Manager
  • A. Wilkey, NQA & Evaluation Site _ Audit Group Manager Other licensee employees contacted during this inspection included engineers, operators, security force members, technicians, and administrative personnel.

NRC Resi6ent Inspectors L

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I P. Harmon K. Jenison D. Loveless L

2.

Audits (84750)

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The inspector reviewed one audit conducted by the Nuclear Quality Audit &

Evaluation (NQA&E) organization. This audit was identified as NQA&E Audit

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Report SQA88815, and covered Plant Chemistry Control among several other subjects.

The audit was conducted from September 19, 1988 to January 6, 1989.

Within the scope of Plant Chemistry Centrol, the audit identified i

two Conditions Adverse to Quality (CAQR) and one Problem Reporting

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Document-(PRD).

Three items were corrected during the audit. Corrective actions had beer specified for the CAQRs and the PRD, and one CAQR had been closed.

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'The. inspector.also reviewed several Quality Surve111ances in the following

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areas:

Technical Specifications (TSs) (Four during July-October 1989);

ChemistrySampling(TenduringFebruary-August 1989);

LaboratoryAnalysis(ElevenduringFebruary-August 1989);

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Chemistry Online Instrumentation (One in May 1989);

Post Accident Sampling System (PASS) (Two in June and July 1989); and l

Radwaste(OneinAugust1989).

The most significant problems were observed during review by the licensee of the PASS operation.

Samples could not be taken due to equipment problems. The problems occurred in June 1989 and required a repair of'a gas leak prior to sampling.

Repairs were performed that month, and the

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licensee has declared that the PASS is fully operational.

The above surveillances were discussed with the Quality Surveillance Evaluator.

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D No violations or deviations were identified.

3.

Changes to Chemistry Program (84750)

The inspector discussed changes in the Chemistry program with licensee representatives and reviewed current and proposed organizational charts.

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The organization had been changed so that only a Primary Chemistry

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I Manager a Secondary Chemistry Manager, and a Process Control Supervisor

I reported to the Chemistry and Environmental Superintendent.

The Primary L

Lab Supervisor and three Analytical Chemists reported to.the Primary Chemistry Manager, and the Secondary Lab Supervisor and six Chemists-and o

Engineers reported to the Secondary Chemistry Manager.

The six Shift

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' Supervisors reported to the Secondary Lab Supervisor, and the l

20 Technicians were evenly split between the Primary and Secondary _ Labs.

L The proposed oroanization, which the Chemistry and Environmental

. Superintendent -stated had been submitted for. approval, established an

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' Environmental Manager who reported to the Superintendent and had an l

Environmental Engineer and Chemical Traffic Control Engineer reporting to him. The Chemistry Shift Supervisors would report directly to the Primary and Secondary Managers and have 15 Technicians reporting to them.

One-Chemist and the Laboratory Supervisor would report to each Chemistry

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Manager (Primary and Secondary).

One P.adiochemistry and PASS Engineer,

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one Radiolooical Effluents and Countroom Engineer, and three Day Shift L

Technicians would be assigned to the Primary Laboratory Supervisor; one Analytical Chemist, one Instrumentation Specialist, and two Day Shift Technicians would be assigned to the Secondary Laboratory Supervisor. The authorized manning for the Section would remain at 43. The Superintendent i

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also stated that a Nuclear Data 9900 System had been installed to control the gama spectrographic systems and to record _and analyze data, and that a new liquid scintillation system had been installed, but was not yet in use.

No violations or deviations were identified.

4.

Laboratories and Count Room (84750)

The inspector evaluated the Primary and Secondary Chemistry Labs and Radiochemistry Count Room.

The Secondary Lab provided a workspace for work and calibration-of. instruments, and space for a gamma spectroscopic

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system.

The Count Room and the Analytic Lab were collocated inside the Power Block.

The Count Room was equipped with three gamma spectroscopic

'I systems which were controlled by a ND9900 system, a NMC gas proportional alpha and' beta counter, and a Packard 2200CA Tricarb Liquid Scintillation system.

The Analytic Lab was equipped with four hoods, a. gas chromatograph, an atomic aosorption spectrophotometer, and two ion chromatographs, in addition to several other pieces of equipment. Because of all-the equipment available, the Lab had = little countertop space available for other work.

A section of the Analytic Lab was marked and

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posted as a radioective contaminated area.

The posted area included the-

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boron titration apparatus.

The laboratories were generally maintained in a clean and orderly manner.

The corner of the Analytic Lab that was

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posted appeared to be cluttered, but this was largely due to the radiation ropes used to mark off the area.

Considering the design of the Lab, the lack of space, and the equipment installed, it would be difficult to l

improve the functionality of the room.

No violations or deviations were identified.

5; Liquid Radiological Effluents (84750)

The inspector-toured the plant and examined radwaste processing system components.

The system appeared to be fully operational as described in l

the FSAR.

The inspector also discussed the liquid radwaste processing system with representatives of the Chemistry and Redweste Sections.

The l

inspector reviewed the Chemistry Section's Liquid Effluent Logbook.

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Logbook provided a sumary of chemistry and radiochemistry parameters for l

releases' from the Radwaste Tank for the period from May 30, 1989 through

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November 16, 1989, and for releases from the Condensate Demineralizer

Waste Tank for the period from June 4,1989 through November 16, 1989.

' The Log showed that releases were within limits for both chemical and

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radiochemical parameters.

No violations or deviations were identified.

6.

Gaseous Ftodiological Effluents (84750)

The inspector toured the plant and examined radwaste processing system components.

The system appeared to be fully operational as described in

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the FSAR.

The inspector also discussed the gaseous radwaste processing system with' representatives of the Chemistry and Radwaste Sections.

The I

inspector reviewed the Chemistry Section's Gas Book.

The Gas Book

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L provided summaries of Gaseous Effluent release. parameter values'from the

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Auxiliary Building Exhaust, the Auxiliary Particulate Monitor (charcoal I

and particulate. filters).. Unit 1 and Unit 2 Containment Exhaust Monitors.

Units'1 and 2 Condenser Vacuum Exhaust Monitors, Service Building Exhaust.

Units 1 and 2 Shield Buildino Effluent Monitors, and Waste Gas Decay Tank Releases.

The licensee initiated control and analysis in the gamma

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spectroscopic systems-with the ND9900 system on October 14, 1989.

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resulted in a change of format in the effluent release analytical results.

Release activity was-expressed in terms of dose rates rather than release rates. The records showed that effluents were within TS.

No violations or deviations were identified.

L 7.

Water Chemistry (84750)

The inspector discussed the water chemistry program with Chemistry Section representatives, observed analyses in the Analytical Lab, and reviewed Section records.

The radiochemistry records' consisted of trend plots and Radeon Chemistry Reports.

These records showed primarily the iodines, iodine ratios, cesiums,- cesium ratios, and other nuclides present in the reactor coolant.

No limits appeared to have been exceeded. The inspector-also reviewed the Daily Chemistry Trend Book.

These-plots were done u

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daily, and showed the past 14 days of radiochemistry and chemistry.

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parameter values for reactor coolant, and chemistry parameter values for

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steam -generator blowdown and various points on the secondary-coolant system.

These plots were supplemented by a plot of power level for each unit.

Parameter limits were marked on each plot.

Parameter values were generally maintained within the specified limits, and anomalies were explained on the Lab records.

No violations or deviations were identified.

8.

Radwaste Processing (84750)

The inspector toured the plant, examining components of the liquid and gaseous radwaste system, and -discussed the program with the Manager, Operations Water Processing.

The Manager stated that since the previous inspection (50-327, 328/88-59, conducted in December 1988), the - solid

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radwaste processing responsibility had been reassigned to the Radcon

)J organization, leaving liquid and gaseous radwaste processing with the

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Operations Water Processing organization.

The organization was divided into six shifts of one Unit Operator as a Radwaste Shift Supervisor and five or six Assistant Unit Operators each.

The individuals assigned to the Radwaste group had the basic Operator Trainino, then once assigned to the plant and af ter fourth period training, were allowed to choose Operations or Radwaste (subject to the needs of the plant).

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'Six condensate demineralizers for each unit were located in th'e Condensate Demineralizer Building.

Flow from the Hotwell Pumps provided input to these units.

Five units were required _to be on line for each reactor for-full-flow polishing.

The Manager stated that the plant was getting from

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55 to 95 million gallons flow through each polisher before the unit was removed from service due to high conductivity.

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The Manager also stated that the Condensate Deminertlizer Waste Evaporator was operational and working well.

The only problem area.in the system appeared to be the Boric Acid Evaporators, which were down with blown seals.

The plant had a contract with a vendor to provide ' portable demineralizers to supplement-the Condensate Demineralizer Waste Evaporators (CDWE), and that consideration was being given to replacement of the CDWE with portable demineralizers.

The Radwaste Manager stated that the nine Waste Gas Decay Tanks were

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normally configured so that one was on standby, one held cover gas, one l

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was in service from the waste gas compressors, one was full, and the rest

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were empty.

No violations or deviations were identified.

l 9.

ConfirmatoryMeasurementsandQualityControl(84750)

The inspector reviewed documentation and verified that calibrations and quality control checks had been performed on the aansna spectroscopic

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systems in the count room and Secondary Lab at required frequencies.

As part of the NRC Confirmatory Measurements Program, spiked liquid samples were sent to the plant on July 13, 1989, for selected

I radiochemical analysis.

The NRC was provided with the results of these analyses via letter dated September 14, 1989. The inspector discussed the-L'

results with Chemistry Section management during the inspection.

The

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comparison of licensee results with NRC analyses is presented in Attachment 1 to this report, and the acceptance criteria for the i

E comparisons are listed in Attachment 2.

The inspector's review of this data showed that the results were in agreement for all four nuclides.

No violations or deviations were identified.

10. FollowupItems(92701)

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(Closed) Inspector Followup Item (IFI) 50-327,328/88-38-01: Review

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results of studies of all chemicals used to control corrosion in the Emergency Raw Cooling Water (ERCW) piping.

The inspector reviewed documents describing the chemical treatment program used in the ERCW system.

The water was chlorinated with sodium hypochlorite and treated for microbiologically induced corrosion with a sodium bromide solution.

Corrosion coupons were placed in the system to determine corrosion rates with and without this treatment.

Evaluation of the

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i results indicated.that no unanticipated. corrosion occurred with this

.I treatment.

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(Closed) IFI 50-327, 328/88-38-02:

Feasibility of using morpholine for secondary chemistry control.

The inspector reviewed documentation evaluating morpholine chemistry Lversus annonia chemistry in secondary systems for pH control.

Benefits and.

disadvantaoes of both systems were discussed and a recommendation

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was made to conduct a full scale-test.

A representative of the TVA

. Chemistry Department stated that a meeting had been held with ~a vendor who would conduct the program.

It was anticipated that-injection would be made in one unit, possibly in May 1990, and the test would probably be run for the rest of the fuel cycle.

If this program were adapted, full flow polishing could no longer be used, c.

(Closed) 'IFI 50-327, 328/88-38-03:

Assessment of the effectiveness of the Unit 1-layup. The inspector reviewed documentation originated by' the. Chemistry Superintendent evaluating the layup.

The criteria for effectiveness was the cleanliness of the system on return to power. The return to power occurred in late 1988. No long chemistry holds occurred, specific power levels were reached in a. timely manner, secondary chemistry ranked well, and chemistry parameter-values compared favorably with industry statistics.

Sludge lancing results in the next outage would also be an indicator.

11.-

Recent Events (84750)

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The inspector reviewed the case of two recent Containment Vent Isolations (CVIs) for Unit 2.

The inspector reviewed the licensee's

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Potential Reportable Occurrence Report (PRO) Number 2-89-149 and PRO

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Number 2-89-151, and discussed the incidents with a licensee j

representative.

The first incident occurred during the evening of November 10 when l

the head vent line clearance procedure was being performed.. This-

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procedure vents the reactor vessel head-to the pressurizer relief-tank (PRT). An attempt was made to purge potentially explosive gases

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from the head to the containment purge system exhaust ductwork. This L

purge system exhausts to the shield building.

When the head vent L

line purge valve was opened, water and gas vented out into the purge system.

Most of the water was contained in a plastic bottle placed on the line.

Apparently, the gas and water were drawn from-the PRT.

The radiation monitors on the purge exhaust spiked and initiated a CVI.

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l The second CVI occurred during the morning of November 11.

Cutting and weldina were being performed on the head vent line valve system.

The work areas had been " bagged" in plastic and a filtered vacuum l

cleaner was used to draw out contaminated particles.

When welding L

started, it was necessary to open the plastic baaging.

The purge system had been activated to keep airborne contamination in the work

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area down, and apparently material rele'ased from the open lines'

activated the CVI on the Shield Building monitors.

A licensee representative stated that these were preliminary findings

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and that an investigation would be conducted.

The Senior Resident f

Inspector stated that his staff was monitoring these events.

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Source Check of Radiation Monitors The inspector reviewed Licensee Event Report (LER) 50-328/89011,

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"RE-90-119 Radiation Monitors Inoperable Because of Inadequate Source

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Check Performance," dated September 22, 1989, and Revision 1 to the

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LER, dated October 23, 1989, and discussed the subject with the -

licensee's cognizant System Engineer and other licensee personnel, i

From the LER' and its Revision, the inspector verified that the-

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licensee had determined on August 23, 1989, that a TS surveillance i-

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requirement was not being fully met.

TS 3.3.3.10 requires that radioactive gaseous effluent monitoring channels shown in Table 3.3-13. shall be operable.

TS 4.3.3.10 requires that each L

radioactive gaseous effluent monitoring instrumentation channel shall l

be demonstrated operable by performance of the channel check, source check, channel calibration, and channel functional test at the L

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frequencies shown in Table 4.3-9.. This table requires that a monthly l

source check be performed on the following Noble Gas Activity

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Monitors:

1-RE-90-99, Unit 1, Condenser Vacuum Exhaust System (intermediate r

I rance);

' 2-RE-90-99, Unit 2,CondenserVacuumExhaustSystem(intermediate rance);

1-RE-90-119, Unit 1. Condenser Vacuum Exhaust System (normal range);

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'2-RE-90-119, Unit 2. Condenser Vacuum Exhaust System (normal range);

l 1-RE-90-100B, Unit 1, Shield Building Exhaust System; I

2-RE-90-100B, Unit 2, Shield Building Exhaust System; l~

0-RE-90-101B, Auxiliary Building Ventilation System; and l

0-RE-90-132B, Service Building Ventilation System i

l The Table also specified a source check prior to each release for 0-RE-90-118, the Waste Gas Disposal System Noble Gas Activity

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TS 1.32 defines a source check as the qualitative assessment of channel response when the channel sensor is exposed to a radioactive source.

The source check on the two RE-90-119 monitors had been performed by using a light-emittino-diode (LED) light source provided by the monitor's manufacturer to simulate a radioactive source.

This LED source checked the electronic circuits in the monitor but did not check the scintillator.

The LER and licensee representatives

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_ indicated that the licensee recoanized:that this' method of source

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~ heck was not in accordance with the definition of TS-1.32 and.that-

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c the two monitors have been source checked with radioactive sources at the required frequency since the problem was identified.

L The remaining monitors identified above were source checked with a radioactive source as - installed by the monitor's manufacturer.

However. this - radioactive source _ was' exposed to a second scintillator, which was installed only for source checking, and not exposed to the main scintillator used in the monitoring of the h

process effluent.

The main scintillator was a part of the channel L

sensor as defined in TS 1.32.

This particular system and

1 constructiont for source checking was provided by the monitor vendor I-and had been done this way since startup of each unit.

  • L The inspector identified this as a violation.

NCY 50-327, L

328/89-28-01: Failure to conduct source checks on effluent monitors

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as-required by TSs.

- 1 The violation is not being cited because the criteria specified in Section V.A..of the Enforcement Policy were satisfied.

The LER specified that the current method of source check was l-considered technically adequate in that a downscale alarm would occur

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if the scintillator became detached from the plastic window and that the scintillator did not have a credible failure mechanism that would be detected by a source check. Licensee representatives stated that, in response to NRC Generic Letter 89-01 they were in the process of-removing the effluent and environmental requirements from the'TSs and placing-them in the Offsite Dose Calculation Manual (0DCM) and the

' Process Control Procedures (PCPs).

In telephone conversations on January 25 and 26, 1990, licensee representatives stated that the TS change was being' reviewed by the Plant Operations Review Committee

(PORC), then would be reviewed by the Nuclear Safety Review Board (NSRB), and was expected to be sent to the NRC for approval no later q

than the end of February.

They also stated that-the source check requirements would be placed in the ODCM and the definition of a source check would be revised to define it as qualitative assessment of channel response using either a radioactive source or tested with an internal test circuit.

This issue was referred to NRC l

Headquarters (NRR) for determination of technical adequacy.

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Inaccuracy in Boron Analysis The Resident Inspector (RI) staff requested assistance from the Region II Radiological Effluents and Chemistry Section in evaluating Unresolved Item 50-327, 328/89-25-03, identified in the RI's report, concerning inaccuracies in boron determination.

The inspector reviewed the RI's draft report, the Licensee's Final Event Report Number 11-89-076, concerning the Unit 2 Refueling Water Storage Tank

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(RWST) Boron Analysis, and discussed the event with the RI staff and

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-the Chemistry and Environmental Section Superintendent and his staff.

The RWST 2 sampling and analysis was done as part of Chemistry's weekly surveillance conducted as required by Surveillance i

Instruction SI-51. -The tank had been recirculated in preparation for sampling.

A ' condensed sequence of events for October 20, 1989 follows:-

Time Event 0200 RWST.2 was sampled.

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0630-The sample was analyzed with results of 1,952 ppm boron. The sample was reanalyzed with results of 1,971 ppm boron.

(100 and 3,000 ppm boron standards were analyzed during this period and -

results were within specification).. Limits for.

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this tank were 2,000 to 2,100 ppm.

0735 A second RWST 2 sample was obtained.

0815 The second sample was analyzed with results of 1,971 ppm.

The Secondary Chemistry Manager arrived at this time and requested that a 1,000 ppm standard be run.

.i 0845 The 1,000 ppm standard was analyzed with results

of 956 ppm boron, which was below the 1 percent control limit.

It had been determined that no changes had taken place in the RWST 2 which would cause the boron concentration to be lower than

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previous analyses had indicated.

At this point, one titrator had been used.

1000 A full calibration of both boron titrators was i

done.

New pH buffers were used in the

. recalibration and the Sodium Hydroxide titrant was restandardized.

Both the 1,000 'and the 3,000 ppm boron stalidards were.within

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specification.

1025 The 0200 sample was reanalyzed and determined to be 2,048 ppm boron on one titrator and 2,025 ppm 1.

on the other.

1050 The 0735 sample was reanalyzed with results of 2,038 ppm.

1235 The RWST 2 was resampled.

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1305 The 1235 sample was determined to be 2,043 ppm

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boron.

Records were reviewed for any other suspect boron analysis. The only sample requiring reverification was Unit I boron.

Instructions were oiven that any boron standardization would more closely bracket the boron concentration being-analyzed.. The conclusion drawn by the

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investigation described in the Final Event Report was that the error associated with the analysis was due to the wide range of standards used to bracket the expected concentration and the higher acceptance tolerance for the lower concentration-standard.

These changes had been implemented earlier in the week in order to improve the

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Chemistry Control process. The bracket ranges were tightened to more closely approach the expected boron concentration and the acceptance criteria -for 100 ppm boron tightened to plus or mir:as one percent.

This corrective action was done on October 20, 1989.-

No violations of NRC re plations were identified.

q 12. Semiannual Radioactive Effluent Release Report (84750)

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The inspector reviewed the licensee's Semiannual Radioactive Effluent l

Release Report for the period from January 1. through ' June 30,-1989. The

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L Report was evaluated against the requirements of TS 6.9.1.8 and TS 6.9.1.9 and the criteria of NRC Regulatory Guide 1.21. Revision 1. June 1974. The j

report was submitted within 60 days of the closing date as required by

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TS 6.9.1.8 and was appropriately formated and included the data specified-:

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a in TS 6.9.1.9 and Regulatory Guide 1.21~.

The releases for_the first six

months of 1989 showed an increase over the past two years' releases.

For

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qaseous effluents, noble gases and iodines-for the six month period were

- higher than: the releases for the entire year for 1987 and 1988.

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Particulates showed only a slicht increase, and. tritium appeared to have

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levelled off.

For liquid releases, tritium showed an increase, the other nuclides decreased.

The Chemistry Superintendent stated that the increases were due to the units being started up again after an extended shutdown.

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l One abnormal release was reported.

The Chemistry Superintendent stated p

that the release was from venting the pressurizer in preparation for an outage.

The gas was purged through filters and the licensee determined the release parameters and potential dose commitment, and determined that it would be safe to release the gas. The licensee had previously released gas from the pressurizer.

When work was taking place afterward, it was

discovered that some more gas was present. During the lineup for another

venting, an eductor was installed backward and some gas was inadvertently released into containment.

Workers cleared the area and the gas was

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Calculations were performed after the fact.-

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j No violations or deviations were identified.

13.

ExitInterview(30703)

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The inspection-scope and results were summarized on November 17, 1989, with'those persons indicated in Paragraph 1.

The inspector described the l

areas inspected and discussed in detail the inspection results listed below.. Proprietary information is not contained in this report.

The inspector stated that the Quality Surveillance program conducted by the Quality Surveillance Section appeared to be a very thorough, comprehensive program. Three open items were closed.

One NCV was identified:

Failure to perform a source check on effluent

. noble gas monitors as required by TSs (described in Paragraph 11.b.).

The i

L licensee declined to affirm or deny the violation at the time of the exit interview.

The licensee stated that they had discovered the problem, had reported it to the NRC, and considered their method of source checking the

detectors to be technically adequate.

The licensee stated that they had

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checked and discovered that the same method of source check was used at

other licensees' plants where the same type monitor provided by the same L

vendor was used. The licensee further stated that in implementing changes authorized in NRC Generic Letter 89-01 they were removing effluent and environmental requirements from TSs and placing them in the ODCM. Licensee

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representatives stated. in telephone conversations on January 25 and 26,

l 1990, (Paragraph 11.b), that these changes were in the approval process

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