IR 05000327/1993029

Insp Repts 50-327/93-29 & 50-328/93-29 on 930621-25.No Violations Noted.Major Areas Inspected:Effluent Monitor Calibration & Setpoints,Water Chemistry & post-accident Sampling Sys

ML20056D172
Person / Time
Site:	Sequoyah
Issue date:	07/23/1993
From:	Decker T, David Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20056D171	List: IR 05000327/1993029 ML20056D170
References
50-327-93-29, 50-328-93-29, NUDOCS 9308050060
Download: ML20056D172 (8)

Text

UNITED STA1 ES

1. g#U o,, NUCLEAR REGULATORY COMMisslON j

[ o R EGION I1 6

$

.. g E 101 MARIETTA STREET, ~f ATL ANT A, GEORGI A 30323

4 $

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JUL 2 31993 i

Report Nos.: 50-327/93-29 and 50-328/93-29  ;

Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street i

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Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 Licen e Nos.: DPR-77 and DPR-79 i

Facility Name: Sequoyah 1 and 2 .

l Inspection Conducted: June 21-25, 1993 '

Inspector: maw W., Joi et'/

)[J3/93 Date Signed '

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lE#_ b. 16 J3 d J) ,r? 3 j Approved by:T.'R. Decker, Chief p Date(Signet _

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Radiological Effluents and Chemistry Section i Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY

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Scope:

This routine, announced inspection was conducted in the areas of effluent ,

monitor calibration and setpoints, water chemistry, and post-accident sampling systems (PASS). ,

Results: f One unresolved item was identified regarding calibration of effluent monitor [

The licensee's practices with regard to establishing traceability of effluent radiation monitor calibrations to the national system of measurements were questionable and will require further review by the NRC (Paragraph 2). *

The licensee had complied with the requirements in the ODCM for determination i of effluent monitor setpoints (Paragraph 3).  ;

i The licensee had developed an aggressive plan for chemistry program l improvements (Paragraph 4).  !

L The licensee has had continuing reliability problems with in-line measurement f l

components of the post-accident sampling systems and the licensee was

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requested to provide the NRC with specific information concerning their plans  ;

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for improving the reliability of those systems (Paragraph 5).

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9308050060 930723 PDR l

O ADDCK 05000327 PDR

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l REPORT DETAILS i

l Persons Contacted i

Licensee Employees l

t*D. Adams, Program Manager, Chemistry <

D. Amos, Nuclear Chemist, Chemistry )

J. Barker, Secondary Chemist, Chemistry '

• J. Baumstark, Manager, Operations D. Bayles, Senior Chemistry Instructor, Training i tR. Beecken, Plant Manager )

t*D. Bodine, Manager, Chemistry Support  ;

• Driscoll, Manager, Site Quality  !

• Eiford-Lee, Program Manager, Corporate Radiological Effluents !

• Eytchison, Vice President, Nuclear Operations

• Fenech, Site Vice President ,

• Goodman, Manager, Technical Training i

• Harvey, Program Manager, Corporate Chemistry I

• J. Hereford, Engineer, Maintenance ,

t*C. Kent, Manager, Radiological Control and Chemistry i

• J. Newton, System Engineer, Technical Support t*J. Osborne, Manager, Environmental Control t*S. Poage, Manager,' Audits and Assessment i

• G. Rich, Manager, Corporate Nuclear Chemistry -i'

18. Schofield, Manager, Licensing

• M. Shepherd, Manager, Site Training  ;

1M. Skarzinski, Manager, Technical Programs and Performance

G. Taylor, Training Specialist, Corporate Training G. Taylor, Radiochemical Analyst, Chemistry  ;

t*R. Thompson, Manager, Compliance Licensing j

• P. Trudel, Manager, Design Engineering l 1*J. Ward, Manager, Engineering and Modifications ,

t*C. Whittemore, Licensing Engineer, Compliance Other licensee employees contacted included engineers, technicians, and administrative personne j Nuclear Regulatory Commission t*W. Holland, Senior Resident Inspector

• C. Hughey, Resident Inspector, Grand Gulf t*K. Poertner, Resident Inspector, Oconee S. Shaeffer, Resident Inspector .

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tAttended entrance interview I

• Attended exit interview

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2. Radioactive Effluent Monitoring Instrumentation (84750)

Technical Specification (TS) 6.8.5.f.1 for both Units required the licensee to implement a program for the control of radioactive ,

effluents. The program was required to be described in the Offsite Dose Calculation Manual (ODCM), to be i nplemented by operating procedures, .

and to include limitations on the operability of radioactive liquid and :

gaseous monitoring instrumentation including surveillarce test i Section 1/2.1 of the ODCM described the operational and surveillance ;

requirements _for the effluent monitoring instrumentation. The instrumentation was required to be operable during specified operations ,

and demonstrated to be operable by the performance of channel checks, I source / sensor checks, channel calibrations, and channel functional tests 1 at specified frequencies. The initial channel calibration was required '

to be performed by using one or more reference standards certified by the National Bureau of Standards (NBS) or standards obtained from suppliers that participate in measurement assurance activities with NB The standards were required to permit calibration of the systems over '

their intended range of energy and measurement range. Sources that had l been related to the initial calibration were required to be used for subsequent calibrations. Section 3.1 of the ODCM defined channel calibration as the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values t

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of the parameter which the channel monitors. The channel calibration shall encompass the entire channel including the sensor and alarm and/or i trip functions, and shall include the channel functional test. The

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channel calibration may be performed by any series of sequential, i overlapping, or total channel steps such that the entire channel is :

calibrate ;

The inspector discussed calibration of effluent monitors with the a

licensee and reviewed selected calibration records for the effluent ',

monitors listed belo P 0-RM-90-122 Liquid Radwaste Effluent Line  !

0-RM-90-225 Condensate Demineralizer Effluent Line  :

i 1-RM-90-099 Condenser Vacuum Exhaust (High Range) ,

2-RM-90-099 Condenser Vacuum Exhaust (High Range) ,

, 1-RM-90-Il9 Condenser Vacuum Exhaust (Low Range) 'l 2-RM-90-119 Condenser Vacuum Exhaust (Low Range) l l-RE-90-400 Shield Building Exhaust  :

2-RE-90-400 Shield Building Exhaust l

The licensee indicated that the initial calibrations of their effluent ,

monitors had not been performed on the entire monitoring systems as a !

whole after installation but rather the initial calibrations of the radiation detectors originally used in the monitoring systems were

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performed by their equipment vendor at the vendor's facilit Calibration checksources related to the initial calibrations were then provided for subsequent channel calibrations. Prior to plant startup the ;

l licensee requested their vendor to provide checksources which could be ;

used for the subsequent channel calibrations of each model of detector !

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being used rather than a source for each detector. The inspector determined that the licensee's calibration records for the first six

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monitors listed above indicated that their initial calibrations were I traceable to NBS by detector model and their checksources were related to those detector model initial calibrations. The records for the shield

building exhaust monitors indicated that their initial calibrations were l traceable to NBS for each detector and their checksources were related l to those initial calibrations. The licensee also indicated that most, if

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not all, of the first six monitors listed above have had at least one of their major system components (detector, photomultiplier, preamplifier)

replaced since plant startup and that initial calibrations were not l performed after those components were replaced. The licensee's practice of using checksources related to initial calibrations by detector model rather than to initial calibrations of individual detectors and the I practice of not performing initial calibrations following replacement of major components in the monitors have been deemed to be an unresolved item pending further review by the NRC (URI 50-327,50-328/93-29-01).

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The inspector reviewed relevant sections of the procedures listed below l and determined that they included provisions for using the vendor supplied sources during routine surveillance tests to calibrate effluent monitors.

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0-SI-ICC-090-122.0 Rev. 3 " Channel Calibration of Waste Disposal

, System Liquid Effluent Radiation

! Monitor 0-R-90-122"

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0-SI-ICC-090-225.0 Rev. 0 " Channel Calibration of Condensate Demineralizer Effluent Liquid Radiation Monitor 0-R-90-225"

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1-SI-ICC-090-099.0 Rev. 1 " Channel Calibration of Condenser Vacuum Pump High Range Air Exhaust !

Radiation Monitor 1-R-90-99" l l

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1-S1-ICC-090-119.0 Rev. 1 " Channel Calibration of Condenser Vacuum Pump Air Exhaust Radiation Monitor 1-R-90-119"

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1-PI-ICC-090-400.0 Rev. 2 " Calibration of Shield Bldg Vent i Radiation Monitor 1-RM-90-400" i During the inspection conducted on February 23-26, 1993 (Reference Inspection Report Nos. 50-327/93-08 and 50-328/93-08), it was determined that required surveillances for selected effluent monitors had been performed in accordance with their applicable procedures and at the

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required frequencies.

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Based on the above reviews and discussions, it was determined that the i licensee's practices with regard to establishing traceability of i effluent radiation monitor calibrations to the national system of measurements were questionable and will require further review by the NR One unresolved item was identifie l D. Effluent Radiation Monitor Setpoints (84750)

TS 6.8.5.f.1 for both Units required the licensee to implement a program for the control of radioactive effluents. The program was required to be described in the ODCM, to be implemented by operating procedures, and to include provisions for determination of effluent monitor setpoints in accordance with the methods delineated ir the ODCM. Section 6.2 of the ODCM described the methods of establishiag setpoints for liquid effluent monitors to ensure that the concentration of radioactive material released did not exceed the applicable limits specified 10 CFR 20, Appendix B, and to identify any unexpected releases. Section 7.1 of the ODCM described the methods of establishing setpoints for gaseous effluent monitors to ensure that the required dose rate limits were not exceeded and to identify any unexpected release The inspector discussed the methods by which setpoints were determined !

with the licensee. The licensee indicated that their effluent monitors l were not used to quantify the amounts of radioactive materials released i in the effluents but rather to detect any higher than expected levels of I radioactivity in the effluents. The amounts of radioactivity in the effluent streams known to have radioactivity present were determined from batch sampling and analysis prior to each batch release. The normally- uncontaminated effluent streams were routinely sampled and analyzed to determine the amount of activity released if any were ;

detected during continuous releases. Generally those analytical results !

were used to calculate the expected effluent monitor instrument response and the setpoints were set at a procedurally specified fraction above the expected instrument respons The inspector reviewed selected records and calculations for setpoints !

of the monitors listed in Paragraph I above and relevant sections of the

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following procedures related to setpoint determinatio SI-CEM-014-40 " Condensate Demineralizer Waste Effluent Periodic Contine is Releases"

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0-SI-CEM-030-41 " Containment Upper and Lower Compartment Purge Sampling"

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0-SI-CEM-030-41 " Gaseous Effluent Requirement (Gross Alpha, Noble Gas, and Tritium)"

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d-S0-77-1 " Waste Disposal System (Liquid)"

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51-29 " Readjustment of Setpoint for Noble Gas l Radiation Monitors With Variable  !

Setpoints" l

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SI-40 " Liquid Waste Effluent Batch Release"

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TI-18 " Radiation Monitoring"  !

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TI-12 " Radiological Analytical Methods"  ;

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i The ODCM specified that the setpoint for the liquid radwaste monitor (0-RM-90-122) was to be calculated for each batch release based on the i radionuclide concentrations in the batch. The inspector selected a  :

recent liquid radwaste batch release and verified that the setpoint for {

the monitor during that release was calculated in accordance with the i method described in the ODCM and the licensee's batch release procedur :

The current setpoint for the condensate demineralizer effluent monitor '

(0-RM-90-225) was established on February 22, 1992, based on the  :

analytical results from the routine sampling program and the' ll calculations described in the ODCM. The licensee indicated that no  ;

change to the setpoint had been warranted based on subsequent results :

from the routine sampling program. The setpoints for the shield building exhaust monitors (l&2-RE-90-400) were set at default values as described ,

in the ODCM. The default setpoints were established at a value which '

would ensure that the dose rate limits for gaseous effluents specified in the ODCM were not exceeded. The licensee's procedures and the ODCM ,

provided for increasing the setpoints above the default values for the a condenser vacuum exhaust monitors (l&2-RM-90-099&l19) due to primary to i secondary leaks in order to detect further increases in the leak rat l The licensee's records indicated that the cur: nt setpoints for those ;

monitors had been established on May 18, 1987, March 5, 1992, February 22, 1993, and February 29, 1992, respectively. The inspector i determined that those setpoints had been established in accordance with l the licensee's procedure .j Based on the above reviews and discussions it was determined that the !

licensee had complied with the requirements in the ODCM for '

determination of effluent monitor setpoint ,

No violations or deviations were identifie ;

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4. Water Chemistry (84750)  !

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TS 6.8.5.c required the licensee to establish, implement and maintain a j program for monitoring secondary water chemistry to inhibit steam i generator tube degradatio j i

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The inspector reviewed the licensee's procedure " Site Standard Practice SSP-13.1 Conduct of Chemistry" which described the site chemistry program and determined that it incorporated the required secondary water chemistry program. The program included provisions for implementing the 1 Electric Power Research Institute (EPRI) guidelines for primary and j l secondary water chemistr ,

l During discussions of the program with licensee chemistry personnel, it ;

was indicated to the inspector that, as a result of a recent independent l audit finding, a chemistry program improvement plan had been initiate ,

The proposed improvements for secondary water chemistry included j implementing ethanolamine treatment, cation / anion molar ratio control, .j maximizing condensate polishing, optimizing feedwater hydrazine, boric :

acid treatment, and upgrading the sampling, instrumentation, and I laboratory facilities. The objectives of these improvements were to !

reduce stress corrosion cracking and intergranular attack in the steam ,

generator tube to tube support crevices, reduce steam generator sludge i buildup, reduce iron and copper transport to the steam generators, and i reduce overall erosion / corrosion in high pressure system Implementation of these programs improvements will require installation i of additional plant equipment, increased capabilities for monitoring and controlling chemical parameters, operational and analytical procedure revisions, training of chemistry and operations personnel, and safety -

reviews. The licensee's progress in the chemistry program improvements l l will be reviewed during subsequent inspection j l

Based on the above reviews and discussions, it was concluded that the ;

licensee had developed an aggressive plan for chemistry program !

improvement No violations or deviations were identifie . Post Accident Sampling Systems (84750)

1 TS 6.8.5.e for both units required the licensee to establish, implement,

! and maintain a program which would ensure the capability to obtain and l analyze samples of reactor coolant, radioactive iodines and particulates

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in plant gaseous effluents, and containment atmosphere under accident conditions. The program was required to include training of personnel, procedures for sampling and analysis, and provisions for maintenance of sampling and analytical equipment.

l The licensee's post-accident sampling and analysis program was

! previously inspected on May 24-28, 1993, (Reference Inspection Report Nos. 50-327/93-19 and 50-328/93-19). As discussed in the report for that inspection, the licensee has had continuing problems with the i reliability of the in-line measurement components of the post-accident sampling systems (PASS) and with training of personnel to operate the PASS. Based on NRC management review of those inspection findings, the .

licensee was requested to provide the NRC Region II Office a letter I indicating the following

what actions are being taken to make the PASS

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equipment operable: what will the policy be for timeliness in repairing i

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the equipment should it become inoperable in the future; and what actions are being taken with regard to training of personnel to operate the PASS. The licensee acknowledged the inspector's request for the above informatio . Exit Interview The inspection scope and results were summarized on June 25, 1993, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed above. No dissenting comments were received from the license Proprietary information is not contained in this repor Item Number Description and Reference 50-327,328/93-29-01 URI - Establish traceability of effluent radiation monitor calibrations to the national system of measurements (Paragraph 2).

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