IR 05000334/1978032

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IE Insp Rept 50-334/78-32 on 781105-09.Noncompliance Noted: Failure to Test Filters,To Follow Procedures & Improper Sampling Technique
ML19256A520
Person / Time
Site: Beaver Valley
Issue date: 11/30/1978
From: Crocker H, Thonus L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19256A515 List:
References
50-334-78-32, NUDOCS 7901080328
Download: ML19256A520 (7)


Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

Region I NOTICE 1g bj Report No. 50-334/78-32

AS CF RIG:CN I HAS NOT OBTAINED PRC?illE Docket No. 50-334 Ci.EARANCE IN ACCORDANCE WITH 1 License No.

OPR-66 Priority Category C

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Licensee:

Duouesne Licht Comoany 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Facility Name:

Beaver Valley Power Station, Unit 1 Inspection at:

Shippingport, Pennsylvania Inspection conducted:

November 5-9, 1978 Inspectors:

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/ t /3c[76 L. H. Thonus, Radiation Specialist date signed date signed date signed

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Approved by: rd

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//[7 B/> f H. W. Crocker N eting Chief, Radiation

' date signed Support Section, FF&MS Branch Inspection Summary:

Insoection on November 5-9, 1978 (Recort No. 50-334/78-32)

Areas Insoected: Routine, unannounced inspection by a regional based inspector of Radioactive Waste Systems including effluent releases, records and reports, supplemental leak collection and release system, procedures, reactor coolant tests, and facility tours. Upon arrival, offshift on the weekend, areas where work was being conducted were examined to review radiation safety procedure-and practices. The inspection involved 35 inspector-hours on site by one NRC regional based inspector.

Results: Of the six sreas inspected, three apparent items of noncompliance were identified in three areas (infraction - failure to test filters, paragraph 4; infraction - failure to follow procedures, paragraph 7; and infraction -

improper sampling technique, paragraph 2).

Region I Form 12 (Rev. April 77)

7 9 010 80 3 A8

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DETAILS 1.

Persons Contacted Princioal Licensee Emoloyees Mr. D. Arnold, Radcon Foreman Mr. R. Burski, Station Senior Engineer Mr. K. Grada, Shift Supervisor Mr. D. Hosmer, Maintenance Foreman

  • fir. D. Kochman, Radcon Engineer
  • Mr. J. Kosmal, Radcon Supervi-sor
  • Mr. V. Linnenbom, Radiochemist
  • Mr. F. Lipchick, Station QA Engineer Mr. R. Mafrice, Results Coordinator Mr. E. Schnell, Radcon Foreman
  • Mr. L. Schad, Operations Suoervisor
  • Mr. J. Starr, Site Engineer Mr. J. Turner, Shift Supervisor
  • Mr. R. Woodling, Senior Engineer The inspector also interviewed eight other personnel including members of the security force, health physics technicians, and cl erks.
  • denotes those present at the exit interview.

2.

Radioactive Effluent Releases Appendix B, Environmental Technical Specifications (ETS), sections 2.4.1 and 2.4.3, delineate the liquid and gaseous effluent discharge limits, respectively, for the station. The inspector reviewed approximately fifty Radioactive Waste Discharge Authorizations -

Liquid (RWDA-L) for the period May through October 1978 to verify compliance with ETS limitations of release rates and total quan-tities released. Approximately thirty Radioactive Waste Discharge Authorizations - Gas (RWDA-G) for the period May through August 1978 were examined for compliance with ETS limitations on combined release rates (vent and stack) and total accumulated releases of particulates, iodines, and noble gasse '.

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ETS sections 2.4.2 and 2.4.4 delineate the requirements for effluent sampling and monitoring.

The inspector examined a strip chart for the liquid waste discharge monitor for the period September 12-22 and a strip chart for the ventilation vent gas monitor for the period July 27 through August 4,1978.

Isotopic analyses of approximately twenty liouid samples and fifteen gas samples taken between April and October 1978 were reviewed.

ETS Section 2.4.2.3 requires in part for liouid effluents that

" Prior to taking samples from a monitoring (test) tank, at least two tank volumes of entrained fluid shall be recirculated through the mixing eductors." Review of RWDA-L's indicated that several samples had been taken without the required two volumes of recircu-lation. Licensee representatives stated that there is no flow measuring device on the recirculation piping on the liquid waste monitoring tanks (laundry waste tanks), low level test tanks, steam generator drain tanks, and evaporator test tanks.

The Beaver Valley Power Station Operating Manual and Final Safety Analysis Report give the following rated discharge flows for the respective pumps:

Steam Generator Drain Tank Pumps - 100 gpm

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Contaminated Drains Transfer (laundry) Pumps - 10 ppm

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Low Level Waste Drain Tank Pumps - 30 gpm

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Evaporator Test Tank Pumps - 50 gpm

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Based upon data observed during actual discharges including flow readings, gallons discharged, and time of initiation and completion of discharge, the following approximate flow rates were observed:

Steam Generator Drain Tank Pumps - 30-35 gpm

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Evaporator Test Tank Pumps - 25-30 gpm

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The discharge path has more resistance to flow than the recirculation path and would serve as a lower limit to flow rate from the pumps.

In that no data was available demonstrating higher flow rates, the inspector used the observed discharge flow rates in calculating required recirculation time.

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On RWDA-L No. 1001 dated May 20, 1978 (test tank 58), the recircu-lation time prior to sampling was insufficient for recirculation of two volumes using either rated pump capacity or observed flow rates during discharge. The same was the case for RWDA-L tio.

1005 (test tank 5B) dated May 21, 1978.

In the case of RWDA-L Nc. 1013 (laundry tank 6A), dated May 25, 1978, records indicated that the sample was taken prior to the start of recirculation.

For RWDA-L No. 1032 (Steam Generator Drain Tank 7B), dated July 21, 1978, no data was recorded regarding recirculation.

The inspector identified the four above instances as examples of noncompliance with ETS 2.4.2.3.

(334/78-32-01)

3.

Records and Reoorts of Effluents The inspector reviewed the licensee's Semi-Annual Effluent Release Report covering the period January through June 1978 against the criteria given in Regulatory Guide 1.21 and Environmental Technical Specification (ETS) 5.6.1.B.

ETS 5.6.1.C requires that additional reports be submitted if averaged releases exceed one half the design objective. Releases were much below this level and no additional reports were required.

No items of noncompliance were identified.

4.

Sucolemental Leak Collection and Release System (SLCRS)

Technical Specification (TS) 4.7.8.1.6 requires, in part, that each SLCRS exhaust air filter train be demonstrated operable after each complete or partial replacement of a HEPA filter or charcoal adsorber bank by:

a.

Verifying that the charcoal adsorbers remove > 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the ventilation system at a flow rate of 36,000 cfm i 10%.

b.

Verifying that the HEPA filter banks remove > 99% of the D0P when they are tested in-place in accordance with ANSI N510-1975 while operating the ventilation system at a flow rate of 36,000 cfm i 10%.

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c.

Subjecting the carbon contained in at least one test canister or at least two carbon samples removed from one of the charcoal adsorbers to a laboratory carbon sample analysis and verifying a removal efficiency of > 90% for radioactive methyl iodide at an air flow velocity of T.35 ft/sec + 20% with an inlet methyl iodide concentration of 0.05 to 0.15 mg/m3, > 95% relative humidity, and > 125'F; other test conditions shall be in accordance witE USAEC RDT Standard M-16-lT, June 1972.

Both charcoal filter banks were replaced March 21, 1978, and visual and halogenated hydrocarbon tested prior to plant operation.

Neither filter train was DOP tested prior to plant operation. A licensee representative stated that since the HEPA filters had not been replaced the licensee did not deem it necessary to 00P test them. The inspector noted that the Technical Specifications required the D0P test if either the HEPA or charcoal filters were replaced.

In addition, the licensee's ?.athyl iodide removal test data indicated that the required tests had not been performed in accordance with TS 4.7.8.1.b.3 requirements. The tests which the licensee performed did not meet the TS requirements for face velocity (1.35 ft/sec +

20%) or inlet methyl iodide concentration (0.05 to 0.15 mg/m3), -

The inspector identified these findings as noncompliance with TS 4.7.8.1.b.

(334/78-32-02)

5.

Procedures The inspector reviewed the following Radiological Control (Radcon)

procedures to verify that they had been approved in accordance with Technical Specification 6.8.2:

6.1 Liquid Waste Tank Sampling, Revision 2, dated March 13,

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1978 6.3 Gaseous Waste Sampling, Revision 2, dated September 15,

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1978 6.5 Radioactive Waste Discharge Authorization - Liquid, Revision

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4, dated March 10, 1978 6.6 Radioactive Waste Discharge Authorization - Gas, dated

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August 31, 1978 2.5 Orumming of Solid Waste, Revision 3, dated July 13. 1978

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No items of noncompliance were identifie. '.

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6.

Reactor Coolant Tests Technical Specification (TS) 3.4.7 places steady state and transient limits on dissolved oxygen, chloride, and flouride.

Technical Specification 4.4.7 requires that these parameters be samoled three times per seven days with a maximum of seventy two hours between samples. The inspector reviewed the licensee's dissolved oxygen, chloride, and flouride tests for the period April through July 1978 to verify that the tests had been performed within the required interval and that the results were within the TS limits.

Technical Specification (TS) 3.4.8 limits dose equivalent I-131 to 1 uCi/gm of primary coolant and total activity to 100 E uCi/gm. TS 4.4.8 delineates the required surveillance _ intervals for sampling and analysis of dose equivalent I-131 and E.

The licensee's analyses for the period April through October 1978 were examined to verify that the tests were performed in a timely manner and results were within TS 3.4.8 limits.

No items of noncompliance were identified.

7.

Facility Tours Upon arrival, approximately 10:30 p.m., on November 5, 1978, a tour of the facility was conducted to observe licensee posting and control of radiologically controlled areas and to observe radio-logical work practices on jobs in progress. Two additional facility tours were taken during the course of the inspection.

On the initial tour the inspector examined the alarm setpoints on " friskers,"

instruments used to survey personnel for contamination.

a.

Technical Specification (TS) 6.11. " Radiation Protection Program," requires that " procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure." Radcon procedure 4.1, " Requirements for setting up a frisker station," developed pursuant to TS 6.11, requires in step 3.2.1 that the alarm be set at a point 100 cpm above general background. On November 5, 1978, there were four friskers at the exit of the radiation control area; general background in this area was slightly less than 100 cpm. The

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alarm setpoint of three of the four friskers was 500 cpm (400 com above general background) and the alarm setpoint of the fourth was 400 cpm (300 cpm above background).

b.

On the same tour the inspector noticed several used respirators lying in various locations in the Primary Auxiliary Building.

Radcon procedure 10.1, " Respiratory Equipment," developed pursuant to TS 6.11, requires in step 3.1.2 that as respiratory equipment is issued it shall be logged on the Respiratory Equipment Log.

In step 3.7 it states that it is the responsibility of the individual to whom respiratory equipment is issued to return the equipment to the issue point after each use (except when Radeon designates otherwise) and to assure that the equipment is logged back in.

Review of Respiratory Equipment Logs indicated that in August 1978 ninety respirators which had been logged out had not been logged in and that twenty six of these had been improperly logged out in that no name was filled in on the log sheet.

Additionally, in September at least 273 respirators had been logged out without being logged back in, in 43 of these cases the respirator type had not been logged.

The inspector identified these findings as examples of non-compliance with TS 6.11.

(334/78-32-03)

8.

Exit Interview The inspector met with licensee management representatives (denoted in paragraph 1) at the conclusion of the inspection on flovember 9, 1978.

The inspector sumarized the purpose and scope of the in-spection and the findings.