IR 05000335/1994016

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Insp Repts 50-335/94-16 & 50-389/94-16 on 940718-22.No Violations or Deviations Noted.Major Areas Inspected: Organization of Chemistry & Radwaste Group,Primary & Secondary Water Chemistry & Monitoring of Gaseous Effluent
ML17228A696
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 08/19/1994
From: Robert Carrion, Decker T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17228A695 List:
References
50-335-94-16, 50-389-94-16, NUDOCS 9408290183
Download: ML17228A696 (18)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323-0199

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Report Nos:

50-335/94-16 and 50-389/94-16

'Licensee:

.Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:

50-335 and 50-389 Facility Name:

St.

Lucie 1 and

License Nos.:

DPR-67 and NPF-16 Date Signe SUMMARY Inspection Conducted:

July 18-22, 1994 Inspector:.,-~

A 7.

/ pjggi g S

R

.

arrion, Radiation Specialist T.

R. Decker, Chief ate igned Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards Scope:

This routine, announced inspection was conducted in the areas of the organization of the Chemistry Department and Radwaste Group, primary and secondary water'hemistry, the Semiannual Radioactive Effluent Release Report, monitoring of gaseous effluents, the Radiological Environmental Monitoring Program (REMP), the Annual Environmental Operating Report, monitoring of the Refueling Water'ank (RWT) leak migration, status of the Unit 1 nitrogen system check valve installation, contaminated sludge disposal, and radioactive waste shipping operations and transportation documentation.

Results:

The licensee's organization of its Chemistry Department and Radwaste Group satisfied Technical Specification (TS) requirements.

(Paragraph'2)

The licensee's plant water. chemistry continued to be effectively implemented.

(Paragraph 3)

The Semiannual Radioactive Effluent Release Report indicated that the licensee had met the requirements of the TSs and that doses to the public were minimal.

(Paragraph 4)

9'408290i 83 940819 PDR ADOCK 05000335 PDR

The licensee's personnel were knowledgeable and competent to take and prepare samples for analysis despite questionable handl"ing techniques.

(Paragraph 5)

The licensee had an effective program in place to monitor radiological effluents, direct radiation, etc.

due to plant operations and the plant operations had caused minimum impact to the environment and virtually no dose to the general public from those effluents.

,(Paragraph 6)

The Annual Environmental Operating Report for 1993 was well written and complied with applicable regulations.

(Paragraph 7)

The licensee continued to monitor isotope. migration due to the RWT leak.

(Paragraph 8)

The licensee was almost'ready to install the double check valves and complete the upgrade of the Unit 1 nitrogen system to prevent future valve leakby potential.

(Paragraph 9)

The licensee had proceeded in a prudent manner on the issue of contaminated sewage sludge disposal.

(Paragraph 10)

The licensee's radwaste processing and shipping was conducted in a competent, professional manner and the radwaste shipping documentation was thorough and in compliance with the applicable regulations.

(Paragraph ll)

REPORT DETAILS Persons Contacted Licensee Employees

  • K. Beichel, Secondary Chemistry Supervisor
  • W. Blandon, Quality Manager
  • H. Buchanan, Health Physics (HP) Supervisor
  • C. L. Burton, Plant Manager
  • R. L. Church, ISEG Chairman R.

E.

Cox, Chemistry Effluents Supervisor

  • D. H. Faulkner, Primary Chemistry Supervisor
  • T. Glenn, Instrumentation and Controls (I&C) Department
  • J. Holt, Licensing Engineer
  • L. McLaughlin, Licensing Manager
  • J. Scarola, Operations Manager R.

B. Somers, HP (Radwaste)

  • D. Wooldridge, Chemistry Training Instructor Other licensee employees contacted during this inspection included technicians and administrative personnel.

Florida Department of Health and Rehabilitative Services (DHRS)

K. Heath, Public Health Physicist II Nuclear Regulatory Commission (NRC)

S.

A. Elrod, Senior Resident Inspector

  • M. S. Miller, Resident Inspector
  • Attended exit interview Acronyms and Initialisms used throughout this report are listed in the last paragraph.

Organization (84750 and 86750)

Technical Specification (TS) 6.2 describes the licensee's organization.

The inspector reviewed the licensee's organization, staffing levels, and lines of authority as they related to the Chemistry Department and Radioactive Waste Group to verify that the licensee had not made organizational changes which would adversely affect the ability to control radiation exposures or radioactive material.

There had been no structural changes in the Chemistry Department since the previous inspection.

However, the normal, periodic rotation of technicians (which was made to assure that the technicians maintain a

high level of expertise in all areas within the Department)

had taken plac There had been no changes in the Radwaste Group since the last time this area was reviewed.

(Refer to Inspection Report (IR) 50-335, 389/93-27, Paragraph 2.)

The inspector concluded that the licensee's organization in the areas of Chemistry and Radioactive Waste satisfied the requirements of the TS.

No violations or deviations were identified.

Plant Water Chemistry (84750)

During the inspection, both units were operating at one hundred percent power.

Unit 1 was in its twelfth fuel cycle and Unit 2 was in its eighth fuel cycle, having completed its seventh refueling outage during the spring.

The next Unit 1 refueling outage was scheduled to begin in November 1994.

Primary Water Chemistry The inspector reviewed the plant chemistry<<.controls and operational controls affecting primary plant water chemistry since the last inspection in this area.

TS 3.4.7 specifies that the concentrations of dissolved oxygen (DO), chloride, and fluoride in the Reactor Coolant System (RCS)

be maintained below 0.10 parts per million (ppm), 0. 15 ppm, and 0.10 ppm, respectively.

TS 3.4.8 specifies that the specific activity of the primary coolant be limited to less than or equal to 1.0 microcuries/gram (pCi/g) dose equivalent iodine (DEI).

These parameters are related to corrosion resistance and fuel integrity.

The oxygen parameter is established to maintain levels sufficiently low to prevent general and localized corrosion.

The chloride and fluoride parameters are based on providing protection from-halide stress corrosion.

The activity parameter is based on minimizing personnel radiation exposure during operation and maintenance.

Pursuant to these requirements,.

the inspector reviewed daily summaries for both units which correlated reactor power output to chloride, fluoride, and dissolved oxygen concentrations, and specific activity of the reactor coolant.

For both Units 1 and 2, the arbitrarily-chosen period of Hay 1, 1994 through June 30, 1994 was reviewed and the parameters were determined to have been maintained well below TS limits.

Typical values for DO, chloride,

,and fluoride were less than five parts per billion (ppb), less than four ppb, and six ppb, respectively, for Unit 1 and less than five ppb, five ppb, and five ppb, respectively, for Unit 2.

Typical DEI values at steady-state conditions 'ranged from 7.79E-3 pCi/g to 1.54E-3 pCi/g for Unit 1 and from 4.65E-3 pCi/g to 1.69E-3 pCi/g for Unit 2.-

Neither unit had shown any evidence of leaking fue The inspector concluded that the Primary Plant Water Chemistry was maintained well within the TS requirements.

Secondary Water Chemistry TS 6.8.4.c requires the licensee to establish, implement, maintain, and audit a Secondary Water Chemistry Program to inhibit steam generator (S/G) tube degradation.

The inspector discussed the impact of the licensee's program on the condition of the steam generators.

The licensee had implemented the EPRI PWR Secondary Water Chemistry Guidelines on both units (Unit 1 since 1982 and Unit 2 since 1983).

Although not all of the latest (Rev. 3) guidelines had been incorporated into its procedures, the licensee generally operated within the latest guidelines.

For example, the licensee's upper limit for feedwater concentrations of iron and copper were 20 ppb and 2 ppb (reflecting the Rev.

2 guidelines),

respectively, while the Rev.

guidelines have reduced these concentrations to 5 ppb and 1 ppb, respectively.

However, the licensee had typically been operating in the 1 ppb to 2 ppb range for iron and less than 0. 1 ppb for copper, thereby easily meeting even the latest guidelines.

The most notable example where the licensee elected not to adopt or operate within the newly-revised guidelines was in the feedwater hydrazine concentration.

The previous guideline value for feedwater hydrazine concentration was to be three times the

~ condensate dissolved oxygen concentration.

The latest revision

.recommended that the feedwater hydrazine concentration be greater than 100 ppb.

The licensee had increased its feedwater hydrazine/condensate dissolved oxygen ratio, from the previously-'ecommended 3/1 to 5/1.

The licensee had determined that operating at feedwater concentrations greater than 100 ppb would result in pH levels being too high in the feedwater and condensate.

Although this could have been resolved by increasing the blowdown rate, the associated expense (from using excessively-large quantities of make-up water or recovery via the processing of the blowdown through the dimineralizer beds and their eventual disposal of the resultant greater radwaste volumes of contaminated resins)

had been deemed to be too great.

Intergranular Attack/Stress Corrosion Cracking (IGA/SCC) on the outside diameter, circumferential cracking at the hot leg tube sheet, and minor denting were observed in the Unit 1 S/Gs during the last (eleventh) refueling outage.

Minor IGA/SCC on the outside diameter, minor circumferential cracking at the hot leg tube sheet, and wear were identified in the Unit 2 S/Gs during the recent (seventh)

refueling outage.

Since the early 1980's, sludge lancing has been carried out during the respective refueling outages of each unit.

A summary of sludge removed follows on the next pag St.

Lucie Slud e Removal Histor Fuel Cycle No.

3

6

8

10

Unit

~1bs.

3900 1100 590 400 496 295*

167*

Unit 2

~1b s.'

200

'00 558.

153" 475*

  • Dry Weight During the most recent Unit 2 refueling outage, the sludge lancing was performed using peripheral spray equipment while the sludge was siphoned from the tubesheet center tubelane.

The sludge lancing was completed from three directions to clean

"shadow" areas.

It was noted that significantly more sludge was removed during the last outage as compared to the previous one.

The

'licensee attributed the increase to an increase in the number of

'ondenser leaks and changes in power operations during the fuel cycle, which may have increased the amount of feedtrain corrosion products carried into the S/Gs.

To date, the number of plugged tubes was 1082, 736, 269, and 198 for S/G 1A, S/G 1B, S/G 2A, and S/G 2B, respectively.

Review of

'historical data with the Secondary Chemistry Supervisor determined that the plugging of the Unit 1 S/Gs was occurring at a slower rate since 1990, when boric acid had been added to the feedwater.

~ The licensee hoped that the reduction would enable it to postpone'he replacement of the Unit 1 S/Gs, currently scheduled for 1997.

The licensee attributed the large number of plugged tubes to-less than optimal chemistry practices during the early years of operation, before detailed chemistry data had been compiled and chemistry parameter interactions were understood.

The Unit 2 S/Gs had experienced a significant increase. in plugged tubes between 1983 and 1985, but the number of plugged tubes had increased very slowly since then.

For example, only five tubes were plugged in S/G 2A and four in S/G 2B during the last outage.

The Unit 2 S/Gs are now substantially below the maximum allowable plugging rate for a forty-year design life (or 1430 tubes per S/G in forty years).

The inspector concluded that the licensee had implemented an effective Secondary Water Chemistry Program.

No violations or deviations were identifie Semiannual Radioactive Effluent Release Report (84750)

TS 6.9. 1.7 required the licensee to submit a Semiannual Radiological Effluent Release Report within specified time periods covering the operation of the,facility during the previous six months of operation.

(The -inspector noted that the TS had been revised to 'require the licensee to submit an Annual Radiological Effluent.Release Report, beginning with data for 1994.)

The inspector reviewed the'Semiannual Radiological Effluent Release Report for the second half of 1993, including the liquid and gaseous effluent results for that period..

Those results were added to the

. results of the first half of 1993 and the sum was compared to those of.

full years 1991 and 1992.

The data for those years are summarized as follows.

St.

Lucie Radioactive Effluent Release, Summary 1991 1992 1993 Unplanned Releases a.

Liquid b.

Gaseous Activity Released (curies)

o'

a ~

b.

Liquid 1.

Fission and Acti-vation Products 2.

Tritium 3.

Gross Alpha 2.

3.

4.

Gaseous 1.

Fission and Acti-vation Products Iodines Particulates Tritium 1.28E+0 1.25E+3 3.10E-5 4.24E+3 1.43E-2 2.96E-4 1.74E+2 1. 02E+0 8; OOE+2 3.27E-5 9.90E+2 5.69E-3 2.31E-4 6.04E+1 1.43Ew0 5.09E+2 6.00E-5 3.47E+2 2.46E-3 1.22E-4 2.50E+1 Dose Estimates

'a ~

Gaseous Effluents*

2.

3.

Noble Gas Gamma Dose (mRad)

Noble Gas Beta Dose (mRad)

Infant Thyroid (mrem)

4.20E-2 1.31E-2 7.93E-2 2.78E-2 5.17E-3 1.09E-2 1.60E-1 9.45E-2

" 5.42E-2

b.

Liquid Effluents (mrem)

Adult Whole body 7.99E-2 2.08E-1 3.72E-l

  • Estimated individual organ dose using the Land Use Census for the worst sector and existing pathways.

A comparison of the activity released from liquid,fission and activation products, tritium, and gross alpha, as well as gaseous fission and activation products, iodines, particulates, and tritium data for 1991, 1992, and 1993 showed decreasing trends for all categories of gaseous releases and liquid releases of tritium.

No significant changes were noted in the other results.

In addition, the dose estimates showed no significant changes; The maximum-exposed real member of the public due to releases of airborne I-131, tritium, and all radionuclides in particulate form with a half life of greater than eight days was.identified as an infant, with the critical organ being the thyroid.

The maximum-exposed organ of the public due to radioactive materials in liquid effluents in unrestricted areas was identified as the lung of an adult, while the maximum whole body dose was that of an adult.

For 1993, St.

Lucie liquid, gaseous, and particulate effluents were maintained well within TS,

CFR 20, and

CFR 50 effluent limits.

Revisions 12 and 13 were made to the Offsite Dose Calculation Manual (ODCM) during this reporting period.

In each case, the revisions were made to conform to standardized regulatory guidance.

Revision 12 moved the Radioactive Effluent Limiting Conditions for Operation (LCOs) from the TSs to the ODCM, per guidance of NRC Generic Letter 89-01.

Revision 13 implemented the revised

CFR 20 revisions for Radioactive Effluents.

No revisions had been made to the Process Control Program (PCP) during the second half of 1993.

The following table summarizes solid radwaste shipments for burial or disposal for the previous three years.

These shipments typically include spent resins, filter sludge, dry compressible waste, and contaminated equipment.

St.

Lucie Solid Radwaste Shipments 1991 1992 1993 Number of Waste Disposal Shipments

28

Volume (cubic meters)

Activity (curies)

182.1 825.7 213.8 388.2 88.1 12395

For the calendar year to date, July 21, 1994, the licensee made five radwaste shipments, including two to Scientific Ecology Group, Incorporated (SEG),. and three to the disposal facility.

For solid radwaste, the most significant change noted for the perioP r'eviewed was that the volume of the shipments had declined.

Discussions with the licensee representative responsible for shipping radioactive materials indicated that the volume was somewhat suppressed due to the processors giving priority to non-members of the 'Southeast Compact who were trying to dispose of their radioactive material prior to their official exclusion from the Low Level Radioactive Material Disposal Facility in Barnwell, South Carolina.

(The large activity reported for 1993 was due to a shipmeht of irradiated hardware.)

Furthermore, in an effort to reduce/minimize future radwaste volumes, the licensee had recently established.

several teams to,investigate alternative -ideas.

The inspector concluded that the Semiannual Radioactive Effluent Release Report was complete and satisfied TS requirements.

No violations or deviations were identified.

Monitoring of Radiological Gaseous Effluents (84750)

Section 4. 11.2. 1.2 of the ODCM requires that representative..samples of radioactive gaseous effluents be taken and analyzed.

Pursuant to this requirement, the inspector observed a Plant Technician take noble gas grab samples of the Plant Vent and the Fuel Handling Building of Units 1 and 2.

This work was done under Section 8.4. 1 of Chemistry Operating Procedure No. C-72, Rev. 33, approved June 14, 1994,

"Processing Gaseous Waste".

The inspector reviewed the procedure and referred to it as the technician took the sample to assure that it was being properly implemented.

The technician was very familiar with the procedure and obtained the samples without incident.

The samples were immediately taken to the Count Room for analysis as they were collected.,

The samples were counted for fifteen minutes and'typically were determined to have an activity of "'less than 3'.SE-8 pCi/ml for tritium and less than 4.0E-13 pCi/ml noble gases.

Analysis of the particulate filters and four-liter gas marinelli beakers determined that the activities were less than the Lower Limit of Detection (LLD).

In the course of observing the collection 'and preparation of the samples for analysis, the inspector observed that the technician used handling techniques which were less than optimum, although there was no spread of contaminated material or cross-contamination of the samples.

This was acknowledged by the technician at the time.

Subsequent discussions with supervisory personnel resulted in the issuance of a memorandum to the staff of the Chemistry Department to be more conscious of their handling technique's/practices.

A copy of the memorandum was also sent to the Training Department so that greater emphasis would be given to this subject during future training unit The inspector concluded that the licensee's personnel were knowledgeable and competent to take and prepare samples for analysis despite handling techniques which were'ess than exemplary.

No.violations or deviations were identified.

Radiological Environmental Monitoring Program (REMP)

(84750)

Sections 3/4. 12. 1 of the licensee's ODCH specify that the licensee shall conduct a Radiological Environmental Monitoring Program in accordance with TS 6.8.4.g.

1 (as specified in ODCM Table 3. 12-1) to monitor radiation and radionuclides in the environs of the plant and define how the program shall be conducted.

The REMP shall provide representative measurements of radioactivity i'n the highest potential exposure pathways and verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways.

Accumulation of radioactivity in the environment can thereby be measured and trends can be, assessed to determine whether the radioactivity resulted from plant operations.

The data may also be used to project-"the potential dose to offsite populations based on the cumulative. measurements of any plant-originated radioactivity, as well as to detect unanticipated pathways for the transport of radionuclides through the environment.

The St.

Lucie Nuclear Plant Environmental Monitoring Program is designed to detect the effects, if any, of plant operation on environmental radiation levels by monitoring airborne, waterborne, ingestion, and direct radiation pathways in the area surrounding the plant site. It also supplements the REMP by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

Indicator sampling stations are located where detection of the radiological effects of the plant's operation would be most likely, 'where the samples collected should provide a significant indication of potential dose to man, and where an adequate comparison of predicted radiological levels might be made with measured 'levels.

Control stations are located where radiological levels are not expected to be significantly influenced by plant operation, i.e., at background locations.

An environmental impact assessment of plant operation is made from the radiological measurements of the sampling stations.

The REMP was conducted at the St.

Lucie Plant by the Office of Radiological Control, Florida Department of Health and Rehabilitative Services (DHRS).

Samples were collected and analyzed by DHRS personnel at the DHRS Environmental Radiation Control Laboratory in Orlando, Florida.

The REMP was discussed with the Florida DHRS Health Physicist.

a ~

Observation of Sample Collection The inspector accompanied the Health Physicist on part of her normal weekly rounds to collect samples to observe collection technique and to check the physical condition and operability of the sampling stations.

Samples were taken at five indicator

stations; H-14, H-30, H-33, and H-34 (for air samples),

and H-15 (for a water sample).

All air sampling stations included thermoluminescent dosimeters (TLDs) for the detection of direct gamma radiation.

The DHRS Health Physicist pointed out additional TLD locations as well. The air sampling stations were located such that there would be no interference from tall weeds/vegetati'on in taking representative samples.

The inspector noted that the, sampling units were well maintained, within calibration, in good working order, and that there was no evidence of vandalism.

The inspector observed that the samples were properly collected and that the technician used good HP techniques to avoid sample contamination and conducted her work in an efficient, competent manner.

=1993 Annual Radiological Environmental Operating Report TS 6.9. 1.8 requires.that the Annual Report be submitted prior to Hay 1 of the following year.

TS 6.9. 1.8 also states format and content requirements for the Report.

The inspector reviewed the Annual Radiological Environmental Operating Report for calendar year 1993 to verify compliance with the TSs.

The Report had been submitted in compliance with TS 6.9. 1.8 on April 20, 1994 and the format and contents were as prescribed by the TS.

There were no changes to the. environmental monitoring network during 1993.

For the 1993 calendar year, 827 samples were taken and analyzed.

Analytical results were divided into four categories based on exposure pathways:

Airborne, waterborne, ingestion, and direct radiation.

Each of the pathways was described as follows:

The airborne exposure included airborne iodine and airborne particulate samples.,

No fission products or other man-made isotopes in the airborne particulate media were detected in 1993.

Overall 1993 airborne results were very similar to those of previous years and preoperational levels.

The waterborne exposure pathway included surface water samples and shoreline sediment samples.

Tritium was the only man-made isotope detected in the surface water or shoreline sediment at collection station H-15.

Activity levels in the surface water samples were consistent with past measurements.

Tritium was reported in three (of fifty-two) samples.

The highest measured tritium activity was less than two percent of the reporting level defined in Table 3.12-2 of the ODCH.

The shoreline sediment contained no detectable levels of any man-made isotopes, but the naturally-occurring K-40, Ra-226, and Th-232 were detected.

The ingestion exposure pathway included fish and crustacea, and broad-leaf vegetation samples.

Naturally-occurring K-40 and Ra-228 were detected at normal environmental level Vegetation samples yielded concentrations of radioisotopes which were similar to those of the control sampling stations and of the preoperational period.

Only naturally-occurring K-40 and Be-7 were detected.

I I

The environmental direct radiation exposure pathway was measured by use of TLDs.

TLD results for 1993 remained consistent with those of previous years, i.e. essentially unchanged since the preoperational period.

The report showed that the program was conducted in accordance with requirements and that supplemental-sampling and analyses were performed.

The radiological environmental data indicated that the levels of radiation and concentrations of radioactive materials in environmental samples (representing the highest potential exposure pathways to members of the public) were not increasing.

Therefore, plant operations had no significant. impact on the environment or public health and safety.

The maximum radiation dose from airborne, waterborne, ingestion, or direct exposure pathways attributed to plant operations in 1993 to any offsite member of the public was well within the criteria established. by

CFR 190.

Analytical Comparison of 1993 Report The NRC contracts with the Radiological, and Environmental Sciences Laboratory (RESL) to analyze samples split between the State of Florida and the NRC.

The NRC compares the RESL results to those."

of the State of Florida for analysis confirmation.

The inspector randomly selected the analytical results for twelve gross beta air particulate filter split samples from Sample Station H-14 (specifically, the four samples collected in'ay, the four samples collected in August,.and for the samples collected on November 23 and 30 and Dec'ember 6 and 13, 1993) for comparison of the results.

After adjusting for the different units used by the different laboratories to report the results, the inspector determined that the reported results compared favorably.

Typical.

values for gross beta in the air particulates were reported by the licensee to be 0.015 pCi/m'.

The inspector also compared the analytical results of shoreline sediment of Sample Station H-15 taken on February 15 and August 12, 1993 and determined that the reported results compared favorably.

Typical values of Cs-137 were 15 picocuries per kilogram (pCi/kg) and K-40 were '300 pCi/kg, for example.

C The inspector concluded that the results of analyses of environmental samples by the State of Florida compared favorably to those of RESL, which served as an independent verification of the result The inspector concluded that the licensee had an effective program in place to monitor radiological effluents, direct radiation, etc.

due to plant operations and that the Report was in compliance with the TSs.

In 1993, plant operations caused minimum impact to the environment and virtually no dose to the general public from those effluents.

No violations or deviations were identified.

Annual Environmental Operating Report for 1993 (84750)

Section 5.4. 1 of Appendix B of the St.

Lucie Unit 2 Environmental Protection Plan (EPP) requires the submittal of an annual report for various activities at the plant site related to Federal and State environmental permits and certifications.

A report on aquatic and terrestrial sea turtle monitoring programs as required by EPP Subsections 4.2. 1 (Beach Nesting Surveys),

4.2.3 (Studies to Evaluate and/or Mitigate Intake Canal Mortality), and.4.2.5 (Capture and Release Program)

was submitted on April 26, 1994.

(The NRC has jurisdiction for sea turtl'e studies and is considered to be the lead federal agency relative to consultation under the Endangered Species Act.)

The inspector reviewed the'eport to verify compliance with the referenced regulation.

The report was well-written and thorough.

It detailed methods utilized to capture and release turtles found in the intake canal, to determine the sex of immature turtles, to analyze nesting data, etc.

In addition, it included a listing of five non-routine reports submitted to the NRC in 1993 in accordance with Section 5.4. 1(c) of the EPP, such as incidents involving a CERCLA-reportable release of hydrazine to the onsite stormwater basin, exceeding the National Pollutant Discharge Elimination System (NPDES)

Permit minimum pH limitation for sewage treatment plant effluent, and an increase in sea turtle entrapment in the plant's condenser cooling water intake canal.

No non-compliances under EPP Section 5.4. 1(a),

as determined by the licensee, were reported.

No plant activities were determined to be reportable, as determined by the licensee, under Section 5.4. 1(b) of the EPP.

The inspector concluded that the report was well-written and complied with applicable regulations.

No violations or deviations were identified.

Refueling Water Tank (RWT) Leak Status (92700)

The RWT leak was addressed in IRs 50-335, 389/93-17 and 50-335, 389/93-27, which described the circumstances surrounding the leak, measures taken by the licensee, and planned actions to monitor the released material.

The licensee had treated the event as an Unplanned Release and had incorporated this information into the Semiannual Radioactive Effluent Release Report for the second half of 199 The licensee had continued to monitor the migration of the tritium released through a system of twenty monitoring wells and four recovery wells, originally established to monitor a diesel fuel leak from the nearby diesel fuel tanks; The inspector went to the RWT location to review the general area, including nearby structures and monitoring.

wells.

The inspector also reviewed results of. analyses from well samples taken on January 26 and May 5, 1994.

For the three wells nearest the RWT (Monitoring Wells Nos.

4 and 18D and Recovery Well No=. 2), the tritium concentrations had dropped continuously'for Monitor Well No.

4 since the initial leak and had dropped for Monitor Well No.

18D since a moderate increase seen in its 0'ctober 1993 results.

However, Recovery Well No.

2 had shown a moderate increase since the October 1993 results, but the activity was still less (by a factor of 20) than the sample results of July 1993, taken shortly after the leak was originally identified.

In wells located more distant from the RWT, tritium activities were reported to be less than the Minimum Detectable Activity (MDA) to a maximum of 1.43E-4 pCi/ml (for the four other wells reporting activity).

The Hay samples were analyzed for gross beta activity and, with the exceptions of Monitor Well No.

18D and Recovery Well No.

2 (where activities of 8.66E-6 pCi/ml and 6.38E-6 pCi/ml were detected, respectively),. all were found to be 1'ess than 3.3E-6 pCi/ml.

The inspector concluded that the licensee was adequately monitoring the migration of the release and that the public health and safety was not in jeopardy from this release.

No violations or deviations were identified.

Check Valve Installation Status (92700)

Due to two similar unplanned releases in late 1992 and early 1993 via leakby of the nitrogen supply valve, the licensee had decided to install a double check valve on the nitrogen supply line to the Unit 1 Reactor Auxiliary Building (RAB) identical to that of Unit 2 to prevent back flow from the potentially radioactive RAB to the Secondary Plant side of the nitrogen system.

(The installation would bring the Unit 1 design up to a level equal to that of the Unit 2 design, which had incorporated the double check valve into its original design.

Refer to Paragraph

of IR 93-09.)

The licensee currently plans to execute the check valve

,installation via Plant Change/Modification (PCM)-142-193M and its associated Construction Work Order (CWO) 6519.

The valves were onsite and the CWO was being reviewed in preparation for the installation, which was-expected by mid-August, prior to the next schedule'd Unit "1 refueling outage.

The inspector reviewed the associated Minor Engineering Package (MEP), which provided the engineering justification and design information to install the check valves, and concluded that it was well-written and complete.

The inspector concluded that the licensee was taking appropriate action to upgrade the nitrogen system to prevent future valve leakby potential

by the installation of the double check valves and that progress to date was satisfactory.

No violations or deviations were identified.

Contaminated Sewage Sludge Disposal (92700)

The issue of contaminated sludge and its disposal was addressed in Paragraph 12 of IR 50-335, 389/93-17 and Paragraph 11 of IR 50-335, 389/93-17.

Since the last inspection, the licensee had completed the disposal of the twenty-five 55-gallon drums, which had been temporarily stored near the Unit 1 sewage treatment plant (STP).

The licensee had shipped the material to SEG for incineration (thereby 'substantially reducing its volume) before final disposal.

The material was included as part of Shipment No. 94-26, which was made on Hay 6, 1994.

With regards to the future disposal of contaminated sludge, the li'censee had explored the alternatives referenced in IR 50-335, 389/93-27.

Of those alternatives, the licensee had pursued the shipping of its STP material to a local municipal STP for normal processing.

The licensee had secured approval from the Florida Department of Health and Rehabilitative Service's (DHRS) to dispose of the material by shipping it to the Indian River County STP for normal treatment and processing providing that:

The DHRS samples each shipment of STP material prior to shipping to detect possible radiological contamination in excess of allowable limits.

The Indian River County STP has the right of refusal of any material from the licensee, as well as the right to sample any shipment prior to its leaving the site.

Actual shipping of the STP material was expected to be permitted within the next several weeks, pending a final review by corporate management.

The inspector concluded that the licensee had proceeded in a prudent manner on this issue.

No violations or deviations. were identified.

Radwaste Processing and Transportation (86750)

CFR 71.5 (a) requires that each licensee who transfers licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR, Parts 170 through 189.

Pursuant to these requirements, the inspectors reviewed the licensee's activities affiliated with these requirements, to determine whether the

licensee effectively packages, stores, and ships radioactive solid materials.

The licensee's program for the packaging and transportation of radioactive materials, including solid radwaste, was conducted by the Radioactive Waste Group within the Health Physics Department.

Radwaste was processed and packaged (including the preparation of shipping documentation)

by the Radwaste Group, with the assistance of Radiation Protection Hen (RPH)

on loan from the Health Physics Operations Department to complete specific tasks, such as loading a shipment or compacting contaminated material.

a.

Radioactive Haterial Shipping Documentation Packages The inspector reviewed the documentation packages for Radioactive Haterial Shipment No.- 94-26, a

Low Specific Activity (LSA), Type A

shipment, destined for incineration or compaction before final disposal.

It included twenty-five drums of solidified sludge from the STP as well as seven drums of metal oxide material from the steam generators, and seventeen drums of DAW mixed with asbestos.

The package contained thorough documentation about the shipment and included items such as unique shipment and shipping container number, waste content and volume, total activity, analytical summary and breakdown of isotopes with a half-life greater than five years, special comments, etc.

The radiation and contamination survey results were within the

CFR requirements and the shipping documents were being maintained as required.

b.

Observation of Setup for Radioactive Naterial Process The inspector observed licensee personnel activities associated with setting up'quipment to transfer spent resin to a High Integrity Container (HIC) inside a shipping cask, where the resin would be dewatered prior to shipping to the disposal facility at Harnwell, South Carolina, to evaluate the effectiveness of training, activities and attitudes of personnel, adequacy of procedures, etc.

The wor k proceeded well; each member of the work detail handled his responsibilities in an efficient, professional manner.

The licensee personnel were conscious of potential radiological material hazards, as was evidenced the use of radiation dose meters, smear samples, protective clothing, etc.

The inspector concluded that the licensee's program for the processing and transportation (including the required paper documentation)

of radioactive materials was adequate to satisfy regulatory requirements.

No violations or deviations were identified.

12.

Exit Interview (84750)

The inspection scope and results were summarized on July 22, 1994, with those persons indicated in Paragraph 1.

The inspector described the

areas insp'ected and discussed the inspection results, including likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection.

The licensee did not identify any such documents or processes as proprietary.

Dissenting comments were not received from the licensee.

Acronyms and Initialisms CERCLA CFR Ci CP CWO DEI DHRS DO DOT EPP EPRI FPL g

HIC HP IIl.C IGA IR kg

LCO LLD LSA pCi m

MDA MEP ml mRad mrem No.

NPDES NRC ODCM pCi PCM PCP ppb ppm PSL PWR RAB RCS Comprehensive Environmental Response, Liability Act of 1980 Code of Federal Regulations curie Chemistry Procedure Construction Work Order Dose Equivalent Iodine Department of Health and Rehabilitati Dissolved Oxygen Department of Transportation Environmental Protection Plan Electrical Power Research Institute Florida Power and Light gram High Integrity Container Health Physics Instrumentation and Controls Intergranular Attack Inspection Report kilogram liter Limiting Condition for Operation Lower Limit of Detection Low Specific Activity micro-Curie (1.0E-6 Ci)

meter Minimum Detectable Activity Minor Engineering Package milli-liter milli-Rad mi 1 1 i -r em Number National Pollutant Discharge Eliminat Nuclear Regulatory Commission Off-site Dose Calculation Manual pico-Curie (1.0E-12 Ci)

Plant Change/Modification Process Control Program parts per billion parts per million Plant Saint Lucie Pressurized Water Reactor Reactor Auxiliary Building Reactor Coolant System Compensation, and ve Control ion System

REHP

- Radiological Environmental Honitoring Program RESL

- Radiological and Environmental Sciences Laboratory Rev

- Revision RPH

- Radiation Protection Han RWT

- Refueling Water Tank SCC

- Stress Corrosion Cracking SEG

- Scientific Ecology Group, Incorporated S/G

- Steam Generator STP

- Sewage Treatment Plant TLD

- Thermoluminescent Dosimetry TS

- Technical Specification