IR 05000338/1990013

Insp Repts 50-338/90-13 & 50-339/90-13 on 900514-18 & 29. Noncited Violations Noted.Major Areas Inspected:Radiation Monitoring Sys,Water Chemistry & QC

ML20055H619
Person / Time
Site:	North Anna
Issue date:	06/27/1990
From:	Decker T, Seymour D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20055H616	List: IR 05000338/1990013 ML20055H615
References
50-338-90-13, 50-339-90-13, NUDOCS 9007270094
Download: ML20055H619 (10)

Text

rm

. :--

4 neog

/ ps UNITEISTATES

., +

NUCLEAR RE!ULATOSY COMMISSION

=[ o REGION 11 (* g

• .]'

101 MARIETTA STREET, ATLANTA. GEORGIA 30323 k

• *O

,

g 2,8 $9)

' Report Nos.: 50-338/90-13 and 50-339/90-13 Licensee: Virginia Electric and Power Company Glen Allen, Virginia 23060 Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7-

.,q Facility Name: North Anna 1 and 2 Inspection Conducted: May 14-18 and May 29, 1990

.t

] -;

j Inspector: _

D~.

hh Ai seyfoGr

-

-

6/O

~

Date signed

,

r Approvsd by: 485 [ lo - 4'/2 7Ne' >

'

~ CR Decker, Chief Date Signed l Radiological Effluents and Chemistry Section i

,

Emergency Preparedness and Radiological Protection Branch Division,'fo Radiation Safety and Safeguards i

f f

SUMMARY t

Scope This routine, unannounced inspection was conducted in the areas? of. the Radiation Monitoring System, Water Chemistry, and Quality Contro j Results: -*

In the areascinspected, two non-cited v'i olations (Paragraph 7) were-identifie .

No significant radiological consequences attributable to the operation of the plant during 1989 were noted from airborne, waterborne,-aquatic, ingestion, or direct exposure pathways; .1neJ chemistry parameters were maintained within procedural specifications, adequately tracked and documented, and adequate -

corrective actions were taken -during system. perturbations. Diesel fuel was

=

!

maintained within Techncial Specifications. The Station Nuclear- Safety and 5 Operating Committee _was functioning adequately. -Parts of.the on going study o'

the Radiation Monitoring System have been completed, while others have not oeen schedule i i

9007270094 90062S '

PDR ADOCK 0300 O {S

.

k l

-v

.-.

.i'-

, .

.-

. .

.

.

(

REPORT DETAILS Persons Contacted Licensee Employees M. Bowling Assistant Station Manager

• Clark, Supervisor-Quality-Auditing

• E. Dreyer, Supervisor of Health Physics Technical Services

"G. Kane, Station Manager

• Sadollah, System Engineer, Radistion Monitoring System

• R. Simpson, Licensing' Engineer

• 0. Sloane, Chemistry Supervisor

• J. Smith, Manager of-Quality Assurance

• A. Stafford, Superintendent of Radiation Protection

• Thornton,' Corporate Director of Health Physics and Chemistry Services

• C. Wallen, Licensing Engineer

Other licensee employees contacted during this inspection included engineers, security force members,- technicians, and administrative personne * Attended exit interview Licensee Action on Previously Identified Findings and Inspector' Follow-up Items (IFIs) (92701) (Closed) IFI 50-338/88 REC-01: Review of Licensee Revised Control Room Dose Evaluatio Of fice of Nuclear Reactor Regulation 1(0NRR) reviewed' and' approved-License Amendments " <26 and 110 to Facility Operating Licens Nos. NPF-4 and NPF-7 ior the North Anna Power *tation Units 1 and These amendments covered the revision of the limiting dose to control room operators. The licensee submitted _ an engineering evaluation of the radiological consequences to the control room operators during and following an accident as part of this safety evaluatio The licer.see recalculated the dose evaluation and determined that despite multiple entries ..ito the control room, control room ~ operators would be adequately- protected and that' the dose : limits specified -in the General Design Criterion 19 would not be exceeded.- The letter of >

citing approval for these amendments was dated February 28, 199 This' item is considered closed, (Closed) IFT S0-338, 339/89-33-02: Review of Licensee's Tritium Analysis Retults of NRC Spiked Sampl An NRC confirmatory measurements inspection-in June of 1989-indicated

.

that the licensee was in disagreement with the NRC for a tritium entlysi s. A corporate ' health physics (HP) staf f. ccnfirmatory .

-

. ,

t

.m _

_ ~

.

. o

• - ..

,

.

'

. 2

.

measurement analysis in May of 1989 also; showed disagreement for tritium. The . causes for these disagreements and the corrective actions were discussed with licensee representatives. Subsequent comparisons conducted between the plant, an outside vendor (June 1989), and the corporate HP staff (September ' 1989) showed good agreement. To confirm. the adequacy- of the licensee's corrective actions, an additional NRC tritium-spiked sample -was - shipped to the licensee in February,1989. The results of the analysis follow:

NRC-LICENSEE SAMPLE COMPARISON EVALUATION FOR TRITIUM AT NORTH ANNA

• -Licensee NRC Sample Licensee NRC Resolution Ratio Comparison Spiked H-3 1.65E-04 1.7740.05E-04 35 0.93 Agreement Liquid Sample This item is considered close . Radiological Environmental' Monitoring (84750)

Technical Specification (TS) 6.9.1.8 requires; the ~ submittal of a routine Radiological Environmental Operating Repor Pursuant to this requirement, the inspector reviewed the report for.198 The following observations were made: The air particulate gross beta concentrations lof all the indicacor -

5; locations for '1989 followed the gross beta concentrations at the

^

control location. Gamma isotopic-analysis of the samples showed only; naturally occurring isotopes. Fission products or man-made isotopes-were not detected. lodine-131 was detected at activity' levels below the required lower limit of detection:1n three of the 607 filters analyze The results of the surface. water tritium,$amples collected from Lakh Anna at the Waste Heat Treatment Facility averaged 3,725 pCi/ liter -

for 1989, slightly below the _ average of 3,915 pCi/ liter reported i . Tritium analyses for rivar ' water collected 5.8 miles downstream of the site averaged 3749 pC1/11ter .in 1989, as compared to 3,925 pCi/ liter in 1988. No gamma 'amitters were . detected;in the river water or .in the ground water from the on-site environmental well. Tritium was detected in one well sample at 210.pCi/11ter, which was considered an environmental level. It has been p*eviously noted that the tritium levels in Lake' Anna have shown an increasing trend since 1977, although these levels have been below the reporting:

.

level of 20,000 pC1/11ter'(TS Table 4.12-2, as required by Regulatory -

-

' Guide 4.8). Preoperational levels were 150 pCi/ liter for the Waste Heat Treatment Facility. The 1989 values show a small decrease from-the 1988 values, but it would be premature to conclude that the amount' of tritium has stabilited because it is possible that these-

. .

.

.

'

,

differences could be attributed to other factors, including experimental error or naturally occurring cyclical changes. No significant offsite doses would result from these levels of tritium in the lake wate Analysis of sediment / silt samples indie.ated that additional man-made isotopes appear to have accumulated in the sediment since the preoperational perio Iodine-131, cesium-137, and strontium-89 were not detected in any of the 24 milk samples taken during 1989. Potassium-40 was measured in all of the milk samples at normal environmental levels in 198 htrontium>90 was measured in all of the 1989 milk samples. These values were comparable to 1988 values and lower than preoperational values. The strontium-90 levels were attributed to past atmospheric nuclear weapons testing, The activity levels in the 1989 fish samples were statistically similar to those of 1987 and 1988. These levels were 10 percent or less of the reporting level Activity levels in the 1989 vegetation samples were statistically similar to preoperational and 1988 levels, The thermoluminescent dosimetry results fluctuate around preoperational levels and are less than the estimated levels due to na. Leal terrestrial and cosmic radiation and the internal dosage from natural radionuclide In summary, no significant radiological consequences attributable to the 5 operation of North Anna in 1939 were noted from airborne, waterborne, aquatic, ingestion, or direct exposure pathwa No violations or deviations were identified, s

4. Semi-Annual Effluent Report (84750)

TS 6.9.1.9 requires the submittal of routine Radioactive Effluent Release Reports covering the operation of the units during the previous six months of operation. Pursuant to these requirements, the inspector reviewed these reports for January 1, 1989 through June 30, 1989, and for July 1,

,

1989 through December 31, 1989. A summary of the effluent releases for 1987, 1988, and 1989 is presented below. The amount of activity released remained stable or decreased for most effluent streams. The liquid borne !

fission and activation products did increase in 1989. The licensee '

attributed this primarily to the tube leak in Unit I that occurred in February 1989. This tube leak allowed radionuclides to cross over from the primary side to the secondary side and resulted in higher release Gaseous iodines also showed an increase in 1989 relative to 1988. The licensee attributed this increase to the fact that the plant was in steady state operation in 1988, and was in outages for extended periods in 1989

'

. .

.-

-

'

. 4'  !

!

(4 to .5 months per. ' unit). During outages, it is ' typical to show a I increase in gaseous -releases due to containment purging. The annual

~

}

radiation doses to the maximum exposed member of the public due. to y radioactive. liquid effluents for 1989 was approximately 50 percent of. the -

TS limits.- The annual total radiation doses to the maximum exposed member i of the public due to gaseous effluents were approximately 1 percent of the ,

TS limit '

The effluent releases were were within TS,10 CFR 20, Appendix B,' and . '

10 CFR 50, Appendix ! effluent limit j Except for the two findings presented in~ Paragraph 7 of.this report, no I violations or deviations were identifie t i

North Anna Radioactive Effluent Summa y .

-

.

North Anna, Units 1 and 2 1987 1988 1989 i No.'of unplanned releases i

' Liquid 0 0' l j Gaseous 0 0- -O'  :

Activity Released (Curies)

f c Liquid Fission and Activation 1.33E+00 4 32Ei01

. 1.17E+00- ,

Gasses 1 Tritium 8.45E+02 l'.94E+03 1.40E+03 : Gross Alpha 2.81E-04 <LLD (LLD *

! Gaseous l

! Fission and Activation 1.05E+03 4.83E+02 :1.44E+03 ;

Gasses i Iodines 1.27E-02 1.56E-03 3.76E-03 i

- Particulates 4.60E-03 7.36E-04- 5.68E-04 :

i Tritium 1.73E+01- 9.44E+01' 1;22E402 1 Volume of Liquid Wastes 2.83E+08 3.38E+08 2;75E+08~ j released (prior to 4 i

dilution) (liters), j

!

t E. Primary and Secondary Coolant Chemistry Programs 1_'(84750)  !

TSs 3.4.7.and 3.4.8 require ihat Reactor Coolant System chemistry shall be ~j maintained within predetermined limits. TS 6,8.4.C' requires the licensee l to establish, implement, and maintain a program for monitoring secondary - >

water chemistry to inhibit steam generator tube ~ degradatio Pursuant to- l

.

{

'

.

q w ,

a

. _ _ __ . _ . _ _

. _ ,

,

. .

.4 e i  :-

'

,

t i

>

these requirements, the inspector discussed the licensee's primary and secondary coolant chemistry program . with licensee representative '

reviewed chemistry logs. and reviewed quality control correlations betwee '

on-line chemistry mo.itoring readouts and the analysis of periodic grab a sample ;

The primary coolant chemistry, parameters being . tracked included boron,; i lithium, primary coolant temperature, percent o full power, i dose-equivalent iodine (DEI), decontamination factor for primary coolant j cleanup, and reactor; coolant gas activity. . Secondary coolant parameters monitored included pH, conductivity, cation conductivity, and. sodium (in i ppm). . Feedwater was sampled and analyzed for silica, sodium, chloride, fluoride, and. sulfate j Discussions with the licensee -indicated that- there was a total of 96 online analyzers utilized for both unit The inspector reviewed ' the Online Chemistry Monitoring System Quality Control Data Sheets for Steam l Generator B of Unit-1 for the tine period of April 14, 1990 to May 14, ,i 1990. This log covered specific conductivity, cation conductivity. .pH, 'l sodium concentrations, and ' chloride concentrations. This log compared .

grab samples with online monitor results. The inspector also; reviewed log l sheets for the isotopic analyses used to determine the -leak' rates on blowdown for the time period of May 13,-1990 through May. 15, 1990. . Unit 2 f showed calculated leak rates of "not detectable" to 0.63 gallons per day (gpd). Unit I had a leak rate of 1.3 gpd for the B steam generator, i The inspector reviewed Procedure No. CAP-48, Guidelines. for Online i Chemistry Monitoring System, dated June 2, 1989, and Procedure No, i ADP 19.22, Secondary System Chemistry, dated February 1,199 !

lhe inspector reviewed selected daily North Anna chemistry data-sheets for [

both unit These sheets listed the r6.sults for several chemistry 1 parameters for the steam generators and the condensers.1 These: sheets also j listed parameters that fell out of specification, the limits 'for these parameters and the corrective action planned. The inspector. reviewed the'

,

March 1990 report entitled, " Virginia Power Nuclear Performance." This 1

.

report listed the Chemistry Index Values for January. through March of  !

1990. This index is based on the concentrations of key impurities in the ,

condensate and steam generators, including blowdown cation conductivity ;

and sodium. North Anna had a monthly goal: of 0.18. -Their January - March values for' the Chemistry Index ranged from 0.68 to 0.22.- This was attributed to-an. increase in cation conductivity caused by the morpholine- ;

addition in Unit I and by high condensate oxygen in Unit 2. Unit I showed zero out-of-specification hours for Reactor . Chemistry for fluorides,,

chlorides, oxygen, lithium, and hydrogen for: January through March of 1990. Uni; 2 showed .four out-of-specification- hours for lithium in January of 1990. Lithium hydroxide is added to the coolant to maintain an elevated pH. Lithium is not a TS parameter. . Table 3.4-1 of thef TSs require that the reactor coolant system chemistry limits for dissolved oxygen, chlorides, and fluoride be maintained at <0.10 ppm .'<0.15 ppm, and- -

<0.15 ppm, respectively. The licensee has maintained values of <5 ppb for

. ., f

,

,

__ . ____ _ _ _ _ .-. _

.

___- ____ __-_ . _ _ _ . _ _ _ _ _ _ . . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ - - _ _ _ _ _ - _ _ _ .

. .

,

-i

...

.

.

.

' .6 I

dissolved oxygen, <2-9 ppb for chloride, and <1 ppb for fluorides at f steady state for the last two year The inspector also reviewed '

deviation reports for the secondary chemistry for the time period of January, 1990 through May 12, 1990. Discussions with the licensee i revealed that the licensee is planning on implementing morpholine in Unit-  !

2. The licensee plans on performing a study of corrosion transport on t this unit prior to this implementation to' create 'a baseline data bas This study will basically consist of filters with- ion exchange ' sites so f that both soluble and insoluble. corrosion products could be quantifie The study will continue after implementation of the morpho 11ne, allowing

.

,

the licensee:to optimize the specifications for the syste In summary, the inspector determined, based on this selective review and +

discussions with the licensee, that the chemistry parameters were <

generally maintained within procedural specifications, adequately tracked  :

and documented. and - that adequate corrective actions .were taken during i system perturbations.- i No violations or deviations were identifie f Diesel Fuel (84750) *

.

TS 4.0.1.1.2b requires that a sample of diesel fuel from the fuel. storage l tank be tested at least once per 92 days to verify.that the diesel fuel is within specified limits for viscos.ity, water . andl sediment. Pursuant to

,

!

these requirements, the inspector reviewed Procedure No.1-PT-89.2A,- Fuel 1 011 Analysis "A" Tanks and Other Miscellaneous- Tanks, dated February 12,- j 1987. The inspector also reviewed Procedure No. 5.2.10, Revision 2, Fuel i

'

011 Tanks, dated January 30, 1990. The inspector reviewed a chemistry log for January 1990 through June 8,1990, and determined that'the licensee

_

was meeting TS requirement ;

No violations or deviations were identifie i Quality Assurance (QA) (84750)  !

TS 6.5.3.1.k requires that the Quality Assurance Department audit the radiological environmental monitoring- program and' the results. thereof at- ,

least once per 12 months. . Pursuant to this requirement', the ' inspector reviewed -QA Audit. Report No. 90-03' for Radiological l' Environmental- j!

Monitoring. Of f site pose Calculation Manual . (ODCM)r and Process Control ,

Program. This. audit was performed by a' team of six personnel and covered' ,

a five week time fram The' audi_t resulted -in . ten findings 4nd four i observations. The first finding concerned . liquid"and gaseous' dow *

projections not being performed in 1989 as required by.TSs,' TSs 4.11. :

and 4.11.1.3 state.that doses to gaseous and liquid releases from the site i shall be projected at least once per.31 days in accordance with the:0DC !

The audit team determined, through-record reviews'and^ interviews,'that.the gaseous dose projections were not performed in 1989, and _that. thel 11guid e

. dose projections were performed only four times in 1989. -The inspector-

' discussed this tinding with cognizant licensee' personnel and reviewed -the : ,

'

H l' 1

>

j

. _ . a

, -

• l

,

. 8

'

. 7

Audit Finding Initici Response Form for this findin The cause of the ;

deficiency was attributed to personnel error and to the fact that a '

periodic test procedure to verify and control the TS surveillance did not exist. The inspector also reviewed Licensee Event Report (LER) 004-90 which was submitted on March 29, 199 Calculations showed that applicable TS limits were not exceeded. The licensee also indicated that !

the personnel error was contributed to by the implementation of a large set of revised /new procedure The corrective action to resolve and ;

prevent recurrence of this event included implementation by August 2,1990 of Periodic Test Procedures to control the TS surveillance This licensee identified violation is not being cited. because criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfie The inspector informed the licensee that this issue was considered a NC of TSs 4.11.1.3 and 4.11.2.4 and would be considered closed based on the licensee's adequate corrective action A written response is not :

require (Closed) NCV S0-338, 339/90-13-01: Failure to perform liquid and gaseous dose projections at least once every 31 days in accordance with the ODC r Another audit finding dealt with a violation' of TS 3.3.3.11.b which requires the licensee to explain in the Semiannual Radwaste Effluent Release Report (SRERR) why radioactive gaseous effluent monitoring instrumentation was inoperable for time periods greater than 30 day ;

The audit team discovered that two ventilation vent stack flow rate :

I monitors were out of service between March 22, 1989 and May 10, 1989, and i that the explanation for this inoperability was nr,t recorded or explained ;

in 1989's SRERR.

l The inspector reviewed the licensee's response to this finding and #

interviewed cognizant personnel and determined that these monitors were ,

inoperable because a Station Design Change was being performed. Personnel ,

responsible for preparing the SRERR reviewed the Station Deviation Report Logs to determine instrumentation which had been out of service. Because a Design Change caused the inoperable status, a Deviation Report was not filed, and these monitors were not included in the SRERR. The inspector i discussed with the licensee the corrective actions taken to prevent recurrence of this event. These actions included the ' review, by the Health Physics personnel responsible for including inoperable monitors in

,

the SRERR, of three additional reports. These reports are a daily plant i status report identifying out-of-service equipment which have Limiting Action Statements, a weekly Radiation Monitoring System Status Report, and a Shif t Technical Advisor's Report. The inspector also reviewed Station Deviation Report 90-906, dated March 23, 1990, which reported these monitors as not being included in the SRERR; and discussed with the licensee how flow out of the ventilation vents was estimated while these monitors were inoperabl .

w.-

. .

O

,

. 8 This licensee identified violation is not being cited because of criteria specified in Section V.G.1 of the NRC Enforcement Policy were satifie Tha inspector informed the licensee that this issue was considered a NCV of TS 3.3.3.11.b and would be considered closed based on the licensee's adequate corrective actions. A written response is not require (Closed) NCV 50-338, 339/90-13-02: Failure to report, in the SRERR, two monitors which had been inoperable for greater than 30 day There were eight other findings and four observations discussed in the audit repor These findings and observations included: radiation monitor setpoints, sampling of the waste gas decay tanks, repair of inoperable radiation monitoring equipment, and control fish samples. The inspector reviewed the licensee's responses to each of the findings / observations and the corrective actions taken to resolve these issues and prevent recurrence This-review included documentation of a '

special QA performance evaluation of TS Compliance in Radiation Protection at the site, performed April 9-24, 1990; and included discussions with cognizant personnel. In general, the audits were four. to be well'

planned, thorough, and adequately documented. The audit responses contained commitments by management to effect corrective actions for the deficiencies that had been identifie Two NCVs were identifie . Station Nuclear Safety and Operating Committee (SNSOC) (84750)

TS 6.5.1.4 requires the SNSOC to meet at least once per ellendar mont TS 6.5.1.6.g requires that the SNSOC be responsible for review of facility operations to detect potential nuclear safety hazards. Pursuant to tht.se requirements, the inspector attended a portion of the site's weekly SNSOC I meeting and observed the activities thereat. This portion of the meeting covered the approval for the movement of a filter into a high integrity container (HIC). This job had the potential for high personnel exposur The job supervisor explained the logistics and radiation concerns surrounding this job, and detailed the precautions to be taken, including the use of respirators, pre-job briefings, and determinations of predicted dos The inspector determined that the SNSOC responsibilities included the review of Engineering Work Requests, procedure changes, radiation work permits for jobs that could generate high radiation areas, and the use of scaffolding around safety related equipment in the protected area. The ;

inspector concluded that the review of this job function appeared to be ,

adequat '

No violations or deviations were identifie . Radiation Monitoring System (RMS) (84750)

TS 3.3.3.1 states that radiation monitoring instrumentation channels

"

...shall be operable with their alarm / trip setpoints within the specified limits." Pursuant to these requiramant5, the inspector reviewed pertinent

.

,

.

-.

.. 9  ;

data and discussed the status of the- RMS with cognizant licensee personne Inspectio i Report No. 90-03 detailed an on going study at ,

North Anna which identified problems with the etMS, and which would formulate an action plan and corrective activities for these problems, '

Discussions with the licensee during this inspection ind'eated that, while interim reports have been issued, this effort has temporarily been put on hold and scheduling was uncertain. Parts of the study had been divided into several projects. One of these had been completed, while others were -

waiting for scheduling and/or completion. The inspector discussed the importance of RMS operability with licensee management and technical personnel, and reviewed RMS Status Reports dated May 10, 1990, May 15, 1990, and May 17, 1990. These status reports indi .ated that- primarily .

minor maintenance problems were occurring with the RMS. The inspector !

also reviewed selected daily plant status reports which identified out-of-service radiation monitors which have limiting action statement ,

The prioritization and rescheduling of the RMS study will be reviewed by regional inspectors during subsequent inspection l No violations or deviations were identifie . Exit Interview The inspection scope and results were summarized on May 18, 1990 with those persons indicated in Paragraph 1. The inspector described the areas ,

inspected and discussed in detail the inspection results as listed in the '

summar Proprietary information is not contained in this repor Dissenting comments were not received from the license . Acronyms and Initialisms ,

CFR - Code of Federal Regulation '

DEI - Dose Equivalent Iodine gpd gallons per day HIC - High Integrity Container HP - Health physics l

"

IFI - Inspector Followup Item ,

LER - Licensee Evaluation Report -

NCV - Non-Cited Violation No. - number

! NRC - Nuclear Regulatory Commission -

! 00CM - Offsite Dose Calculation Manual l ONRR - Office of Nuclear Reactor Regulation +

pCi picoeurie l ppb parts per billion i ppm parts per million QA - Quality Assurance

'

QC - Quality Control RMS - Radiation Monitoring System l SNSOC - Station Nuclear Safety and Operating Committee i SRERR - Semiannual Radwaste Effluent Release Report TS - Technical Specification