IR 05000348/1978026
| ML19259A561 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/09/1978 |
| From: | Gibson A, Hosey C, Zavadoski R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19259A551 | List: |
| References | |
| 50-348-78-26, NUDOCS 7901080047 | |
| Download: ML19259A561 (10) | |
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UNITED STATES t>* "8 00 g
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NUCLEAR REGULATORY COMMISSION REGloN il
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Report No.:
50-348/78-26 Docket No.:
50-348 License No.: NPF-2 Licensee:
Alabama Power Company P. O. Box 2641 Birmingham, Alabama 35291 Facility Name: Farley Unit 1 Inspected at: Farley site, Ashford, Alabama Inspection Conducted: September 25-29, 1978 Inspectors:
C. M. Hosey R. W. Zavadoski
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Reviewed by:
A. f. Gibson, Chief Date Radiation Support Section Fuel Facility and Materials Safety Branch Inspection Summary Inspection on September 25-29, 1978 (Report No. 50-348/78-261 Areau Inspected: Routine, unannounced inspection of radiation r
protection program, incAojing notification and reports, re oi atory protection, posting, labeling and control, radiological protection procedures and radiological surveys; and radioactive vaste management program including radioactive effluent releases, records and reports of radioactive effluents, effluent control instrumentation, prr.cedures for controlling the release of effluents, testing of containment air cleaning systems and solid radioactive vaste processing ano disposal.
The inspection involved 66 inspector-hours on-site by two NRC inspectors.
Results: Of the eleven areas inspected, no apparent items of non-compliance or deviations vere identified in ten areas. One apparent item of noncompliance was found in one area (Infraction - failure to have written procedures to transfer resin to bulk loading facility (348/78-26-01), Paragraph 4).
7901080041
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RII Rpt. No. 50-348/78-26 I-1
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DETAILS I Prepared by:
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C. M. Hosey, Radiation Specialist Date
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Radiation Support Section FuelFacilityandMateriaqsSafetyBrarch
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CUC'2nwlb nd/7e Date R.W.Zavadojki,Radiat'ionSpecialist Radiation Sypport Section Fuel Facil'ity and Materials Safety Branch Dates of Inspectio
Se mber 25-29, 1978 Reviewed by:
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A. F. Gibson, Chic!
Date Radiation Support Section Fuel Facility and Materials Safety Branch 1.
Individuals Contacted
- W.
G. Hairston, Plant Manager
- K. W. McCracken, Technical Superintendent
- D. C. Poole, Operating Superintendent
- C. D. Nesbitt, Chemistry and Health Physics Supervisor
- M. W. Mitchell, Assistant Chemistry and Health Physics ' 'pervisor (Acting)
P. S. Farnsworth, Chemistry and Health Physics Foreman J. Walden, Chemistry and Health Physics Foreman P. Patton, ALARA Engineer W. Peterson, Chem-Nuclear Services Engineer
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The inspectors also talked with and interviewed other licensee employees.
2.
Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items cf noncoapliance or deviations.
Two unresolved items were identified during this inspection.
348/78-26-03 Lack of Documentation for Prerequisite Test of Filtration Systems A review of documentation for prerequisite test for filtration systems revealed that records concerning ' residence time calculations and visual inspections were not available at the plant. Failure to have docui.entation for the required test would be in noncompliance with
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RII Rpt. No. 50-348/78-26 I-2 Technical Specifications 4.7.7.1.c and 4.7.8.1.c.
This item is discussed further in paragraph 9.
348/78-26-02 Safety Review of Mobile Solidification Units Documentation concerning a safety review of the mobile solidificaticn unit was n.t available at the plant. Failure to have a record which provides the bases for the determinations that the mobile solidification does not involve an unreviewed safety question would be in noncompliance with 10 CFR 50.59(b). This item is discussed further in paragraph 5.
3.
Radiation Protection Procedures An inspector reviewed changes made to the following radiological control procedures and verified that the changes are consistent with regulations and Technical Specifications 6.8.2 and 6.5:
FNP-0-RCP-26 " Radiological Surveys and Monitoring" a.
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FNP-0-RCP-1 " Schedules, Health Physics Activities" c.
FNP-0-RCP-2 ""adiation Work Permit" d.
FNP-1-RCP-252 " Radiation Monitoring Systems Setpoints" e.
FNP-0-RCP-29 " Contamination Guidelines" The inspector had no further questions.
4.
Radioactive Effluent P.eleases a.
Technical Specification 6.8.1 states, in part, that " written procedures shall be established, implemented anu maintained covering the applicable procedures recommended in
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Appendix A of Regulatory Guide 1.33, November,1972." Regulatory Guide 1.33 Appendix A (Nov., 1972), paragraph G.2a recommends that spent resins and filter sludge handling be covered by written procedures.
The inspectors discussed the transfer of spent resins and evaporator concentrations to the Chem-Nuclear Services mobile solidification unit located on site.
An inspector reviewed plant procedures FNP-1-SOP-49.0 " Solid Waste Processing System" and FNP-1-SOP-50.3 " Liquid Waste Evaporator Operation."
These procedures cover the transfer of resin and evaporatcr concentrates to the in plant druming station.
TLe in plant drumming station has not been used for the solidification of resin or evaporator concentrates. No written procedures were available for tri.nsferring this material to the Chem-Nuclear solidification unit v1. che outside bulk loading platform. The inspectors toured
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RII Rpt. No. 50-348/'/8-26 I-3 the solidification unit and discussed the operation of this unit with a
Chem-Nuclear representative.
The Chem-Nuclear representative acknowledged that written procedures had been prepared for the operation of the unit. An inspector questioned a licensee representative concerning a review of Chem-Nuclear procedures by Alabama Power Company. The licensee representative stated that the plant staff had not reviewed the operating procedures for the solidification unit.
A licensee representative stated that procedure FNP-1-SOP-49.0 and FNP-1-SOP-50.3 would be revised to include the transfer of resins and evaporator; concentrates to the bulk loading platform and that the plant stsff would review Chem-Nuclear operating procedures.
Tle inspector stated that failure to have written procedures for transferring spent resin a nt'
evaporator concentrates to the outside bulk loading facility and failure to review Chem-Nuclear operating procedures for the solidification unit was in noncompliance (348/78-26-01) with Technical Specification 6.8.
b.
An inspector observed the analysis of a sample from Waste Monitor Tank No. 1, the completion of the cliecklist (Appendix A to FNP-1-S0P-50.1A) for transfer of radioactive liquid waste from the WMT to the environment, and verified that the Liquid Radiation Monitor (RE-18) setpoints were properly set. The inspector also reviewed the Operator's Log for the Liquid Waste Processing Panel and the Liquid Waste Release Permit for the release and verified that the release was made in accordance with plant procedures and technical specifications. The inspector reviewed selected Liquid Radiation Waste Release Permits for 1978. During the review of Liquid Waste Release Permits it was noted that the volume released on LWR-78-527 (9/26/78) was 3875 gallons when change in tank level was used to determine volume released and 128 gallons when flow totalizer was used. A licensee representative stated that the change in tank level was used to determine volume released. He further stated that the cause of the discrepancy would be investigated. The inspector identified this as an open item for followup at a later date (348/78-26-06).
Environmental Technical Specification 5.6.1.b requires in part c.
that "a report on radioactive discharge released from the site shall be submitted... The report shall include a summary
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as outlined in Regulatory Guide 1.21, Revision 1,
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Appendix B..." An inspector reviewed the plant's Semiannual Radioactive Effluent Release Report for the period of January 1-June 30, 1978 and discussed the report with a licensee representative. The inspector identified numerous errors in the
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RII. Rpt. No. 50-348/78-26 I-4 report which the licensee representative attributed to typing errors.
The licensee representative stated that an amended rep'rt would be submitted. The inspector identified this as an open item for followup at a later date (78-26-05).
d.
During a tour of the Auxiliary Building an inspector observed a number of rooms that were posted as contaminated areas. Reviews of records and discussions with licensee representatives revealed that these rooms became contaminated when the Floor Drain Tank overflowed several times to the Auxiliary Building floor drains on the 83 foot and 100 foot elevations.
The overflow occurred when the Auxiliary Feedwater Condensate tank relief valve lifted and released water to non-rad floor drains.
These drains are connected to the Floor Drain Tank. The inspector commented that the increase in radioactive liquid waste inventory caused by the addition of non-radioactive water could reduce effectivenest of waste treatment and cause increase radiation exposure from working in the contaminated A licensee representative stated that the contaminated areas.
areas of the Auxiliary Building would be decontaminated following the current outage and that the flow path of water from non-rad drains would be evaluated and possibly rerouted to the turbine building sump.
An inspector reviewed the calibration / functional test and check e.
records for the Liquid Waste Monitor (RE-18) and verified that the calibration, tests and checks are being performed in accordance with technical specifications. The inspector also reviewed the inservice test results for the liquid radioactive waste discharge isolation valves (RCV-018 and RCV-023b). The inspector had no further questions.
5.
Safety Review of Mobile Solidifications Units 10 CFR 50.59(b) states in part that " licensee shall maintain records of changes in the facility... to the extent that such changes constitute changes in the facility as described in the safety analysis report.
These records shall include a written safety evaluation
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which provides the bases for the determination that the change.
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does not involve an unreviewed safety question." An inspector reviewed the operation and records of the Chem-Nuclear solidification unit at the plant.
When questioned concerning a safety review of the mobile solidification unit, a licensee representative stated that the unit had been reviewed as a safety-related service under the Operational Quality Assurance Program, however cacumentation of the review was not available at the plant.
In addition, the licensee representative
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RII. Rpt. No. 50-348/78-26 I-5 stated that he was not sure the review performed was comparable to the review required by 10 CFR 50.59.
The inspector stated that the item would be unresolved (348/78-26-02) pending review of the documentation.
6.
Surveys a.
An inspector reviewed the radiation, contamination and airborne radioactivity surveys associated with the following maintenance performed during the current outage:
(1) Pressurizer spray valve repair (2) Conteinment sump pump "A" replacement (3) Floor drain tank filter change The surveys reviewed appeared to be adequate and extent of surveys was in accordance with plant procedures and Radiation Work Permits.
b.
An inspector performed independent radiation and loose surface contamination surveys in the Auxiliary Building and Reactor Building and verified that the areas checked were properly posted.
7.
ALARA Pro cam The licensee has appointed an ALARA Engineer to implement the plants ALARA program for the current maiitenance outage. A licensee repre-sentative stated that *.he radiation exposure received by plant personnel and vendors was being reviewed on a daily basis and the need for exten-sions of administrative exposure limits was being carefully evaluated prior to approval.
The licensee representatire stated that a breakdown of exposure received by major job was not available.
The inspector commented that to have an effectiva ALARA program, exposure estimates should be made for each major maintenance job involving radiation exposure and that actual exposure should be compared with the estimates.
The inspector further stated that recommendations contained in Regulatory Guide 8.8 should be considered in establishing an ALARA Pm gram.
8.
Temporary Shielding While touring the containment the inspector noted two areas where temporary lead sheets and bl:.nkets had been placed/ suspended on Residual Heat Removal (RHR) piping.
Later, from discussionc with
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RII. Rpt. No. 50-348/78-25 I-6 licensee's representatives, the inspector found that there were no procedures or criteria used in the placement of temporary shields. The licensees representatives stated that the temporary shields would be removed prior to power escalation.
In addition, the licensees repre-sentatives stated that written procedures for installation and removal of temporary shielding would be available prior to the next refueling outage.
The inspector told the licensee's representatives that, at a minimum, the procedures should include (1) criteria as to when the use of temporary shielding from a health physics viewpoint would be considered (2) criteria as to the placement and positioning of the shielding such that static and dynamic loadings are not exceeded and (3) a program for numbering or coding the shielding so that the whereabouts of each piece is always known.
The inspector identified this as an open item (348/78-26-04).
9.
Filtration Systems The inspector visually reviewed the Control Room Recirculation Filter Units, the Control Room Filter Units, the Control Room Pressurization Filter units and the Penetration Room Filtration System.
In addition the inspector reviewed the supporting documentation for each filter unit as required by Technical Specification 4.7.7.1.c and 4.7.8.1.c.
Technical Specificaticas 4.7.7.1.c.2 and 4.7.8.1.c.2 require that inplace leak tests meet the requirements of ANSI-N510-1975, " Testing of Nuclear Air-Cieaning Systems", Sections 10 and 12.
Sections 10 and 12 of ANSI N510 further require that the prerequisite tests and calculations of Sections 8 and 9 of ANSI N510 be performed before in place tests.
In addition, Section 5 of ANSI N510 requires that a visual inspection be performed before each test.
Further, each mentioned section of the ANSI N510 standard prescribe the form and content of the final report for each section.
The inspector reviewed an assortment of documentation for compliance with the requirements of ANS1 N510 on the filtration systems in question and found several discrepancies, noteably the absence of residence time calculations for all systems as required by ANSI N510 Section 8.3.3, apparent inappropriate DOP concentrations and sample points as required by ANSI N510 Section 9.4.3 and 4, and apparent lack of visual inspection reports.
Licensee representatives stated that after contacting their consultants they had ascertained that not all the pertinent data was in their files and was being mailed to them.
The inspector told the licensee representatives that this matter would remain unresolved (348/78-26-03) pending review of their consultant's dat.
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RII. Rpt. No. 50-346/78-26 I-7 10.
Solid Radwaste Shipments The inspector reviewed records of solid radwastes shipped from the plant from January thru September 1978 and discussed the solid waste program with licensee representatives. The inspector determined from the shipping papers and discussions with licensee representatives that waste shipments were Low Specific Activity (LSA) and transported by the carrier on a " sole use" basis. A review of selected licensee surveys of shipments showed that the shipments met the criteria fcr LSA pursuant to 49 CFR 173.392. The inspector cautioned the liceraee representative that the present procedures were inadequate for waste shipments under 10 CFR 71.
At present, no waste shipments from the plant have had to meet the requirement of 10 CFR 71.
The licensee's representative stated that procedures would be available prior to 10 CFR 71 shipments.
The inspector had no further questions in this area.
11.
Respiratory Protection Program The inspector selectively reviewed the following procedures concerning respiratory protection prior to visiting the facility:
(1)
"Use and Testing of Respiratory Protective Equipment",
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FNP-0-RCP-101, 12/11/76 (2) " Selection of Respirators for Radiological Applications" FNP-0-RCP-102, 8/5/77 (3)
" Maintenance and Care of Respiratory Protective Equipnient" FNP-0-RCP-103, 8/5/77 (4) ' )peration of Air Tank Cascade Recharging System" FNP-0-RCP-104, 4,'?I'7 (5)
"Use and Operation of Half-Face Filter Type Respirators" FNP-0-RCP-105, 11/29/76 (6)
"Use and Operation of Full Face Filter Type Respirators" FEP-0-RCP-106, 11/30/76 (7)
"Use and Operation of Self-Contained Breathing Apparatus" (Pressure Tank Type), FNP-0-RCP-107, 8/6/77 (8) "Use and Operation of Pressure Demand Air Line Respirators" FNP-0-RCP-108, 8/5/77
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RII. Rpt. No. 50-348/78-26 I-8 At the facility, by review of records, observations and discussions with licensee representatives, an inspector evaluated the respiratory protection program for bioassay, engineering controls, MPC-hour controls, respirator medical evaluation, training, fitting, issuance controls and determined that these areas of the respiratory protection program appeared to be in compliance with 10 CFR 20.103.
The inspector had no further questions.
12.
Termination Reports The inspector reviewed licensee records to determine if exposure data had been provided to terminated employees as required by 10 CFR 19.13(d).
The inspector selected several names of recently terminated employees and cross checked these names with an exposure history file and verified that each employee had been sent a letter regarding his exposure history.
No items of noncompliance or deviatinns were observed by tae inspector.
13.
Posting, Labeling and Control An inspector reviewed the licensee's posting for radiation areas a.
(10 CFR 20.203b), high radiation areas (10 CFR 20.203c), airborne radioactivity areas (10 CFR 20.203e) and container labeling (10 CFR 20.203f). Accompanied by a licensee's representatives, an inspector randomly surveyed several areas for radiation level in
the radiation controlled area.
The inspector had no questions in the area of posting and labeling.
b.
An inspector reviewed with licensee's representatives the controls they have over radioactive materials as required by 10 CFR 20.203c for high radiation areas, and 10 CFR 20 207 for storage areas. An inspector also reviewed the use of Radi aiogical Work Permits (RWP's) and the control measures for radioactive or contaminated areas and equipment as required by procedures.
The inspector had no questions in the area of control.
14. Exit Interview The inspectors met with management representatives (denoted in paragraph 1) on September 29, 1978, and summarized the scope and findings of the inspection.
Items discussed include one item of noncompliance and two unresolved items identified during this inspectio '
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RII. Rpt. No. 50-348/78-26 I-9
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In addition, a telephone conversation was held with the plant manager on October 17, 1978. The plant manager stated that to ensure the requirements of 10 CFR 50.59 are complied with, the plant would conduct
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a 50.59 safety review of the mobile solidification units, even though I
the previous review of the units as a safety-related service may have
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fulfilled the requirements of 10 CFR 50.59.
The 50.59 safety review will be completed by January 1, 1979.
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