IR 05000354/1986039

Insp Rept 50-354/86-39 on 860812-15.Violations Noted:Cooling Tower Blowdown Effluent Radioactivity Monitor Inoperable. No Notice of Violation Issued.Each Violation Met Tests for Licensee Identified Items

ML20210E850
Person / Time
Site:	Hope Creek
Issue date:	09/15/1986
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210E826	List: IR 05000354/1986039 ML20210E823
References
50-354-86-39, NUDOCS 8609250105
Download: ML20210E850 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-39 Docket N License N NPF-50 Priority -

Category C Licensee: Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, New Jersey 08038 Facility Name: Hope Creek Generating Station Inspection At: Hancock's Bridge, NJ Inspection Conducted: August 12-15, 1986 Inspectors: .( .b 9[S[64 H. J.'Bicehouse, Radiation Specialist date Approved by: [ cor "

9 is N W M iscftk, Cnief, datel Efflue ts Radiation Protection Section Inspection Summary: Inspection on August 12-15, 1986 (Inspection Report Number 50-354/86-39)

Areas Inspected: Routine, unannounced inspection of the licensee's radioactive waste (radwaste) program during initial criticality and low power testing including previously identified items, chemical / radiochemical tests, radioactive effluents, liquid radwaste system, g4suus radwaste system, nonradioactive system surveillance, and an exposure incident followu Results: Within the areas reviewed, three violatf ors were noted. However, each violation met the tests for licensee-identified item PDR ADOCK 05000354 G PDR

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DETAILS 1. Persons Contacted During the course of this routine inspection, the following personnel

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e 1.1 Public Service and Gas Company (PSE&G)

• R. S. Salvesen, General Manager, Hope Creek Operations (HCO)

• S. LaBruna, Assistant General Manager, HC0

• J. Cicconi, Planning Manager

• J. Clancy, Principal Health Physicist, Radiation Protection Services

• M. Farschon, Power Ascension Manager

, * C. Fuhrmeiste, Lead Quality Assurance (QA) Engineer

• J. Lovell, Radiation Protection / Chemistry Manager

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• M. Metcalf, Principal QA Engineer

• J. Molner, Senior Radiation Protection Supervisor

• L. Piccirelli, QA Engineer

• M. Sullivan, Radiation Protection Engineer

• T. Vannoy, Senior Chemistry Supervisor Other licensee employees were contacted or interviewed during this inspectio .

1.2 Contractors

• J. Livingston, Startup Group Lead, General Electric Company Other contractors were contacted or interviewed during this inspection.

I 1.3 NRC Personnel

• D. Allsopp, Resident Inspector

• W. Borchardt, Senior Resident Inspector

• D. Florek, Lead Reactor Engineer

• L. Norrholm, Chief, Reactor Projects Section 2B

• denotes those present at the exit meeting on August 15, 1986.

2. Purpose The purpose of this routine inspection was to review the licensee's ongoing startup/ power ascension radwaste program with respect to the following elements:

Previously Identified Items;

Chemical / Radiochemical Tests;

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Radioactive Effluents; Liquid Radwaste System;

Gaseous Radwaste System; and,

Surveillance of Non-Radioactive Systems under Bulletin 80-1 In addition, the events surrounding a reported radiation exposure to the hand of a worker were reviewe . Previously Identified Items 3.1 (0 pen) Inspector Followup Item (50-354/85-44-10) Review test results for solid radwaste system. The licensee has placed testing of the solid radwaste system on hold pending correction of problems noted during earlier testing. This item remains ope .2 (Closed) Unresolved Item (50-354/85-44-14) Deferral of Radiation Monitoring System (RMS). The deferral of RMS capabilities was reviewed in NUREG-1048, " Safety Evaluation Report Related To The Operation Of Hope Creek Generating Station," Supplement No. 5, Appendix R (April 1986). The scheduled completion of deferred RMS capabilities was approved in Appendix R to Supplement No. 5 and as a condition to NPF-50. Milestone completion in providing full RMS capability was reviewed during previous inspections. During this inspection, completion of computer links and establishment of full computer capability as described by the licensee in submittals to the NRC was reviewed and demonstrated. This item is close .3 (0 pen) Inspector Followup Item (50-354/85-52-38) Line loss determination for. sampling North and South Plant Vents. This item was reviewed during Inspection No. 50-354/86-33. At that time, particulate line loss tests had been completed but the report for the North Plant Vent hadn't been received and the licensee hadn't evaluated test results from the South Plant Vent Report. During this inspection, the licensee was unable to locate the report for the North Plant Vent and hadn't completed review of either test report. This item remains ope .4 (0 pen) Inspector Followup Item (50-354/85-52-34) Develop procedures for shipping containers used under 10 CFR 71.12. The licensee has developed a draft letter of agreement between the Hope Creek Generat-ing Station (HCGS) and the Salem Generating Station (SGS) whereby SGS would assume responsibility for generally-licensed use of shipping containers. The agreement was undergoing discussion but had not re-ceived final acceptance by the respective station managers. This item remains ope . Chemical / Radiochemical Tests Technical Specification 3/4.4.4, " Chemistry," establishes limits and sur-veillance requirements for chlorides, conductivity and pH in the Reactor

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. 4 Coolant System. Technical Specification 3/4.4.5, " Specific Activity,"

establishes limits and surveillance requirements for radioactivity in.the Reactor Coolant System. NRC Regulatory Guide 1.68, (" Initial Test Pro-grams For Water-Cooled Nuclear Power Plants"), requires, in part, chemical and radiochemical tests and measurements to demonstrate the design capabi-lity of chemical control systems to maintain reactor water quality within limit During Inspection No. 50-354/86-05, the licensee's test program, " power ascension" test procedures and schedules were reviewed. A modification to this program to substitute plant surveillance procedures for chemistry and radiochemistry monitorinc . id delete the integrated performance test-ing of the Reactor Water Cleanup and Condensate Demineralizer Systems at 45-55% power levels was reviewed and approved as Amendment 14 to the licensee's Final Safety Analysis Report (FSAR).

During this inspection, measurements to determine base levels and es-tablish water quality of the reactor coolant during precritical, heatup, initial criticality and low power tests were reviewed to determine if test results were evaluated, surveillance requirements were met and necessary corrective actions were taken. The inspector noted that the licensee was implementing Station Administrative Procedure (SA-AP.ZZ)-052(Q), "Chemis-try Control Program," and Chemistry Technical Instruction (CH-TI.ZZ)-

012(Q), " Chemistry Sampling Frequencies, Specifications And Surveil-lances," in addition to test procedures to determine base levels, provide surveillance of reactor coolant chemistry, establish trends and monitor chemical and radiochemical parameter Within the scope of the review, no problems were noted. The licensee ap-peared to be implementing a generally adequate chemical and radiochemical test and measurement progra . Radioactive Effluents Technical Specification 3/4.11, ' Radioactive Effluents," establishes, in part, limiting conditions for operation and surveillance requirements for liquid and gaseous effluents. Technical Specifications 3/4.3.7.10,

" Radioactive Liquid Effluent Monitoring Instrumentation," and 3/4.3.7.11,

" Radioactive Gaseous Effluent Monitoring Instrumentation," provide effluent monitoring instrumentation requirement .1 Liquid Effluents Liquid releases from the licensee's "A" and "B" Waste Storage and

"A" and "B" Floor Drain Storage tanks for the period July 1,-August 12, 1986 were reviewed. Concentrations, total estimated activities, radiation monitor setpoints/ operability, lower levels of detection for grab samples and offsite dose projections resulting from each release were reviewed and discussed with cognizant personnel within the licensee's Radiation Protection / Chemistry Departmen .

Within the scope of this review, the following items were noted:

Technical Specification 3.3.7.10 requires, in part, that the Cooling Tower Blowdown Effluent Radioactivity monitor ( RE-8817) be operable during radioactive liquid releases. If that monitor is inoperable, effluent releases via the Cooling Tower Blowdown may continue for up to 30 days provided that grab samples are collected and analyzed for gross radioactivity at least once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Contrary to the above, on August 8, 1986, the Cooling Tower Blowdown Effluent Radioactivity monitor was inoperable, poten-tially radioactive liquid effluents were being discharged via the pathway and grab samples were not collected and analyzed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. On August 7, 1986, the licensee took RE-8817 out of service to conduct preoperational tests of the RMS. At approximately 1820 on August 7, 1986, the sample pump supplying RE-8817 was determined to be inoperable. At approxi-mately 2200 on August 7, 1986, chemistry personnel were informed that RE-8817 was operable and suspended their grab sampling activitie Since the sampling pump was out of service, RE-8817 remained inoperable at that time. From 2200 on August 7, 1986 until 1300 on August 8, 1986 while RE-8817 was_ inoperable, no grab samples were taken. During this period, the licensee was discharging approximately 100,000 gallons per day from the vari-ous holdup tanks. Failure to obtain and analyze grab samples during the period from 2200 on August 7, 1986 until 1300 on August 8, 1986 constitutes a violation of Tecnnical Specifi-cation 3/4.3.7.1 Under SA-AP.ZZ-006(Q), " Incident Report And Reportable Occur-rence Program," the licensee has established a program to iden-tify, investigate, document, report, track, close and trend discrepancie Licensee's Incident Report No.86-165 (initiated at 1700 on August 8, 1986) identified the apparent violation above. The Incident Report was being processed under

SA-AP.ZZ-006(Q) during the inspectio Under 10 CFR 2, Appendix C, " General Statement Of Policy And Procedure For NRC Enforcement Actions," a notice of violation is not generally issued if a violation meets the following tests:

(1) it was identified by the licensee; (2) it fits in Severity Level IV or V;

, (3) it was reported, if required; (4) it was or will be corrected, including measures to prevent recurrence, within a reasonable time; and, (5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation.

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The inspector reviewed the failure to obtain grab samples against the tests above and concluded that a notice of violation need not be issued since:

(1) the violation was identified by the licensee under SA-AP.ZZ-006(Q);

(2) the safety significance was small since the plant's power levels had been low since its initial criticality, previous analyses of liquid effluents showed barely detectable levels of radioactivity and the missed '

surveillance perioo was less than one day; (3) Incident Report 86-165 was provided to the NRC Resident Inspectors; (4) Licensee actions included formalization of communications with other departments when equipment was inoperable and verification to those departments of equipment being returned to service (see also Licensee Event Report (LER)

86-37 in paragraph 5.2); and, (5) previous violations of Technical Specifications related to sampling had not been noted by the NRC in previous inspection Licensee actions taken in response to Incident Report 86-165 will be reviewed during a subsequent inspectio /86-39-01 Cooling Tower Blowdcwn (CTB) Sample Pump (0P-524) was inoperative April 17 - May 20, 1986 resulting in RE-8317 being inoperative. Under Technical Specification 3/4.3.7.10, the inoperable RMS instrumentation channel must be restored to service within 30 days (during which grab sampling at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is permitted).

Since initial criticality wasn't achieved until June 28, 1986 and grab sampling showed less than delectable levels of radioactivity, the significance of RE-8817 being inop-erable for greater than 30 days was minimal. However, under Technical Specification 6.9.1.7, " Semiannual Radio-

' active Effluent Release Report," an explanation of why the inoperability was not corrected in a timely manner is re-quired. The Semiannual Radioactive Effluent Release Report

, covering the period April 17 - May 20, 1986 will be re-l viewed for inclusion of that explanatio /86-39-02

On August 7, 1986, NRC Region I was notified of a l connector defect on the cable assemblies connecting the liquid effluent monitor system detectors and their pre-amplifiers by the manufacturer. Discussions with the l

i licensee indicated that the problem had been identified in a letter to the licensee from the manufacturer dated l August 8, 1986. The licensee reported that occasional l

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t separations of the cable had resulted in electrical shocks to two workers during testing of the licensee's liquid effluent monitors. The licensee reported that detector functions were not imp.'. ired in use since the connectors remained intact unless work activities,'(e.g. testing, mcintenance, etc.), disturbed the cable. The manufacturer will replace the connectors upon request and the licensee will request the replacemen .2 Gaseous Effluents Noble gas, radioiodine and radioactive particulate release concentrations, total activities and projected doses for gaseous efflue'nt releases via the North Plant Vent (NPV) and South Plant Vent (SPV) were reviewed from July 1, - August 13, 1986. Effluent

~ monitoring instrumentation (including the offgas hydrogen monitors

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and noble gas activity monitors) calibration, operability and alarm setting were also reviewe Within the scope of the review, the following items were noted:

a Technical Specification 3/4.3.7.11 requires, in part, that grab samples be taken at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyzed within

' 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for gross activity whenever the SPV Noble Gas Activity Monitor (RE 4814A)_ is inoperabl Contrary to-this requirement, on July 12, 1986 at 0614 the SPV s Noble Gas Activity Monitor was declared inoperable to allow repairs to be made. A grab sample was not obtained until 0200 on. July 13, 1986. During the period, the plant was in hot standby and continuous gaseous effluents were being discharged via the SPV; iSample analys!s showed that less than 1.2E-6 microcurias/ cubic centimeter were present in the sample taken at 0200 on July 13, 1986. Previous samples and monitor readings on the SPV'showed similar concentrations. Failure to obtain a grab ~ sample from 0614 on July 12, 1986 to 0200 on July 13, 1986 while RE 4814A was inoperable is a violation of Technical Specification 3/4.3.7.1 '

Under SA-AP.ZZ-006(Q), the licensee initiated Incident Report No.86-130. Subsequently on August 12, 1986, the licensee issued LER No. 86-37 describing the event and the corrective actions to be taken as result of the problems noted. The

.s inspector reviewed the violation relative to the tests for a i, '

, licensee-identified item as described in paragraph 5.1, (under

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10 CFR 2, Appendix C), and concluded that a notice of violation need not be issued. However, actions taken as a result of LER

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No. 86-37 will be reviewed during a subsequent inspectio i 50-354/86-39-03 jo

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Technical Specification 3/4.11.2.2 requires, in part, that the air dose due to noble gases released in gaseous effluents not exceed 5 millirads for gamma radiation and 10 millirads for beta radiation to areas at or beyond the site boundary during any calendar quarter as a limiting condition for operation (LCO). Surveillance requirements for this LC0 require determination of cumulative dose con-tributions for the current calendar quarter and current calendar year for noble gases by methods described in the licensee's Offsite Dose Calculation Manual (00CM) every 31 days. The licensee was calculating the cumulative dose contributions based on a single grab sample analysed in the licensee's radiochemistry laboratory. This method failed to integrate the noble gas concentrations and assumed that all releases were at concentrations recorded for the single grab sample. Since the grab samples were not correlated to either peak or average release rates, the licensee was un-able to determine prospective air doses due to noble gases and, thus, unable to determine compliance with the LC In response to this finding, the licensee established an alert level for noble gas releases. Continuous release of noble gases at the alert level would result in air doses to areas at or beyond the site boundary during a calendar quarter approximately 95% of Technical Specification 3/4.11.2.2. Since operators would be alerted to the in-creased release of noble gases, corrective actions could be taken to reduce noble gas air doses prior to reaching LCO levels. These actions will be reviewed in a subsequent inspection. 50-354/86-39-04 Composite particulate samples were submitted to an offsite vendor for gross alpha and strontium-89/90 analyses on July 17, 1986 by the licensee. The results of those analyses will be reviewed during a subsequent inspectio /86-39-05 5.3 Comparisons of Readings NRC Regulatory Guide 1.68 recommends, in part, tests to verify the response of installed process and effluent monitors by laboratory analyses of samples from process or effluent Streams. Insufficient radioactivity was present in the process and effluent streams from June 28-August 12, 1986 to accomplish those tests and comparison The comparison of the response of installed process and effluent monitors to analyses of samples of those streams analysed in the laboratory will be reviewed during a subsequent inspectio /86-39-06 g

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. 9 l 6. Liquid Radwaste System Technical Specification 3/4.11.1.3, " Liquid Waste Treatment," establishes the LCO and surveillance requireme,ts for the licensee's liquid radwaste treatment system. The licensee's liquid releases from June 28, - August 12, 1986 were reviewed relative to surveillance requirements in Technical Specification 3/4.11.1.3. NRC Regulatory Guide 1.6.8 recommends, in part, that the licensee demonstrate that liquid radwaste processing, storage and release systems operate in accordance with design. Operation of the liquid radwaste system from June 28, - August 12, 1986 was reviewed rel-ative to descriptions in the licensee's FSA Within the scope of this review, no problems were noted. Automatic termi-nations of liquid releases were noted as a result of setting the alarm setpoint on the liquid radwaste effluent monitor at expected countrates based on laboratory analyses of the liquid. Since the settings were well below those which would have been established as a result of ODCM calcu-lated setting, the terminations effectively tested the automatic isolation of effluent flow in response to liquid radwaste effluent monitor alarn actuatio . Gaseous Radwaste System Technical Specification 3/4.11.2, " Gaseous Effluents," establishes ~the LCOs and surveillance requirements for the licensee's gaseous radwaste treatment systems, (i.e. Gaseous Radwaste Treatment, Ventilation Exhaust Treatment and Purge Systems). NRC Regulatory Guide 1.68 recommends, in part, preoperational, low power and power ascension testing of the gaseous radwaste systems. The licensee requested deferral of completion of preoperational testing for the offgas system until before the reactor pressure head closure bolts were fully tensioned. The deferral request was granted as a schedular exemption-in License No. NPF-5 The results of Preoperational Test Procedure (PTP)-HA-1, " Gaseous Radwaste," (April 30, 1986) were revie ed and dispositioning of 77 test exceptions was examined. Test exceptions requiring completion / resolution during power ascension tests were noted. Power Ascension Test TE-SU.HA-741(Q), " Gaseous Radwaste System Performance Test, " Revision 1 (July 10, 1986) was reviewed. The inspector noted that TE-SU.HA-741(Q)

was a test to demonstrate that the gaseous radwaste system operates within design limits during the full range of power operation and that the procedure would be performed six times to cover the normal test condition /in-service loop combinations. Detailed testing of the hydrogen analysers, recombiner efficiency and charcoal bed delay coefficients, (i.e. Xenon and Krypton Delay tests) were incomplete. Those tests will be reviewed in a subsequent inspection. 50/354/86-39-07 The calibration of the offgas hydrogen monitor was reviewed and discussed with chemistry personne Testing of the ventilation exhaust treatment systems was reviewed during previous inspections. During this inspection, surveillance tests for

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- 10 operability were reviewed (see related items in paragraph 5.2). Venting or purging tests of the Mark I containment- drywell were also reviewed during previous inspections. Containment purge operations will be re-viewed during subsequent inspections following operation at power levels exceeding 20%.

8. Nonradioactive System Surveillance In responding to NRC Bulletin No. 80-10, (" Contamination of Nonradioactive System and Resulting Potential For Unmonitored, Uncontrolled Release Of Radioactivity To The Environment," May 6, 1980),

the licensee committed to conducting surveillance activities of nonradioactive process and effluent stream Surveillance of liquid process and effluent streams associated with nonradioactive systems under CH-TI.ZZ-012(Q) were reviewed for the following systems from June 28 -

August 12, 1986:

Domestic water supply system;

Diesel Jacket cooling water; Chilled water;

Sewage treatment plant; and,

Demineralized water syste Within.the scope of this review, no problems were note . Incident Report No.86-168 .

9.1 Summary of Events On August 7, 1986, a radiation protection worker handling four calibration sources during Filtiation, Recirculation and Ventilation System radiation monitor tests reported a reading in excess of three rads / hour beta taken with a survey meter from one of the source Since the sources were being handled by hand without remote handling devices, (e.g. tongs or tweezers), the licensee initiated an investi-gation into the possible overexposure of the worker's hand. Initial calculations suggested a possible dose of 16 rads to the hands and the licensee briefed the NRC Resident Inspector of the results on August 8, 1986. Dosimeter readings for the worker were 15 millirem shallow dose and 10 millirem deep dose for the whole body badge (worn on the chest). The licensee measured dose rates on each of the four check sources used in the testing, conducted time-motion studies to estimate exposure times to each of the sources, interviewed the worker to obtain additional details and had independent dose calcula-tions made by a consultant. Since the disc check sources were han-died from the side as well as flat against the palm of the hand, the licensee determined ratios of dose rates flat source to side of source for each of the four sources. The licensee's revised calcu-lated dose to hand of the worker is summarized below:

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Total handling source Dose corrected Source time (seconds)* Dose rate rad /sec Ratio side for decay (rads)

Stontium-90 525 1.565E-2 8.80E-3 7.11E-2 Chlorine-36 285 1.806E-4 1.18E-2 6.07E-4 Barium-133 39 .972E-5 0.25 3.75E-3 Cesium-137 39 .066E-2 0.33 1.363 Total Dose = 1.439 rad

• Total handling time is the sum of the number of times handling source (a) multiplied by the average time-motion study time for the evolution (b) and handling time (c).

(a) Strontium-90 10X Barium-133 15X Chlorine -36 10X Cesium-137 15X (b) Placing source near RMS detector 22.5 seconds (c) Handling times:

Chlorine - 36 60 seconds Barium - 133 60 seconds Cesium - 137 60 seconds Strontium- 90 300 seconds 9.2 Finding 10 CFR 19.12, " Instruction To Workers," requires, in part, that indi-viduals working in any portion of a restricted area be instructed in precautions or procedures to minimize exposure. Contrary to this requirement, the worker had not received radioactive source handling training sufficient to prevent direct handling of check source The worker was not instructed to handle the check sources with remote handling devices, (e.g. tongs or tweezers) which would have minimized his exposure. Procedures used in the test did not provide precau-tionary statements to warn the worke Licensee training programs for these workers failed to provide instruction in the use of remote handling devices. The Radiation Work Permit for the test did not specify remote handlin Incident Report No.86-168 and the licensee's investigation of this incident were reviewed to determine if the violation noted was licensee-identified under 10 CFR 2, Appendix C tests for licensee-identified items. The inspector concluded that the tests had been met. The following licensee corrective actions will be reviewed during a subsequent inspection:

Source handling guidance on the use of remote tools, jigs, extremity monitoring and survey instrumentation will be formal-ized in a radiation protection procedure. Interim guidance (in

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the' form of a department directive) was already in place. The radiation protection procedure will be completed by September 1, 198 * Radiation protection workers will not be allowed to handle or work with licensed sources until improved training and qualification are provide Source handling training will be addressed by the licensee's training program for Radiation Protection Assistants. Training will also be provided in the continuing training program in the next course offerin Groups other than the Radiation Protection / Chemistry Department

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will not handle sources until appropriate training and qualification is available. This action was taken immediatel *

Duties of Radiation Protection Workers will be reviewed to determine if other tasks being performed are not appropriate for the training and skill level of those workers. This will be completed by September 1, 198 * By October 1, 1986, a generic review of similar source handling tasks will be conducted. If appropriate in the Radiation Pro-tection Manager's judgement, extremity doses will be assigne Preoperational Test Procedures currently in use will be reviewed and remedial action taken as necessary to upgrade radiation protection practices associated with those procedures. 50-354/86-39-08 10. Exit Interview The inspector met with the licensee's representatives (denoted in para-graph 1) at the conclusion of the inspection on August 15, 1986. During the meeting,'the inspector summarized the purpose and scope of the inspec-tion and identified findings as described in this report. The inspector pointed out the apparent communication problem associated with failures to obtain. grab samples during periods when effluent monitors were out of ser-vice and the importance of prompt identification and action in regards to the violations noted. At no time during this inspection was written material provided to the licensee by the inspecto No information exempt from disclosure under 10 CFR 2.790 is discussed in this report.