IR 05000354/1987007

Insp Rept 50-354/87-07 on 870309-13.Unresolved Items Re Evaluation of Offgas Delay Time & Determination of Dose & Dose Commitments & Continuing Problems W/Licensee Process & Effluent Monitors Noted

ML20206E582
Person / Time
Site:	Hope Creek
Issue date:	04/03/1987
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206E562	List: IR 05000354/1987007 ML20206E559
References
50-354-87-07, 50-354-87-7, NUDOCS 8704130661
Download: ML20206E582 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report No. 87-07 *

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Docket No. 50-354 License No. NpF-57 Priority -

Category C Licensee:: Public 'ervice S Electric & Gas Company 80 Park Plaza - 17C Newark, New Jersey 07101 facility Name: Hope Creek Generating Station Inspection At.: Hancocks Bridge, New Jersey Inspection Conducted: March 9-13, 1987 Inspectors: H. h, 4!/!ff7 li. J. Lice se, Radiation Specialist date Approved by:

W . MCLM aitla'k, Chief '

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Effl nts Radiation Protection Section '

Inspection Summary: Inspection on March 9-13 1987 (inspection Report No. 50-354/87-07)

Areas Inspected: Routine, unannounced inspecticn of the licensee's gaseous and liquid radwaste control program including previously identified items, chemistry / radiochemistry, radioactive effluents, instrumentation, ..

nonradioactive system surveillance and audit Results: Within the areas reviewed, two unresolved items, relating to evaluation of off gas delay tinie (Detail 3.8) and determination of. dose and dose commitments (Detail 5.2) were noted. In addition, continuing' problems with the licensee's process and effluent monitors were also note k 870406 Opj05000354

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

] were contacted or interviewe .1 Public Service Electric and Gas Company (PSE&G)

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

*R. Beckwith, Station Licensing Engineer

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

M. Farschan, Power Ascension Manager

• A. Giardino, Manager Station Quality Assurance (QA)

• E. Karpe, Radiological Engineer

*P. Krishna, Assistant to General Manager - HC0

! *J. Lovell, Radiation Protection / Chemistry Manager i *J. Molner, Senior Radiation Protection Supervisor l L. Piccirellt, QA Engineer 1 W. Schultz, Manager, QA Programs & Audits

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T. Vannoy, Senior Chemistry Supervisor j M. Zeigler, Lead Auditor, QA 1

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. Other licensee employees were contacted or interviewed during this l l inspectio *

i i 1.2 NRC Personnel i

l * K. Allsopp, Resident Inspector t

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• Denotes those present at the exit interview on March 13, 198 ! Scope and Purpose

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This routine, unannounced inspection reviewed the licensee's gaseous and tiquid radioactive waste (radwaste) control program from August 1986 to t March 1987 including completion of the startup/ power ascension test program and early full power operations. In addition, the licensee's

! actions regarding previously identified items were also reviewe . Previously Identified Items l ,

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3.1 (0 pen) Followup Item (50-354/85-44-10) - Test results Solid Radwaste l System.

1 The test program for the licensee's installed solidification /dewater- ;

l ing (asphalt) solid radwaste system remained incomplete. This item l

remains open.

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I 3.2 (Closed) Followup Item (50-354/86-05-04) - RWCU Chloride removal Chemistry uperating data were reviewed relative to Reactor Water ,

Cleanup (RWCU) System filter demineralizer removal of chloride

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i ions. The data indicated that chloride ion removal met RWCU System design specifications. This item is close .3 (Closed) Followup Item (50-354/86-05-05) - Condensate Demineralizer effluent analyses

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Operating data were reviewed relative to removal of chemical contami-nants by the licensee's condensate demineralizers. The data in-

dicated that contaminant removal met system design specification This item is close ,

i 3.4 (Closed) Followup Item (50-354/86-05-08) - Chemistry / Radiochemistry

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Test-Results ,

The licensee's chemical and radiochemical tests during power ascension were reviewed. Surveillance data, integrated performance tests of the RWCU and Condensate Demineralizer systems and isolation

, tests were reviewed and test exception dispositionint was discussed i with the licensee. This item is close !

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3.5 (Closed) Licensee Event Reports / Followup Items (50-354/86-39-01; ,

86-39-03) - Inoperable Radiation Monitors t Corrective actions taken as a result of Licensee Event Report (LER)

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Number 86-37 and 86-58 and related LERs listed below were reviewed and discussed with the licensee

LER 86-68, Inoperable North Plant Vent (NPV) Flow Rate Monitor;

LER 86-72, Inoperable Reactor Building Exhaust Duct Monitor;

LER 86-84, Inoperable North and South Plant Vent Monitors; i

LER 86-90, Inoperable Refuel Floor Exhaust Monitors; and

j LER 87-09, Inoperable Cooling Tower Blowdown Effluent Monito '

Although the licensee completed corrective actions as described in LERs 86-37 and 86-58, continuing problems with inoperable process and effluent monitoring instruments were noted suggesting a lack of effective corrective action to prevent recurrence. The licensee's radiation monitoring system installation and testing was delayed by vendor problems forcing the licensee into testing the system while

it was being used for Technical Specification surveillance activi-i ties. As noted in earlier inspections, testing has been completed l and the radiation monitoring system is fully operational. The li- l

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censee has improved administrative control of the determination of l

[ operability by changes to procedures in operations, provision of l

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" status boards" for chemistry and radiation protection personnel and additional training for responsible personnel. Followup Items 50-354/86-39-01 and 86-39-03 are closed administrative 1y. However, the effectiveness of the licensee's actions to prevent recurrence of inoperable monitors, missed grab samples, etc. will be reviewed in subsequent inspection .6 (Closed) Followup Item (50-354/86-39-04) - Alert Level Settings /

Noble Gas Monitors The licensee established alert level settings for the effluent noble gas monitors as discussed in Inspection Report No. 50-354/86-3 This item is close .7 (Closed) Followup Item (50-354/86-39-06) - Effluent Monitor /Labora-tory Sample Intercomparisons The licensee was completing a series of gaseous and liquid sample measurement intercomparisons between continuous radiation monitoring system readings and laboratory grab sample measurements for those effluent streams. The licensee planned to establish procedures for periodic quality control intercomparisons by June 1,1987.

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This item is close .8 Off-Gas System Tests / Followup Item (50-354/86-39-07)

NRC Regulatory Guide 1.68, (" Initial Test Programs for Water-Cooled

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Nuclear Power Plants, Revision 2, August 1978) recommends, in part, preoperational, low power and power ascension testing of gaseous radwaste systems. The licensee completed Power Ascension Test

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TE-SU.HA-741(Q), " Gaseous Radwaste System Performance Test," in partial fulfillment of a commitment to NRC Regulatory Guide 1,6 During the test, the licensee checked the hydrogen analysers and determined recombiner efficiencies. However, NRC Regulatory Guide 1.68 recommends that licensee's demonstrate that gaseous radwaste processing and release systems operate in accordance with desig The licensee's offgas system is designed to provide 35 days for xenon and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for krypton delay times with 75 standard cubic feet per minute total air in leakage. Review of the completed power ascension test and earlier preoperational tests of the licensee's offgas system showed that those tests had not provided an evaluation of the system's delay times for xenon and krypton. The licensee was unable to demonstrate that an evaluation of the delay times had been completed during the offgas system testing. Followup Item 50-354/

86-39-07 is closed administratively. Evaluation of the licensee's offgas system's delay times for xenon and krypton is unresolve /87-07-0 .

l 3.9 (Closed) Unresolved Item (50-354/86-44-01) - Reorganization per 00-18 The licensee rescinded Radiation Protection / Chemistry Department Directive (00)-18 on March 13, 1987. As a result, the organization as described in the licensee's current Technical Specifications and Final Safety Analysis Report (FSAR) was re-established. This item I is closed.

l 3.10 (Closed) Followup Item (50-354/86-44-02) - Procedures to classify, j mark, label and manifest solid radioactive waste shipments l

The following procedures were reviewed which classify, mark, label and manifest licensee solid radwaste shipments:

Radiation Protection Technical Instruction (RP-TI)-902(Q),

" Radioactive Waste Sampling and Classification," Revision 0, March 13, 1987;

RP-TI-903 (Q) "Use of RADMAN," Revision 0, March 13, 1987;

RP-TI-904 (Q) " Dose Curie Conversion Calculations,"

RP-TI-905 (Q) " Transfer of Radioactive Waste to SNGS,"

Revision 0, March 13, 198 This item is close .11 (Closed) Followup Item (50-354/86-44-03) - Administrative Controls to evoke recharacterization of waste streams RP-TI-902(Q) provides examples of conditions which cause additional samples to be taken to evaluate the licensee's radioactive waste streams. Implementation of the procedure would address concerns identified in this ite This item is close . Chemistry / Radiochemistry

Technical Specification 3/4.4.4, " Chemistry," establishes limits and surveillance requirements for chlorides, conductivity and pH in the Reactor Coolant System. Technical Specification 3/4.4.5, " Specific Activity," establishes limits and surveillance requirements for radio- '

activity in the Reactor Coolant System. The licensee's program to *

provide survaillance of reactor coolant chemistry and radiochemistry, establish tiends of important chemical / radiochemical parameters and maintain high purity reactor coolant water during early full power operation was reviewed.

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4.1 Reactor Coolant Chemistry Surveillance records related to chlorides, conductivity and pH from September 1, 1986 through March 9, 1987 were reviewed . Conductivity of the reactor coolant water averaged 0.22 micro Siemens per centi-meter, (uS/cm). Chlorides remained below 20 parts per billion (ppb)

throughout the period and pH was maintained in the range 5.6 to during full power operatio Within the scope of this review, no violations were note .2 Reactor Coolant Radiochemistry Surveillance records related to Dose Equivalent Iodine (DEI)-131 and 100/E microcuries per gram from September 1,1986 through March 9, 1987 were reviewed. The licensee's primary coolant specific activity sampling and analysis program for gross beta and gamma activities, DEI, radiochemical average energy determination, and isotopic offgas sample analyses was reviewed. Selected records were verified by calculational checks done by the inspector from primary coolant licensee dat Within the scope of this review, no violations were note .3 Chemistry Control Program Under Station Administrative Procedure (SA-AP)-0252(Q), " Chemistry Control Program," and Chemistry Technical Instruction (CH-TI)-012 (Q), " Chemistry Sampling Frequencies, Specifications and Surveil-lances," the licensee implements a water chemistry control program generally consistent with guidelines provided by the Boiling Water Reactor (BWR) Owner's Group. Although the licensee was meeting Technical Specification limits for the reactor coolant for conduc-tivities, chlorides and pH, sulphate'and silica levels had exceeded guideline values established by the BWR Owner's Group and licensee procedure Discussions with chemistry personnel indicated that high silica levels in the Delaware River water used by the makeup water facility, incomplete silica removal in the makeup facility and the need for 60-70,000 gallons per day of makeup water contributed to the 100-200 l

i parts per billion (ppb) silica levels noted in the reactor water, The sulphate levels were believed to be due to protective coatings used on turbine internals by the turbine manufacturer from which residual sulphates were being removed by reactor steam.

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5. Radioactive Effluents Technical Specification 3/4.11, " Radioactive Effluents," establishes, in part, limiting conditions for operation and surveillance requirements for radioactive liquid and gaseous effluents. Radioactive effluents from August 13, 1986 through March 9, 1987 were reviewe .1 Semiannual Radioactive Effluent Release Report The licensee reports radioactive gaseous and liquid effluents and

solid radioactive waste shipments (under Technical Specification i 6.9.1.7) twice annually. The report covering the period from July 1, 1986 through December 31, 1986 was reviewed for errors, ancialous measurements, omissions, trends and conformance to reporting requirements in NRC Regulatory Guide 1.21. During the period covered by the report, the licensee completed power ascension testing (on December 19,1986) and commenced full power operatio Within the scope of the review, the inspector noted that radioactive gaseous effluents included 4.20 curies and 0.393 curies of tritium for the third and fourth quarters of 1986. In view of the operating history of the unit, those activities appeared to be higher than expected for a unit which were initially critical on June 28, 198 Review of tritium activities in the reactor coolant, sampling and analyses procedures and records and discussions with chemistry personnel indicated that sampling calculational errors were (at least in part) responsible for the tritium activities reporte The licensee's liquid scintillation counting procedures suggest that a 10 milliliter water sample be added to the scintillation

" cocktail". Several data entities indicated 0.1 milliliter was t used. Calculation of the activities in those samples indicated I activities in the gaseous sample water higher (by factors of 100)

l than those present in reactor coolant samples. In addition,

! discussions indicated that insufficient time for extinguishing l chemiluminescence in the sample-liquid scintillation cocktail mixture had also occurred resulting in high count rates due to light from the chemiluminescence. The licensee is evaluating the apparent errors in the tritium gaseous activities and will revise the l

Semiannual Radioactive Effluent Release Report to correct those error .2 Radioactive Liquid Effluents Batch liquid releases from the licensee's "A" and "B" Waste Storage and "A" and "B" Floor Drain Storage tanks for the period January 1 -

March 9, 1987 were reviewed. Concentrations, total estimated activ-ities, radiation monitor setpoints/ operability, lower levels of detection for grab samples and offsite dose projections resulting l

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from 5 releases were reviewed and discussed with cognizant personnel within the licensee's chemistry group. Verification of release activities during period of liquid radwaste monitor (RE 4861) inoper-ability were also reviewe Within the scope of this review, the following item was noted:

On February 25, 1987, the licensee's Site Operations Review Committee approved Revision 6 to the Offsite Dose Calculation Manual (0DCM). The revision was completed to provide consistency between the Salem and Hope Creek ODCMs and included changes from an estuarine to saltwater ingestion pathway model for offsite dose projections. Offsite dose projections with the revised ODCM increased due to higher bioaccumulation factors in postulated saltwater ingestion pathways. However, computer-code data base tables and procedural calculational tables were not updated to the revised ODCM site-related ingestion dose commitment factors. As a result, projected and cumulative dose commitment calculations for radionuclides released into the liquid ingestion pathways were incorrect for liquid radwaste releases after February 25, 1987.

, Using methods described in the licensee's revised ODCM, the inspector calculated organ and wholebody dose commitments and com-

pared those dose commitments to ones obtained by computer calcula-

tions using the licensee's computer data base:

Computer ODCM Dose ODCM Dose Release Projection Projection Permit N Date Organ (mrem) (mrem)

870126-L March 3, 1987 GI-LLI* 0.073 0.0157 870131-L March 2, 1987 GI-LLI 0.057 0.0059 870110-L February 27, 1987 GI-LLI 0.056 0.0113 i

870121-L March 2, 1987 Wholebody 0.0136 0.00198 870121-L March 2, 1987 Bone 0.011 0.00163

• Gastrointestinal tract - lower large intestine The inspector noted that the licensee had 31 days to update cumula-tive dose contributions under Surveillance Requirement 4.11.1.2 and ;

project dose commitments under Surveillance Requirement 4.11.1. Since those surveillance periods had not been exceeded, the adequacy of the cumulative dose contributions and projected dose commitments from the liquid radwaste permits is unresolved. 50-354/87-07-0 l

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5.3 Radioactive Gaseous Effluents '

i Noble gas, radioiodine and radioactive particulate release concen-trations, total radioactivities and projected and cumulative dose and dose commitments for gaseous effluent releases (via the NPV, SPV and FRVS) were reviewed from January 1 through March 10, 1987. Re-

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lease permits were reviewed for completeness and consistency with provisions of the licensee's Technical Specifications. Dose calcu-lations using methods in the licensee's revised ODCM were completed and compared with the licensee's calculations. Composite particulate sampling was reviewed and discussed with the license Within the scope of this review, no violations were note . Instrumentation Technical Specifications 3/4.3.7.10, " Radioactive Liquid Effluent Monitor-ing Instrumentation," and 3/4.2.7.11, " Radioactive Gaseous Effluent Mon-itoring Instrumentation," provide effluent monitoring instrumentation requirements. Channel checks, source checks, calibrations and functional

, tests for the following effluent / process monitoring instrumentation from September 1, 1986 through March 9, 1987 were reviewed on a sampling basis:

Monitor Name Instrument Number Filtration, Recirculation & RE-6620 Ventilation System (FRVS)

South Plant Vent (SPV) RE-4875 North Plant Vent (NPV) RE-4873 Liquid Radwaste RE-4861 Cooling Tower Blowdown (CTBD) RE-8817 Pretreatment Noble Gas RE-6633 Post-Treatment Noble Gas RE-6623

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In addition, flow rate monitors for the NPV, SPV and CTBD and hydrogen gas monitor for main condenser offgas treatment system were also briefly re-viewed relative to calibration and operability. As noted in Detail 3.5, the licensee has identified problems with operability of the monitors. No additional problems were noted in the brief review conducte . Nonradioactive System Surveillance The licensee committed to routine surveillance of normally nonradioactive process and effluent streams in response to NRC Bulletin No. 80-10, (Con-

tamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to the Environment,"

May 6, 1980). Surveillance activities for the domestic water supply, sewage treatment and demineralized water systems were briefly reviewe No problems were note . Audits The licensee's QA organization reviews radiation protection and chemistry activities during annual audits. The inspector reviewed a joint Salem-Hope Creek Radiation Protection / Chemistry audit, (NQA 87-0196) conducted January 19 - March 3, 1987. However, the audit did

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not specifically cover areas reviewed in this inspection. The licensee plans a June 1987 audit of radwaste activitie . Exit Interview ,

The inspector met with the licensee's representatives (denoted 16 p ra-graph 1) at the conclusion of the inspection on March 13, 1987. -During the meeting, the inspector summarized the purpose and scope of the

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inspection and identified fin: lings as described in this report. The

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inspector expr'essed concern over the continuing problems with the process and effluent radiation monitors and the apparent lack of effective corrective action to prevent recurrenc In addition, the inspector emphasized the need to ensure that all elements necessary to implement changes to the ODCM were in place pri.or to the effective date of revisions to the ODCM. At no time du/ing this inspection was written material provided to the licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this repor s a

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