IR 05000361/1997003
| ML20137S129 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20137S099 | List: |
| References | |
| 50-361-97-03, 50-361-97-3, 50-362-97-03, 50-362-97-3, NUDOCS 9704150037 | |
| Download: ML20137S129 (25) | |
Text
{{#Wiki_filter:- . - - . . l . ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 50-361 50-362 License Nos.- NPF-10 NPF-15 Report No.: 50-361/97-03 50-362/9/ 03 Licensee: Southern California Edison Co.
Facility: San Onofre Nuclear Generating Station, Unitt 2 and 3 Location: 5000 S. Pacific Coast Hwy.
San Clemente, California Dates: February 24-28,1997 , Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ATTACHMENTS: Attachment 1: Supplemental Information Attachment 2: Airborne Effluent Releases Attachment 3: Liquid Effluent Releases
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4 EXECUTIVE SUMMARY 1.
i San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/97-03; 50-362/97-03 '
This routine, announced inspection focused on the licensee's radiological waste effluent management program.
) Enaineerina . ' ~ No deviations to the commitments in Chapter 11 of the Updated Safety Analysis
Report were identified (Section E2.1).
Plant Suoogn ,
The liquid and gaseous radioactive waste effluent management programs were
j properly implemented (Section R1.1).
Inappropriate sample handling techniques were used while collecting and handling
charcoal cartridge samples and airborne particulate filter samples (Section R1.1).
Between 1994 and 1996, the curies of airborne fission and activation gases
released from Units 2 and 3 were less than half of the curies released during 1992 I and 1993 indicating a marked improvement in the gaseous effluents released
(Section R1.2).
, ' Between 1992 and 1996, the curies of airborne iodine 131 and particulates and
' . liquid dissolved and entrained fission and activation gases released from Units 2 and 3 remained about the same. The amount of liquid tritium released during 1996
increased significantly (Section R1.2).
The engineered-safety-feature air cleaning ventilation systems were properly
maintained and tested (Section R1.3).
Housekeeping around the control room emergency air cleanup system filter units t
j was not properly maintained (Section R1.3).
i The radiochemistry counting room instrumentation was properly maintained, tesi >d,
- i and calibrated (Section R2.1).
i ' I Liquid and gaseous radioactive waste management systems were installed and
T; operated properly (Section R2.1).
The postaccident sampling system generally met the operational test criteria
, (Section R2.2).
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. - - - ~ , I , . -3-Liquid and gaseous effluent radiation monitoring instrumentation was operable and
properly maintained, tested, and calibrated. New effluent radiation monitors was i considered a program strength (Section R2.3).
, l Implementing procedures for the liquid and gaseous radioactive waste effluent
management programs provided proper guidance. Excellent annual radioactive effluent release reports for 1994 and 1995 were submitted in a timely manner (Section R3.1).
Chemistry personnel and radwaste operations personnel had an excellent
understanding of the radioactive liquid and gaseous waste management procedures, l ' Offsite Dose Calculation Manual requirements, and regulatory requirements (Section R4).
Training and qualification programs for chemistry technicians and radwaste
operators were properly implemented. A trained and qualified staff for conducting radioactive waste effluent processing and release operations was maintained (Section RS).
All chemistry technicians had completed the required biennial postaccident sampling
system retraining (Section R5).
In the past 2 years, the chemistry technician staff experienced a significant
reduction. The radwaste operations staff changed very little (Section R6).
Oversight of the radioactive waste effluent management program was excellent.
- The quality assurance audit, surveillances, and observation reports of the radiological waste effluent management program activities were technically comprehensive and providad excellent program evaluation and oversight (Section R7.1).
There was appropriate evaluation of the contractors' performance (Section R7.2).
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Report Details . . Summary of Plant Status i Unit 1 was in a shutdown safe store condition. Unit 2 was in Mode 5 " cold t,hutdown."
following 'a refueling outage, and Unit 3 was operating at power during the en' tire ! inspection.
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E2 Engineering Support of Facilities and Equipment E2.1 Updated Safety Analysis Report (UFSAR) Review
! $ j a.
Inspection Scoce Chapter 11, " Radioactive Waste Management," of the UFSAR was reviewed to ! ensure agreement with any commitments contained therein that pertained to the l
inspection.
I b.
Observations and Findinos A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares ' plant practices, procedures and/or parameters to the UFSAR descriptions. While ! performing the inspection discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was consistent with the observed plant practices, procedures and/or parameters.
, c.
Conclusio,rl
No deviations to the commitr,ents in Chapter 11 of the UFSAR were identified.
IV. Plant Support ! R1 Chemistry and Radioactive Waste Effluent Controls R1.1 Radioactive Waste Effluent Manaaement Proarams a.
Inspection Scoce (84750) ' ' implementation of the liquid and gaseous radioactive waste effluent management ' programs, as described in the Offsite Dose Calculation Manual, were reviewed.
, This review included: radioactive effluent waste processing, sampling and analyses,' - . -w.- . - - . . , .
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i _ analytical sensitivities and results; offsite dose results and performance of required j surveillance tests. The following activities were observed: The collection of the Unit 3 containment vent samples, performance of j
radiochemistry analyses, and preparation of the vent release permit.
The collection of a radioactive liquid waste sample from Radwaste Secondary
Tank T-057, performance of radiochemistry analyses, preparation of the release permit, and the performance of the valve lineup.
i The collection of gaseous release samples from the Unit 3 condenser air
' ejector and performance of radiochemistry analyses.
Ten batch radioactive liquid waste effluent release permits for the period
January 1995 through December 1996 were reviewed , l Seven batch radioactive gaseous waste effluent release permits for waste
gas decay tanks and containment purges for the period January 1995 through December 1996 were reviewed.
Selected gaseous waste effluent sample analyses of samples from the plant
vent stack, condenser air ejector, and south yard facility continuous reicases for the period January 1995 through December 1996 were reviewed.
b.
Observations and Findinas The chemistry technicians followed the appropriate sampling procedures. The sample analyses and release permit preparations were performed properly. The radioactive liquid and gaseous waste effluent releases were performed in accordance with approved procedures and the Offsite Dose Calculation Manual requirements. However, the inspector made the following observations during the sampling activities: While collecting the samples for the Unit 3 containment vent and condenser
air ejector, the technician did not use gloves while handling the charcoal cartridge and particulate samples. Forceps were not used to remove the particulate filter from the sample holder.
< The particulate filter used in the sample holder was not the correct size, the
filter diameter was too large. When the particulate filter was placed in the sample holder, the filter overlapped the inside edge of flange inside the sample holder. The inspector noted that the filter holder sealed when closed and no leaks were detected. The filter's diameter was also too large to fit properly in the petri dish counting geometry and had to be crimped on the edges when pushed into the petri dish for analysis. This did not provide a proper reproducible counting geometry.
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. -6-Gloves were not used when handling the particulate filter and forming it into
the petri dish counting geometry. These observations were discussed with the licensee during the inspection. The licensee stated that the chemistry technicians would be properly informed of the proper size filter paper to be used in the various filter holders and instructed to take proper protective j actions when handling potentially radioactive samples.
Radioactive liquid waste samples from the various waste processing tanks
were collected at each individual tank's local sample point. These local sample points were located at very inaccessible locations near the individual tank's recirculation pump. The inspector observed that these local sample points were a concern because of the high potential for spread of contamination by sample spillage from the flexible tubing connected to the sample point. There was also a high potential for sample spillage due to the awkward position the technician must be in while collecting and handling the samples. This is due to the very inaccessible local sample locations.
A similar observation was identified in a previous NRC inspection report . 50-361/94-19; 50-362/94-19. The observation stated that a sample sink was not provided to facilitate more accessible and efficient sampling of the j radioactive liquid waste tanks. The inspector discussed this observation with the licensee during the 1994 inspection and during this inspection and at the exit meeting conducted on February 28,1997. At the exit meeting in 1994, the licensee stated that they would evaluate the possibility of providing sample sinks at the radioactive waste tanks' local sample locations. The inspector noted that the licensee had installed a funnel at the local sample point for the miscellaneous waste evaporator condensate monitor tank local sample point, but had not upgraded the sample accessibility for all radioactive siquid waste tanks. At the February 28,1997, exit meeting, the licenseo stated that they would further evaluate the installation of appropriate sample areas for sampling the radioactive liquid waste tanks.
The following activities were conducted in accordance with Offsite Dose Calculation Manual requirements: (1) processing, sampling, and analyses of batch and continuous radioactive liquid and gaseous waste effluents, (2) approval and performance of batch radioactive liquid and gaseous waste discharges, and (3) monitoring of continuous liquid and gaseous waste effluents.
Quantities of radionuclides released in the radioactive liquid and gaseous waste effluents were below the limits specified in the Offsite Dose Calculation Manual.
Offsite doses were calculated according to Offsite Dose Calculation Manual methodologies at the required frequencies. The radiation doses resulting from liquid and gaseous radioactive waste effluents were below regulatory limits. Required analyses of monthly and quarterly composite samples of batch radioactive liquid and qaseous waste effluent releases were performed in accordance with Offsito Dose f siculation Manual requirement ! . j - l-7-l c.
Conclusions The liquid and gaseous radioactive waste effluent management programs were properly implemented, inappropriate sample handling techniques were used while collecting and handling charcoal cartridge samples and airborne particulate filter samples. Quantities of radionuclides released in the liquid and gaseous radioactive waste effluents were within the Offsite Dose Calculation Manual limits. Offsite doses to the enviror..nent from the liquid and gaseous radioactive waste effluents met regulatory limits.
R1.2 Radioactive Waste Effluent Data a.
Insoection Scope (84750) Radioactive waste effluent data for Units 2 and 3 between 1991 and 1996 were reviewed.
b.
Observations and Findinos Radioactive waste effluent data for Units 2 and 3 for the time period 1992 through 1995 and draft effluent data for 1996 are summarized in Attachments 2 and 3.
Airborne fission and activation gases released between 1994 and 1996 were less than half of the curie amounts released during 1992 and 1993 indicating a marked
improvement. The airborne iodine-131 and particulates released between 1994 and 1996 remained about the same as the curie amounts released during 1992 and j 1993. The liquid dissolved and entrained fission and activation gases released i between 1992 and 1996 remained relatively constant. The liquid tritium released between 1992 and 1995 remained relatively constant. However, the amount of liquid tritium released during 1996 increased significantly. This increase was attributed to the increased use of lithium chemical treatment in the reactor coolant water starting in late 1995 in Unit 2 and early 1996 in Unit 3. Also, quarterly 1996 liquid effluent data showed that six liquid hatch releve were made during the j fourth quarter of 1996. These six liquid batch releases contributed 500 curies of j tritium causing a significant tritium increase to the total curie amount of tritium released in the liquid effluents during i996.
The radioactive waste effluent data was discussed with the licensee. The licensee stated, that prior to the inspection, they had only a general knowledge of their overall effluent release performance when compared to the annual effluent performances of other operating pressurized water reactors nationally. The licensee . stated that improvement in the reduction of effluent radioactivity released from Units 2 and 3 was a pnonty.
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Conclusions Between 1994 and 1996, the curies of airborne fission and activation gases t released from Units 2 and 3 were less than half of the curies released during 1992 and 1993 indicating a marked improvement in the gaseous effluents released.
Between 1992 and 1996, the curies of airborne iodine-131 and particulates and liquid dissolved and entrained fission and activation gases released from Units 2 and 3 remained about the same. The amount of liquid tritium released during 1996 increased significantly.
R1.3 Enaineered-Safetv-Feature Air Cleanina Systems a.
Inspection Scooe (84750) Surveillance and test results for the engineered-safety-feature air cleaning ventilation systems testing program were reviewed to determine compliance with the requirements in Technical Specifications 3/4.7.5 and 3/4.9.12.
b.
Observations and Findinas The surveillance tests for periodic functional checking and testing of the engineered-safety-feature air cleaning ventilation systems' components were performed properly. The surveillance tests included evaluation of the high efficiency particulate air filters, activated charcoal adsorbers, and in-place filter testing of the control room emergency air cleanup system and the fuel handling building post-accident cleanup filter system. The in-place filter testing was performed by the licensee. The activated charcoallaboratory surveillance tests were performed by an offsite contract laboratory. All test results were verified to be within Technical Specification limits.
The inspector performed a walkdown inspection of the control room emergency air cleanup system filter units and the fuel handling building post-accident cleanup filter system filter units with the system engineer. No problems were identified with filter units' physical condition. However, the inspector observed that the areas surrounding the control room emergency air cleanup system filter units were not well maintained and lighted. The areas were crowded and scaffolding was left in place which did not allow good access to the filter units. This housekeeping observation was discussed with the licensee at the exit meeting. The licensee stated that they would evaluate the inspector's housekeeping concern.
c.
Conclusions The engineered-safety-feature air cleaning ventilation systems met the Technical Specification requirements. A good engineered-safety-feature air cleaning systems surveillance program was implemented. All surveillance test results met Technical
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l " Specification requirements. Housekeeping around the control room emergency air cleanup system filter units was not properly maintained.
R2 Status of Chemistry and Radioactive Waste Effluent Facilities and Equipment i J R2.1 Radiochemistrv Countina Room and Radioactive Waste Effluent Processina Systems a.
Inspection Scone (84750) ] ' Operations in'the radiochemistry counting room were observed.
- The radioactive liquid and gaseous waste processing equipment was
inspected. The equipment included the reactor coolant waste processing j system, primary liquid waste tanks, secondary liquid waste tanks, and the gaseous radioactive waste processing system.
l { b.
Observations and Findinas The radiochemistry counting room was equipped with state-of-the-art analytical , ' instrumentation. The analytical instrumentation was properly maintained and calibrated.
The liquid and gaseous radioactive waste processing and storage systems were installed as described in the UFSAR and were operated in accordance with station procedures.
No major equipment or design modifications were made to the liquid or gaseous O radioactive waste management systems during 1995 and 1996.
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Conclusions The radiochemistry counting room instrumentation was properly maintained, tested, and calibrated. Liquid and gaseous radioactive waste management systems were i - insta!!ed and operated properly.
R2.2 Postaccident Samotina System
a.
Insoection Scooe (84750)
Postaccident sampling system instrumentation and equipment were j
inspected to verify if an adequate operational surveillance program was i implemented.
j I Postaccident sampling system surveillance test results for 1995 and 1996
were reviewed.
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l . - 10-l The performanc6 if a postaccident sampling system monthly operational
surveillance test was observed.
j i b.
Observations and Findings i ) An annual surveillance program for testing all of the sarnpling and analytical ) capabilities of the postaccident sampling system for determining operability was implemented. The postacciden* sampling system was generally operable.
However, the survei;iance test results indicated numerous in-line instrument problems. Maintenance on the postaccident sampling system instrumentation was performed in a timely manner. Alternate analytical methods were tested quarterly.
All chemistry technicians had completed bier.nial required training on the operation of the postaccident sampling system. The licensee's expectation was for each chemistry technician to perform at least one monthly postaccident sampling system operational surveillance test within a 24-month period. All but six chemistry technicians had performed the monthly postaccident sampling system operational surveillance test during the past 24-months.
A routine monthly postaccident sampling system operational surveillance test was observed by the inspector. The surveillance was performed according to an approved procedure. The in line pH meter, which was out-of-service since October 1996, was calibrated and installed on January 29,1997, but the pH results did not meet acceptance criteria during the performance of the observed February 1997 monthly surveillance test. An Action Request was written to initiate corrective maintenance.
c.
Conclusions The postaccident sampling system was operated monthly and generally met the operational test criteria.
R2.3 Liauid and Gaseous Effluent Radiation Monitors a.
Insoection Scope 184750) The liquid and gaseous effluent radiation monitors were inspected for
operation, calibration, and reliability in accordance with the surveillance requirements specified in Offsite Dose Calculation Manual Tables 2-3 and 3-3.
Liquid and gaseous radioactive waste effluent radiation monitor source
check, channel check, channel operational test, and channel calibration
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i records, for the period of January 1995 through December 1996 were reviewed.
i b.
Observations and Findinas Reviewed records and surveillance test results indicated that the liquid and gaseous-radioactive waste effluent monitoring instrumentation was properly maintained, tested, and calibrated in compliance with Offsite Dose Calculation Manual requirements.
- The older Nuclear Measurements Corporation effluent radiation monitoring instrumentation (eight monitors in Units 2 and 3) were being upgraded with new Merlin Gerin radiation monitors. The inspector witnessed the in-place field testing for one of the monitors. The new monitors' installation, testing, and calibration for operation is scheduled to be completed in 1997. The effluent radiation monitor uogrades were considered a program strength, c.
Conclusions Liquid and gaseous effluent radiation monitoring instrumentation was operable and properly maintained, tested, and calibrated. New effluent radiation monitors were considered a program strength.
i R3 Radioactive Waste Effluent Procedures and Documentation i R3.1 Radioactive Waste Effluent Procedures. Offsite Dose CalculatiorL anual. and M Annual Rqdioactive Effluent Release Reports a.
Inspection Scoce (84750) Procedures for the sampling, analysis, and release of radioactive liquid and '
gaseous waste effluents were reviewed.
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Revisions to the Offsite Dose Calculation Manual were reviewed.
- Annual radioactive effluent release reports for 1994 and 1995 and the 1996
- draft effluent data were reviewed.
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ObservatioDs and Findinas Chemistry and radwaste operations procedures for performing batch release of liquid and gaseous radioactive waste effluents provided proper guidance to personnel implementing the radioactive waste effluents program. The procedures were written with sufficient detail to properly perform the radioactive waste effluent j program.
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- 12-Annual radioactive effluent release reports were well written, used the format described in NRC Regulatory Guide 1.21, Revision 1, June 1974, and contained the required information. Summaries of the radioactive airborne and liquid radioactive effluent release data are presented in Attachments 2 and 3.
{ Changes to the Offsite Dose Calculation Manual were properly documented in the annual reports.
c.
Conclusions implementing procedures for the liquid and gaseous radioactive waste effluent management programs provided proper guidance. Changes to the Offsite Dose Calculation Manual were properly documented. Excellent annual radioactive effluent release reports for 1994 and 1995 were submitted in a timely manner.
R4 Staff Knowledge and Performance l a.
Insocction Scone (84750) Chemistry personnel and radwaste operators were interviewed and observed to determine their knowledge of regulato.y and Offsite Dose Calculation Manual requirements regarding the implementation of the liquid and gaseous radioactive waste effluent management programs.
b.
Observations and Findinas Chemistry personnel and radwaste operations personnel were knowledgeable of the programmatic procedures, Offsite Dose Calculation Manual requirements, and I regulatory requirements.
c.
Conclusion . Chemistry personnel and radwaste operations personnel had an excellent understanding of the radioactive liquid and gaseous waste management procedures, Offsite Dose Calculation Manual, and regulatory requirement * -- .. . -13- ' RS-Staff Training and Qualification a.
Inspection Scoce (84750) Training and qualification programs for chemistry technicians and radwaste
operators were reviewed.
Training and qualifications of chemistry technicians and radwaste operators 1
were verified.
The training and qualification program for operating the postaccident
sampling system was reviewed.
b.
Observations and Findinas Training and qualification matrices and attendance records for radwaste effluent training for chemistry technicians and operations crews included required formal classroom training and on-the-job training.
All chemistry technicians had completed the required classroom training and on-the-job' training to be qualified to perform all radioactive waste effluent management program activities.
All chemistry technicians had completed the required biennial postaccident sampling system retraining and were qualified to independently operate the postaccident sampling system.
The inspector noted that all but four persons listed on the seven operations shift crews were trained and qualified to conduct radioactive waste liquid and gaseous j effluent batch releases and operate the radioactive waste processing equipment.
' ' c.
Conclusions i Training and qualification programs for chemistry technicians and radwaste operators were properly implemented. The experience, training, and working j knowledge of the chemistry department and the operations department personnel ~ ' met the training and qualification requirements for conducting radioactive waste
liquid and gaseous effluent processing and release operations. All chemistry technicians had completed the required biennial postaccident sampling system j retraining.
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. . . - 14-R6 Chemistry Organization and Administration a.
Insoection Scone (847501 Organization, staffing, and assignment of the radioactive waste effluent
management program responsibilities were reviewed.
Administrative and chemistry departmental procedures were reviewed for the
assignment of responsibilities for the management and implementation of the radioactive waste effluent management program, b.
Observations and Findinas Chemistry and radwaste operations personnel were responsible for the implementation of the radioactive waste effluent management program.
The chemistry department was adequately staffed. However, there had been a significant change in the chemistry technician staff during the past 2 years. The chemistry department reduced the number of chemistry technicians from 23 to 18.
The plant chemistry supervisor was reassigned and replaced. The effluent chemistry supervisor was recently reassigned, and the vacant position had not been filled at the time of the inspection. The licensee's reduction in chemistry staff did not appear to have adversely affected implementation of the radioactive waste effluent management program.
The radwaste operations department was adequately staffed, and personnel had not changed significantly during the past 2 years.
c.
Cpnclusions Staffing of the chemistry and radwaste operations departments met Technical Specification requirements. In the past 2 years, the chemistry technician staff experienced a significant reduction. The radwaste operations staff changed very little.
R7 Quality Assurance in Chemistry and Radiological Waste Effluents Activities R7.1 Badioactive Waste Effluent Quality Assurance Proaram a.
Insoection Scone (84750) The quality assurance audit and surveillance programs of the radioactive waste effluent management program activities were reviewed for scope, thoroughness of program evaluation, and timely followup of identified deficiencies. The following quality assurance items regarding the radioactive waste effluent management program activities were reviewed:
. . . -15-l Qualifications of personnel who performed the quality assurance audits and
surveillances Quality assurance audit performed during 1994-1996
Quality assurance surveillances performed during 1994-1996
Nuclear Oversight Division Observation Reports performed during 1994-1996
San Onofre Topical Report SCE-1 A, " Quality Assurance Program
Description," Amendment 18, Change Notice 41, dated July 1996 b.
Observations and Findinqs i Audits of the radioactive waste effluent management program and Offsite Dose i Calculation Manual and implementing procedures were scheduled periodically.
The quality assurance radioactive waste effluent management program audit, i surveillances, and observation reports performed between January 1995 and December 1996 were conducted in accordance with quality assurance procedures by qualified auditors. The audit, surveillances, and observation reports of the radioactive waste effluent management program were of excellent quality, technically comprehensive, and provided excellent oversight and evaluation of the licensee's performance in implementing the radioactive waste effluent management program, c.
Conclusions Oversight of the radioactive waste effluent management program was excellent.
The quality assurance audit, surveillances, and observation reports of the radiological waste effluent management program activities were technically comprehensive and provided excellent program evaluation and oversight.
R7.2 Quality Assurence Proaram for Contractorg
a.
Inspection Scope (84750)
. The quality assurance vendor audit program regarding contractors performing surveillance activities involving the radioactive waste effluent program and safety-related air cleaning ventilation systems was reviewed.
b.
Observations and Findinas A contractor laboratory was used to perform required radiochemistry analyses of radioactive waste effluent composite samples. A second contractor laboratory was used to perform laboratory charcoal adsorber analyses on the station's engineered-
. . . - 16-safety-feature air cleaning ventilation systems. The licensee used Nuclear Procurement issues Committee audits of the two contractors to evaluate their performance in performing the surveillance testing requirements and to retaining their current status on the licensee's routine suppliers list. The audits of the two contractors evaluated the contractor's abilities to perform the Technical Specification required testing and surveillance activities.
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Conclusion -
There was appropriate evaluation of the contractors' performance.
V. Manaaement Meetinas i X1 E.xit Meeting Summary The results of the inspection were presented to members of licensee management i at the conclusion of the inspection on February 28,1997. The licensee acknowledged the findings presented. No proprietary information was identified.
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- ' .j > C h 'O ] ATTACHMENT 1 .l PARTIAL LIST OF PERSONS CONTACTED-J Licensee D. Nunn, Vice President, Engineering 'and Technical Services D Axline, Licensing Engineer, Compliance J. Beebe, Project Manager Radiation Monitors, Maintenance R. Borden, Supervisor, Nuclear Oversight L. Bray,' Supervisor, Chemistry J.' Clark, Manager, Chemistry J. Denlow,~ Auditor, Nuclear Oversight i D, Dick, Effluent Engineer, Chemistry -{ ' K. Flynn, Supervisor, Auxiliary Mechanical Systems S. Gawne, Training Specialist, Training G. Gibson, Manager, Compliance G. Plumlee 111, Compliance ' K. Rauch, Supervisor, Operations Training R. Sandstrom, Manager, Training K. Slagle, Manager, Nuclear Oversight P. Shaffer, Supervisor, Maintenance M. Thurburn, Radwaste Coordinator NBC J. Sloan, Senior Resident inspector J. Russell, Resident inspector J. Kramer, Resident inspector INSPECTION PROCEDURES USED 'l 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring i LIST OF DOCUMENTS REVIEWED Oraanization Charts Chemistry Department - January 31,1997 Quality Assurance Documents j Quality Assurance Audit Schedules for 1993-1997 San Onofre Topical Report SCE-1 A, " Quality Assurance Program Description," i Amendment 18, Change Notice 41, dated July 1996 ' I
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, , Draft Audit Plan for the Radioactive Effluent Controls Program Topical Quality Assurance Manual (TQAM), Revision 13, December 20,1996 Quality Assurance Audit . Quality Assurance' Audit Report SCES-434-94, " Radioactive Effluent Controls Program," , conducted July 25 through October 20,1994 ' Quality Assurance Surveillances Quality Assurance Surveillance Report SOS-017-94,." Units 2 and 3 Evaluation of the Waste Gas System," conducted February 23-24,1994 i Quality Assurance Surveillance Report SOS-043-94, " Unit 2 Process Equipment Calibration," conducted February 10 - March 18,1994 L Quality Assurance Surveillance Report SOS-091-94, " Unit 2 Liquid Effluent Sample Collection and Analysis," conducted May 6-9,1994
Quality Assurance Surveillance Report SOS-200-94, " Units 2 and 3 Liquid Effluent Sample Collection," conducted September 30,1994 Quality Assurance Surveillance Report SOS-234-94, " Units 2 and 3 Rad Monitor Design Change," conducted September 27 - December 12,1994 Nuclear Oversiaht Division Observation Reoorts Activity Observation Report AOR96-07502, " Liquid Batch Release of Coolant Radwaste Secondary Tank (T-057)," October 25,1995 Activity Observation Report AOR96-07843, " Units 2 and 3 Containment Purge Permits," November 30,1995 Activity Observation Report AOR96-00276, " Gaseous Effluent Release Permit," January 17,1996 Activity Observation Report AOR96-01544, " Steam Generator Blowdown Monitor OOS Actions," February 29,1996 Activity Observation Report AOR96-03012, " Chemistry Out-of-Service Effluent Monitor " Response," May 29,1996 Activity Observation Report AOR96-06822, " Chemistry Effluent Sampling," ) ~ September 25,.1996 i
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, Activity Observation Report AOR96-09295, " Effluent Release Controls on Containment Atmosphere," December 1,1996 Activity Observation Report AOR96-09584, " Air Sampling Analysis," December 6,1996 <" Vendor Audits NUPIC Joint Quality Assurance Audit of NUCON Corporation, conducted May 5,1995 NUPIC Joint Quality Assurance Audit of Yankee Atomic Environmental Laboratory, conducted June 22-23,1994 NUPIC Joint Quality Assurance Audit of Teledyne Brown Engineering Environmental Services, conducted August 26-30, 1996 Adminc.trative Procedure SO123-ill-0, " Chemistry Organization and Administrative Policies," Revision 9 Chemistry Procedures SO123-ill-0.1, " Organization of Chemistry Division Procedures," Revision 16 SO123-lll-4.10.4, " Operation and Calibration of Beckman LS6000 Liquid Scintillation Counter," Revision 2 SO123-Ill-4.5.3, " Operation of the VAX/VMS Gamma Spectrometer," Revision 5 SO123-lil-5.1.23, " Units 2 and 3 Effluent Sampling and Analysis," Revision 17 SO123-ill-5.2.23, " Units 2 and 3 Liquid Effluent Sample Collection," Revision 8 SO123-Ill 5.3.23, " Units 2 and 3 NMC Airborne Radioactivity Monitor Sample Collection," i Revision 14 SO123-lll-5.5.23, " Units 2 and 3 GA Airborne Radioactivity Monitor Sample Collection," j Revision 9-3 SO123-Ill-5.10, " Liquid and Gaseous Effluent Dose Determinations," Revision 8 , S0123111-5.11.23, " Units 2 and 3 Liquid Effluent Releases," Revision 12-4 SO123-lil-5.12.23, " Units 2 and 3 Gaseous Effluent Release Permit," Revision 10 J SO123-ill-5.23.23, " Units 2 and 3 Nuclear Data ND6685 Computer Operation for the
Generation of Radioactive Effluent Release Permits," Revision 0-3 l i
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SO123-ill 5.24'.23, " Units'2 and 3 Nuclear Data ND6685 Computer Operation for the ' ' Generation of Radioactive Effluent Release Reports," Revision O ' ' Radweste Ooeratina Instruction j
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SO23-8 7,'" Release of Radwaste Tanks," Revision 8 r , ). . Chemistrv Trainino Documentation J " Nuclear Chemistry Technician Task Qualification Matrix," dated February 24,1997 ' I " Nuclear Chemistry Technician Qualification Manual," QM5700-U23, Revision 8 " Lesson Plan (CYO38) " Miscellaneous Liquid Waste System" Lesson Plan (CYO39) " Coolant Radwaste System" j Lesson Plan (CYO40) " Gaseous Radwaste System" Lesson Plan (CYO12) " Liquid Radwaste Treatment Program" 4 - Lesson Plan (CY151) " Evaluation of Unplanned, Monitored Radioactive, Gaseous Releases Lesson Plan (CY157) " Liquid Release Permit Generation"
Lesson Plan (CY158) " Gaseous Release Permit Generation" Lesson Plan (CY211) " Release Permit Generation Using the ND6685 Computer" . Lesson Plan (CYO15) " Wide Range Gas Monitoring System" i~ 8.esson Plan (CYO20) " Process and Effluent Radiation Monitoring System" j-Lesson Plan (CYO19) "Postaccident Sampling System Overview" Lesson Plan (CY113) "Postaccident Sampling System Reactor Coolant System Purging and + Sampling" Lesson Plan (CY114) "Postaccident Sampling System Containment Atmosphere Purging and Sampling" Lesson Plan (CY115) "Postaccident Sampling System Procedures Overview" Lesson Plan (CY210) "Postaccident Biennial Retraining" ' SO123 XXI-1,11,10, " Chemistry Training Program Description," Revision 4 . n -.,, ,. , - -,, +... , -... .,..,- - ., - - - - - - -
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SO123 ill-0.14, " Chemistry Division On-The-Job TraiHng and Evaluation Program," Revision 1 peerations Trainina Documentation " Operations Crew Task Qualification Matrix," dated January 24,1997 " Units 2 and 3 Radwaste Operator Qualification Guide," 2JO202, Revision 3 Lesson Plan (2XRLO4) " Miscellaneous Radwaste System" Lesson Plan (2XRLO5) " Coolant Radwaste System" Lesson Plan (2XRLO6) " Gaseous Radwaste System" Lesson Plan (2XRLO7) " Radiation Monitoring System" Lesson Plan (2XRR07) " Release Permit /Offsite Dose Calculation Manual" Postaccident Samplina System Procedures S0123-111-8, "Postaccident Sampling Program and Analytical Requirements," Revision 11 SO123 ill-8.1, Postaccident Sampling System Surveillance Program," Revision 10-3 SO123-PS 1, "Postaccident Sampling System Program," Revision 21 Surveillance Operatina instructions SO23-3-3,21, " Radiation Monitoring and Common Daily Surveillances - All Modes," Revision 9 Badiation Monitorina Pgedures SO23-XXV-4.12, " Condenser Evacuation S',' stem Loop 2/3RT-7818 Channel Functional Test," Revision 4 SO23 XXV-4.13, " Condenser Evacuation System Loop 2/3RT-7818 Channel Calibration," Revision 0 SO23-XXV-4.14, " Containment Purge / Plant Vent Stack Wide Range Gas Monitoring System Loop 3RT-7865-1 Channel Functional Test," Revision 3 SO23-XXV-4,16, " Liquid Radwaste Effluent Line Loop 2/3RT-7813 Channel Functional Test," Revision 1 SO23-XXV-4.17, " Liquid Radwaste Effluent Line Loop 2/3RT-7813 Channel Calibration," Revision 2 i ]
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SO23-XXV-4.18, " Plant Vent Stack / Waste Gas Holdup System Loop 2/3RT-7808 Channel Functional Test," Revision 2 SO23-XXV-4.22, " Neutralization Sump Discharge Radiation Monitor Loop 2/3RT-7817 Ch m si Calibration," Revision 2 SO23-XXV-4.23, " Turbine Plant Area Sump Radiation Monitor Loop 2/3RT-7821 Channel l l Calibration," Revision 4 I l SO23-XXV-4.36, " Steam Jet Air Ejector Wide Range Gas Monitoring System Loop l 2/3RT-7870-1 Channel Functional Test," Revision 2 SO23-XXV-4.42, " Turbine Plant Area Sump Radiation Idonitor Loop 2/3RT-7821 Channel Functional Test," Revision 5 SO23-XXV-4.43, " Neutralization Sump Discharge Radiation Monitor Loop 2/3RT-7817 Channel Functional Test," Revision 2 SO23 XXV-4.44, " Steam Generator (E089) Blowdown Bypass Effluent Line Radiation Monitor Loop 2/3RT-6753 Channel Calibration," Revision 1 SO23-XXV-4.50, " Containment Purge Stack Radiation Monitoring System Loop 2/3RT-7828 Channel Functional Test," Revision 2 SO23 XXV-4.51, " Containment Purge Stack Radiation Monitoring System Loop 2/3RT-7828 Channel Calibration," Revision 1 SO23-XXV-4.59, " Steam Generator (E088) Blowdown Bypass Effluent Line Radiatiori Monitor Loop 2/3RT-6759 Channel Functional Test," Revision 1 SO23-XXV-4.60, " Steam Generator (E089) B!owdown Bypass Effluent Line Radiation Monitor Loop 2/3RT-6753 Channel Functional Test," Revision 2 SO23-XXV-4.62, " Steam Generator (E088) Blowdown Bypass Effluent Line Radiation Monitor Loop 2/3RT-6759 Channel Functional Test," Revision 2 SO23-XXV-9.360, " Plant Vent Stack / Waste Gas Holdup System Loop 2/3RT-7808 Channel Calibration " Revision O ' SO23-XXV-9.464, " Containment Purge Stack Radiation Monitoring System Loop 2/3RT-7828 Channel Calibration," Revision 2 Instrumentation Procedures SO23 ll-8.489, "Radwaste Discharge Flow to Circulating Water Outf all 2/3FT-7643 Channel Functional Test," Revision 8
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SO23-il 8.489.1, "Radwaste Discharge Flow to Circulating Water Outfall 2/3FT-7643 Channel Calibration," Revision 2 SO23-ll a 464, " BPS Neutralization Sump Overboard Discharge Flow 2/3FT 3772 Channel Calibration," Revision 6 < i S02311-8.852, " BPS Neutre'ization Sump Overboard Discharge Flow 2/3FT-3772 Channel f
Functional Test," Revision 5 SO23-ll-8.597, " Waste Gas Holdup System Flow Rate Monitor Channel Functional Test," ) Revision 5 SO23-il 8.597.1,." Waste Gas Holdup System Flow Rate Monitor Channel Calibration," Revision 1 . S023-11-9.670, " Steam Generator (E088) and (EO89) Blowdown Flow 2FT-4055 and 3FT-4056 Channel Calibration," Revision 4 ' SO23-il 9.712, " Steam Generator (E088) and (E089) Blowdown Flow 2FT-4055 and 3FT-
4056 C6.nel Functional Test." Revision 1 Miscellaneous Documents Selected Liquid and Gaseous Radioactive Waste Effluent Batch Release Permits , Annual Radioactive Effluent Release Reports - 1994 and 1995 SO23-ODQ'4 "Offsite Dose Calculation Manual," Revision 29, dated July 31,1996 , . ,
l ., , ATTACHMENT 2 SUMMATION OF AIRBORNE EFFLUENT RELEASES 1992 1993 1994 1995 1996* Nuniber of Batch Releases 13*' 10** 2** 11** 7 Fission & Activation Products (Curies) 1405 1542 365 696 426 Total lodine-131 (Curies) g 2.30E-2 4.98 E-2 1.79E-3 4.76E-2 6.69 E-3 Particulates with Half-Lives > 8 days (Curies) g 4.91 E-4 1.85E-3 5.79E-4 4.76E-4 5.18E-3 Gross Alpha (Curies) l 4.86E-9 5.30E-6 3.06E-6 3.52E-6
Tritium (Curies) l 25.8 50.1 49.7 39.6 25.6 _ 1996 data is draft data.
- * Gas Decay Tank batch releases only; containment purges are considered continuous releases.
- * * Data was not available at the time of the inspection.
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.. - . ~ .. e..a , ATTACHMENT 3
SUMMATION OF LIQUID EFFLUENT RELEASES l 1992 1993 1994 1995 1996* Number of Batch Releases l 209 198 108 105
Fission & Activation 7.70E-2 2.94E-1 2.81 E-1 2.58E-1 1.28E-1 Products (Curies) l Tritium (Curies) 969 978 891 971 1451 Dissolved & Entrained 0.232 1.27 0.028 1.403 0.115 Noble Gases (Curies) Gross Alpha (Curies) l 3.38E-5 1.13 E-5
0
Waste Volume Released 1.31 E + 7 7.28E + 7 3.45E + 7 8.06E + 7
(liters) 1996 data is draft data.
- Data was not available at the time of the inspection.
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