IR 05000382/1982011
| ML20055C050 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/21/1982 |
| From: | Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20055C047 | List: |
| References | |
| 50-382-82-11, NUDOCS 8208100070 | |
| Download: ML20055C050 (26) | |
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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Report:
50-382/82-11 Docket:
50-382 Construction Permit CPPR-103 Licensee:
Louisiana Power and Light Company (LP&L)
142 Delaronde Street New Orleans, Louisiana 70174 Facility: Waterford-3 (WF-3)
Taft, Louisiana Inspection Conducted:
April 26-30, 1982 Inspector:
8/ A
//[E R. E. Baer, Radi4 tion p cialist Date '
Approved:
0 4LL h $t'ntAV, Wo?//fr Blaine Murray, Chief, Rhe'ilities Radiation Protection (Tate /
Section Inspection Summary Inspection on April 26-30, 1982 (Report 50-382/82-11)
Areas Inspected:
Routine, unannounced initial inspection of the licensee's radioactive waste program and transportation activities including:
organization; training; waste systems; instrumentation; audits, and procedures.
The inspection involved 64 onsite hours by one NRC inspector and the Chief, Facilities Radiation Protection Section.
Results:
No violations or deviations were identified.
Fourteen open items are discussed in paragraph 3.
8208100070 820712
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Persons Contacted Louisiana Power and Light Company
- D. B. Lester, Plant Manager
- J. A. Alleman, Assistant Plant Manager J. Barker, Instrumentation and Controls Consultant
- F. J. Drummond, Project Support Manager-Nuclear (Corporate)
J. G. Edwards, Nuclear Operator Supervisor
- R. Goodwin, Associate Engineer, Radiation Control (Corporate)
R. Hinson, Instrumentation and Controls - Staff Assistant
- K. R. Iyengar, Nuclear Power, Technical-Services Support Group
- R. W. Kenning, Health Physics Superintendent K. LeBlanc, Instrumentation and Controls-Maintenance Assistant Superintendent J. Lewis, Radiation Control Engineer (Corporate)
D. Lowe, Training Superviscr-Nuclear
- W. M. Morgan, Operational Quality Assurance T. Payne, Instrumentation and Controls Engineer
- W. N. Perry, Chemistry Engineer D. Rupert, Instrumentation and Controls Z. A. Sabri, Training Director-Nuclear L. Simon, Radwaste Engineer M. J. Wise, Technical Support Advisor R. L. York, Nuclear Auxiliary Operator Others L. Arnold, Startup Engineer, Combustion Engineering T. Earle, Startup Engineer, Combustion Engineering
- P. Psomas, Radwaste Engineer, TERA Corporation
- R. C. Snyder, Radwaste Engineer, TERA Corporation C. Spencer, Startup Engineer, Combustion Engineering
- G. L. Constable, NRC Senior Resident Inspector
- J. E. Cummins, NRC Senior Resident Inspector
- Denotes those present at the exit interview.
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Scope of Inspection The inspection covered an initial review of the licensee's liquid, solid, and gaseous radioactive waste programs and transportation activities.
3.
Open and Unresolved Items Identified During this Inspection (0 pen) Open Item (50-382/82-11/01):
Corporate Radwaste Organization - The licensee had not:
developed a corporate radwaste policy; developed position qualifications-and job descriptions; defined responsibilities and interface with the onsite radwaste department; or developed procedures governing activities.
See paragraph 4.a for additional details.
(0 pen) Open Item (50-382/82-11/02):
Station Radwaste Organization - The licensee had not:
developed a station radwaste policy; developed position qualifications and job descriptions; defined responsibilities and inter-face with the corporate organization; or developed procedures governing activities.
See paragraph 4.b for additional details.
(0 pen) Open Item (50-382/82-11/03):
Radwaste-Training Program - The licensee had not established a training program for radwaste personnel.
See paragraph 5 for additional details.
(0 pen) Open Item (50-382/82-11/04):
Personnel Selection and Qualification Criteria - The licensee had not established minimum selection and qualifi-cation criteria for personnel involved with radwaste and transportation activities.
See paragraph 6 for details.
(0 pen) Open item (50-382/82-11/05):
Liquid Waste Management - The licensee had not:
developed preoperation test procedures; developed surveillance and calibration procedures; defina calibration standards; or corrected identified problem areas.
See paragraph 7.a for additional details.
(0 pen) Open Item (50-382/82-11/06):
Gaseous Waste Management - The licensee had not:
developed preoperation test procedures; developed surveillance and calibration procedures; defined calibration standards; or corrected identified problem areas.
See paragraph 7.b for additional details.
(0 pen) Open Item (50-382/82-11/07):
Control of Effluent Releases - The licensee had not developed a program for controlling the release of gaseous and liquid effluents.
See paragraph 8 for details.
(0 pen) Open Item (50-382/82-11/08):
Solid Waste Management - The licensee had not:
completed system performance tests; corrected identified problem
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areas; or provided an acceptable waste storage area.
See paragraph 9 for additional details.
(0 pen) Open Item (50-382/82-11/09):
Air Cleaning Systems - The licensee had not:
developed filter system test procedures; or tested all air cleaning systems.
See paragraph 10 for additional details.
(0 pen) Open Item (50-382/82-11/10):
Instrumentation - The ' licensee had not:
defined responsibility for process, effluent and area radiation monitors; defined calibration standards; developed system startup pro-cedures; or developed functional test and calibration procedures.
See paragraph 11 for details.
(0 pen) Open Item (50-382/82-11/11):
Technical Specifications - Technical Specifications covering radwaste and transportation activities had not been developed.
See paragraph 12 for details.
(0 pen) Open Item (50-382/82-11/12):
Transportation Activities - The licensee had not:
defined responsibility; developed procedures; developed training programs; or established audits for transport activities.
See paragraph 13 for additional details.
(0 pen) Open Item (50-382/82-11/13):
Audit and Review Program - The licensee had not developed an audit and review program for: waste handling, storage, and transportation; operation of liquid, gaseous and solid systems; control of effluent releases; effluent, process and area radiation monitor calibration and operation; air cleaning systems; and radiological effluent technical specification items.
See paragraph 14 for additional details.
(0 pen) Open Item (50-382/82-11/14):
Procedures - The licensee had not completed all procedures necessary to implement a radwaste or transporta-tion program.
See paragraph 15 for additional details.
4.
Radioactive Waste Management Organization The inspectors examined the licensee's corporate and onsite organizations regarding radioactive waste management to determine compliance with the Final Safety Analysis Report (FSAR) commitments.
Documents Reviewed FSAR Chapter 13, " Organizational Structure of Applicant"
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Job Description for "Radwaste Department Head Engineer - Nuclear"
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(Draft), dated March 29, 1982
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Job Description, " Waste Management Associate Engineer - Nuclear"
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(Draft), April 15, 1982 Job Description, " Waste Management Transportation Engineer Utility
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Engineer - Nuclear" (Draft), April 15, 1982 i
Job Description, " Waste Management Process Control-Engineer Associate
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Engireer 11/1 - Nuclear (Draft), April 15, 1982 Job Description, " Solidification Operator Radwaste Operator-Nuclear"
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(Draft), April 15, 1982
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Job Description, "Radwaste Operator-Nuclear" (Draft), April 15, 1982 Job Description, "Radwaste Helper-Nuclear" (Draft), April 15,
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Corporate Radioactive Waste Management Organization The management of radioactive waste activities within the Louisiana Power and Light (LP&L) Corporate organization had been assigned to the Corporate Radiation Control organization for Waterford-3.
The following chart depicts thc Corporate organization.
Nuclear Operations V P. Nuclear Ops. _
u Nuclear Proj. fupport Proj. Support Manager
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Eng. Supv. Nuclear
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The Radiation Control Engineer had tentatively assigned the following responsibilities to the Exposure Control and Laboratory Service groups:
Exposure Control Group As Low As Reasonably Achievable (ALARA) program Design reviews Radioactive waste Respiratory protection Exposure control Emergency Plan Contracts administration Equipment evaluations Vendor files Procedure review Appraisals and audits Special Projects Institute of Nuclear Power Operations (INPO) and American Nuclear Insurers (ANI) criteria NRC exposure reports NRC monthly operating reports NRC bulletin, circular, and notice review Other plant information Review and prepare Licensee Event Reports (1.ERs)
Maintain Health Physics Manual Laboratory Service Group External and internal dosimetry program Radiological effluent technical specifications Environmental program Counting room (site)
Counting room (Corporate office)
Byproduct licenses Procedure reviews Appraisals and audits Training interface Special Projects NRC effluent reports Equipment evaluations Regulations (review and comment)
Licensing activities support NRC bulletin, circular, and notice review Other plant information Review and prepare LERs
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The Corporate Radiation Control Engineer had assigned a utility Engineer-Nuclear the responsibility of Corporate Radwaste Coordinator.
The duties of the Corporate Radwaste Coordinator will include the audit / review function of the onsite Radwaste Department and radioactive waste transportation activities, review of process systems for equipment operation and volume reduction, and the review of station radwaste procedures.
A corporate radwaste policy state-ment was being developed.
There was no position qualification or job description available for the Corporate Radwaste Coordinator.
This item is considered open (82-11/01) pending:
Completion of Corporate Radwaste Policy Statement.
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Development of position qualifications and job description.
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Define the responsibilities and interface with the onsite
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radwaste department.
Development of procedures governing activities within the
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assigned area of responsibility.
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Onsite Radioactive Waste Management Organization The following chart shows the existing station management organi-zation as it pertains to Radwaste Department activities.
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Plant Manager-Nucleari AssistantPlanyManager-Nuclear Technical Support Superintendent-i
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Chemistry PlantEndineering!
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(1) Engineer-Nuclear (1) Eng. Tech-Nuclear (5)
Helper
- The numbers in parentheses denote the staffing authorized.
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The responsibilities for implementing various aspects of the Radio-active Waste Program were assigned to various departments including radwaste, chemistry, health physics, operations, and maintenance.
No individual had been assigned the overall responsibility for coordi-nating the radioactive waste program.
The Radwaste Engineer - Nuclear will be responsible for solid waste management including resin solidification, waste compaction, storage, and transportation activities. Operations department will be responsible for liquid and gaseous waste management.
The inspectors are concerned regarding the present onsite management organization, approved job descriptions, qualification requirements, and implementing procedures for functional area assignment have not been completed.
The Radwaste Engineer-Nuclear was the only job position filled in the proposed organizational structure.
The functional area assignment or scope of radwaste personnel involvement in the overall radioactive waste management program was not defined.
The inspectors were unable to determine the adequacy of the radwaste department staffing from the limited information available.
This item is considered open (82-11/02) pending:
Completion of a station radwaste policy statement.
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Development of job descriptions.
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Define the responsibilities and interface with the Corporate
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Radwaste Organization.
Development of procedures governing activities within the assigned
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area of responsibility.
5.
Radioactive Waste Management Training Program The inspectors reviewed the licensee's radioactive waste training program to determine compliance with FSAR commitments,10 CFR 19.12 requirements, and the recommendations of ANSI /ANS 55.1-1979, 55.4-1979, 55.6-1979, NUREG-0761, and Regulatory Guide 8.8 and 8.10.
Documents Reviewed PMD-TR-002, " Program Description for General Employee Training"
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PMD-TR-006, " Program Description for Non-Licensed Operator Training,"
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Revision 0, February 17, 1982 PMD-TR-009, " Program Description for Nuclear Training Group
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Organization" (Draft), Revision 0
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PMD-TR-010, " Program Description for Nuclear Operations Department
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Training Program" (Draft), Revision 0
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PMD-TR-021, " Program Description for Health Physics Training" (Draft),
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Revision 0 PMD-TR-028, " Program Description for Chemistry Training" (Draf t),
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Revision 0, January 7,1982 UNT-3-002, " Administrative Procedure for Training Records and Forms"
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(Draft 1), Revision 1 At the time of this inspection the Nuclear Training Division was being reorganized.
As such, the roles and responsibilities for the Corporate Nuclear Training Division and the onsite Radwaste Department concerning training activities had not been established.
The inspectors discussed the proposed training programs for radioactive waste personnel with the Training Director-Nuclear. A con-sultant (TERA Corporation) has been contracted to furnish the essential elements of a training program by June 1982, and the complete training program should be available for review by mid-July 1982.
It was expected the training program would be implemented.in August 1982.
Training will be performed by instructors from the Nuclear Training Division or con-tractor supplied.
Due to the absence of official program objectives and lesson plans; the inspectors did not investigate further.
i This item is considered open (82-11/03) pending implementation of a training program for Radioactive Waste and Transportation activities.
6.
Personnel Selection and Qualification Criteria
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The licensee had not established minimum qualification criteria for personnel responsible for radwaste and transportation activities.
The inspectors were concerned that criteria had not been established to ensure that properly trained and qualified personnel are assigned for the above activities.
This item is considered open (82-11/04) pending the development of selection and qualification criteria.
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Radioactive Waste Management The inspectors reviewed selected portions of the licensee's Radioactive Waste Management Program with respect to FSAR Chapter ll, " Radio-active Waste Management"; Chapter 12, " Radiation Protection"; Chapter 13,
" Conduct of Operations"; and Chapter 14, " Initial Tests and Operations."
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Liquid Radioactive Waste System Documents Reviewed System Description No. SD-28-0, " Liquid Waste Management System"
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System Description (Draft), " Boron Management System"
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Procedure No. OP-7-001, " Operating Procedure Boron Management,"
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Revision 0, January 25, 1982 Procedure No. OP-7-005, " Operating Procedure Resin Waste
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Management," Revision 0, December 31, 1981 Procedure No. OP-901-025, "Off-Normal Operating Procedure Liquid
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Waste Discharge High Radiation," Revision 0, December 9, 1981 Procedure No. OP-903-080, " Surveillance Procedure Liquid Waste
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Management System Operability Test," Revision 0, January 22, 1982 ALARA Design Review of the Waterford-3 Steam Electric Station,
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dated March 1982, performed by TERA Corporation The inspectors reviewed the licensee's liquid waste management system to determine compliance with FSAR commitments, the recommen-dations of ANSI-55.6-1979, N323-1978, and Inspection and Enforcement Bulletin 80-10.
The inspectors' review of this area indicated that the licensee is in the process of completing construction of this system.
Preoperation and system acceptance test procedures are projected to De completed about mid-October 1982.
Verification by visual inspection indicated that the major components of the liquid waste system, as described in Section 11 of the FSAR, were installed.
The inspectors noted some sample lines and sample recirculation lines passed through uncontrolled areas and normally occupied areas within the licensee's Radiation Controlled Area (RCA).
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The inspectors also noted that this liquid radioactive waste system was not consistent with the recommendations of ANSI-55.6-1979.
The following areas were observed which did not meet the standard:
Oil Separator Filter Cubicle - Ventilation lines discharged to
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cubicle; manually operated valves were located inside cubicle; and opening for reach rods was not provided for in the. shield wall.
Waste Condensate Ion Exchanger Cubicle - No platform and ladder
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were provided for access to valves located above the ion ex-changer; some valves near the floor were difficult to access.
Boric Acid Condensate Tanks and Pump Area - Manually operated
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valves were located near the ceiling; no reach rods or mechnical means were provided for valve operation; the area was not provided with a means to contain or collect leakage from pumps.
Fuel Pool Heat Exchanger Cubicle - No provisions have been made
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for routing vents or drains to the floor drains.
Regenerative Health Exchanger - There was no labyrinth or other
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means to provide shielding from the regenerative heat exchanger to the normal walkway at the doorway to the cubicle.
Holdup Tank "A" - The access to Holdup Tank "A" has been re-
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stricted by piping routed through the labyrinth at the entrance to the room; the ladder and platform for access to valves over Tank "A" are opposite the room entrance; no means for accessing the tank upper had been provided.
Holdup Drain Pump - No provisions have been made to flush the
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sample line prior to obtaining a sample; access to the area has been restricted by instrument lines and conduit.
The inspectors spent a limited amount of time. reviewing the liquid radioactive waste system.
The licensee commissioned the TERA Corpor-ation in early 1982 to provide an ALARA review of the system.
This report details numerous deviations from the recommendations of ANSI 55.6-1979.
The licensee should corrrect these identified deviations to have an acceptable liquid radioactive waste system.
The licensee commissioned EBASCO Services Incorporated to review Waterford-3 plant systems as recommended in IE Bulletin 80-10.
The inspectors noted that the review was not complete.
Systems and
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interfaces have been identified where contamination of nonradioactive systems could result.
The licensee had not reviewed operating procedures and identified valving errors or operating conditions which could result in the contamination of a nonradioactive system or established a routine sampling / analysis or monitoring program for these systems as required by the Bulletin.
The licensee had not verified that tank volumes for all tanks listed in the proposed Technical Specifications were correct developed procedures for or verified the flow rates used to determine volume releases; or verified that reorders were properly calibrated for the liquid radioactive waste system.
This item is considered open (82-11/05) pending:
Completion of preoperational test procedures.
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Completion of surveillance and calibration procedures.
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Calibration of Liquid Radiation Monitors with Liquid
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Radioactive Standards.
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Correction of identified problem areas in TERA Corporation ALARA Review.
Developed a sampling program for compliance with IE
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Review operating procedures for valving errors or operating
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conditions which could contaminate a nonradioactive system.
Verification of tank volumes, discharge flow rates and recorder
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readings.
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Gaseous Radioactive Waste System Documents Reviewed
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Procedure No. OP-7-003, " Operating Procedure Gaseous Waste Management," Revision 0, December 9, 1981 Procedure No. OP-901-026, "Off-Normal Operating Procedure Waste
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Gas Discharge High Radiation," Revision 0, November 11, 1981 Procedure No. OP-903-081, " Surveillance Procedure Gaseous Waste
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M&nagement System Operability Check," Revision 0, April 1,1992
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ALARA Design Review of the Waterford-3 Steam Electric Station,
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dated March 1982, prepared by TERA Corporation.
Preoperational Test SP0-55A-001, " Gaseous Waste Management
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System," Revision 0, September 3, 1981 The inspectors reviewed the licensee's gaseous waste system to determine compliance with FSAR commitments and the recommendations of ANSI-55.4-1979 and ANSI-N323-1978.
The inspectors' review of the gaseous radioactive waste system in-dicated that the licensee is in the process of completing con-struction of the system.
Preoperational test procedures were complete and performance tests were scheduled for mid-August 1982.
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Verification by visual inspection indicated that the major components as described in Section 11 of the FSAR were installed.
The inspectors noted that gaseous radioactive waste system was not consistent with the recommendations of ANSI-55.4-1979.
The following areas were observed which did not meet the standard:
Waste Gas Compressor "A" - Manual valves were located inside
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this cubicle, no remote operated valves or reach rods were used.
Waste Gas Compressor "B" - Manual valves were located inside
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this cubicle, no remote operated valves or reach rods were used.
Waste Gas Surge Tank Room - Sample isolation valves were located
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above the tank, no ladder or platform was provided for access to valves.
Wasta Gas Decay Tank "A" - Sample isolation valves were located
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above the tank; lighting was minimal and fixture locations were inadequate for servicing; and drain lines contained 90 degree elbows.
Waste Gas Decay "B" - Sample isolation valves were located above
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the tank; lighting was minimal and fixture locations were inadequate for servicing; and drain lines contained 90 degree elbows.
Waste Gas Decay "C" - Sample isolation valves were located above
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the tank; lighting was minimal and fixture locations were inadequate for servicing; and drain lines contained 90 degree elbows.
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Charging Pump "A" - Manual valves were used, no remote operators
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or reach rods were used on valves located in the cubicle; and discharge piping contained socket welds and 45 degree elbows.
Charging Pump "B" - Manual valves were used, no remote operators
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or reach rods were used on valves located in the cubicle; and discharge piping contained socket welds and 45 degree elbows.
No ladder or platform for access to heating, ventilation, air conditioning emergency equipment was provided.
The inspectors spent a limited amount of time reviewing the gaseous radioactive waste system.
The licensee commissioned the TERA Cor-poration in early 1982 to perform an ALARA review of this system.
This report details numerous deviations from the recommendations of ANSI 55.4-1979.
The licensee should correct those identified to have-an acceptable gaseous Radioactive Waste System.
The licensee had not verified that tank volumes were correct, developed procedares for or verified the flow rates used to determine volume releases, or verified that reorders were properly calibr:ted.
The inspectors reviewed the effluent and process radiation monitors including operability checks, calibration procedures, and method of calibration.
Gaseous radioactivity monitors should be calibrated in the same medium in which they will be used.
No radiation monitoring systems were installed or calibration data available during this inspection.
This item is considered open (82-11/06) pending:
Completion of surveillance and calibration procedures.
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Calibration of gaseous radiation monitors with gaseous Radio-
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active Standards.
Correction of identified problem areas in TERA Corporation ALARA
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Review.
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Verification of tank volumes, discharge flow rates and recorder
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readings.
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Controls for Effluent Releases The licensee had not established procedures for controlling liquid and gaseous releases.
The inspectors were-informed that the Radiation Pro-tection Group had been assigned the responsibility of developing the liquid and gaseous release permits.
The following items would be expected to be addressed in the release permit procedures:
Radiochemistry analyses results
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Technical specification limits
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Function tests of gas / liquid monitors
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Function tests of isolation valves
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Allowable release rate
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Dilution flow
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Valve line-up verified
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Total volume released
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Total activity released
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Authorization signatures
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This item is considered open (82-11/07) pending the development of effluent release procedures.
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Solid Radioactive Waste System Documents Reviewed Procedure No. OP-7-006, " Operating Procedure Solid Waste Management,"
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Revision 0, January 22, 1982 Procedure No. HP-2-812, " Technical Procedure Receipt of Radioactive
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Material," Revision 0, December 9, 1981 Procedure No. HP-2-813, " Technical Procedure Radioactive Waste
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Handling," Revision 1 Procedure No. MM-4-810, " Maintenance Procedure Radwaste Cask Handling
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Crane PM," Revision 0, April 5, 1982
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Radwaste Handling and Storage Study of Waterford-3 SES, dated
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September 1981, prepared by Chem-Nuclear Systems, Incorporated Process Control Program for Waste Solidification (Draft), dated
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November 20, 1981, prepared by Charles Moore and Associates, Inc.
ALARA Design Review of the Waterford-3 Steam Electric Station, dated
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March 1982, prepared by TERA Corporation LP&L memorandum W3H82-0065, " Task 40 Radwaste Building," dated
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March 26, 1982 LP&L Memorandum W3Z82-0007, " Task 40 Conceptual Design Subject,"
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dated March 26, 1982 LP&L Memorandum W3Y82-0010, " Task 40 Review," dated April 15, 1982
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The inspectors reviewed the solid radioactive waste system to determina compliance with FSAR commitments and the recommendations ANSI /ANS 55.1-1979.
The inspector's review of the solid radioactive waste system indicated that the licensee is in the process of completing construction of the system.
Preoperational test procedures and performance tests were scheduled for completion by mid-October 1982.
The system was expected to be operational prior to fuel loading.
Verification by visual inspection indicated that the major components as described in Section 11 of the FSAR were installed.
The inspectors noted that the solid radioactive waste system was not consistent with the recommendations of ANSI /ANS-55.1-1979.
The following areas were observed which did not meet this standard:
The crane used to transfer solidified liners was not provided with
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remote controls.
The filter transfer monorail crane was not provided with remote
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controls.
The transfer cart requires personnel to enter the fill aisle for
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positioning change-out drum.
The filter cubicles lacked adequate lighting.
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The area designated for the waste compactor was located in a clean
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area.
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Ventilation in the compactor area was inadequate.
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Short radius elbows were used on the resin. transfer system piping.
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The resin tank safety valve is located after the resin screen.
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Boric acid and waste concentrations use manual valves and have
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no provisions to use reach rods.
The inspectors spent a limited amount of time reviewing the solid radioactive waste system.
The licensee commissioned Charles Moore and Associates, Inc.; Chem-Nuclear Systems, Inc; and TERA Cor-paration to review the solid waste system.
Numerous deviations from the recommendations of ANSI /ANS-55.1-1979 were identified.
A licensee representative stated the entire solid radwaste system including spent resins and evaporator bottoms were under review.
A decision by the licensee on whether or not to modify the solid radio-active waste system will be made soon.
The licensee has undertaken a review, referred to as " TASK 40," for onsite storage of radioactive waste packages.
The licensee has committed, NUREG-0787, Section 11.2.3.3, to increase the space available for storage of solidified and compacted waste.
This item is considered open (82-11/08) pending:
Completion of system performance tests and correction of identi-
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fied problem areas Completion of the radioactive waste storage area
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10.
Air Cleaning Systems The inspectors reviewed the licensee's air filtration systems to determine compliance with FSAR commitments, and the recommendations of ANSI-N509-1980, N510-1980, and Regulatory Guides 1.140 and 1.52.
Documents Reviewed FSAR Chapter 9.4, " Air Conditioning, Heating, Cooling, and Ventil-
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ation Systems."
Procedure No. MM-6-009, " Maintenance Procedure Prefilter and HEPA
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Filter Removal and Replacement," Revision 0, January 19, 1982
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Procedure No. FN-6-016, " Maintenance Procedure HEPA Adsorber Filter
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Unit Fill and Drain," Revision 0, January 22, 1982 Procedure No. MM-6-017, " Maintenance Procedure HEPA adsorber test
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canister removal, fill, and installation," Revision 0, January 7, 1982 The inspectors reviewed the licensee's testing requirements for all air cleaning systems which contained high efficiency particulate air (HEPA)
filters and activated charcoal adsorber beds for the removal of airborne radioactivity.
ANSI-N510-1980 recommends a series of inspections and
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tests and specifies minimum requirements for reporting of test results.
These inspections and tests are needed to establish that airflow and airflow characteristics are adequate to achieve the desired air cleaning function, that there are no bypasses or leaks which could compromise the desired function, and that components have been installed properly and are in good working order.
The recommended inspections and tests needed for acceptance of a system are:
visual inspection; duct and housing leak test; mounting frame l
pressure leak test; airflow capacity and distribution test; air-aerosol mining uniformity test; in place leak test, HEPA filters; in place leak test, adsorbers; laboratory testing ot' adsorbent; and duct heater perform-
ance test.
There are five air filtration systems which use HEPA filters and activated charcoal adsorber beds.
These systems: control room air conditioning system; fuel handling building ventilation system; reactor building ventilation system; reactor auxiliary building (RAB) ventilation system; and RAB hot machine shop and decontamination area ventillation system, were not complete at the time of this inspection.
The licensee stated that no air filtration system test procedures had been
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developed for in place filter or charcoal filter testing.
A generic filter test procedure would be developed by August 1982.
The filter and charcoal systems would be installed and tested by a contractor, supervised by licensee startup personnel.
Installation and testing will conform to ANSI-N509-1980, and N510-1980 standards, and that tests would be performed
I on all air filtration system trains.
The inspectors indicated the air cleaning system program would be reviewed during a subsequent inspection.
This. item is considered open (82-11/09) pending:
Completion of filter system test procedures,
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Completion of iodine removal efficiency tests on charcoal adsorber
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beds.
Completion of duct and housing leak test.
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Completion of airflow capacity, distribution, and residence time
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tests.
Completion of testing and air filtration trains
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11.
Radiation Monitoring Instrumentation The inspectors reviewed the licensee's in plant radiation monitoring systems.
This included area radiation monitors, process radiation monitors, and plant effluent monitors (including NUREG-0737 monitors).
This review indicated no process or effluent monitoring instrumentation and a limited number of the area radiation monitoring instruments were installed.
These area radiation monitoring instruments were not opera-tional.
The inspectors were unable, from the status of installed equip-ment, to determine whether installation would be in agreement with the FSAR and NUREG-0737 or the recommendation of applicable ANSI standards.
Documents Reviewed FSAR Chapter ll, " Radioactive Waste Management."
a.
Area Radiation Monitoring System The area radiation monitoring system should conform to ANSI /ANS-6.8.1-1981, " Location and Design Criteria for Area Radiation Monitoring Systems for Light Water Nuclear Reactors," for detector range; primary and secondary calibration; and alarm and indication recommend-ations.
b.
Process Radiation Monitoring System The Process Radiation Monitors should conform to ANSI-N13.1-1969,
" Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities"; ANSI-N323-1978, " Radiation Protection Instrumentation Test and Calibration"; ANSI /ANS-55.6-1979, " Liquid Radioactive Waste Processing System for Light Water Reactor Plants"; and ANSI /ANS-55.4-1979, "Gascous Radioactive Waste Processing Systems for Light Water Reactor Plants."
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c.
Effluent Radioactivity Monitoring System The effluent radioactivity monitors should conform to ANSI-N13.10-1974, " Specification and Performance of Onsite Instrumentation for Continuously Monitoring Radioactivity in Effluents," ANSI-N13.1-1969, and ANSI-N323-1978 mentioned above.
This item is considered open (82-11/10) pending:
Defined responsibility for Gulf-General Atomics process monitor-
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ing system.
Determine effluent monitor calibration sources.
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Completion of area radiation monitoring startup procedure.
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Completion of area radiation monitoring system operating pro-
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cedure.
Completion of area radiation monitoring system calibration
.
procedure.
Completion of " Process Radiation Monitoring System" operating
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procedure.
Completion of " Process Radiation Monitoring System" functional
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test procedures.
Completion of " Process Radiation Monitoring System" calibration
.
procedure.
12.
Technical Specifications The Technical Specifications. covering radwaste and transportation activities have not been established.
The item is considered open (82-11/11) pending review of the proposed Technical Specifications.
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13.
Transportation Activities The inspectors reviewed the licensee transportation activities to deter-mine compliance with 10 CFR Parts 20, 71, and 49 CFR Regulatory require-ments.
The inspectors were interested in the management-controlled program for ensuring safety. in the receipt, packaging, delivery to a carrier, and transport of licensed radioactive material.
It was noted that:
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No solid radioactive waste handling, storage, and transportation
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program (including quality assurance audit program) had been -
established.
No individual or organization was designated responsible for trans-
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port activities.
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Duties.and authority of the responsible individual and organization
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were not identified.
Written procedures for the various processes and details of the
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transport activities were not written.
A documented program for indoctrination and training of persons
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performing transport activities was not established.
A documented program of audits to verify compliance and determine the
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effectiveness of the transport activities were not established.
Thisitemis-consideredopen(82-11/12) pending:
Designation of a department and an individual specifically i
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responsible for transportation activities.
Development of written procedures.
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Establishment of a training program.
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I Establishment of an audit program.
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14. Audits and Review The inspectors reviewed the licensee's internal audit / review program regarding radioactive waste and transportation activities to determine
,
!
compliance with FSAR commitments, the requirements of 10 CFR 50, Appendix B, I
and the recommendations of ANSI N18.7-1976, Regulatory Guide 1.33,
!
1.144, 1.146, and 4.15.
Documents Reviewed t
Safety Evaluation Report (NUREG-0787) Waterford Unit No. 3
.
LP&L Quality Assurance Manual
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The inspectors were specifically interested in the existence of l
audit / review programs and the scope of these programs.for the following areas:
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Reviews performed by supervision within the Radwaste Department of
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such activities as staff effectiveness work practices, adequacy of training, and procedural compliance.
Reviews performed by the onsite Operational Quality Assurance (QA)
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Department in the areas of low-level radioactive waste transfer, packaging, and transport activities.
Reviews performed by the onsite QA Department in the areas of opera-
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tion of liquid, gaseous, and solid waste systems, including the control measures used for liquid and gaseous effluent releases.
Reviews performed by the onsite QA Department in the areas of instru-
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ment operation and calibration for all effluent, process, and area radiation monitors.
Reviews performed by the onsite QA Department in the area of air
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cleaning system testing and operation.
Corporate audits / evaluations to ensure compliance with Technical
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5pecifications, Code of Federal Regulations, and stated objectives.
Audit / review format, including the existence of audit procedures and
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checklists, to provide an insight regarding the adequacy and scope of proposed audit / review activities.
The composition of audit / review teams to ensure that team members
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possess the necessary expertise to properly evaluate the assigned areas.
A corrective action program for timely resolution of identified
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deficiencies.
The licensee stated that a detailed audit / review program covering the above items had not been developed. According to the licensee, it is their intention to review the requirements and develop and implement a comprehensive audit / review program.
This item is considered open (82-11/13) pending the implementation of an audit / review program for Radioactive Waste Management.
15.
Procedures The inspectors reviewed the licensee's procedures to determine compliance with 10 CFR 20, 10 CFR 71, 49 CFR 100-199 requirements, and recommend-ations contained in Regulatory Guides 1.33, 4.15, 8.8, 8.10; and ANSI N13.1-1969, N13.10-1974, 55.1-1979, N101.1-1972, N199-1976, N323-1978, N510-1975, and NUREG-0761.
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For documentation purposes, in this report, the licensee's procedures have been classified as either:
(1) approved procedures that appear to be satisfactory, (2) procedures in draft form, and (3) procedures not identi-fled which need to be written. All procedural findings will appear under one open item.
The inspectors were concerned about the large number of procedures which were not completed at the time of this inspection.
a.
Approved Procedures that Appear to be Satisfactory OP-7-001, " Boron Management," Revision 0
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OP-7-003, " Gaseous Waste Management," Revision 0
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OP-7-004, " Liquid Waste Management System," Revision 0
.
OP-7-005, " Resin Waste Management," Revision 0
.
OP-7-006, " Solid Waste Management System," Revision 0
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OP-901-025, " Liquid Waste Discharge High Radiation," Revision 0
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OP-901-026, " Waste Gas Discharge High Radiation," Revision 0
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OP-903-080, " Liquid Waste Management System Operability Test,"
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Revision 0 OP-903-081, " Gaseous Waste Managment System Operability Check,"
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Revision 0 HP-2-812, " Receipt of Radioactive Material," Revision 0
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HP-2-813, " Radioactive Waste Handling," Revision 0
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MM-4-810, "Radwaste Cask Handling Crane PM," Revision 0
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MM-6-009, "Prefilter and HEPA filter removal and replacement,"
.
Revision 0 MM-6-016, "HEPA Adsorber filter unit fill and drain," Revision 0
.
MM-6-017, "HEPA adsorber test canister removal, fill, and
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installation," Revision 0
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b, Procedures in Draft Form OP-4-001, " Area Radiation Monitoring System"
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OP-4-013, " Process Radiation Monitoring System"
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OP-903-019, " Radioactive Liquid Effluent Monitoring System
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Source Check" OP-903-021, " Radioactive Gaseous Process and Effluent
.
Monitoring System Source Check" OP-903-080, " Liquid Waste Management System Operability Check"
.
OP-903-082, " Solid Waste Management System Operability Check"
.
MI-3-350, " Containment Purge Isolation Area Radiation Monitor
.
Safety Channel "A" Functional Test" MI-3-351, " Containment Purge Isolation Area Radiation Monitor
.
Safety Channel "B" Functional Test" MI-3-352, " Containment Purge Isolation Area Radiation Monitor
.
Safety Channel "A" Calibration" MI-3-353, " Containment Purge Isolation Area Radiation Monitor
.
Safety Channel "B" Calibration" MI-3-354, " Containment Area Radiation Monitor Safety Channel
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"A" Calibration" MI-3-355, " Containment Area Radiation Monitor Safety Channel
.
"B" Calibration" MI-3-356, " Full Handling Building Airborne Isolation Radiation
.
Monitor Safety Channel "A" Functional Test" MI-3-357, " Fuel Handling Building Airborne Isolation Radiation
.
Monitor Safety Channel "B" Functional Test"
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MI-3-358, " Fuel Handling Building Airborne Isolation Radiation
.
Monitor Safety Channel "A" Calibration" MI-3-359, " Fuel Handling Building Airborne Isolation Radiation
.
Monitor Safety Channel "B" Calibration" MI-3-360, " Control Room Airborne Radiation Monitor Safety
.
Channel "A" Functional Test"
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MI-3-361, " Control Room Airborne Radiation Monitor Safety
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Channel "B" Functional Test" MI-3-362, " Control Room Airborne Radiation Monitor Safety
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Channel "A" Calibration"
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i MI-3-363, " Control Room Airborne Radiation Monitor Safety
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Channel "B" Calibration" i
MI-3-364, " Containment Atmospheric Particulate and Gaseous
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Monitor Safety Channel "A" Functional Test"
,
MI-3-365, " Containment Atmospheric Particulate and Gaseous
.
Monitor Safety Channel "A" Calibration" MI-3-381, " Radioactive Liquid Effluent Monitoring Instrument
.
Channel Calibration" MI-3-382, " Radioactive Liquid Effluent Monitor Instrumentation
.
Channel Functional Test"
,
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MI-3-383, " Radioactive Gaseous Effluent Monitoring
.
Instrumentation Channel Calibration" MI-3-384, " Radioactive Gaseous Effluent Monitoring
.
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Instrumentation Channel Functional Test" MI-5-603, " Waste Gas Flow Loop Calibration"
.
MI-5-604, " Liquid Waste Discharge Flow Loop Calibration"
.
HP-1-231, " Radiological Effluent Release Report"
.
CE-1-901, " Testing and Maintenance'of Post Accident Sample
.
Systems" CE-2-016, " Monitoring Gaseous Waste Management"
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t CE-2-018, " Monitoring Liquid Waste Management"
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CE-3-305, " Sampling of Ventilation and Gaseous Waste Management
.
Systems for Radioactive Effluents" I
CE-3-703, " Tank Sampling Recirculation Times"
.
CE-3-900, " Operation of the Post Accident Sampling System"
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CE-3-901, " Post Accident Sampling of Containment Atmosphere"
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PE-5-003, " Shield Building Ventilation System Surveillance"
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PE-5-004, " Control Room Ventilation System Surveillance"
.
PE-5-005, " Controlled Area Ventilation System Surveillance"
.
PE-5-006, " Fuel Handling Building Ventilation System Surveil-
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lance"
"
c.
Procedures Not Identified Which Need to be Written The inspectors noted that procedures for following areas had not been identified by the licensee to be written:
Gas Release Permit
.
Liquid Release Permit
.
Shipping Gf Radioactive Materials
.
Cask Handling Procedures
.
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Process Radiation Monitoring Instrumentation Functional Test
.
Process Radiation Monitoring Instrumentation Calibration
.
Ventilation Systems Calibrations
.
High Efficiency Particulate Air Filter In-Place Leak Testing
.
This item is considered open (82-11/14) pending:
.
Completion of procedures referenced in Section 14.b of this report Licensee evaluation and completion of procedures referenced in
.
Section 14.c of this report.
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15.
Exit Interview The inspectors met with licensee representatives identified in parsgraph 1 at the conclusion of the inspection.
The inspectors discussed the scope and findings of the inspection.
The inspectors stated that open items identified in this report must be resolved before issuance of an operating license.
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