IR 05000395/1999006
| ML20217F935 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/08/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20217F889 | List: |
| References | |
| 50-395-99-06, NUDOCS 9910210127 | |
| Download: ML20217F935 (24) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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Docket No.: 50-395 License No.: . NPF-12 .
Report No.: 50-395/99-06-Licensee: South Carolina Electric & Gas (SCE&G)
Facility: Virgil C. Summer Nuclear Station Location: P. O. Box 88 Jenkinsville, SC 29065 Dates: August 1 - September 11,1999 Inspectors: M. Widmann, Senior Resident inspector M. King, Resident inspector '
M. Scott, Reactor Inspector, Ril (Section F1.1)
G. Kuzo, Senior Radiation Specialist, Rll (Sections R1.1, R1.2, R2.1, R2.2, R3.1, and R7.1)
W. Smith, Radiation Specialist (in training), Ril (Sections R1.1, R1.2, R2.1, R2.2, R3.1, and R7.1) -
Approved by: R. C. Haag, Chief, Reactor Projects Branch 5 Division of Reactor Projects I
Enclosure 9910210127 991008 PDR l
8 ADOCK 05000395 PDR
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EXECUTIVE SUMMARY Virgil C. Summer Nuclear Station NRC Inspection Report No. 50-395/99-06 This integrated inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a six-week period of resident inspection; in addition, it includes the results of announced inspection by two regional radiation specialists and a regional reactor inspecto Operations
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A walkdown of the Control Room Evacuation Panel (CREP) and related support systems, discussions with a control room shift supervisor on the performance of CREP procedures, and a review of training indicated the licensee is maintaining the capability to shutdown the plant from locations outside the control room in accordance with General Design Criteria 19 of 10 CFR 50, Appendix A (Section O2.1).
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A one-hour notification per 10 CFR 50.72 was not made upon discovery that the service water pond siphon breakers would not perform their intended function and that the service water pond minimum water level could not be assured. The blind flanges were promptly removed which restored the function of the siphon breakers. Additional NRC review of the reportability of this issue is pending (Section 07.1).
Maintenance
- The inspectors concluded that routine maintenance and surveillance activities were satisfactorily performed and documentation reviewed met established acceptance criteria (Section M1.1).
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Modifications to the circulating water / service water crosstie pipe were well planned and the associated instructions included appropriate precautions to ensure continued fire suppression water was available. The engineer technical work records and 10 CFR 50.59 safety evaluation reviews were detailed and technically adequate. Good oversight of contractor personnel was noted. The equipment setup for the temporary fire service pumps and installation testing were well controlled and implemented in accordance with the work instructions (Section M1.2).
Enaineerina 4 ;
- Blank flanges were discovered on siphon breakers for the 36-inch diameter pipe connecting the service water (SW) pond (ultimate heat sink) with the Monticello I Reservoir. This resulted in the siphon breakers being unable to perform their design function and would have resulted in lower SW pond level than previously assumed for a loss of reservoir event. Additional NRC review of this issue is pending (Section E1.1).
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Westinghouse discovered an error in the computer code (LOCBART) used for the Summer large break LOCA analysis and provided a re-analysis using an updated computer code. Licensee actions taken in response including the 10 CFR 50.59 Safety Evaluation and Core Operating Limits Report (COLR) revision appeared reasonable, appropriate and timely (Section E1.2).
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The licensee has implemented a new TS amendment to use BEACON as a core power distribution monitoring system to augment the moveable incore detectors for flux mapping activities. The inspectors concluded that the licensee's use of BEACON is an effective tool and should provide additional insight and understanding of core characteristics, and operational flexibility with less flux maps being required (Section E2.1).
Plant Support
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Radioactive effluent and waste processing systems and storage facilities met Final Safety Analysis Report and 10 CFR Part 50 requirements. Radiological controls for radioactive gaseous and liquid effluent storage and processing systems and areas, and for radioactive material / waste storage areas met technical specification (TS), and 10 CFR Part 20 requirements (Section R1.1).
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Chemistry and operations personnel demonstrated appropriate knowledge of procedural requirements, and proficiency in initiating and conducting liquid effluent release Licensee programs to control effluent releases were implemented effectively with effluent radionuclide concentrations and resultant projected offsite doses within established regulatory limits and design objectives (Section R1.2).
A non-cited violation was identified for failure to calibrate liquid radiation monitoring systems in accordance with vendor or accepted industry practices as required by10 CFR Part 20.1501(b) requirements. General area radiation monitoring system equipment was calibrated properly (Section R2.1).
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The radiological environmental monitoring program for airborne radionuclides and leafy vegetation, and monitoring of direct radiation was implemented in accordance with the
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Offsite Dose Calculation Manual (Section R2.2).
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The 1998 Annual Effluent Release Report and Annual Radiological Environmental Monitoring Report were submitted in accordance with TS and documented results demonstrated gaseous and liquid effluent processing and subsequent releases met established regulatory limits and Appendix I to 10 CFR 50 design objectives (Section R3.1).
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Routine chemistry sampling of the reactor coolant system was conducted in accordance with written procedures with satisfactory results. The chemistry technician was experienced and knowledgeable of his assigned task and used appropriate safety precautions and radiation control measures (Section R4.1).
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Counting-room quality control activities were implemented appropriately and verified the accuracy of radionuclide analytical measurement instrumentation (St ction R7.1).
An annual fire drill utilizing off site fire fighting assistance was performed satisfactoril The drill was adequately monitored and controlled. The inspectors identified a concern with the thoroughness of the original critique process not capturing lessons leamed from the annual fire drill. The inspectors' concems were captured in the critique documentation for follow-up action following discussions with the licensee (Section F1.1).
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H l Report Details i
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Summary of Plant Status
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The unit operated at'approximately 100 percent power during the entire inspection perio . Operations I
01 Conduct of Operations 01.1 General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of operations was professional and safety-conscious; specific events and noteworthy observations are detailed in the sections belo O2 Operational Status of Facilities and Equipment O2.1 Enaineered Safety Feature System Walkdown a inspection Scope (71707)
The inspectors conducted a walk down of accessible portions of the Control Room Evacuation Panels (CREPs) and related support system l l Qbservations and Findinas The inspectors performed a walk down of the CREPs and related support systems. The CREP and related procedures ensure sufficient capability is available to permit shutdown of the reactor and maintain it in hot standby from locations outside the control room in accordance with General Design Criteria 19 of 10 CFR 50, Appendix A. The inspectors verified components were in their correct position, power was available where required and proper air conditionira and ventilation were being supplied to the CREP rooms. All i transfer switches were selected to the appropriate " remote" position. The inspectors l confirmed system configuration was consistent the Final Safety Analysis Report (FSAR)
description in Section 7.4, " Systems Required for Safe Shutdown." The surveillance requirements of Technical Specification (TS) 3.3.3.5, " Remote Shutdown Instrumentation," were verified to have been performed satisfactory during the previous year. Performance of TS surveillance per Table 4.3-6, " Remote Shutdown Monitoring l
Instrumentation Surveillance Requirements," demonstrated that each remote shutdown monitoring instrumentation channel was operable by completion of channel checks and l
calibration During the inspectors' walkdown and review of System Operating Procedure (SOP)-211
" Emergency Feedwater System," Revision 11, it was noted that the procedure instructed the operator to verify that the emergency feedwater (EFW) valvas to the steam generators were in the full open position. This verification prevides assurance that the EFW valves would be in the full open position if the CREP controls were taken to the
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" local" position. This verification was accomplished by verifying the valve demand L
position meter (0-100 percent) was indicating 100 percent open. However, the inspectors noted that the Hagan controller providing the input signal to the valve was isolated because the handswitch was in the " remote" position. Therefore, verification of the valve demand position meter was of no value. Actual valve demand position could be verified through the pot settings on the Hagan controllers. If an operator verified that the pots were set to the full counterclockwise position this would provide assurance that the valve when swapped to the " local" position would be in the full open position. After this observation was brought to the attention of the licensee, operations management stated that the prrcedure would be revised to have the operator verify the valve position by checking the r>ot settings. An additional observation by the inspectors noted that the normallighting ;n one of the CREP rooms was reduced due to degraded flourescent lights. The licensee was responsive to this observation and corrected the degraded lighting condition in a timely manne The inspectors examined the CREP emergency tool locker, which contains the essential tools, equipment, procedures and drawings to shutdown and control the plant from outside the control room. An inventory of the locker identified no discrepancie Required tools and updated procedures and drawings were verified to be present. A review of four control room evacuation procedures was performed with a Control Room Shift Supervisor (CRS). The CRS demonstrated an adequate knowledge of the duties each building operator is required to perform for an orderly transition from the control room to the CREP. Training of other personnel on the CREP and the associated i procedures were verified through discussions with training department personnel. This I review indicated continuing training occurred dJring Licensed Operator Requalification Cycle 97-10, conducted October 19 through November 20,1998, which had a simulation of a control room evacuation. The inspectors also reviewed the Job Performance Measures (JPMs) associated with the CREP panel and concluded these appropriately addressed the testing of duties associated with the performance of a control room evacuation. Several of these JPMs were included as part of the annual requalification examination conducted during the period of February 22 through March 26,199 I c. Conclusions A walkdown of the CREP and related support systems, discussions with a control room shift supervisor on the performance of CREP procedures, and a review of training ;
indicated the licensee is maintaining the capability to shutdown the plant from locations outside the control room in accordance with General Design Criteria 19 of 10 CFR 50, l
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07 Quality Assurance in Operations 07.1 Missed 10 CFR 50.72 Notification Inspection Scope (71707)
The inspectors reviewed '.he 10 CFR 50.72 reportability requirements for discovery of blind flanges installed or, two siphon breaker pipe stubs on the crosstie pipe connecting the service water pond (ultimate heat sink) and the Monticello Reservoir, Observations and Findinas On July 29, during a re/iew of an underwater video in preparation for Modification Request Form (MRF)-22423 (refer to Section M1.2) an engineer raised questions conceming the status of siphon breakers installed on the 36-inch diameter pipe connecting the service water pond and the Monticello Reservoir. A Non-Conformance Notice (NCN 99-1119) was generated on July 30 to address this condition. On July 30, the inspectors observed investigative activities as divers inspected the siphon breaker The divers reported that no air path existed (i.e., no holes or spacers were present on either of the blind flanges) to allow the siphon breakers to perform their design basis function. Based on this information, the FSAR design basis parameters specified in Sections 2.4.8, " Cooling Water Canals and Reservoirs," and 9.2.1.3, " Service Water System - Safety Evaluation," and TS 3.5.5, " Ultimate Heat Sink," requirements to be able to maintain the service water pond level at or above elevation 415 feet mean sea level could not be assured. This resulted in the plant being in a condition outside the design basis. The NRC is continuing to review this event to determine if the requirements of 10 CFR 50.72.(b)(ii)(B), "Non-Emergency Events," were applicable and if the licensee should have made a one hour notification under the criteria of an event or condition during operation that results in a condition that is outside the design basis of the plan Pending additional NRC review of this item, this issue is identified as unresolved item (URI) 50-395/99006-0 The licensee issued Licensee Event Report (LER) 50-395/99010-00, "Ultimat7 Heat Sink (UHS) Dependent Components Potentially Outside the Design Basis of the Plant," on August 30. Further discussion of the engineering evaluation is contained in Section E Conclusions A one-hour notification per 10 CFR 50.72 was not made upon discovery that the service water pond siphon breakers would not perform their intended function and that the service water pond minimum water level could not be assured. The blind flanges were promptly removed which restored the function of the siphon breakers. Additional NRC review of the reportability of this issue is pending.
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.M1 Conduct of Maintenance M1.1 Observation of Work Activities Inspection Scope (61726. 62707)
The inspectors observed all or portions of maintenance and surveillance testing activities listed below or reviewed the completed surveillance documentation to verify test results met established acceptance criteri EMP-190.015 " Test Procedure for General Electric (GE) Type PJV Relays,"
Revision (Rev.) 7 (for testing the overvoltage relay on the A Emergency Diesel Generator (EDG))
EMP-190.016 " Test Procedure for GE Type PJG Relays," Rev. 5 (for calibration of the A EDG field ground relay)
EMP-405.001 "7.2 KV Circuit Breaker Maintenance," Rev.15B (for breaker
! swap, inspection, cleaning and operational check of XSW1DA 03,
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and XEG001 A-DG) i l
l ICP-180.002 " Emergency Diesel Generator A," Rev. 7A (for calibration of EDG l
oil storage tank A level switch ILS05415 including setpoint change
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per Engineering Change Request 50139 which raised Lo-Lo Level alarm for EDG fuel oil storage tank instruments ILS05415 and ILS05425)
ICP-240.027 "Dwyer Series Differential Pressure (D/P) Gauge Generic
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Calibration Procedure," Rev. 4 (for IPl097158, Residual Heat Removal (RHR)/ Spa ay Room roughing filter D/P indicator)
ICP-350.009 " Residual Heat Removal Pump Differential Pressure Indicating Switch Calibration IFS 00602A, IFS 00602B," Rev. 3 (for IFS 00602B, RHR Pump B Finw Switch)
l_ STP-102.002 " Nuclear Instrumentation System Power Range Heat Balance," l L Rev. 8 i
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STP 105.006 - " Safety injection /RHR Monthly Flowpath Verification Test," Rev. 9F i l
STP-105.015 " Train 8 Slave Relay Go Circuit Testing," Rev.16B STP-106.001 " Moveable Rod insertion Test," Rev. 4 i
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STP-108.001 " Quadrant Power Tilt Ratio," Rev. 9
+ STP-113.001 - " Remote Shutdown Instruments Channel Checks," Rev. 5 l STP 136.001 " Steam Generator Blowdown Valve Operability Test," Rev. 6C ,
STP-228.001 " Fire Protection System Fire Pump Test," Rev. 2E (for annual j diesel fire pump test)
STP-360.044 " Waste Gas Discharge Atmospheric Radiation Monitor (RM-A10)
Operational Test," Rev. 5
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l STP-506.001 " Pressurizer Heater Capacity Test," Rev. 5 j l
b. Observations and Findinas j l
The inspectors verified that the work was performed with the work package present and actively referenced. Generally, activities observed were conducted in accordance with written proceduralinstructions. Procedures provided sufficient detail and guidance for the intended activities. Technicians demonstrated that they were experienced and knowledgeable of their assigned tasks. Quality control personnel were present whenever required by procedure. The inspectors noted that appropriate radiation control measures were in place when applicable. The inspectors concluded that routine maintenance and surveillance activities were satisfactorily performed. Specific areas of concern or noteworthy items are documented belo The inspectors observed and reviewed the pressurizer heater capacity test results for STP-506.001. Although the test was completed with satisfactory results, the inspectors questioned the use of the word "approximately" to evaluate the acceptance criteria for a heater failure between actual and calculated meter readings. As a result, the licensee revised the procedure to include a defined acceptance criteria of greater than two amperes. Based on the amount of heaters available and the measured output of the operating heaters, the inspectors verified the criteria of 125 kilowatt output delineated in TS 4.4.3.2, " Pressurizer," was me On September 9, the inspectors observed the performance of the annual diesel fire pump operability test conducted in accordance with Section 6.2 of STP-228.001. The inspectors verified all acceptance criteria was met. Several issues were identified during the performance of this test that were appropriately captured in maintenance work requests, CERs 99-1228,99-1229, and 99-1231, and through the procedure feedback form process. The inspectors concluded the diesel fire pump test verified operability of the pump and that licensee personnel properly self-identified and entered issues into their corrective action program )
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? Conclusions nThe inspectors concluded that routine maintenance and surveillance activities were satisfactorily performed and documentation reviewed met established acceptance criteri M1.2 Circulatina Water (CW) / Service Water (SW) Crosstie Pipe Isolation Valve Modification Review Inspection Scope (62707. 37551)-
The inspectors reviewed the engineering package that instat!ed a motor operated butterfly valve in the CW/SW crosstie pipe per MRF-22423. This review included the 10 CFR 50.59 safety evaluations and the temporary backup fire service suppression supply which was installed to support implementation of the modificatio Observations and Findinos The inspectors reviewed and observed portions of MRF-22423 implementation . Based on a review of the package, the valve installed in the 36-inch diameter CW/SW crosstie pipe will normally be closed to allow chemical treatment of the service water pond, but can be opened to provide makeup water to the SW pond. Isolation of the SW pond from ;
the Monticello Reservoir during this modification via a pipe plug did not impact the I operation of the SW system and its safety-related function. Due to the requirement to dewater the CW pump house during this modification the permanently installed fire service pumps would be tagged out and unavailable for a scheduled period of time not to exceed two weeks! The valve modification was completed without incident, however, on July 29 during preparation for MRF-22423 divers discovered a condition that raised questions concerning the status of two four-inch diameter siphon breakers installed on the CW/SW pond crosstie pipe (refer to Sections 07.1 and E1.1 of this report).
The inspectors rmwed the instructions provided fen.he installation and operation of the temporary fire syttem. The associated instructions, engineer technical work records, and 10 CFR 50.59 safety evaluation reviews were detailed and technically adequat The inspectors observed portions of the installation and testing conducted by a contractor to verify that two diesel driven portable fire pumps were functionally equivalent to the permanent fire service pumps. The equipment setup, testing and manning of the temporary fire service pumps were well controlled and implemented in accord &nce with l MRF-22423 work instructions. The inspectors noted that licensee personnel provided ,
good oversight and control of the modification activities. The licensee had carefully l considered the requirements of TS, FSAR, Fire Protection Evaluation Report (FPER) i and the requirements of NRC Branch Technical Position Auxiliary Power Conversions l System Branch APCSB 9.5-1, " Guidance for Fire Protection for Nuclear Power Plants," {
to ensure the functional requirements of the fire service system would be met during the time that the permanent pumps were inoperable. The licensee took the necessary actions to minimize the time the permanent pumps would be out-of-servic _ __ _ -______ _ - _
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7 Conclusions Modifications to the circulating water / service water crosstie pipe were well planned and the associated instructions included appropriate precautions to ensure continued fire suppression water was available. The engineer technical work records and 10 CFR 50.59 safety evaluation reviews were detailed and technically adequate. Good oversight of contractor personnel was noted. The equipment setup for the temporary fire service pumps and installation testing were well controlled and implemented in accordance with the work instruction Ill. Enaineerina E1 Conduct of Engineering E Ultimate Heat Sink Siphon Breakers Inspection Scope (37551. 71707)
The inspectors reviewed the licensee's actions and engineering evaluation of the discovery that blind fianges were installed on two siphon breaker pipe stubs on the 36-inch diameter pipe connecting the service water pond (ultimate heat sink) and the Monticello Reservoi Observations and Findinas On Ju'y 29, during preparation for MRF-22423 (refer to Section M1.2), divers discovered a cordition that raised questions concerning the ability of the siphon breakers on the CW/SW pond crosstie pipe to properly function. These siphon breakers are described on the FSAR Figure 10.4-5, " Circulating Cooling Water - System Flow Diagram," and in Sections 2.4.8, " Cooling Water Canals and Reservoirs," and 9.2.1.3, " Service Water System - Safety Evaluation." The FSAR states that the siphon breakers are installed so that the flow path is interrupted following a loss of Monticello Reservoir. With the siphon breakers unavailable due to the installed blind flanges, a siphon effect could occur and allow the pond level to be reduced to 412 foot level (physical end of the pipe), which is three feet below the 415 foot level described in FSAR Sections 2.4.8 and 9.2.1.3, and specified in TS 3.5.5, " Ultimate Heat Sink."
Following the discovery of the potential condition, a diver inspection plan was developed and implemented on July 30 under NCN 99-1119. The plan was to determine n the blind flanges had holes or spacers that would enable the siphon breakers to perform as designed. The divers inspected the siphon breakers then promptly removed the blind flanges, thereby restoring the capability of the siphon breakers to perform their design basis function. There were no holes or spacers installed in the blind flange Investigation by the licensee was unable to determine the reason for or the duration that these blind flanges were installed. Additional NRC review of the siphon breakers not being able to perform their design function is required and will be tracked as URI 50-395/99006-0 __-
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8 Conclusions Blind flanges were discovered on siphon breakers for the 36-inch diameter pipe connecting the service water (SW) pond (ultimate heat sink) with the Monticello Reservoir. This resulted in the siphon breakers being unable to perform their design function and would have resulted in lower SW pond level than previously assumed for a j loss of reservoir event. Additional NRC review of this issue is pendin j i
E1.2 Re-analysis of Larae Break LOCA for an Error in Computer Code Inspection Scope (37551) '
The inspectors reviewed the licensee's response to the discovery by Westinghouse of an error in the computer code (LOCBART) used for the V. C. Summer large break LOCA l analysi l Observations and Findinas A logic error in the LOCBART computer code which performs the rod heat-up calculation i for the V. C. Summer large break LOCA analysis had been discovered by Westinghous Westinghouse performed a re-analysis for the Cycle 12 V. C. Summer 50.59 reload criteria, the Core Operating Limits Report (COLR) and the current limits (Reload Safety Analysis Checklist) with an updated computer code The re-analysis took credit for a reduced Peaking Factor (Fo, of 2.40 versus 2.45). The re-analysis resulted in a peak cladding temperature of 2162 degrees Fahrenheit which meets the 10 CFR 50.46 acceptance criteria of 2200 degrees Fahrenheit. Formal documentation of this information was provided to V. C. Summer by Westinghouse on August 3 Based on the information provided by Westinghouse, a revision to the V. C. Summer COLR was necessary to reduce the Fo Peaking Factor from 2.45 to 2.40. No other revisions to the COLR were required. The conclusions in the V. C. Summer Final Reload Safety Evaluation, Revision 1, remained valid and bounding according to the Westinghouse evaluation. A 10 CFR 50.59 safety evaluation was completed for the COLR revision and approved by the Plant Safety Review Committee (PSRC) on August 31. The inspectors reviewed the Westinghouse information provided in letter (99CG-G-0036), "SCE&G V.C. Summer Nuclear Station Cycle 12 Revised 50.59 Criteria, COLR and Current Limits for LOCA," dated August 31,1999. The licensee's actions which included the 10 CFR 50.59 Safety Evaluation and COLR revision appeared to be reasonable, appropriate and timely. The licensee issued a 30-day report in accordance 10 CFR 50.46 requirement d 9 Conclusions Westinghouse discovered an error in the computer code (LOCBART) used for the Summer large break LOCA analysis and provided a re-analysis using an updated computer code. Licensee actions taken in response including the 10 CFR 50.59 Safety Evaluation and Core Operating Limits Report (COLR) revision appeared reasonable, appropriate and timel ,
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E2.1 Review of New Reactor Core Monitorina Proaram !
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a. Inspection Scope (37551)
l The inspectors reviewed the licensee's implementation of a new reactor core Power '
Distribution Monitoring System (PDMS).
l b. Observations and Findinas The inspectors reviewed the implementation of a new core monitoring program that uses an NRC-approved Westinghouse proprietary computer system, the best estimate analyzer for core operation-nuclear (BEACON), to perform a core power distribution surveillance. BEACON will be used to augment the existing moveable incore flux mapping system. The new TS allows the use of BEACON as a PDMS at power ranges greater than 25 percent of rated thermal power. The BEACON software system provides direct and continuous core power distribution determinations and directly relates power distrlution to fuel safety limits. The licensee plans to use BEACON to reduce the monthly flux mapping to once every three months. The disadvantage of BEACON is that there is increased uncertainties in the calculations that accumulate between calibration Because flux maps will not be necessary for a minimum three month period with BEACON, small uncertainties will develop. However, based on discussions with the licensee these uncertainties will have a negligible impact due to the magnitude of the uncertaintie The 'NRC has reviewed and approved the use of tne BEACON as a PDMS as documented in TS Amendment number 142, dated April 9,1999. The licensee implemented this change effective August 7,199 The inspectors verified proper implementation of the BEACON PDMS through a review of applicable procedures and the newly approved T c. Conclusions The licensee has implemented a new TS amendment to use BEACON as a core power distribution monitoring system to augment the moveable incore detectors for flux mapping activities. The inspectors concluded that the licensee's use of BEACON is an effective tool and should provide additionalinsight and understanding of core characteristics, and operational flexibility with less flux maps being require IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R Radioloaical Control Area Tours a. Inspection Scope (83750. 84750)
During ours of radiologically controlled areas (RCAs), the inspectors evaluated postings and physical controls for high and locked-high radiation areas associated with radioactive effluent processing and waste storage, and with radioactive material storag The adequacy of general radiological housekeeping and labels for containers of radioactive material and radioactive waste were reviewed. In addition, a detailed walk-down and discussion of the waste processing demineralizer system and operation were conducte Radiation protection program activities were reviewed against the FSAR, TS, and 10 CFR Part 20 and Part 50 requirements.10 CFR 50.59 screening reports and safety analyses and evaluations for the demineralizer system and for changes to the outside rad; Active material storage area were reviewed and discusse Observations and Findinas Radiological housekeeping practices and surface contamination levels within the auxiliary building and outside radioactive waste / material processing and storage areas were acceptable, with RCA unrestricted areas maintained radiologically clean and uncluttered. Area postings and container labels were maintained in accordance with the associated access controls or radiological conditions. High and locked-high radiation areas were controlled appropriately, although the inspectors noted difficulty in observing a ushing red light used as a supplemental control for access to a locked-high radiation area inside of a shielded demineralizer. Licensee personnel accompanying the inspectors repositioned the flashing light to increase visibility to personnel approaching from all direction The inspectors verified that the licensee had conducted 10 CFR 50.59 screening reviews for changes made to the outside radioactive waste / material storage pad. Further, an amendment updating the FSAR Section 11.5.6, " Storage," to meet the current "as built" structure was scheduled for submittal. For the current demineralizer system, the inspectors did not identify any concerns regarding the 10 CFR 50.59 screening reviews
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and safety evaluations documented in design package number 20752 and for system operation as described in SOP-108, " Liquid Waste Processing,"
Revision 1 Conclusions Radioactive effluent and waste processing systems and storage facilities met FSAR and 10 CFR Part 50 requirements. Radiological controls for radioactive gaseous and liquid effluent storage and processing systerns, and for radioactive material / waste storage areas met TS and 10 CFR Part 20 requirement R1.2 Liouid Radwaste Analysis. Processina and Release Inspection Scope (84750)
The inspectors directly observed and evaluated radionuclide sampling and quantitative analyses, waste permit processing, and operations conducted for liquid effluent releases from waste monitor tanks. Procedural adequacy, equipment operability, and staff proficiency were evaluated during discussion and observation of pre-release sample coliection, radiological analyses, liquid effluent monitor set-points and dilution calculations. Pre-release valve lineups and control room activities associated with waste monitor tank A release were observed. The inspectors also reviewed radioactive release permits and the performance of liquid monitor source check and alarm / set point data for previous release License program guidance, implementation, and results were evaluated against applicable sections of 10 CFR Part 20, Appendix i to 'O CFR Part 50, TS, Offsite Dose Calculation Manual (ODCM),40 CFR 190 and approved procedural requirement Observations and Finding _s Chemistry laboratory technicians demonstrated appropriate knowledge of procedural requirements and proficiency in completing assigned tasks. Technicians conducting pre-release sampling and radionuclide analyses were knowledgeable of equipment and procedures. The inspectors observed sampling of waste monitor tanks A and B, source checks of liquid waste effluent monitor (RML-0005) and liquid waste aischarge monitor RML-0009, and the alarm / trip-point setting for liquid release. Operators demonstrated -
knowledge of release pathways, valve lineups, liquid effluent monitor setpoints and procedural requirements. Inspectors noted increasing background count rates for monitors RML-0005 and RML-0009 and a poor practice in reusing sample containers determined to have residual radioactivity resulting in a positive bias for effluent sample measurements. No significant concems were noted for sampling, analysis methods, and calculations performed.
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The inspectors reviewed ten of approximately 178 liquid waste release permits performed year-to-date. The reviewed permits indicated that the ODCM requirements for sampling, monitor source check, and alarm / trip set point determinations were met prior to each releas For 1999, released radionuclide concentrations and resultant doses were a small fraction of 10 CFR Part 20, ODCM and 49 CFR 190 limits. Further, releases were a small fraction of the radioactive effluent design objectives specified in Appendix l to 10 CFR Part 5 Conclusions Chemistry and operations personnel demonstrated appropriate knowledge of procedural requirements, and proficiency in initiating and conducting liquid effluent release Licensee programs to control effluent releases were implemented effectively with effluent radionuclide concentrations and resultant projected offsite doses within established regulatory limits and design objective R2 Status of Facilities and Eauipment R2.1 Radiation Monitor System (RMS) Calibrations a. Inspection Scope (84750)
Approved guidance and resultant data for selected radiation monitoring system (RMS)
detector calibrations were reviewed and discussed. For each detector reviewed, source and electronic calibration surveillance test procedure packages for the previous two surveillances conducted were reviewed, evaluated and discussed with responsible licensee personnel. The following RMS detectors and associated electronics were I included in the review: containment high range monitor (CHRM), general radiation monitor (RMG)-0018, incore area RMG-0014, and liquid radiation monitor (RML)-000 Source and electronic calibration activities were evaluated against applicable sections of the FSAR, TS, and ODCM requirements. In addition, calibration activities to implement and maintain licensing commitments associated with Three Mile Island (TMI) Action item II.F.1 for the CHRM were reviewe b. Observations and Findinas For the reviewed systems, calibrations frequencies met TS, procedural or ODCM specifications. For the RMG-0018 and RMG-0014 detectors and associated electronics, no concerns or trend issues were identified for detector radioactive source and electronic loop calibrations reviewe During review of liquid effluent waste monitor (RML-0009) source calibration activities conducted on July 1997 and Febnsary 1999, the inspectors noted an approximate two to l ten percent increased in the calculated yield, i.e., monitor response efficiency, reported l l
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for the two calibrations. The inspectors noted that vendor manual, " Isotopic Calibration of the Liquid Process Monitors, NMC, IT-7613," Revision 5, requires use of a liquid source and calibration geometries to be identical to the normal monitoring geometr The inspectors noted that two different sets of solid radioactive disks rather than vendor-provided liquid sources had been used for the subject calibrations. The inspectors noted that American National Standards Institute (ANSI) N42.18,1980, " Specification and Performance of On-Site Instrumentation for Continuously Monitoring Radioactivity in Effluents," and currently accepted industry practices recommends that the original vendor primary calibration be related to a secondary source or method which will be used for periodic in-plant re-calibration. The licensee was unable to provide documentation demonstrating an empirical relation for either set of disk sources with the original vendor monitor calibration conducted using liquid sources. Although several licensee representatives believed that the original vendor-supplied liquid secondary calibration sources continued to be used in the efficiency determinations, records indicated that use of the liquid sources to conduct the monitor calibrations were discontinued in 1990 and use of the disk sources was initiated. The inspectors noted that although the subject disk sources were traceable to the National Institute of Standards and Technology, the licensee had not established traceability of the efficiency responses to the original liquid monitor calibrations and their use as secondary calibrations was not acceptabl Subsequent licensee follow-up of the concern identified that calibrations for approximately five liquid monitors, steam generator blowdown monitor (RML-0003),
liquid waste effluent monitors (RML-0005 and RM-L0009), nuclear blowdown waste effluent monitor (RML-0007), and steam generator blowdown discharge monitor (RML-0010), were affected by the change in the secondary calibration sources. Based on operating history, assumptions used in the routine sampling and release of liquid waste tanks, and conservative assumptions for determining alarm set-points, licensee calculations demonstrated that no ODCM instantaneous release rates or dose limits would have been exceeded for releases made under the worst case assumption However, the failure to properly calibrate, since 1990, liquid effluent discharge monitoring equipment in accordance with vendor or acceptable industry practices was identified as a violation of 10 CFR Part 20.1501(b) requirements. These monitors are used for quantitative radiation measurements. This Severity Level IV violation is being treated as a Non Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is identified as NCV 50-395/99006-03 and is in the licensee corrective action program as CERs 99-1170 and 99-117 l c. Conclusions A non-cited violation was identified for failure to calibrate liquid radiation monitoring systems in accordance with vendor or accepted industry practices as required by 10 ;
CFR Part 20.1501(b) requirements. General area radiation monitoring system i equipment was calibrated properly, i
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R2.2 Radioloaical Environmental Monitorina Proaram Samplina Stations Inspection Scope (84750)
The inspectors accompanied a technician and directly observed collection of selected Radiological Environmental Monitoring Program (REMP) samples specified in the ODCM. Operability requirements for particulate and iodine airborne sampling equipment were evaluated and distributions of Thermoluminescent Dosimeters (TLD) for specific ODCM sample locations were verified. Procedural adequacy, equipment operability, and staff proficiency were evaluated during observations of particulate filter ,
and charcoal cartridge change-out operation '
Equipment and sampling procedures were evaluated against applicable sections of the ,
FSAR, ODCM, and approved procedure Observations and Findinas The inspectors verified that sampling sites 2, 7, 6, 8, and 30 met the location descriptions and contained the necessary sampling equipment (TLD, air, and leafy vegetation), as specified in the ODCM. The technician demonstrated proficiency in completing required actions to verify total air volume flow and unit operational times for air samples collecte Sampling filters for particulates and iodine were properly installed. Airborne sampling ,
equipment was operational, and flow calibrations were maintained in accordance with l approved procedure ; Conclusions The radiological environmental monitoring program for airborne radionuclides and leafy vegetation, and monitoring of direct radiation was implemented in accordance with the Offsite Dose Calculation Manual specifications.
R3 Radioloalcal Environmental & Effluent Monitorina Proaram R3.1 Annual Report Inspection Scope (84750)
The inspectors reviewed and discussed the 1998 Annual Radiological Environmental Monitoring Report and the Radioactive Effluent Release Report submitted in accordance with TS 6.9.1.6 and 6.9.18 respectivel I Effluent data were evaluated relative to the design objectives specified in Appendix l to -
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15 Observations and Findinos The data in the following tables were compiled from the licensee's effluent reports for the years 1996 through 1998:
LlQUID EFFLUENTS Curies Released Dose * (mrem)
Year Fission & Activation Tritium Dissolved & Total Body Organ Products Entrained Gases Limit [ 3 mrem] Limit [ 10 mrem]
1996 0.14 579 1.25E-2 9.96E-3 (0.33%) 3.8E-2 (0.38%)
1997 0.04 922 1.97E-2 9.8E-3 (0.33%) 1.0E-2 (0.10%)
1998 0.03 792 2.76E-3 6.85E-3 (0.23%) 7.25E-3(0.07%)
- to maximally exposed individual in the unrestricted are GASEOUS EFFLUENTS Curies Released Dose * (mrem)
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y Year Fission & Activation todine ' Particulate Tritium Air ( y 10 mrad, organ S Products p 20 mrad ) [ 10 mrem]
1996 .76E-7 1.25E-2 14 y 9.0E-5 7.4E-3
$ 2.3E-4 1997 0.34 7.20E-7 1.97E-2 6 y 2.5E-5 3.0E-3
$ 1.1E-4 1998 .00 2.76E-3 5 y .4E-3 S [] Limits.
() % of Limits y - gamma radiation s - beta radiation
- Dose to maximally exposed individual in the unrestricted area The reported data indicated a decreasing trend in the amounts of radioactivity released from the plant in liquid and gaseous effluents and resulting radiation dose. The inspectors observed that the 1998 Annual Environmental Radiological Monitoring Report confirm the results above. The radioactivity in effluent samples resulted in a calculated maximum total body dose equivalent of 4.02 E-2 mrem / year, a small fraction of the effluent dose limits.
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16 Conclusions The 1998 Annual Effluent Release Report and Annual Radiological Environmental Monitoring Report were submitted in accordance with Technical Specifications and documented results demonstrated gaseous and liquid effluent processing and subsequent releases met established regulatory limits and Appendix l to 10 CFR 50 design objective R4 Staff Knowledge and Performance in RP&C R4.1 Observation of Routine Chemistry Samplina Inspection Scope (71750)
The inspectors observed the conduct of routine chemistry sampling of the RCS for boron and lithium result Observations and Findinas On August 3, the inspectors observed routine RCS sampling from the letdown heat exchanger that was conducted under Section 6.8 of Chemistry Procedure (CP)-903,
" Operation of the Nuclear Sample System under Normal Conditions," Revision 16E. The results were properly documented on Attachment Vll of CP-614, " Reactor Coolant Chemistry Control," Revision 9G. The samples were drawn and analyzed in accordance with the procedure requirements. The technician actively referenced the procedure and the results for boron and lithium were verified to be within the expected range and within the coordinated chemistry control band. The technician was knowledgeable and experienced with the equipment and properly demonstrated appropriate radiation control measures (i.e. use of protective clothing, proper radwaste disposal), and chemistry safety precautions (i.e. verifying sample fume hood was operational). Conclusions Routine chemistry sampling of the reactor coolant system was conducted in accordance with written procedures with satisfactory results. The chemistry technician was experienced and knowledgeable of his assigned task and used appropriate safety precautions and radiation control measure R7 Quality Assurance in Effluent and Environmental Monitorina R Radioloaical Measurement Quality Control Inspection Scope (84750)
The inspectors reviewed implementation of the effluent monitoring program Quality Control (QC) activities to meet the intent of Regulatory Guide (RG) 4.15, Revision 1, February 1978 as specified by TS 6.8.1(i). Reviewed activities included laboratory
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i methods for liquid and airborne sample preparation and processing, Lower Limit of Detection (LLD) capabilities for gaseous effluent measurements, and implementation and results for selected counting room analytical radionuclide measurement system QC performance activitie b. Observations and Findinas The counting room instrumentation QC program was implemented in accordance with approved procedures. No significant concerns nor negative trends were identified from review of the gamma spectroscopy and liquid scintillation counting systems' QC performance data. The inspectors verified that gamma-spectroscopy systems with out-of-specification OC performance data were not used for quantitative effluent radionuclide measurements. In addition, reviews of sampling and analysis times for selected gaseous effluent purge release permit samples verified that LLDs specified in the ODCM were me From discussions with counting room technicians and supervisors, and review of sample preparation procedures, the inspectors identified inconsistent answers and a lack of documented guidance regarding when distillation is needed to adequately determine tritium concentrations and the required pH to prevent radionuclide plate-out in process composite liquid samples. Licensee representatives stated that documented guidance to address these issues would be incorporated into the upcoming procedure revision c. Conclusions Counting-room QC activities were implemented appropriately and verified the accuracy of radionuclide analytical measurement instrumentation.
F1 Control of Fire Protection Activities F Annual Fire Drill a. Inspection Scope (71750)
The inspectors observed the performance of an annual fire drillinvolving both th'e onsite fire brigade and three local fire companie b. Observations and Findinqs
On August 18, a fire drill was conducted to meet the requirements of Emergency Plan (EP) Procedure EP-100, " Radiation Emergency Plan," Revision 41, Section 8.1.1.e, Fire Control. The fire drill scenario involved an explosion in the non-contaminated auxiliary boiler with an injured person. The inspectors observed the preparations for the drill, the pre-drill briefing of both the onsite fire brigade and the local fire companies, the actual drill performance, and the post-drill critiques. Of the three local fire companies that responded only two were needed inside the protected area to support the drill. The fire brigade team leader made the determination as to the number of people necessary to
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respond to the event. The third fire company was staged in the owner controlled area in standby readines The inspectors noted that the fire drill was suspended by the contruiiers due to four licensee personnel who needed minor medical attention as a result of heat exhaustio Existing ambient conditions at the time of the drill were approximately 95 degrees Fahrenheit. Fire team members were in full fire fighting gear. Based on discussions with emergency preparedness personnel after ina drill, it was determined to be in the best interest of involved fire personnel that the drill be suspended before any serious health problems occurred. The licensee issued CER 99-1166 to document and review the circumstances surrounding the heat exhaustion even In spite of the drill suspension, the fire drill was rated overall as satisfactory by the licensee, meeting both the intent of the EP and the established drill scenario objective However, the inspectors questioned the thoroughness of the critique conducted by the licensee. Specifically, the inspectors noted that the drill scenario objectives were not consistent with that of the EP objectives and although not all objectives were met, the
. drill was rated satisfactory. The drill scenario objectives were based on standard fire drills and were orientated toward fire fighting tactics, whereas, the EP objectives were focused on the local fire companies becoming more familiar with site layout, equipment used by onsite fire brigade members, and communications between the groups. Based on review of the issued critique sheet, the inspectors were concerned that lessons learned from the drill were not captured by the licensee. Based on further inspector discussions with licensee personnel, lessons leamed were being considered for inclusion in the critique documentation and for further action. These items involved potential enhancements in operations training, offsite crew training, and strengthening communications. These items were not captured as part of the original critiqu In accordance with the site security plan, local fire company personnel were teamed up with licensee personnel while inside the protected area. Security provided sufficient personnel to adequately monitor activities around the auxiliary boiler area. Security properly escorted the crews offsite following completion of the dril Conclusions An annual fire drill utilizing off site fire fighting assistance was performd satisfactoril The drill was adequately monitored and controlled. The inspectors idef afied a concern with the thoroughness of the oilginal critique process not capturing lessons leamed from the annual fire drill. The inspectors' concems were captured in the critique documentation for follow-up action following discussions with the license .
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l V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented the effluents inspection results to members of the licensee management and plant staff on August 20,1999. The inspectors presented additional inspection results to members of licensee management at the conclusion of the inspection on September 17,1999. The licensee acknowledged the findings presente ;
The inspectors asked the licensee whether any materials exarnined during the inspection should be considered proprietary. No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED Licensee J. Archie, Manager, Planning & Scheduling F. Bacon, Manager, Chemistry Services L. Blue, Manager, Health Physics and Radwaste Mi Browne, Manager, Plant Suppo.1 Engineering
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S. Byrne, General Manager, Nuclear Plant Operations C. Fields, Manager, Quality Systems M.' Fowlkes, Manager, Operations L. Hipp, Manager, Nuclear Protection Services D. Lavigne, General Manager, Nuclear Support Services G. Moffatt, Manager, Design Engineering A. Rice, Manager, Nuclear Licensing and Operating Experience R. White, Nuclear Coordinator, South Carolina Public Service Authonty B. Williams, General Manager, Engineering Services G. Williams, Manager, Maintenance Services INSPECTIONS PROCEDURES USED
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IP 37551: Engineering IP 61726: Surveillance Observations IP 62707: Maintenance Observations i IP 71707: Plant Operations IP 71750: Plant Support Activities !
IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste and Effluent and Environmental Monitoring I
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ITEMS OPENED AND CLOSED
- Opened 50-395/99006-01 URI service water siphon breakers not functioning was not reported per 10 CFR 50.72 (Section 07.1)
50-395/59006-0?. URI siphon breakers on service water crosstie pipe to circulating water were blind flanged and not functional (Section E1.1)
50-395/99006-03 NCV fai8ure to properly calibrate liquid effluent discharge monitoring equipment in accordance with 10 CFR Part 20.1501(b) requirements (Section R2.1)
Closed 50-395/99006-03 NCV failure to properly calibrate liquid effluent discharge monitoring equipment in accordance with 10 CFR Part 20.1501(b) requirements (Section R2.1)
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