IR 05000413/1991002
| ML20217B825 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 02/15/1991 |
| From: | Robert Carrion, Decker T, Gloersen W, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20217B797 | List: |
| References | |
| 50-413-91-02, 50-413-91-2, 50-414-91-02, 50-414-91-2, NUDOCS 9103120241 | |
| Download: ML20217B825 (17) | |
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NUCLE AR HLGULATOHY COMMISSION nE GION 11
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FEB 2 01991 Report Nos.: 50-413/91-02 and 50-414/91-02 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 Facility Name: Catawba 1 and 2 Inspection Condu te : a var 14-18, 1991
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Approved by:'f'~ .~)otYer~,' Chief ate Signed facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiatjon Safety and Fafeguards h a ~ 2 /S
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T7h. DFcYe?TChTeT Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope: This routine unannounced inspection was conducted in the area of occupational radiation safety and radiological effluents which included an examination of: audits and appraisals, planning and preparation, training and qualification, environmental monitoring, process and effluent monitors, post accident sampling, semi-annual radioactive release reports, and shipping of low-level wastes for disposal and transportation, In addition, Information Notices and licensee responses to previously identified inspection findings were reviewe l 910220 0 D h k K 0500o413 PDR
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Results: In the areas inspected, two noncited violations were identified in-the areas of high radiation door controls and effluent monitor surveillance Based on interviews with licensee management, supervision, personnel from station departments, and records review, the inspectors found the radiation protection and radiological effluent programs to be managed acceptably. Planning and preparation for the Unit 1 EOC-5 outage, including management support was acceptabl l _ . . . . .
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REPORT DETAILS Persons Contacted Licensee Enployees G. Courtney, Supervising Scientist, Radiation Protection (RP)
*P. Deal, Radiation Protection Manager *J. Forbes, Technical Services Manager J. Glenn, Problem Report Coordinator *J. Hampton, Station Manager *C. Hartzell, Compliance Manager B. Kimray, ALARA Supervisor *V. King, Compliance Engineer J, Mode, General Supervisor- Shift (RP) gg H. Strickland, Radioactive Material Control Supervisor G. Vandervelde, Outage Vendor Supervisor Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personne Nuclear Regulatory Commission *P. Hopkins, Resident inspector *W. Orders, Senior Resident inspector *J. Zeiler, Resident Inspector * Attended exit meeting held January 17, 1991 Audits and Appraisals (83750, 84750, and 86750)
Technical Specification (TS) 6.5.2.9 requires that audits of plant activities be performed under the cognizance of the Nuclear Safety Review Board (NSRB) and that the audits shall encompass, in part, the following: (a) the conformance of plant operation to provisions contained within the TSs and applicable license conditions at least once per 12 months; (b) the PROCESS CONTROL PROGRAM (PCP) and implementing procedures for processing and packaging radioactive wastes at least once per 24 months; (c) the radiological environmental monitoring program and the results thereof at least once per 12 months; (d) the OFFSITE DOSE CALCULATION MANUAL (0DCM) and implementing procedures at least once per 24 nonths; and (e) the performance of activities required by the Quality Asuurance Program for effluent and environmental monitoring at leas t once per 12 month The inspectors reviewed the following audits: Departmental Audit hP-90-06 (CN), May 7, 1990: Radiation Protection, Radwaste Shipments, Radiological and Environmental Monitoring, and ODCM, .
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Departmental Audit NP-89-09 (CN), May 5, 1989: Health Physics, Environmental Monitoring, and Radwast * Departmental Audit NP-89-20 (CN), May 26, 1989: Chemistry and Process Control Progra In general, the audits- were found to be well planned and documented and contained items of substance relating to the radwaste, transportation, radiological protection, and radiological and environmental monitoring programs. The reports of audit findings to management were also reviewed and were found to contain responsive commitments by management to effect corrective actions for the deficiencies note The inspectors reviewed and determined that personnel participating in Departmental Audit NP-90-06 (CN) had the training and experience necessary to perform audits of the transportation and solid radioactive waste program In addition, the inspectors reviewed the experience of the licensee in identifying and correcting deficiencies and weaknesses related to the control of radiation -and radioactive matarial. The licensee used the HP Problem Report and Radiological incident Investigation and Accountability Report (RIIAR) to accomplish this. The RilAR system was intended to document personnel contamination events (PCEs), unplanned external exposures,
-loss / theft of licensed material, unplanned uptakes, and release of radioactive material in excess of 10 CFR 20 or 10 CFR 50 limits. The HP Problem Report system mostly dealt with minor health physics procedure violations and poor practices. The inspectors reviewed selected Problem Reports for 1990 and did not observe any safety significant items. It was evident that the licensee was identifying problems in the field and-implementing adequate corrective action No violations or deviations were identifie . Training and Qualifications (83750, 86750)
10 CFR 19.12 requires the licensee to instruct all individuals working or-frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of the-Commission regulations, individual responsibilities and the availability of radiation exposure dat The inspectors reviewed the continuing training provided to radiation protection personnel and reviewed the qualifications and training provided to new individuals on the RP staff. The inspectors noted that the two new hires (former contract HP Technicians) in calendar year 1990 had successfully completed the Employee Training Qualification System Tasks to perform HP technician duties. Additionally, these individuals were provided training on IN 88-63, "High Radiation Hazards from Irradiated Incore Detectors and
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Cables" through the licensee's Operational Experience Program (0EP) OEP was , also offered in continuing training classes.
!' The licensee's continuing training program typically provided 40 hours per year of training. The inspectors reviewed the plant systems component of the HP continuing training course with respect to radiological aspects of these systems that can cause significant radiological hazards to the worker, in .
calender year 1990, the following was offered in continuing training:
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induced crud burst problems
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auxiliary Building ventilation
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MPC accounting
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airborne, particulate, and gaseous sampling
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decontamination and minimization of contaminated areas LALARA program l l hot particles I
* beta particle program i In addition, the inspectors noted- that the licensee provided permanent and contract personnel with information on safety significant changes in
' procedures and recent events by either providing required reading material or conducting a special class on the-subject.
l The inspectors also reviewed the qualifications, training, education, and ' experience of selected personnel responsible for processing, storage, and shipping of low level radwaste and radioactive materials. It was observed- , that three new Radiological Materials Control (RMC) Technicians had received ' 28 hours worth of training _ in compliance with radioactive material shipping I and disposal regulations on - September 6, 1990. In addition, periodic retraining in 00T/NRC regulations, waste burial license requirements, and operating procedures for the transfer, packaging, and transport of radioactive material was provided in a two day training course in May, August, and December 199 No violatiens or deviations were identifie . Planning and Preparation (83750) The inspectors reviewed the licensee's augmentation of the HP staff to support the Catawba Unit 1 end of cycle 5 (E005) refueling cutage. The licensee had requested 164 contractor radiation protection technicians (RPT) to supplement the permanent staff of 64 RPTs. The contractor health physics staff consisted of 10 surveillance and control supervisors,117 senion technicians, 21 support function senior technicians, 8 upper containment _ _ _ _ , _ .___. _ _.. _ _ _.. ~.._ _. _ _ _ _ , _ _._.. _ . _ _ -
. _ . ' . 4 housekeeping - junior technicians, and 8 dose record and control junior technicians. Permanent supervisors and vendor supervisors reported to a permanent general super mor who in turn reported directly to the radiation protection manager. Ti - licensee implemented a new program to support the radiation protection program. The licensee hired 45 contractor " core" technicians to support Duke Power Conpany's three nuclear stations (15/ station). These core technicians were hired to work at least 10 months / year and would be available to support outage work at any one of the three station The inspectors also examined indicators of management support for the radiation protection program. From discussions with radiation protection personnel, it was apparent that selected members of the radiation protection staff had been included in outage preplanning ncetings and approval of visits by selected radiation protection personnel to the Oconee station to observe outage activities was granted within the last 12 months. In addition, it was noted that the licensee plans to use a two person health physics audit team to perform reviews of the various wo:k areas during the U1 E005 outag No violations or deviations were identifie . Environnental Monitoring (84750)
TS 3/4.12.1 defines the sampling and analytical requirements for the plant's radiological environmental monitoring progra The inspectors reviewed eight stations identified in the licensee's Environmental Report, including Station Nos.. 200, 205, 207, 208, 222, 226, 253, and 254 At the various stations, several types of simples were being
) taken including air, ground water, surface water, broadleaf plants and vegetation. Also, TLDs were located at five of the stations to detect direct gamma radiation. The stations were well-maintained and calibrated, where
> require No violations or deviations were identifie . Process and Effluent Monitors (84750) TS 3/4.3.3.10 and 3/4.3.3.11 define the operation and surveillance requirements for monitors of radioactive liquid and gaseous effluent stream The inspectors reviewed monitor calibration and maintenance records for the following monitors: 1-EMF-31, Turbine Building Sump Monitor; 1-EMF-41 Auxiliary Building Ventilation Monitor; 1-EMF-46, Component Cooling Water Monitor; and 1-EMF-54, Unit Vent High Ramp Monitor. The examined records appeared complete. The calibrations were performed within the required twe period and the meintenance items were completed in a titrely mar.ne _ __ _ _ _ _ - _ - _ _ _ _ _ _ _ _ - _ - _ _
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i b. The inspectors discussed the operability of EMF-31, the Turbine Building Sump (TBS) monitor, and reviewed the EMF operebility status reports for 199 Previously, the licensee had experienced continued problems with the Unit 2 EMF-31 due to clogged lines and valves which has resulted in low flow from the pump. During 1990, the Unit 2 EMF-31 was declared out-of-service for a total of 3.7 months, which included downtime to ' replace a burned-out pum The modifications included the replacement of sample lines and the replacement of carbon steel inlet piping with stainless steel as well as the addition of a de-ionized water check valve to the sample pump discharge line. From a review of the 1990 EMF status reports, the inspectors noted that the Unit 1 EMF-31 was declared out of service for a total of 45 days and the Unit 2 EMF-31 was declared out of service for a total of 110 days during the calendar year. The availability of these monitors was 88 percent and 70 percent for Units 1 and 2, respectivel The inspectors also discussed the current status of the EMF-34s the water sampling n.onitors of the steam generators. As of the date of this inspection, the monitors of both units were still incperabl The 4 various operability problems had been documented in previous inspection reports (50-413, -414/89-10 and 50-413, -414/90-12).. The licensee had determined that the system continued to have problems with plugged lines and flow control to the monitor and had considered modifications to correct the problems. In July 1990, during the Unit 2 refueling outage, the monitoring systems of tuth units were modified. The Kerotest valves, identified as being susceptible to flow obstruction, were eliminated from the sampling lines. Manual control valves were installed upstream of the monitors to provide throttling capability, as were ultrasonic flow meters to accurately balance steam generator flows to the monitor. However, flow testing performed on the modified system indicated that sample flow l temperature to the monitor was higher than the monitor could withstand and that the flow from the steam generator sample line to the monitor was difficult to contro The licensee is currently evaluating options to correct these problems. Alternatives under consideration include the installation of a heat exchanger at the inlet to the monitor and automatically-controlled throttling valves to replace the manual valves, c. LER 413/90-31 TS 4.3.3.11 requires each radioactive gaseous effluent monitoring instrumentation channel to be demonstrated operable by performance of the channel check, source check, channel calibration, and analog channel operational test operations at the frequencies shown in Table 4.3-9. The table lists the channel check frequencies for the MTB Noble Gas Activity Monitor EMF-58 as daily and the discharge flow instrumentation as dail The Process Radiation Monitoring (EMF) System provides early warning to Station personnel of equiprent, component, or system malfunctions or potential radiological hazards that may occur during normal plant ! operation, and certain accident conditions so that corrective action can be taken to prevent exceeding the limits of the TS .,- - . -
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4 i i EMF-58 measures the MTB ventilation discharge levels. It provides only an alarm function to the plant Control Room and the MTB control panel While EMF-58 includes both low- and high-range channels, only the
- low-range channel is needed to monitor the MT On December 7, 1990, at 0320 hours, with Unit 1 in Mode 1, et 100 percent Power Operation, and Unit 2 in Mode 1, at 08 percent Power Operation, a Chemistry technician performed a channel check on EMF-58, located in the MT At 1128 hours, EMF-58 failed high range automatic source check, placing the monitor control panels in an " operate failure" alarm state for that range. An annunciator was actuated in the Control Room, the
- MTB, and on the 543'-elevation of the Auxiliary Building. The MTB was not manned by Chemistry personnel at the time because a release was not ir progress. EMF-58 continued to monitor and record the -ventilation discharge activity concentration and the trip setpoint alarn function was available for the low rang On December 8, 1990, at 1545 hours, another Chemistry technician performed the daily channel checks on the MTB TS-related instruments and discovered the failure of EMF-58. The duty Chemistry Supervisor was notified and began investigating the EMF-58 alarm. The EMF passed two manual source checks. The Chemistry SLpervisor consulted the TSs and determined that " daily" is described as once per 24 hours, not once per calendar day as had been previously thought. The Chemistry Supervisor then determined that the elapsed time between the last two channel check surveillances had been 36 hours and 25 minutes, thereby exceeding the required 24 hour period plus 6 hour extensio The licensee attributed this incident to a management deficiency due to i inadequate training because Chemistry personnel had failed to recognize the TS definition of " daily." This led to the failure to clearly identify the definition in the Chemistry Department's written guidance and training programs. TS 4.3.3.11 was violated when the surveillance interval was exceeded for EMF-5 However, a 24 hour automatic source check was being performed on EMF-5 To prevent recurrence, the licensee had initiated corrective action in the form of increased surveillance frequency, revision of procedures, and supplemental training. Specifically, the Chemistry Department had changed the surveillance frequency for TS-related equipment /
instrumentation from daily to once per shift. Furthermore, the following procedures will be revised to better define " daily" and TS requirements:
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OP/0/B6500/58, " Operating Procedure for the Monitcr Tank Building i Ventilation System" ' OP/0/B/6500/59, " Monitor Tank Building Radiation Monitor"
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PT/0/B/4600/14, " Chemistry Periodic Surveillance items" l . e v-w.-.,-w+v ,,e + m e. . < v. e w n,+ -,,,.w,wwws,c.,--e--,.-~,,m.e, --E~-,--un.,--,,e- , , - , - .---.. w -_ wm --,,-,-,c.-e-,--~,.e-, w ,-wrew.-~,ww----m.-..-,-J
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l ! Chemistry Guideline 3.4.16 " Chemistry Guideline for Chemistry
Controlled EMFs" Training and Qualification Guide RC-803-C, " Operation of the Monitor Turk Building Radiation Monitors" Finally, the licensee has committed to develop a supplemental TS training , plan for continued training of Chemistry Department personnel, with greater emphasis on TS requirement This Licensee Identified Violation is not being cited because criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfied (LIV: 50-413/91-02-02). The licensee was made aware of this LIV during a telephone conversation on February 12, 199 . Post Accident Sampling System Operability (84750) TS 6.8.4.e provides for the establishment, implerrentation, and maintenance of a Post Accident Sarrpling System. The inspectors discussed systen, operation and maintenance experience with licensee personnel. The facility utilized two separate systems for collecting liquid and gaseous samples under accidcnt conditions. Operation and maintenance of the system for liquid sampling, the Post Accident Liquid Sampling (PALS) System, was the responsibility of the Chemistry Department while the system for obtaining gaseous samples, the Post Accident Gas Sampling (PAGS) System, during accident conditions, was the responsibility of the Radiation Protection (RP) Departmen The inspectors discussed the status of the systems with cognizant licensee personnel. The modification to route the waste of the PALS System Panel to the Volume Control Tank (VCT) has been completed on both unit Testing and verification of the flow path has been completed for both panels. However, training on the alternate flow path has not been completed to date. The decision has been made to replace the panels by September 1, 199 The Unit 1 PALS panel has been operated 31 times since July 23, 1990. The panel has passed 58 percent of the time and has been available 75 percent of the time. The Unit 2 PALS panel has been operated 15 times since August 28, 1990. It has passed 47 percent of the time and has been available 64 percent of the tim The licensee committed to maintain the highest possible reliability and availability up to the time of the panel replacemen Leak rate tests performed on the Unit 1 PAGS System did not identify significant leakage. The test will be upgraded and repeated and Unit 2 will be tested. All testing for both units is expected to be completed by August 1, 199 No violations or deviations were identifie L
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8 Semiannual Radioactive Effluent Release Reports (84750) TS 6.9.1.7 requires the licensee to submit a Semiannual Radioactive Release Report within 60 days after January 1 and July 1 of each year covering the operation of the facility during the previous six months of operatio The inspectors reviewed the Semiannual Radioactive Effluent Release Report for the first half of 1990 and discussed the reports with licensee representatives. The effluent and dose information presented in the table was obtained from current and previous effluent report Effluent Release and Dose Surra ry for Catawba Units 1 and 2
first half ActivityReleased,_(curies] 1988 1989 1990 Gaseous Efflue_n_ts Fission and Activation 3.12E+3 6.30E42 8.28E+2 Products , lodines and Particulates 9.02E-3 4.64E-2 2.88E-2 ' Tritium 6.06E+1 4.76E+1 3.54E+1 Licuid Effluents Fission and Activation 1.0AE40 6.84E-1 5.78E+0 Products Tritium 7.06E+2 8.90E+2 2.88E+2 Dose Estimates-(mrem) Gaseous Ef fluents ' (j(ob,1,e,, Gas, Exposur,e,) Whole Body 7.54E-1 4.80E-1 1.30E-1 Skin 2.04E+0 1.03E+0 5.46E-1 Qqujd , Effluents Whole Body 1.09E+0 5.34E-1 4.24E-1 Assuming that the releases continued in the second half of 1990 at the same-rate as in the first half, most categories increased during 199 Only tritium and whole body dose estimates from noble gas exposure decrease While the other categories increased, generally the recorded values were comparable to those of past years. The new Monitor Tank Building (MTB) for liquid radwaste treatment is discussed further in Paragraph 10 b of this
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repor Liquid and gaseous effluents and the resulting dose were well within TS, 10 CFR 20, and 40 CFR 190 limitations.
, The Semiannual Effluent Report identified two abnormal releases during the first half of 199 The first was a liquid release which occurred in April 1990 and was addressed in Inspection Report 50-413 -414/90-12. The second was a gateous release which occurred on June 11, 1990 due to an error in valve alignment which allowed 5000 to 6000 gallons of water to be transferred to the Fueling Water Storage Tank (FWST) in 30 seconds. It was estimated that a total of 3.847 curies of noble gas at the top of the tank were available for release. Based on a sampling program established to track concentrations of gas, an estimated 1.0 curie was released. Subsequent calculations determined that this incident did not exceed any TS limit Since the Semiannual Effluent Report was issued, two additional unplanned releases have occurred. The first was a liquid release, which occurred on September 25,1990, when 30 gallons of water from the Unit 1 Reactor Makeup Water Storage Tank-(RMWST) spilled onto the adjacent ground during a 30 minute period, releasing an estimated 7.353E-3 curies with a dose of 1.425E-1 mrem /yr at the site boundary. The second was a gaseous release from Shutdown Waste Gas Decay Tank A (SDWGDT), which resulted from a seal water loop lea The leak allowed the tank to vent its contents over a three-day period, from November 21 to 23, 1990, into Room 207 of the Auxiliary Building. A total at.4vity of 5.45 curies was estimated to have been release The inspectors concluded that TS reporting requirements regarding the effluent reports had been met and that releases were within TS and regulatory requirement No violations or deviations were identifie . Plant Chemistry (84750) TSs 3/4.4.7 and 3/4.4.8 specify the requirements for reactor coolant system chemistry. The inspectors reviewed graphed dose equivalent iodine (DEI) data for both units covering the past 12 months, which showed that both units maintained DEI levels below the TS limit of 1 microcurie / gram during steady state condition No violations of deviations were identifie . Liquid and Gaseous Releases (84750) TSs 3/4.11.1.1 through 3/4.11.1.4 define the operation _ and surveillance requirements for radioactive liquid effluents released to unrestricted areas and for radioactive liquid stored in unprotected outdoor tank The TSs include limits for the concentration of radioactive material released in liqJid effluents, sampling frequencies, types of analyses, limits for dose to members of the public from released effluents, and limits for the total quantity of radioactive material contained in liquid effluents stored in each unprotected outdoor tan _ . _ _ . _ _ . _ . . _ _ -
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TSs 3/4.11.2.1 through 3/4.11.2.6 define the operating and surveillance i requirements for the gaseous radwaste treatment system The TSs include sampling frequencies, types of analyses limits for dose to members of the public from released effluents and limits for the total quantity of radioactive material contained in each gas storage tank, The inspectors reviewed the licensee's procedures OP/0/0/6500/60,
" Discharge of an AMT to the Environment," and OP/0/B/6500/15, "Radwaste
, ' Chemistry Procedure for Discharging a Monitor Tank to the Environment" and found them to be in accordance with the applicable sections of the above TS The inspectors also observed the-discharge of liquid waste batch LWR N from Monitor Tank "B". The liquid waste was sampled (Chemistry Sample No. AB9101170900) and analyzed for boror., hydrazine, and nitrate ' concentrations and for radionuclide concentrations. The analytical ( results were reviewed and then used by Chemistry and Health Physics , ' supervision to determine that the release limits for specified concentrations and dose would not be exceeded. Set points for the Monitor Tank Building (MTB) Liquid Release Monitor (EMF-57) were calculated and reported to the Control Roctr. A source check of EMF-57 was performed. The monitor trip setpoints were adjusted to the calculated activity level After confirming that a sufficient volume of dilution water was flowing and notifying Operations that the release was ready to commence, the liquid waste was discharged from the plant. The inspectors determined that the discharge was performed in accordance with written procedures, The inspectors toured the MTB, the new liquid radwaste facility, with a cognizant licensee representative and discussed operation of the facilit The MTB became operational in July 1990 upon completion of staff training in the areas of system operation, liquid waste releases, and monitor calibrations. The first release took place en July 19, 199 No violations or deviations were identifie . External Exposure Control (83750) , TS 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. Health Physics Procedure HP/0/B/1000/25, Catawba Nuclear Station High Radiation Area Access, requires each entrance to a high radiation area to be locked to prevent unauthorized entry and that the area remain-locked-except during periods of access by personne The inspectors reviewed Problem investigation Report No.: 1-C91-0035 which documented a high radiation area (HRA) door in the U1 Auxiliary Building Room 238, Post Accident Liquid Sampling Sump Room, which was inadvertently left onen and unattended for upproximately five minutes on January 17, 1991, rvey results taken on January 15, 1991, indicated general area dose rates
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of 175 mR/hr. Surveys taken on Janurry 18, 1991, indicated general area dose rates of approximately 100 mR/hr. The door was inadvertently left open after a work crew and chemistry technician left the area. The licensee's corrective action actions to prevent recurrence included the following:
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HRA door keys issued to chemistry personnel will only be used by chemistry personne * HRA doors can only be physically held open by individuals to complete work activities and not by any other physical mean ' Check the HRA door locking mechanism following each closure of a HRA doo The above corrective actions were passed verbally to all chemistry crews during the week of February 4,1991. In addition, the chemistry technician involved was tasked with developing a Chemistry Significant Event Report, and to develop and present the rules of conduct to chemistry supervision by April 4,1991. The Chemistry Manual Section 2.2.8 will be revised to include the rules of conduct by February 21, 1991. The licensee discussed the corrective actions with the resident inspector on February 1, 199 The inspectors reviewed past inspection reports for similar violation Inspection Report 50-413, 414/89-16 documented a violation for failure to lock a high radiation area door to prevent unauthorized entry, however, the primary root cause of that event was the mechanical failure of the door closer and latching mechanis Since the criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfied, the failure to maintain locked a posted high radiation area (U1, Auxiliary Building, Room 238) in accordance with HP/0/0/1000/25 was considered as a licensee-identified violation (LIV). The licensee was made aware of this LIV during a telephone conversation on February 12, 1991 (LIV: 50-413/91-02-01).
12. Solid Radioactive Waste (86750) 10 CFR 20,311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.56. It further establishes specific requirements for conducting a quality control progra The inspector reviewed the licensee's solid radioactive weste management program, including: adequacy of implementing procedures to properly classify and characterize waste, prepare n.anifest , and mark packages, overall performance of the process control and quality assurance programs, and the-adequacy of required records, reports, and notifications. In addition, the inspector reviewed the methods used by the licensee to assure that waste was
properly classified, met the waste form and characteristic requirements of 10 ,
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.. . 12 CFR 61 and met the disposal site license conditions, and discussed the use of these methods with licensee representative No violations or deviations were identifie . Transportation Of Radioactive Material and Low Level Weste for Disposal (86750)
10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who delivered licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Ocpartment of Transportation in 49 CFR Parts 170 through 18 The inspectors reviewed selected records of radioactive waste and radioactive materials shipments performed in 1990. The shipping manifests examined were consistent with the 49 CFR requiren,ents. The radiation and contamination survey results were within the limits specified for the mode of transport and shipment classification and the shipping documents were being completed and maintained as require The inspectors reviewed plant procedures for the preparation, documentation, shipment and receipt of radioactive material and verified that the procedures were consistent with the regulation No violations or deviations were identifie . Plant Data (83750)
-The inspectors reviewed records of personnel contamination events (PCEs) for 1990. In calender year 1990, the licensee experienced 430 PCEs which was within the annual goal of 517 PCEs, As noted in IR 50-413, 50-414/90-23, the number of reportable PCEs has been increasing since 1987. The number of PCEs since 1987 are summarized below:
E LEAR PCEs 1987 210 1988 281 1989 361 1990 430 The licensee was well aware of this~ increasing trend and the radiation protection staff had performed extensive investigations and implemented several controls to help reduce the nut'er of PCEs, These additional control measures were discussed in IR 50-413, 00-414/90-23. The success of these additional control measures will be reviewed during subsequent inspection In addition, it was noted that the licensee had been aggressive in minimizing the contaminated floor space in the Auxiliary Building. As of December 31, 1990 the area of the plant contaminated was 6,125 square feet out of a total '.
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area of approximately 165,000 square feet. In 1989 and 1988, the contaminated floor space was approximately 5,800 and 15,600 square feet, respectivel The inspectors discussed with licensee representatives the total annual collective dose against their goals . The station's 1990 collective dose goal (revised) was 863 person-rem (431.5 person-rem / reactor). As of December 31, 1990 the station collective dose was 810 person-rem (405 person-rem / reactor).
The licensee's 1991 station collective dose goal was 738 person-rem, which includes two refueling outage The 1990 collective dose was attributable to two refueling outages (U1 E004 and U2 E003). The U1 E004 outage accounted for approximately 73% of the
- station's collective dose- (589 person-rem). The licensee did not achieve -
their outage goal of 480 person-rem for various reasons which are summarized below:
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The dose rates encountered were higher than anticipated, possibly due to . an inadequate reactor water cleanup / filtration cycle following the crud releas * The person-hour estimatas for some activities were exceeded due to increases in the work scope and low initial estimate * The addition of unplanned work, for example, leaking conoseal repair and decontamination activities following spill The outage duration increased from 65 to 88 day It should be noted that the licensee removed and replaced thc resistance temperature detectors (RTDs). RTD removal / replacement accounted for approximately 29% of the total outage collective dose (171 person-rem). The other large collective dose contributor was steam generator (S/G) maintenance work which accounted for approximately 31 percent of the total outage collective dose (181 person-rem). The original scope of the S/G work was increased to include eddy current testing of each hot leg tube sheet and to pull the S/G tubes from "C" steam generato The following summarizes the outage activities for V1 EOC4 resulting in the highest collective dose (person-rem): ACTIVITY COLLECTIVE DOSE (person-rem)
$/G Maintenance Work 181 RTD Removal / Replacement 171 Valve Maintenance 48
, Reactor Head Removal / Replacement 18 Valve Testing 13 ! Lower Containment Decon 12 Lower Containment RP Coverage 12 , s
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The licensee's three year average collective dose (1967-1989) was 315 person-rem / reactor which was below the national average for pressurized water reactors during the same time period (336 person-rem / reactor). As indicated above, the licensee's three year average collective dose for 1988-1990 had increased to 376 person-rem / reactor. Data were nct available to determine the 1988-1990 three year national average collective dose for PWR . Information Notices (92701) The inspectors determined that the following Information Notices (ins) had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate was taken or scheduled: IN 90-08: Kr-85 Hazards from Decayed Fuel IN 90-31: Update on Waste Form and High Integrity Container Topical Report Review Status, Identification of Problems with Cement Solidification, ard Reporting of Waste Mishaps , IN 90-33: Sources of Unexpected Occupational Radiation Exposures at Spent Fuel Storage Pools IN 90-35: Transportation of Type A quantities of Non-Fissile Radioactive Materials IN 90-47: Unplanned Radiation Exposures to Personnel Extremities due to , Improper Handling of Potentially Highly Radioactive Sources IN 90-49: Enforcement Policy for Hot Particle Exposures 16. Licensee Actions on Previously Identified Inspector Findings (92701 'and 92702).
(Closed) VIO 50-413, 414/90-02-01: Failure to assess alpha contamination, in accordance with licensee procedure HP/0/B/1006/09, for the_HICS utilized in radioactive waste shipments 89-48 and P9-49. The inspectors reviewd the licensee's response to the aforementioned violation in a letter to the NRC dated April 5,1990. That letter described the licensee's ccrrective actions which had been taken and the results achieved to correct the problem and similar future problems. The inspectors verified that the corrective actions were implemented. This item is considered close (Closed) IFl 50-413, 50-_414/90-02-02: Review the licensee's ALARA Group implementing procedures. IR 50-413, 50-414/90-02 indicated that Station Directive 3.8.1 ALARA Program, did not adequately describe the corrective action process for problems identified on ALARA Job Observation Reports (AJOR). Additionally, the licensee did not have any additional ALARA Group procedures for implementing other requirements of Station Directive 3. Licensee representatives committed to the development of an ALARA Group procedure that would provide the group necessary guidance and instruction to achieve the requirements of the Station Directive. The inspectors noted that .
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. '* 15 the licensee developed and implemented health physics procedure HP/0/B/1000/39, " Radiation Protection ALARA Planning Activities," August 30, 1990. This procedure incorporated the requirments prescribed in Station Directive 3.8.1. This item is considered close ,
17. Exit Meeting The inspectors met with licensee representativts (denoted in Paragraph 1) at the conclusion of the inspection on January 17, 1991. The inspector summarized the scope and findings of the inspection, including the licensee identified violations which were discussed during a telephone conversation on February 12, 1991. The inspectors also discussed the lik informational content of the inspection report with regard to documen processes reviewed by the inspectors during the inspection. The lict-not identify any -such documents or processes as proprietary. Diss- * comments were not received from the licensee. The inspectors in -o licensee representatives that the previously identified inspector fins u Paragraph 16 were considered closed.
I Item Number Descriptjonto a_nd_ Reference 50-413/91-02-01 LIV: Failure to maintain locked a poste( high radiation area door in accordance wic HP/0/8/1000/25 (Daragraph 11).
' i - l 50-413/91-02-02 LIV: Failure to perform a surveillanc on- ' radioactive gaseous effluent monitor M58 as required by TS 4.3.3.11 (Paragraph 6.c).
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