IR 05000416/1990005

Insp Rept 50-416/90-05 on 900326-30.Violation Noted Re Failure to Obtain NRC Approval for Disposal of Slightly Contaminated Licensed Matl.Major Areas Inspected:Liquid & Gaseous Radiological Effluents & Plant Chemistry

ML20043A024
Person / Time
Site:	Grand Gulf
Issue date:	04/30/1990
From:	Decker T, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20043A020	List: IR 05000416/1990005
References
50-416-90-05, 50-416-90-5, NUDOCS 9005170204
Download: ML20043A024 (9)

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UNITED Sk ATE 8 -

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NUCLEAR RE!ULATZ3Y COMMCION :

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101 MARIETTA STMEET,N.W,

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NAY 0o,1990

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Report No.: 50-416/90-05-

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Licensee:. System Energy Resources, Inc.

Jackson ~, MS 39205 Docket 410 :

50-416.

License'No'.:.NPF-29--

l Facility Name:' Grand' Gulf Inspection Conducted:

arch 26-30, 1990:-

Inspector: Y

6 h7 YT Wrston Date~ igned j ~84

' Approved by: \\

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Date 31gned T

Radiological Effluents and: Chemistry Section

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Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY-

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Scope:

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This routine, unannounced inspection was conducted in the areas of-liquid anci;

gaseous radiological-effluents, plant chemistry, and radwaste: processing.

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Results:.

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The.11 cense'e appeared to ;have maintained: an ' adequate program to. control.

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radioactive effluents and plant chemistry parameters. One non-cited violation was j

identified for failure to obtain NRC approval for. disposal of 'slightly.

contaminated oil,containing licensed material (Paragraph 12).

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REPORT DETAIL.

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Persons ~ Contacted-Licensee Employees

• L. Daughtery,-Compliance Supervisor

• J. Dimmette, Jr., Manager - Plant Maintenance-B'. Edwards, System Engineer

• C, Elsaesser, Operations Superintendent C. Hayes,- Acting Audit Supervisor

• T. Hildebrandt, Radiation Protection Superintendent

• M. Humphries. System Engineer. Supervisor:

• C.'Hutchinson, General Manager

'J. Lassetter, Count Room Specialist M. Michalski, Radwaste Supervisor

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• J.-Parrish,' Manager, Plant Operations ll

• T. Reaves Director, Nuclear Support

• J. Roberts, Manager - Performance'and System Engineering i

• G. Smith, Chemistry Superintendent

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• J. Summers, Compliance Coordinator-q

• S. Tanner, Manager, Quality Services

• T. Williamson, Chemistry Supervisor

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• G. Zinke, Plant Licensing Superintendent

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NRC Resident Inspectors

• H. Christensen, SRI j

• J. Mathis, RI

• Attended exit interview

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Audits (84750)

Technical Specification (TS) 6.5.2.1, Safety Review Connittee (SRC)

Function, requires that the SRC shall function to provide independent

review and audit of designated activities in the areas of (in part):

chemistry and radiochemistry

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metallurgy instrumentation and control

radiological safety

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quality assurance practices

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The inspector reviewed the following Quality Assurance Audits-which were i

conducted subsequent to the last inspection in the areas within the scope of this inspection:

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QSA - 89/0020, Quality Systems Audit of Nuclear Licensing; Plant Management / Nuclear Regulatory Consission Reporting Requirements, l

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Secjions 6.7 and 6.9, conducted October 10 through October 20, 1989.

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This audit identified some minor administrative faults, i

QSA 1-' 89/0018, ' Regulatory Guide J4.15, Quality Assurance for

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Radiological. Monitoring Programs - Effluent Streams. and the

Environment; conducted September 14 through October 2.1989.

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audit identified three record-keeping errors, and covered:the; areas--

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of chemistry and. instrument & control procedures,. chemistry personnel

.recertification, review of.intralab results, calibration and quality'

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contro1 ' records.: standard preparation'and computer checks. The audit also reviewed; determination of setpoints and - software - control.

[regardingg EffluentJTechnical Specification = and' Offsite Dose'

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Calculation Manual -(0DCM) calculations).

Some - errors in: dose l calculations and software quality control problems were. identified.-

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QSA

.89/0064, Chemistry Section, Plant Staff / General Chemistry and-Plant Staff Programs, conducted August 10-through' September 8,1989.

Weaknesses were, identified ~ in : controiL and j tracking Lof non-TS -

commitment items - andLin failurei of Chemistry Procedures to ' address use of survey. instruments:while taking samples.

QSA - 90/0003, Radiological and Environmental Services /Radiologicall Environmental Monitoring Program; Nonradiological Environmental Protection Plan',' conducted January 5 through February 7,.1990.

The Acting Audit Supervisor stated that the Negative Findings were not at i

a level to requi_re a formal response, and that, for most cases,. corrective

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action had been teken before the end of the audit.

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The audits performod included both positive and negative findings, and-l observation / comments (for improvement).

The inspector also reviewed the

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checklists for-the audits reviewed, and determined that the audits were-

thorough and comprehensive enough to' identify any programmatic weaknesses that might exist.

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No violations-or deviations were identified.

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Changes to Chemistry Program (84750)

i The inspector discussed changes to the chemistry-program which took place.

0 since the last inspection in this program area.(Inspection Report.

No.50-416/89-20) with the Chemistry Superintendent.

The Superintendent

'k stated that the authorized level for the Chemistry Group was 35 personnel, with 34 slots filled.

A new " clean" chemistry laboratory was in the-process of being established on the ~133 foot level of the Radwaste

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Building with an adjoining count' room. The count' room was still operating

out of the area adjacent to the Hot Lab on the 118' foot level of the Radwaste Building.

The Superintendent stated that the Hot -Lab would -

remain in the same area but with major remodeling and expansion. The ND66 l

hardware in the count room was being replaced with new Hewlett Packard

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No violations or deviations were identified.

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Count Room and Chemistry Laboratories (84750)-

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Procedures in' the 08-S-04 series specify requirements for chemistry sampling and analysis and calibration-and operation of the' chemistry laboratory and count room _ equipment.

The inspector and a Chemistry Supervisor; toured the Chemistry Laboratories-

and the Count Room.

The:new Clean Lab and Count Room were located-on the 133 foot level of' the Radwaste Building.-

being set up _ and were not yet operational. The lab and count-rocm were.The H

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. Count Room: were located on the 118 foot level of the Radwaste. Building.-

The Count Room still had two operational gamma spectroscopic systems;'one had.been transferred up to-the' new count room but. was not -yet in _

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' operation.

The Hot Lab was equipped with three. hoods, one_PE:5000 Atomic Absorption Spectrophotometer,, two PE UV/VIS Spectrophotometers, twoiIon Chromatographs, two - Gas Chromatographs, : one Photo-chem L Total - Organic'

Carbon analyzer, and a,NMC alpha / beta gas proportional ~ counting system.

L The inspector reviewed calibration and quality control: data: for. gamma _

L spectroscopic systems 3 and 4, which were still operational in the.'old-count _ room.

Efficiency calibrations were done for the various ' geometries during. August - September 1989' for_ Detector 3, and during August 1989 for-

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Detector 4.

The inspector also reviewed calibration. data for the'Tricarbs 460-0 Liquid Scintillation System.

The efficiency calibrations were done

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for Tritium in. January 1989, and for Iron-55. in April 1989.

The efficiency calibrations for these systems had been done approximately one

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year apart as required by the procedures, t-Quality control data and control charts for the~ gamma spectroscopic j

L systems were also reviewed by the inspector. The checks appeared to have'

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been done at required frequencies and maintained within specified limits, i

No violations or deviations were identified.

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ProcessandEffluentMonitors(84750)

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TS 3.3.7.11 requires that the radioactive liquid effluent monitoring instrumentation channels shown in Table 3.3.7.11-1 shall be operable with

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their alarm / trip setpoints set to ensure that the limits of Specification 3.11.1.1 are not exceeded.

TS 4.3.7.11 requires that Leach radioactve

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l liquid effluent monitoring instrumentation channel shall be demonstrated L

operable by performance of the channel check, source check, channel calibration and channel functional test operations -at the frequencies

shown in Table 4.3.7.11-1.

TS 3.3.7.12 requires that the radioactive L

gaseous effluent monitoring instrumentation channels shown in '. Table

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L 3.3.7.12-1 shall be operable with their alarm / trip setpoints' set to ensure l

that the limit of Specification 3.11.2.1 are not exceeded.

TS 4.3.7.12-i requires that each radioactive gaseous effluent monitoring instrumentation

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channel shall be demonstrated operable by performance of the channel

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i check, source check, channel. calibration and channel functional test

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operations at the frequencies shown in Table 4.3.7.12-1.

-The inspector reviewed documentation showing the latest. calibration for

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the'following monitors on the following dates:

June 6, 1989 F.uel Handling Area Gaseous Monitor. Calibration'

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July ll,t1989.-

Radwaste Bui.1 ding' Ventilation ' Gaseous Monitor Calibration'

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Standby Ser'vice Water Loop A Liquid Process Monitor

Calibration i

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Turbine

. Building-Ventilation Gaseous Monitor Sep. 6, 1989

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l Calibration--

4-l Sep. 26, 1989 Main: Condenser Air Ejector Offgas Post Treatment

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Radiation. Monitor, Channel'A, Calibration

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Sep. 27, 1989 Main Condenser Air - Ejector' Offgas Post Treatment

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Radiation Monitor, Chennel B, Calibration-Oct. 6, 1989 Component --Cooling Water:. Liquid Process : Radiation

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Monitor Calibration

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Nov. 14, 1989 Offgas Post Treatment; Gaseous Monitor Calibration

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Nov. 30, 1989 Radwaste Effluent Liquid Process Monitor: Calibration

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Mar. 23, 1990 Liquid Radwaste -Effluents Radiation Monitor

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Calibration

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Mar. 25, 1990 Liquid Radwaste Effluent Setpoint Adjustment anc'

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Source Check-

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The monitors had been calibrated at the required frequencies.

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No violations.or deviations were identified.

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Count Room Quality Control (84750)

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Licensee' Chemistry Procedure 08-S-03-20, Interlaboratory Monitoring

- Program, specifies the requirements for conducting the program.

The inspector examined licensee records in the area for Calendar Year 1989 and determined that the program appeared to have been conducted in accordance with procedures.

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No violations or deviations were identified.

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Gaseous Effluents (84750)

l Technical Specification 3/4.11'.2 specifiesc requirements for gaseous

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nffluent releases and dose limits.- The, inspector reviewed Gaseous Effluent-Release ' Pemits 'and Laboratory Logs.

ReleasesLwere made from the Radwaste Building Vent,. the: Containment-Building -Vent - the; Turbine'

Building Vent, and the Fuel Handling Area Vent.; The records showed that the releases and dose calculations had been conducted in accordance with-TSs and.were within specified limits.

No violations or deviations-were identified'.

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Liquid Effluents (84750)

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Technical Specification. 3/4.11.1 specifies requirements for liquid-

effluent releases.and dose limits.

The. inspector reviewed a selection of Liquid Effluent Release Permits. The records'showed that the releases and-dose ' calculations had been conducted 'in accordance with TSs and were within specified limits.-

No-violations or deviations were identified.

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In-place HEPA and Charcoal Adsorber Testing (84750)

TS 4.6.6.3 specifies requirements for in-place HEPA filter an_d charcoal adsorber testing and laboratory. charcoal 1 testing for the standby gas

treatment subsystems (SBGTS)

and TS 4.7.2' specifies those requirements for the Control Room-Emergency Filtration Subsystems (CREFS).

The inspector reviewed test results 'for -testing.of these systems 'and discussed the testing program with a cognizant system engineer.

The records showed that the filter and charcoal testing had been done at the

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required frequencies, and had successfully passed. the tests with one exception. The charcoal sample from the CREFS, Train.A, failed:the test on May 19, 1989.

The charcoal in ' the adsorber was - replaced-with - fresh charcoal, sampled, and retested.

The.new sample passed the test on May 26, 1989.

No violations or deviations were identified.

i 10. Semiannual Radiological Effluent Report (84750)

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TS 6.9.1.8 requires that routine radioactive release reports covering the

' operation of the unit during the previous 6 months of operation shall be submitted within 60 days after January I and July 1-of each year.

l TS 6.9.1.9 specifies content and format of the report including compliance with NRC Regulatory Guide 1.21.

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The inspector reviewed the licensee's Semiannual Radioactive Effluent Release Report for the last half of 1989.

The effluent release data

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i summar17ed in Table A were obtained~ from' current' and previous release -

reports.

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TABLE A o

Effluent Release. Summary for Grand: Gulf.

GaseousEffluents(Curies)

1986'

1987 1988-1989 Fission and Activation ~ Gases-1.34E+2' 2.08E+2 9.44E+1 1.44E+2

lodines and'Particulates 9.52E-4' 4.79E-3 4.90E-4 jl.48E-3

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MuidEffluents(Curies).

't Fission and Activation Products 3.01E-1 3.66E-1 3.96E-1 3. 20E-1 --

Tritium 1.47E+1 ~1.83E+1 1.34E+1 1.32E+1

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The report appeared ' to be ? complete - and ! to Linclude the linformation '

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specified in the TS and Reg Guide 1.21^.- The: licensee did not identify any-

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unplanned liquid or. gaseous releases duringc 1989, and.alsoi di_d not

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identify any monitors-as being inoperable f_or greater than 30 days.-

The levels of effluents were changing from-one. year to_ the next, but no trends were apparent.

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r No violations or deviations were identM ied.

j 11. Solid Radwaste (84750).

A.radwaste shipment from the licensee > to-the Barnwell burial siteEwas

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discovered to contain methane gas 'on February 6,- 1989. - The111censee believed - that -the bacteria that produced this gas originated when: the Turbine Building Cooling Water Heat Exchanger system was cleaned'out'. ~The waste water was allowed to drain into the ficor drain system and:was.

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subsequently cleaned up.by the radwaste filter-demineralizer system. The i

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methane-producing organisms were' apparently trapped by the filtering material.

When the filter media and resin from the radwaste' system were-alaced in Ja 1.iner which was dewatered prior to shipment, the bacteria,

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3elieved to be anaerobic, started to produce methane..The gas caused.some-f overpressure in the shipping cask, which was relecsed when the cask-was opened on arrival at Barnwell.

Since it was against D0T Regulations to ship explosive gases with radioactive material, the ' South Carolina Department of Health and Environmental Control issued a letter of warning to the licensee, g

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- The licensee conducted subsequent tests with other liners containing;the

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radwaste' filter-demineralizer media.

The. bacteria became' activate'd after-dewatering ' and produced methane for about' five days.. Licensee representatives stated that means wereL being considered to' decontaminate-

. the. radwaste system ; of the' bacteria and-to' ensure gas would not be

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generated in-the = future -in the-liners.

A-licensee representative stated that since.the bacteria.were considered.to be anaerobic, one method would-be to; blow air through;the dewatered media in the liner,- Should this-

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fail,l application of biocides would be considered.

No' violations'or deviations were identified.

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Contaminated Oil' Burn (84750)

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10 CFR ' 20.301 requires that no L11censeen shall dispose of licensed

m6ter.ial, except; (a) by transfer to an authorized recipient-as provided:

in the regulations in other parts of thisEchapter; or.(b) as authorized pursuant to 10 CFR:20.302 or part-61 of this chapter;~or (c) as>provided

in 20.303, applicable-to the disposal of licensed material by release into

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sanitary sewerage systems, or in 20.306'for disposal of' specific wastes or in 20.106.--

The inspector reviewed NRC and licensee-documentation on the: subject' area ~

and discussed the problem with' licensee representatives.:

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In May 1989, during a conversation with a senior licens'ee management official, the Director, NMSS (NRC) learned that the utility had d:sposed

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of some contaminated turbine lubricating oil by burning lat one of-the-

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l utility's fossil fuel electric generating plants.

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Approximately 18000 gallons of oil t had. been discharged from the. turbine during turbine trips from May 1985 through January 1988.

The' oil flowed-l-into the floor sump which contained contaminated water.- The problem which.

caused the discharge.of oil' was corrected in. January 1988.

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separated ' from the water and decontaminated by physical and chemical D

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means.

The contaminated water was processed in the radwaste system,'and.

l solids, sludge, and contaminated. oil were disposed ~of as radwaste. 'There'

remained approximately 14050 gallons of-oil which the-licensee considered L

to be decontaminated and nonradioactive.

Most of this oil was burned in three burns at a fossil power plant on July 20, 1988, January 12, 1989'and

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January 17, 1989.

The licensee had determined that the nuclides present in the remainder of the oil were. Cobalt-58, Cobalt ' 60, Manganese-54,.and Iron-59.

The licensee established analytical conditions such that analyses would be

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performed with a Lower Limit of Detection ~(LLD) of SE-7 microcuries per milliliter, which was the Technical Specification:LLD'for principal gamma emitters in water effluent. The licensee considered that since detectable radioactivity'was lower than this' limit, the oil could be considered to be nonradioactive.

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t The NRC staff determined that if the radioactivity.wasl not detectable at i

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the ' environmental LLD levels,- thel oil could have.been considered-non radioactive and released.

However,; for oil with radioactivity which

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wasinondetectable at effluent levels, the provisions of 10: CFR 20.301 J

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applieds The inspector.determi.ned that a violation of 10-CFR 20.301 (b)

existed,in that the Tlicensee burned contaminated oil without. securing

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prior, approval. from the NRC or the agreement state.

Subsequent to the inspection, in - a telephone conversation with:: Regional management,-

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licensee management conmitted to. modify their; procedures to required = the use of an. environmental TLD threshold for any future - similar releases.

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Therefore, this licensee identified. violation:is not being cited because:-

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of criteria specified in Section V.G.1 of,the NRC Enforcement Policy was-

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satisfied.,

One'non-cited violation was, identified, 50-416/90-05-01:

Failure to

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obtain prior approval for; disposal of. waste con.taining licensed material.

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13.~ExitInterview(30703)

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The inspection scope and results were summarized on March 30,;1990.with.

'those persons indicated in Paragraph I'.

The ' inspector described:the areas

inspected and discussed. in detail-the inspection, results.

One non-cited violation noted failure to obtain ' a) proval: for disposal of-waste'

Econtaininglicensedmaterial(Paragrap1.12)'. This violation was discussed with licensee representatives by telephone on < April 20, 1990.: Thet

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licensee did not admit or. deny the-violation at.this time.;-No. proprietary material is contained-in this report..

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