ML090510184
| ML090510184 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/21/2005 |
| From: | - No Known Affiliation |
| To: | NRC Region 1 |
| References | |
| O2C-IPEC-2005-0257 | |
| Download: ML090510184 (3) | |
Text
/Oversight Observation Checklist 02C-IPEC-2005-0257 Assigned to: Picciano, Andy Date Performed: 11/21/2005 Duration: 3 Activity: Observations and reviews relating to the IE Bulletin 80-10 and Tritium Discovery in a Unit 2 Monitor Well Reference Audit Area: Effluent and Environmental Monitoring Reference Scope Element: Radioactive Effluent Control Related Reference Audit Area: Effluent and Environmental Monitoring Related Reference Scope Element: Radioactive Effluent Control.
Surveillance Number: QA 6 2005 IPI Feedback Provided To: Chemistry and RP CR # or WO #: Pending PCRS/LOCR Comments: Tritium Discovery in a Unit 2 Monitor Well:
IPEC is currently reviewing the cause and effect of the leakage in the Unit 2 SFP. As part of this review, existing wells were sampled. In one well, MW1 11, tritium concentrations above the drinking water standard were discovered. The well was installed to monitor transformer oil, and was utilized because it is located less than 150 yards from the Unit 2 SFB. IPEC has performed a preliminary calculation, backed up by an independent vendor to determine the effluent effect of the tritium, bounding the release to less than 0.08 Ci and 1 E-4 mrem, annually. These values will be re-assessed continuously with data from new monitoring wells established for this purpose. IPEC has not determined the effluent effect of the tritium but will know more over the next few years with routinely collected data from these water monitoring wells. The annual effluent and REMP reports will include a more detailed accounting of the tritium in the monitoring well.
Implementation of IE Bulletin 80-10 requirements by monitoring several discharge areas such as storm drains. IE Bulletin No. 80-10, "CONTAMINATION OF NONRADIOACTIVE SYSTEM AND RESULTING POTENTIAL FOR UNMONITORED, UNCONTROLLED RELEASE OF RADIOACTIVITY TO ENVIRONMENT:
IPEC is implementing the IE Bulletin 80-10 which states in part that nuclear plants are expected to identify systems that are considered as non-radioactive but could possibly become radioactive. IPEC established a routine sampling/analysis or monitoring program for these systems in order identify any contaminating events which could lead to unmonitored, uncontrolled liquid or gaseous releases to the environment.
A concern was raised. IE Bulletin 80-10 provisions are included in several site procedures, and notdescribed in one program description document (one that also addresses all variables such as cost and performance). For example, current procedures define ground and water contaminations, but do not always link them to IE Bulletin 80-10.
Chemistry is addressing the need to develop an effective monitoring program for storm drains and the monitoring wells described above. However, these actions do not include provisions for one definitive IE Bulletin 80-10 program. A recommendation for developing one program description document is suggested and will be proposed as a PCRS LOCR pending further discussion at the QA-6-2005 IPI (E/E Audit) audit briefing.
As mentioned, Chemistry is addressing the need to develop an effective monitoring program for storm drains and the monitoring wells. This action was initiated due to a 2005 Condition Report CR IP2-2005-02893. The CR was issued primarily to address the deficiencies in the implementation of HP-SQ-3.013 rev.12, "Routine Surveys outside the Normal RCA" and Addendum 8.1 "Survey Frequencies. The surveys were not being performed, and there were no guidance in the procedure for several areas such as how to collect and analyze annual sediment samples for gamma and tritium (liquid scintillation by Chemistry). The complete datafrom these surveys were not retained. Also, historical data for tritium in the Unit 2 storm drains (some of data for tritium was in the order of 2.OE-6, where other data was in the order of 5.OE-6) has not been satisfactory trended.
The corrective actions for CR IP2-2005-02893 require that a storm drain and monitor well sampling program be developed and implemented by Chemistry for IPEC. HP-SQ-3.013 was voided on 6/7/05. However, the record issued to void HP-SQ-3.013 rev. 12 incorrectly states that 0-RP-NEM-105 will replace HP-SQ-3.013. This record should be revised.
Monday, November 21, 2005 Page I of 3
Oversight Observation Checklist 02C-IPEC-2005-0257 S NA] NV I:D:
Use of fall protection in excess of 6' Gas cylinders:properly stored and.securedd El Confined space posted and proper communications maintianed based on permit requirements 0' El Vi Electrical powebrtools provided With. grou nd continuity monitor oergrund ,fault,,c~ircuit int~e-rru pter'< `1 ___V:
Adequate ventilation and protective clothing during welding/cutting or when working in electrical enclosures El E V Tho*rugh review of Work Order and Procedure with responsible crew Critical steps reviewed to prevent errors Lessonsleaed fromsimila.r a a ctivityshared Discussion of communication process to be used, Point of Contact, Notification to Operations El] I []
Asisignment of the Dual or Indepedent Verfier made before the start of.the job El l Assuring the crew was qualified to perform the tasks associated with the task assignment El - W Al!required parts and tools available prior to startingthea'ctivity Actions needed to take in the event of a problem L IntemnaLOE information. as..sociated .with :NuclearSafetyco6v~ered during, pre-job.briefing Internal OE information associated with Industrial Safety covered during pre-job briefing 1]
!ntenaed E informration associated with ,Radiological Safety*c*vered during. pre-job brie ing External OE information associated with Nuclear Safety covered during pre-job briefing "]
External OE information associated'with Industria'l Safety covered during 'pre~job briefing4/
External OE information associated with Radiological Safety covered during pre-job briefing Pre-jobi walk down-conducted, Authorization, clearance and permits approved, signed and available E.
M&T equipmentr calibrated / corirecfrarn 9ge'e Replacement parts/material are certified and identical to those they replace Weld filler material control has. been established and issue reiquisition displays all necessar data to.:assure trtaeabi t/ontinuity Vi.
Identify areas for fleet standardization El E1
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Page 2of 3 Monday, 21, 2005 November 21, Monday, November 2005 Page 2 of 3
Oversight Observation Checklist 02C-IPEC-2005-0257 Personnel implement RWP requiremhents, dosimetry placement,,frisking/WBCSs, donning &
R doffing of PCs and use of;step off pads -
P<. Radwaste is minimized by'maintaining disposable material entering the RCS Containmenticontrols &:sound: radiation work practices were continually maintained In Self-Cheeking-ldentification of Potential Error Traps . I Se H Pee'r Checking L P Team Work E Use of.STAR Use of SAFE []
E E
.1 Stop Un:safe Work, Practices PI Latest version of the procedure in use 0Placekeeping used c Strict procedure adherence . JD I [
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.?,Precautions/prerequisites are followed R Entries properly recorded C Use of 3-Point Communications
~0 Use of a Question 1sAtt.itude-Worker Attitu 1de M Face-to-Face L Management or Supervisory, Presence in the. Field E Appropriate Class of System cleanliness and level of FME is maintained E 9/[
F Housekeeping-G(enemal'debrisminimized and work area leftclean andbhazard free M Temporary plugs and dams in pipes are: Suitable Material, Adequately Secured, Properly E identified and Recorded in Work PackageaE, V Etral OEinfo associated' With -nIulclear.safety covered during p~re-job1 briefing Monday, November 21, 2005 Page 3 of 3