ML14175B023
| ML14175B023 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/16/1979 |
| From: | Gibson A, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B024 | List: |
| References | |
| 50-261-79-01, 50-261-79-1, NUDOCS 7903280087 | |
| Download: ML14175B023 (8) | |
See also: IR 05000261/1979001
Text
REG&
UNITED STATES
o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30303
Report No.:
50-261/79-1
Licensee:
Carolina Power and Light Company
411 Fayetteville Street
Raleigh, North Carolina 27602
Facility Name: H. B. Robinson Unit 2
Docket No.:
50-261
License No.:
Inspection at H.
.
nson. ite
Inspector:
-;
02//
G
.
/
/Date
Signed
Approved by:
A. . Gibson, Section Chief, FFMSB
Date Signed
SUMMARY
Inspection on January 8-12, 1979
Areas Inspected
This routine unannounced inspection involved 31 inspector-hours onsite in the
areas of effluent control instrumentation, filter testing, tests of reactor
coolant and secondary water, and followup on previous noncompliance, unresolved,
and inspector identified items.
Results
Of the 5 areas inspected, no apparent items of noncompliance or deviations
were identified.
790328 0 0'g7
DETAILS
1.
Individuals Contacted
- R. B. Starkey, Plant Manager
- D. S. Crocker, E&RC Supervisor
- C. W. Crawford, Maintenance Supervisor
- H. S. Zimmerman, Engineering Supervisor
- J. M. Curley, Senior Engineer
R. Dayton, Engineer
D. R. Gainey, Jr., RC&T Foreman
W. L. MacCready, Engineer
J. Sawyer, Engineering Technician
One Reactor Operator
One RC&T Technician
One I&C Technician
- Denotes those present at the Exit Interview.
2.
Licensee Action on Previous Inspection Findings
(Closed) Open Item (78-21-02) Radiological controls associated with fuel
cask loading. An inspector toured the fuel building, reviewed radiation
work permits and records of contamination surveys on crane hook and yoke.
This item is closed (Details I, paragraph 4).
(Closed) Infraction (78-23-02) Waste drums not smeared prior to shipment.
By review of contamination survey records and discussion with RC&T per
sonnel,
an inspector verified corrective actions as stated in CP&L's
letter of November 27, 1978.
(Closed)
Unresolved Item (78-23-03)
Interpretation of "package"
for
spent fuel shipments.
An inspector reviewed records of recent spent
fuel shipments to Brunswick Plant,
and discussed the NRC position
relative to "package"
interpretation as applied to Certificate
of
Compliance No. 9001.
This item is closed (Details I, paragraph 5).
(Closed)
Open Item (78-28-01)
Computer errors in gas effluent calcu
lations. An inspector reviewed an RC&T memorandum which documented the
licensee's review of effluent gas data. The review identified errors in
both plant vent and condenser off-gas data, but concluded that they were
conservative and well within the total estimated error of plus/minus 10
percent.
The inspector had no further questions.
-2
3.
Unresolved Items
No new unresolved items were identified during this inspection.
4.
Radiological Controls Associated with Fuel Cask Loading (78-21-02)
An inspector toured the fuel handling building and reviewed status of
the following activities which were previously discussed (RII Report
Number 50-261/78-23) with the E&RC Supervisor:
a.
Availability of frisker. At the time of the tour by the inspector,
no frisker was available in the change area at the base of the
stairs leading to the fuel building, although an operator was in
the fuel building in anti-C clothing.
An RC&T foreman said that a
frisker had been located there, but was relocated to the cask decon
area after the fuel cask was removed from the fuel building.
The
inspector stated that a frisker should be available at the base of
the stairs anytime that personnel have to exit from the fuel building.
The RC&T foreman concurred and had a frisker installed in that
location.
b.
Contamination surveys of crane hook.
By review of contamination
survey records and discussion with an RC&T foreman, an inspector
verified that the cask crane hook and yoke had been surveyed and
decontaminated after the three most recent cask loading evolutions.
c.
Radiation Work Permits (RWP). An inspector reviewed about 18 RWP's
issued during December, 1978, for work in the fuel building or cask
decon area. The specificity of protective clothing requirements on
the RWP's appeared to be adequate.
The inspector had no further questions on this item.
5.
Spent Fuel Shipments (78-23-03)
a.
An inspector reviewed shipping documentation associated with trans
fers of spent fuel from H. B. Robinson to Brunswick made on December 6,
1978, December 15,
1978, and January 2, 1979.
The inspector noted that
radiation survey records for each shipment were being maintained, as
well as contamination survey records for the cask and railcar.
b.
The inspector had previously questioned CP&L's interpretation that
the aluminum enclosure,
rather than the spent fuel cask is
the
"package" for purposes of determining contamination levels and the
transport index of a shipment.
Based on subsequent guidance received,
the inspector stated that the aluminum enclosure was an acceptable
reference point for monitoring radiation levels external to the
-3
package, but that "the external surfaces of the package" for radio
active contamination purposes should be considered to include the
cask surface.
Licensee management acknowledged the inspector's
comments. The inspector's review of fuel shipment records during
this inspection as well as during the inspection of October 2-6,
1978 revealed no case where the fuel cask was not surveyed for
contamination both prior to shipment and upon receipt, and revealed
no case where the cask surface contamination exceeded 22,000 dpm/100
square centimeters.
The inspector had no further questions.
6.
Effluent Control Instrumentation
a.
Radiation Monitor Tests and Calibration
Technical Specification Table 4.1-1 requires that the radiation
monitoring system be checked daily, tested monthly, and calibrated
at refueling intervals. An inspector reviewed completed P.T.12.1,
"RMS Daily Check" for the first week of each month of fourth quarter
1978;
completed P.T.12.2,
"RMS
Bi-Weekly Test" for the fourth
quarter,
1978; completed P.T.12.3,
"Process Monitor Source Check
(Bi-Weekly)"
for the fourth quarter, 1978 and completed P.T.29,
"RMS
Refueling Interval (Calibration)" for the 1978 refueling.
Based on this review,
the inspector stated that the licensee
appeared to be in compliance with item 19 of TS Table 4.1-1.
The
calibrations for gaseous monitors R-12, R-14, R-20 and R-21 were
completed in August 1978 as discussed in RH Rpt.
Nos. 50-261/78-13
and 50-261/78-23; the other monitor calibrations were completed in
March 1978, except R-18 which was replaced and calibrated in May 1978.
During review of the Periodic Tests described above, the inspector
offered comments and suggested improvements to P.T.12.2 and P.T.29;
these were acknowledged by the cognizant licensee representatives.
b.
Correlation of Monitor Readings with Laboratory Measurement of
Concentrations
In response to the inspector's questions, licensee representatives
said that, although some monitor comparisons have been made at
times in the past, there is no program established for periodically
correlating process monitor readings with laboratory measurement of
concentrations.
The inspector said that such correlations are
important to establish and maintain confidence that the monitor
calibration curves, which are determined infrequently and, in some
cases, with point sources, accurately reflect the monitored concen
trations. The E&RC Supervisor concurred,
and stated that a more
formal correlation program would be established for periodically
evaluating the monitors for systems where radioactive samples could
be obtained (79-01-01).
-4
c.
Settings for Trips and Alarms
An inspector reviewed Standing Order No.
4,
"Radiation Monitor
Setpoints", which sets forth area and process monitor setpoints,
their basis,
and the mechanism for changes.
At the inspector's
request, a
reactor operator demonstrated the process monitor
setpoints on January 11, 1979; these were compared with the values
on the current Setpoint Log and no discrepancies were identified.
Three setpoints are established for the liquid effluent monitor
(R-18),
with the selected setpoint based on the number of circu
lating water pumps running at the time of a liquid discharge. The
procedure does not specify reducing the setpoint to its minimum
value during periods when no release is in progress. The inspector
stated that this would be good practice, to provide an earlier
alarm in the event of an unanticipated release.
Management repre
sentatives agreed and stated that a procedure change would be made
if evaluation showed no adverse operational problems (79-1-2). The
inspector had no further questions regarding setpoints.
d.
RMS Trip Circuitry
An
inspector questioned
licensee
representatives
regarding a
situation at another facility where the radiation monitor system
trip relays were found to be not failsafe.
Based on a schematic
review and discussion with an I&C technician, the inspector deter
mined that loss of circuit power will actuate the trip functions
for the H. B. Robinson RMS system.
7.
Testing of Air-Cleaning Systems
a.
An inspector reviewed P.T.24.0, "Fans and Associated Charcoal and
Absolute Filters (Refueling and Filter Change)"
for the 1978
refueling outage. The test was completed on March 20, 1978, and
results approved on April 9,
1978.
The inspector also had dis
cussions
with the
cognizant
Engineer,
Senior
Engineer,
and
Engineering Supervisor regarding the test program.
b.
Technical Specification Table 4.1-3,
Item
14,
specifies testing
fans and filters for the control room and RHR compartments at each
refueling shutdown. The review of P.T.24.0 verified that fan and
charcoal and HEPA tests were conducted and met the specified accep
tance criteria for the control room ventilation and the auxiliary
building charcoal systems.
c.
Technical Specification 4.12.1 requires pressure drop and air
distribution tests be conducted each operating cycle for Spent Fuel
Building and Containment Purge filter systems.
The- review of
P.T.24.0 verified that these tests were conducted and met the
acceptance criteria.
0I
-5
d.
Technical
Specification
4.12.2.a.
states:
"The tests of
Specification 3.8.2.a for the refueling filter systems shall be
performed initially and at least once per operating cycle, prior to
each refueling outage operation or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system
operation".
Technical Specification 4.12.2.b states:
"The tests
and sample analysis of Specification 3.8.2.b for the refueling
filter systems shall be performed initially, at least once per
operating cycle prior to each refueling outage operation or after
every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation,
and following significant
painting,
fire,
or chemical
release in
any ventilation zone
communicating with the filter systems."
Neither the in-place tests
(T.S. 3.8.2.a) nor the laboratory carbon test (T.S. 3.8.2.b) were
performed for the Spent Fuel Building filter system during the 1978
refueling outage. A "Comments Section" in P.T. 24.0 states that
due to the fact that HV-EA had been operated for less than 720
hours and the possibility of exceeding this limit prior to the next
refueling is remote,
the system was not subjected to the in-place
or iodine removal tests.
The Engineering Supervisor stated that
the licensee interpreted T.S. 4.12.2.a and b as not requiring the
tests as long as 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of filter system operation had not been
exceeded.
He stated this interpretation was influenced by discussions
he had with NRC licensing personnel at the time (1973 or 1974) this
technical
specification was revised.
This interpretation
was
discussed and approved during a PNSC meeting on February 20, 1978.
The Engineer responsible for filter testing stated that, while
attending a course on filter testing in late Spring or early Summer,
1978, he talked informally with NRC representatives and was informed
that the tests should be conducted at least once each operating cycle.
Subsequently, he began drafting a proposed change to the technical
specification to clarify its intent; that proposed change is still in
draft form.
When questioned, the Engineering Supervisor stated that
he still believed his interpretation to be correct at that time and
did not consider having the tests done at that time (Summer, 1978),
even though spent fuel was being handled frequently throughout C-1978
for transfer to the Brunswick Plant.
On January 18,
1979,
the
inspector contacted the Plant Manager by telephone and stated that
RII management had concluded that T. S. 4.12.2.a and b were worded
and punctuated sufficiently vague to technically permit the licensee's
interpretation and, for this reason, no noncompliance had occurred.
The inspector stated that the intent of the technical specification
was to require testing at least once per operating cycle, and more
frequently if
720 operating hours were reached.
The Plant Manager
stated that a proposed Technical Specification change to clarify
T.S. 4.12.2, along with a number of other sections, will be sub
mitted in the future. He stated that, until the Technical Speci
fication is
revised,
the testing will be accomplished at least
-6
each
operating
cycle
if
720
operating hours have not been reached,
and confirmed
that
this
will
commence with
the
1979
refueling
outage.
The inspector had no further questions.
e.
Technical Specification 3.8.2.b states, in part, that the results
of laboratory carbon sample analysis from the Containment Purge
filter system shall show >90% radioactive methyl iodide removal at
0.05 to 0.15 mg/m 3 inlet methly iodide concentration.
The carbon
in the containment purge system was replaced during the 1978 refueling
outage.
In reviewing test data, performed in November, 1977, by a
sub-contractor, the inspector noted that the carbon was tested at
an inlet methyl iodide concentration of 2.0 mg/m 3 .
A licensee
representative said that this was done pursuant to a statement in
the Basis for T.S. 4.12 which states:
"If test results are unaccep
table, all adsorbent in the system shall be replaced with an adsorbent
qualified according to Table 1 of Regulatory Guide 1.52".
R.G. 1.52
(June 1973), Table 1 references RDT Standard M16-1T, which specifies
an upstream methyl iodide concentration of 1.5 to 2.0 mg/m 3 .
By
telephone on January 18,
1979,
the inspector informed the Plant
Manager that the methyl iodide test was acceptable as performed,
based on the guidance provided in the Technical Specification Basis
as well as the fact that the test concentration used did not degrade
the quality of the test and met accepted industry practice.
The
Plant Manager stated that the proposed technical specification
change discussed in
paragraph d.,
above would eliminate
any
discrepancy between T.S. 3.8.2.b and the Basis to T.S. 4.12.
He
stated that, in the interim, testing of charcoal samples would be
conducted under the conditions
specified
in T.S.3.8.2.b.
The
inspector had no further qeustions.
f.
The inspector identified no items of noncompliance associated with
T.S.3.8.2 or T.S. 4.12.2.
8.
Tests of Reactor Coolant and Secondary Water
An inspector reviewed Daily Chemistry Reports for the 4th quarter 1978,
and verified that chemistry and radiochemistry sampling met or exceeded
the requirements of T.S. Table 4.1-2,
Item 1, that the reactor coolant
activity limit of T.S.3.1.4 was not exceeded,
and that the reactor
coolant chemistry limits of T.S.3.1.6 were not exceeded.
The inspector
also reviewed the Chemistry Reports for September 1978, and verified
that the secondary water activity did not exceed the limit of T.S.3.4.2
during the most recent steam generator tube leak of September 21,
1978.
-7
9.
Air Supply for Respirators
In response to the inspector's questions, the E&RC Supervisor said that
instrument air is
used to supply respirators for air-line operation.
Based on discussion with the E&RC Supervisor and an I&C technician, the
inspector stated that there appeared to be no mechanism where this
breathing air could become radioactively contaminated.
10.
Exit Interview
The inspector met with management representatives (denoted in paragraph
1) on January 12,
1979,
and discussed the scope and findings of the
inspection. In addition, matters relating to testing of air-cleaning
systems were discussed with the Plant Manager by telephone on January 18,
1979.