ML14175B298
| ML14175B298 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/13/1985 |
| From: | Montgomery D, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B297 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-261-85-15, NUDOCS 8507110235 | |
| Download: ML14175B298 (9) | |
See also: IR 05000261/1985015
Text
pR REG UZ
UNITED STATES
0
NUCLEAR REGULATORY COMMISSION
REGION i
101 MARIETTA STREET, N.W.
)
aATLANTA,
GEORGIA 30323
@**
JUN 18 1985
Report No.:
50-261/85-15
Licensee:
Carolina Power and Light Company
411 Fayetteville Street
Raleigh, NC 27602
Docket No.:
50-261
License No.:
Facility Name:
H. B. Robinson
Inspection Conduc
-
ay 20 - 24, 1985
Inspector:
( /
P. S ddart
Date Signed
Accompanying Personnel: A. Stalker (EG&G)
Approved by:
I &
"
3
D. M. Montgomer
Sec en Chief
Date Signed
Emergency Prepaidnes and Radiation Protection
Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope: This routine, announced inspection entailed 40 inspector-hours on site in
the areas of post-accident sampling system evaluation and liquid and gaseous
radwaste management.
Results:
No violations or deviations were identified.
8507110235 850618
PDR ADOCK 05000261
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
R. E. Morgan, General Manager
- J. A. Eaddy, Environmental and Chemistry Supervisor
- R. R. Hitch, Senior Specialist, Environmental and Chemistry
- K. M. Williams, Senior Engineer
- H. F. Watkins, Environmental and Chemistry Foreman
- J. C. Sturdavant, Technician Regulatory Compliance
- D. C. Stadler, Director, Regulatory Compliance
- J. M. Curley, Manager, Technical Support
- C. L. Wright, Specialist, Regulatory Compliance
B. A. Christensen, Environmental and Chemistry Foreman
D. Alleman, Engineer, Technical Support
B. MacCreedy, Project Specialist, Radiation Control
- G. Miller, Foreman, Environmental and Chemistry
- W. J. Flanagan, Manager, Design Engineering
- H. S. Young, Director, Quality Assurance
- T. Stroud, Specialist, Environmental and Chemistry
- A. McCauley, Principal Engineer
NRC Resident Inspectors
H. E. P. Krug, Senior Resident Inspector
- H. Whitcomb, Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on May 24,
1985, with
those persons indicated in paragraph 1 above. The licensee did not identify
as proprietary any of the materials provided to or reviewed by the inspector
during this inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4. Audits and Appraisals (84723.84724)
The inspector reviewed Audit Report QAA/20.42,
June 25-29,
1984,
which
included radwaste system topics under audits of Plant Technical
Specifications and the Plant Operating Manual.
No violations or deviations were identified.
2
5.
Major Changes To Plant Radwaste Treatment Systems
Technical Specification 6.17.1 requires that licensee initiated major
changes to the radioactive waste systems shall be reported to the Commission
in the Semi-Annual Radioactive Effluent Release Reports for the period in
which the safety evaluation was reviewed by the Plant Nuclear Safety
Committee (PNSC).
The
inspector reviewed the Semi-Annual
Radioactive
Effluent Release Reports for January-June 1984 and July-December
1984,
and discussed radwaste systems with licensee personnel.
No violations or deviations were identified.
6.
Procedure Reviews
Technical
Specification 6.5.1.1 requires the licensee to establish,
implement, and maintain procedures including, per Appendix A of Regulatory
Guide 1.33, Rev. 2, dated February 1978, procedures covering operations and
activities relative to liquid and gaseous
radwaste
management.
The
inspector noted that a major revision of plant procedures
had
been
accomplished since January 1984.
The inspector reviewed the following
procedures:
AP-016,
(Administrative Procedure) Radiation Work Permit Administration,
Rev. 1, January 31, 1985
RCP-103, (Radio-Chemistry
Procedure) Chi-Square Test Description, Rev. 1,
October 8, 1984
RCP-110, Gross-Alpha/Beta
Sample
Preparation
and
Analysis,
Rev. 1,
August 17, 1984
RCP-133, Determination of Radiochemistry, E-Bar, and Iodine-131 Equivalent,
Rev. 1, August 17, 1984
RST-010, (Radiation Surveillance Test), Calibration of Radiation Monitoring
System Monitor R-11, Rev. 0, April 30, 1984
RST-011, Calibration of Radiation Monitoring System Monitor R-12, R-20, and
R-21, Rev. 0, April 30, 1984
RST-012, Calibration of Radiation Monitoring System Monitor R-14,
Rev. 0,
June 28, 1984
RST-013, Calibration of Radiation Monitoring System Monitor R-15,
Rev. 0,
May 21, 1984
RST-014, Calibration of Radiation Monitoring System Monitor R-16,
Rev. 0,
May 21, 1984
RST-015, Calibration of Radiation Monitoring System Monitor R-17,
Rev. 0,
May 21, 1984
3
RST-016,
Calibration of Radiation Monitoring System Monitor R-18,
Rev. 0,
May 15,
1984
RST-017,
Calibration of Radiation Monitoring System Monitor R-19,
Rev. 0,
May 21, 1984
RST-018, Calibration of Radiation Monitoring System Monitors R-30 and R-35,
Rev. 0, June 14, 1984
RST-019, Calibration of Radiation Monitoring System Monitor R-31 A, B, C,
R-33, and R-36. Rev. 0, June 27, 1984
EMP-010
(Environmental
Monitoring Procedure) Effluent and Waste Disposal
Report, Rev. 1, March 2, 1985
EMP-011, Liquid Waste Release, Rev. 3, February 12, 1985
EMP-013, Operation and Calibration of RMS-34, Rev. 1, October 30, 1984
EMP-014, Gaseous Continuous Mode Accountability, Rev. 0, March 2, 1985
EMP-015, Completing a Gaseous Waste Release Permit,
Rev. 2, November 27,
1984
EMP-017, Gaseous Batch Mode Accountability, Rev. 0, March 2, 1985
EMP-018, RMS-36:
Gaseous High Level Sample Retrieval and Analysis, Rev. 0,
March 2, 1985
HPP-216, (Health
Physics Procedure), Operation of the
Chem-Nuclear
Services, Inc. (CNSI) Solidification Unit, Rev. 1, August 16, 1984
HPP-217, Compaction and Disposal of Wet Radioactive Waste, Rev. 1, June 14,
1984
PIC-708
(Process
Instrument Calibration Procedure)
Gas Analyzer,
Rev. 0, February 8, 1984
PIC-709, Special Alignment Procedure for the Oxygen Portion of the Gas
Analyzer Temperature Control,
Power Supply, and Amplifier
Settings, Rev. 0, March 9, 1984
PIC-707, Post Accident Sampling System Oxygen Analyzer, Rev. 2, May 4, 1984
(Chemistry Procedure), Chemistry Monitoring Program, Rev. 5,
February 12, 1985
Systems Sampling Procedure, Rev. 4, December 14, 1984
Secondary
Chemistry
Corrective
Action
Program,
Rev. 5,
December 18, 1984
4
PASS Operational Check and System Flush, Rev. 5, May 10, 1985
Post Accident Liquid Sampling, Rev. 5, May 10, 1985
Post Accident Undiluted Sample Collection, Rev. 5, May 10, 1985
Post Accident Containment Air Sampling, Rev. 6, May 10, 1985
PASS Calculation Procedure, Rev. 4, April 5, 1985
PASS Operational Test, Rev. 3, March 27, 1985
Collection and Analysis of Highly Radioactive Samples,
Rev. 1,
December 14, 1984
CPP-087, Collection and Analysis of PASS Samples, Rev. 2, April 25, 1985
EST-016, (Engineering Surveillance Test) HVE-1 Containment Purge System,
Rev. 3, October 1, 1984
EST-017, HVE-2, Auxiliary Building Exhaust, Rev. 3, April 12, 1985
EST-018, HVE-3 and 4, Containment Recirculation, Rev. 2, January 4, 1985
EST-019, HVE-5, Auxiliary Building Emergency Exhaust (ESF),
Rev. 2,
April 12, 1985
EST-021, HVE-15, Spent Fuel Pit Exhaust (Non-ESF), Rev. 1, October 29, 1984
EST-022, HVE-15A, Spent Fuel Pit Exhaust (ESF), Rev. 2, February 19, 1984
EST-023, HVE-19, Control Room Emergency Ventilation, Rev. 1, June 11, 1984
EST-024, Post-Accident
Containment Venting,
Filter
Unit 1, Rev. 1,
February 19, 1984
EST-025, Post-Accident
Containment
Venting,
Filter
Unit B, Rev. 1,
February 19, 1984
OMM-14
(Operating Management Manual), Radiation Monitor Setpoints,
Rev. 2, January 18, 1985
All of the procedures listed above had been reviewed and approved by the
appropriate management, as provided in the Specification. No violations or
deviations were identified.
. 7. Reactor Coolant Chemistry and Radiochemistry
Technical Specification Table 4.1-2 establishes sampling and analysis
frequency requirements for specific activity in reactor coolant, isotopic
analysis of reactor coolant and secondary coolant for 1-131,
1-133,
and
5
1-135,
and for tritium activity, boron,
chloride and oxygen content of
reactor coolant. The inspector reviewed sampling and analytical procedures
and examined selected analytical records and logs of reactor coolant and
secondary coolant analyses for the period of January 1, 1985 through May 1,
1985. No violations or deviations were identified.
8. Radioactive Liquid Wastes and Liquid Effluent Treatment Systems (84723)
Technical Specifications 3.9.1,
3.9.2,
3.16.1,
and 3.16.2 define the
operating requirements
and radioactive effluent limits of the liquid
radwaste treatment system.
The inspector reviewed selected liquid effluent
release permits for the period of January 1, 1985 through May 1, 1985.
No
violations or deviations were identified.
Technical Specification 4.10.1 defines the surveillance requirements for the
liquid radwaste treatment system. The inspector reviewed selected liquid
effluent permits and also analyses of liquids from batch and continuous
releases for the period January 1, 1985 through may 1, 1985.
The inspector, accompanied by licensee personnel, toured the liquid radwaste
treatment and effluent monitoring facilities.
The inspector discussed
liquid radwaste operating and maintenance experience with licensee
personnel.
No violations or deviations were identified.
9. Radioactive Gaseous Waste and Gaseous Effluent Treatment Systems (84724)
Technical Specifications 3.9.3, 3.9.4, 3.9.5, 3.16.3, 3.16.4, and 3.16.5
define the operating requirements and radioactive effluent limits of the
gaseous radwaste treatment systems, including ventilation treatment systems.
The inspector reviewed selected gaseous effluent release permits, as well as
instrumentation logs and analyses of effluent air sampling stations for the
period of January 1, 1985 through May 1, 1985.
The Semi-Annual Radioactive
Effluent Release Reports for January-June 1984,
and for July-December 1984
were also reviewed. The inspector, accompanied by licensee representatives,
toured the gaseous radwaste treatment and effluent monitoring facilities and
the radiochemical
analytical laboratory facilities.
The inspector also
discussed operational and maintenance experience with licensee personnel.
No violations or deviations were identified.
10. Radioactive Liquid and Gaseous Effluent Monitoring Instrumentation,
(84723,
84724)
a. Sampling,
and Analysis Technical Specifications 3.5.2, 3.5.3, 3.16.3,
3.16.4, 3.16.5, and Technical Specification Tables 3.5-6 and 3.5-7.6
define the operating requirements for radioactive effluent monitoring
and sampling of plant liquid and gaseous effluent streams.
The
inspector reviewed
selected logs and
records of instrumentation
maintenance and calibration activities, reviewed procedures for
instrument calibration, reviewed calibration source documentation,
and
6
discussed operating experience with licensee personnel. No violations
or deviations were identified.
b. Technical Specifications 4.1.9.1, 4.19.2, and Technical Specification
Tables 4.19-1 and 4.19-2 define the surveillance requirements for
radioactive liquid and gaseous effluent monitoring and sampling.
The inspector reviewed selected logs and records for the performance of
calibration and functional test operations and discussed operating and
maintenance experience with licensee personnel.
No violations or
deviations were identified.
11.
Engineered Safety Feature HEPA and Charcoal Filtration Systems (84724)
Technical Specifications 3.8.2, 3.15.1, 4.12, 4.15 and Technical Specifica
tion Table 4.1-3 define the operating and surveillance requirements for
Engineered Safety Feature
and charcoal filtration systems.
The
inspector reviewed selected logs and records of system DOP and halogen leak
tests and of methyl iodide retention efficiency tests of system charcoal
absorbers.
The inspector discussed maintenance and operating experience
with licensee personnel.
No violations or deviations were identified.
12.
Record Retention
Technical Specification 6.10 requires the licensee to retain records of
gaseous and liquid radioactive material released to the environment for the
duration of the operating license.
The inspector verified from selected
records of liquid and gaseous effluent releases made during the period from
January 1, 1985,
through May 1, 1985,
that the records required by the
Technical Specification were retained in terms of frequency and content and
were accessible for recall and review.
No violations or deviations were
identified.
13.
Post-Accident Sampling System (PASS) Evaluation
The H. B. Robinson facility PASS was designed and built by Combustion
Engineering. NUREG-0737,
Item II.B.3 established eleven criteria for the
PASS. These criteria specify types of samples to be taken, sampling times,
types, accuracies, and sensitivities of sample analyses, radiation dose to
operators,
and design
consideration.
The inspector evaluated the
H. B. Robinson facility PASS against the eleven criteria.
Through review of. selected records,
observation of sampling equipment
operation, discussions with licensee representatives, and inspection of the
installed system, the inspector verified that the PASS criteria have been
met except as noted below.
a. NUREG-0737, Item II.B.3, Criterion (1), states that the licensee shall
have the capability to obtain and analyze reactor coolant and contain
ment atmosphere samples within three hours.
The licensee demonstrated
the ability to obtain reactor coolant and containment atmosphere
7
samples and to complete the analysis of each within a three hour time
period.
b.
Item II.B.3 Criterion (3) states that PASS samples shall
not require an isolated system to be placed in operation in order to
use the PASS. The reactor coolant and containment atmosphere post
accident sampling systems are designed so that no isolated auxiliary
system is required to be placed in operation in order to use the PASS.
c. NUREG-0737, Item II.B.3, Criterion (2b) states that the licensee shall
be able to measure hydrogen levels in the containment atmosphere. The
licensee has two redundant safety grade hydrogen analyzers in service
at all times. These instruments are separate from the PASS and do not
require any other system to be in service for operation. The analyzers
were operated and were able to draw samples; however, no hydrogen was
present in the containment atmosphere and sample results showed zero
readings.
Both analyzers had been satisfactorily calibrated against
known concentrations of hydrogen gas.
d. NUREG-0737,
Item II.B.3, Criterion (6) states that personnel shall be
able to obtain samples from the PASS and not exceed a radiation dose of
5 Rem whole body or 75 Rem to the extremities.
Evaluations of dose
rates at the PASS control panel were made by both the licensee and the
system vendor. Both evaluations concluded that samples can be taken
without exceeding
the specified doses.
However,
the inspector's
examination of these evaluations indicated the following:
(1) The shielding studies included in the evaluations apparently did
not include RCS and containment atmosphere sample piping external
to the PASS panel.
The areas of concern are the rear of the PASS
panel, where brief personnel access is required for the operation
of one manually-actuated valve, the "pipe alley" adjacent to the
PASS panel, and the reactor auxiliary building access hallway.
(2) Doses from a two foot long section of a reactor coolant sampling
line have apparently not been evaluated with respect to direct
radiation from an unshielded line-of-sight path to the hallway in
front of the
operating panel.
The licensee agreed to
evaluate these concerns.
This inspector followup item will be
reviewed during a future inspection (50-261/85-15-01).
Revision 3, recommends analyses for pH.
The
licensee measured the pH of the reactor coolant with the following
results:
Normal Sample Point
pH
6.3
6.4
8
f.
NUREG-0737, Item II.B.3, Criterion (8) states that if inline monitoring
is used for any sampling and analysis capability, the licensee shall
provide backup sampling, through grab sampling.
The licensee demon
strated the capability to take and analyze both a diluted grab sample
and an undiluted grab sample of the reactor coolant.
A diluted grab
sample of containment atmosphere was also obtained.
These samples
demonstrated the capability to back-up the inline analysis equipment.
g. NUREG-0737,
Item II.B.3, Criterion (2a)
and Criterion (9) state that
[1] the licensee shall provide onsite radiological analysis capability
to quantify noble gases, iodines,
and nonvolatile radionuclides in
reactor coolant and containment atmosphere that many be indicators of
core damage, and [2] the sensitivity of onsite liquid sample analysis
capability should permit measurement of nuclide concentration in the
range 1 pCi/g to 10 Ci/g.
The licensee sampled and analyzed reactor
coolant samples with the following results:
RCS LIQUID (pCi/g)
Normal Sample
Station
Radionuclide
Diluted
Undiluted
RCS Undiluted
Sample
Sample
Normal Sample
Na-24
1.18 x 10-2
9.5 x 10-'
1.10 x 10-2
Cs-134
5.28 x 10-3
5.8 x 10-3
6.66 x 10-3
Cs-136
1.17 x 10-3
N.D
1.54 x 10-3
8.58 x 10-3
7.8 x 10-3
9.71 x 10-3
1-131
4.17 x 10-2
2.8 x 10-2
4.62 x 10-2
1-132
3.25 x 10-3
1.8 x 10-3
2.40 x 10-3
1-133
1.16 x 10-2
1.04 x 10-2
1.38 x 10-2
1-134
3.21 x 10-3
1.75 x 10-3
2.47 x 10-3
STRIPPED RCS GAS (pCi/g)
Radionuclide
Kr-85m
1.50 x 10-3
2.35 x 10-3
Kr-87
1.48 x 10-3
1.79 x 10-3
Xe-131m
6.84 x 10-3
N.D
4.42 x 10-'
6.15 x 10-1
Xe-133m
9.32 x 10-3
1.36 x 10-2
Xe-135
3.64 x 10-2
5.37 x 10-2
Ar-41
7.76 x 10-3
1.29 x 10-2