ML16148A783
| ML16148A783 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/20/1993 |
| From: | Decker T, David Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A782 | List: |
| References | |
| 50-269-93-14, 50-270-93-14, 50-287-93-14, NUDOCS 9306020122 | |
| Download: ML16148A783 (9) | |
See also: IR 05000269/1993014
Text
ICREG
9UNITED
STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
MAY 2 1 1993
Report Nos.:. 50-269/93-14, 50-270/93-14, and 50-287/93-14
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.:
50-269, 50-270,
and 50-287
and DPR-55
Facility Name: Oconee 1, 2, and 3
Inspection Conducted: April 19-23, 1993
Inspector:
D. W.,
ies
Date Signed
Approved by:
2
3
T. R. Decker, Chief
Date 'Signed
Radiological Effluents and Chemistry Section
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted in the areas of radiological
environmental monitoring, radiation dose calculations, and followup on
previously identified issues.
Results:
One unresolved item (URI) was identified regarding the effectiveness of the
licensee's corrective actions for maintaining the Turbine Building Sump (TBS)
monitoring system in an operable condition (Paragraph 5).
One violation was identified regarding failure to follow control room
surveillance procedure for effluent radiation monitors (Paragraph 5).
The licensee's radiological environmental monitoring program was effectively
implemented. The program requirements for sampling, analysis, and reporting
were met. Dose estimates calculated from environmental monitoring program data
were in reasonable agreement with dose estimates calculated from effluent data
and were within 40 CFR 190 dose limits. The program results for 1992,
indicated that there was no significant radiological impact on the health and
safety of the general public resulting from plant operations (Paragraph 2).
9306020122 930521
PDR ADOCK 05000269
G
The results of the licensee's participation in the Environmental Protection
Agency's (EPA's) interlaboratory crosscheck .program indicated that an
effective quality assurance program had been maintained for the analysis of
environmental samples (Paragraph 3).
The licensee had adequately implemented the methodology delineated in the
Offsite Dose Calculation Manual (ODCM) for radiation dose calculations
(Paragraph 4).
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- B. Barron, Station Manager
D. Berkshire, Senior Scientist, Radiation Protection
- J. Davis, Manager, Safety Assurance
- B. Jones, Manager, Chemistry
E. -Lampe, Scientist, Radiation Protection
- M. Patrick, Manager, Regulatory Compliance
- B. Peele, Manager, Engineering
- S. Perry, Licensing Coordinator, Regulatory Compliance
- G. Rothenberger, Superintendent, Work Control
- M. Thorne, Supervising Scientist, Radiation Protection
- E- Wehrman, Scientist, Radiation Protection
- T.-Wehrman, Engineer, Operations
Other licensee employees contacted included engineers, technicians, and
office personnel.
Nuclear Regulatory Commission
- B. DesaiResident Inspector
Harmon, Senior Resident Inspector
K. Poertner, Resident Inspector
- J. Stohr, Director, Division of Radiation Safety and Safeguards
- Attended exit interview.
2.
Radiological Environmental Monitoring Program (84750)
Technical Specification (TS) 6.4.7 required the licensee to establish,
implement, and maintain a program to monitor the radiation and
radionuclides in the environs of the plant as described in Chapter 16 of
the Final Safety Analysis Report (FSAR).
The sampling locations, types
of samples or measurements, sampling frequency, types and frequency of
sample analysis, reporting levels, and analytical lower limits of
detection (LLD) were specified in FSAR section 16.11-6. TS 6.6.1.5 and
FSAR section 16.11-10 delineated the requirements for submitting, the
submittal dates, and the content of the Annual Radiological
Environmental Operating Reports. The reports were required to be
submitted prior to May 1 of each year and to provide an assessment of
the observed impact on the environment resulting from plant operations
during the previous .calendar. year.
The inspector reviewed the licensee's 1992sAnnual Radiological
Environmental Operating Report and discussed its content wih the
licensee. The report was submitted on April 20, 199,
and included the
following: a description of the program, a summary and discussion ofthe
results for each exposure pathway, analysis of trendsand comparisons
'0
2
with previous years and preoperational studies, and an assessment of the
impact on the environment resulting from plant operations. The report
also included the results of the Land Use Census and the results of the
Interlaboratory Comparison Program. The following observations for the
various exposure pathways were produced by the licensee's evaluation of
the 1992 environmental monitoring program data, and documented in the
report, or were noted by the inspector during the review of the report.
Airborne -
No radionuclides, other than those that occur naturally
in the environment, were detected in the air samples during 1992
(or 1991).
Drinking Water - Gross beta activity was detected in (some but not
all) samples collected from the two indicator and the one control
location but the highest concentration ,observed was well below the
required lower limit of detection (LLD). No radionuclides related
to plant operations were identified by.other analyses.
Surface Water - Co-58 was detected in one sample and H-3 was
detected in 5 samples collected from the indicator location. The
concentration of the Co-58 was less than the required LLD and the
highest H-3 concentration observed was less than half of the
reporting level.
Milk - Cs-137 was the only radionuclide, other than naturally
occurring K-40, detected in the milk samples. A total of 81 milk
samples were collected from 3 dairies. Cs-137 was detected in two
samples collected from one dairy but the concentrations were less
than the required LLD.
o
Broadleaf Vegetation - No radionuclides, other than those that
occur naturally in the environment, were detected in the samples
collected from the indicator locations. Cs-137 was detected in 8
of the 13 samples collected from the-control location. The highest
concentration observed was less than 13 percent of the required
reporting level.
Shoreline Sediment - Small increases in concentrations were
observed during 1992 for Mn-54, Co-58, Co-60, Cs-137, Ag-110m, and
Sb-125 at indicator locations. No reporting-levels for sediment
were specified in the FSAR but doses from shoreline sediments were
well below environmental dose limits. The total body dose to the
maximally exposed individual was less than one hundredth of a mrem
per year.
Fish - Co-58, Cs-134, and Cs-137 were detected in the fish samples
collected during 1992. The highest concentrations observed for
Co-58 and Cs-134 were less than the required LLD and-the highest
concentration observed for Cs-137 was approximately I percent of
the required reporting level.
3
Direct Gamma Radiation -
Exposures measured at 40 locations during
1992 were not significantly different form exposures measured
during preoperational studies.
Dose estimates calculated from environmental monitoring program data
were in reasonable agreement with dose estimates calculated from
effluent data and were within 40 CFR 190 dose limits. The reports
summary section indicated that the contribution to the environmental
radioactivity resulting from plant operations was small and had no
significant radiological impact on the health and :safety of the general
public.
Based on the above review, it was concluded that the licensee had
complied with the sampling, analytical, and reporting program
requirements and that the radiological environmental monitoring program
had been effectively implemented.
No violations or deviations were identified.
3.
Environmental Monitoring Quality Assurance Program (84750)
TS 6.4.7.c and FSAR Section 16.11-6 required the licensee to participate
in an interlaboratory comparison program and to include a summary of the
program results in the Annual Radiological Environmental Operating
Report. The licensee's report for 1992 provided a summary of the results
from the licensee's participation in the Environmental Protection
Agency's (EPA's) Environmental Radioactivity Laboratory Intercomparison
Studies (Crosscheck) Program. The report also included descriptions of
the various types of samples analyzed and the analyses performed, and an
evaluation of the analytical results. A total of 34 samples were
analyzed and one analytical result, gross beta in .water, exceeded the
EPA control limit. The licensee investigated the indication that the
measurement system may have been out of control and determined that no
program changes were warranted. Analyses of subsequent crosscheck
samples performed on that system were within control limits.
Based on the licensee's overall performance in the EPA crosscheck
-program, it was concluded that an effective quality assurance program
had been maintained for analysis of environmental samples.
No violations or deviations were identified.
4.
Radiation Dose Calculations (84750)
TS 6.4.6.c required the licensee to implement a program for the control
of radioactive effluents which included monitoring, sampling, and
analysis in accordance with the methodology and parameters in the
Offsite Dose Calculation Manual (ODCM). TS 6.4.6.g and FSAR .
Section 16.11-2 specified the limitations for the dose rate,-resulting
from radioactive material released in gaseous effluents.,
4
The inspector reviewed the licensee's dose rate calculation methodology
for gaseous effluents which was described in section A2.2 of the ODCM.
The dose rate was expressed as a function of the concentration of
radionuclides in the effluent, the effluent release rate, dose factors,
and dispersion and deposition parameters. The licensee rearranged the
expression for dose rate in order to calculate the maximum'release rate
which would meet the dose rate limit, given the measured radionuclide
concentrations. This provided the licensee with a means of assuring
compliance with the dose rate limit by controlling the release rate. The
.
inspector examined the licensee's records for a reactor building purge
for Unit 2 which was performed on January 3, 1993, and verified the
licensee's calculation of the maximum release rate. Those records
indicated that the actual release rate was several orders of magnitude
less than the calculated maximum. The licensee performed the above
calculations with the aid of a computer and the printout listed the
maximum release rates for each of the specified dose rate limits, i.e.,
total body, skin, and organ. The inspector noted that the projected
offsite dose rate resulting from the release did not appear in the
licensee's records for the release. Using the expressions in the ODCM,
the measured radionuclide concentrations, and the recorded release rate,
the inspector calculated the total body, skin, and organ dose rates. The
calculated dose rates were less than one mrem/yr and were well below the
specified limits.
Based on the above, it was concluded that the licensee had adequately
implemented the methodology delineated in the ODCM.
No violations or deviations were identified.
5.
Followup on Previously Identified Issues (92701)
(Closed) Unresolved Item (URI) 50-269, .270, 287/93-10-01:
Failure to
promptly detect inoperable effluent monitors.
During the inspection conducted on March 15-19, 1993, (Ref. Inspection
Report No. 50-269, 270, 287/93-10), the licensee informed the inspector
of recent problems encountered with two effluent monitors and provided
the inspector with the preliminary findings from the investigation of
those problems. The monitors had been inoperable for several days
before the licensee discovered that the monitors were not functioning
properly and therefore the required compensatory actions had not been
taken. The monitors involved were the Unit 3 Turbine Building Sump
(TBS) monitor (3-RIA-54) and the low range noble gas activity monitor
for the Unit 2 Vent (2-RIA-45). After further review of this matter by
regional management, it was determined that this issue would be closed
(URI 50-269, 270, 287/93-10-01).
On March 8, 1993, the licensee discovered that the sample pump for
3-RIA-54 was not running and that the sample line'flow instrument was
incorrectly indicating that the sample flow was normal. -The flow
instrument was jarred to free the flow sensor and the pump was
restarted. As of the date of the previous inspection, the licensee had
5
not determined when or why the sample pump was stopped but had
established that the pump was observed to have been running on March 3,
1993. During this inspection the licensee's progress in the
investigation of this problem and the corrective actions taken to
prevent recurrence were examined. The licensee had determined that the
sample line flow indicator had been plugged with debris from the sump
and that the debris had held the flow indicator's sensor in the open
position. This prevented a no flow alarm in the control room when the
sample pump was not running. The debris was removed from the-sample
line and the system was returned to service. The proposed resolution,
as documented on the licensee's Problem Investigation Form dated
April 20, 1993, was to consider the clogged sample line as an isolated
incident because there had been no previous occurrence of the problem.
Screening or filtering the sample line was considered but not
recommended because of the potential problems which may be encountered
should the screen or filter become clogged. No system modifications
were recommended. During .a routine review of the Unit 3 Supervisors
Log, the Resident Inspector noted an entry which indicated that at
1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on April 21, 1993, the sample pump for the Unit 3 TBS had
tripped off and no alarm was received from the flow indicator. The entry
also.indicated the following: that this was the third occurrence of the
problem; the sample pump was tripping and debris was holding the flow
switch open; the sample line was purged to free the flow switch; and the
TBS release was resumed at 1715 hours0.0198 days <br />0.476 hours <br />0.00284 weeks <br />6.525575e-4 months <br />. During discussion of these
issues, the licensee indicated that instructions had been issued on
April 21, 1993, to non-licensed operators (NLOs) to verify twice per
shift that the sample pumps were running. The inspector reviewed the
NLO Turnover Sheet and confirmed that those instructions had been
issued.
The applicable requirements for the monitor were delineated in
Section 16.11-3, Table 16.11-1 of the FSAR which specified that the sump
monitor must be operable during continuous releases from the TBS. The
compensatory action specified for an inoperable TBS monitor was
collection and analysis of.grab samples prior to each discrete release
from the sump. The previously identified issue of concern was that the
monitor was found to be inoperable on March 8, 1993, and the required
compensatory actions had not been implemented. As a result of the
additional information gathered during this inspection, the previous
issue evolved into an issue of maintaining the TBS monitor in an
operable condition.
Based on the reviews and discussions conducted during this inspection,
it was concluded that this issue is unresolved pending NRC review of the
effectiveness of the licensee's corrective actions for maintaining the
TBS monitoring system in an operable condition (URI 50-269, 270, 287/93
14-01).
The other monitoring system that the licensee had encountered problems
withwas the Unit 2 Vent Monitoring System. The operational functions
of the low range (2-RIA-45) and high range (2-RIA-46) noble gas activity
monitors for the Unit 2 Vent were controlled by a common computer. The
6
computer was programmed to switch the monitoring function to the high
range monitor if the low range monitor failed. The measurable range of
the monitors overlapped and both monitors were set to alarm at the same
activity concentration. On March 12, 1993, the licensee performed a
routine surveillance on the monitors. Restoration of the monitors to
operable status, following surveillance testing, involved entering coded
data into the computer to provide operating instructions for the various
functions performed by the computer. Due to personal error, not all of
the coded data were entered correctly, one of which was the code for
instructing the computer to display in the control room the count rate
for the low range monitor. Computer logic switched the monitoring
function to the high range monitor and displayed the default value of
zero counts per minute (cpm) for the low range monitor. The typical
count rate for the monitor was 20 to 35 cpm. This condition went
unrecognized until March 16, 1993, at which time the error was corrected
and the low range monitor returned to service. The licensee indicated
that the computer logic did not provide an alarm for this condition.
The licensee's procedure for performing daily surveillances in the
control room (PT/2/A/600/01 "Periodic Instrument Surveillance")
specified the "required condition" for 2-RIA-45 as ,"indicating on
scale."
The inspector reviewed the control room surveillance logs for
the night shifts of March 12, 13, and 14, 1993, and noted that those
logs were initialled to indicate that the monitor was indicating.on
scale. During a discussion of this issue with the inspector, the
licensee displayed on a computer screen the data history file for the 2
RIA-45. That file indicated that a zero count rate was displayed in the
control room on the above dates. During the previous inspection the
licensee indicated that the investigation of this issue was in its early
stages and that they could not then commit to specific corrective
actions. The inspector was informed that the corrective actions then
under consideration were to modify the computer logic such that an alarm
would be provided under this condition and to provide guidance in the
control room surveillance procedure-to clarify that "on scale" means a
value greater than zero. During this inspection the licensee's progress
in the investigation of this problem and the corrective actions taken to
prevent recurrence were examined. The licensee informed the inspector
that their vendor for the monitor had been contacted to explore the
possibility of modifying the computer logic. The modification being
considered was to change the logic such that an alarm would sound in the
control room if the low range monitor were inoperable rather than switch
the monitoring function to the high range monitor without an alarm. No
commitment or completion date had been established for modifying the
computer logic. The inspector also reviewed the licensee's Problem
Investigation Form for this issue. The document reviewed was dated
April 20, 1993, and indicated that the control room surveillance
procedure should be changed to indicate that the low range monitor count
rate should be greater than zero when the monitor is operable. The form
also indicated that the due date for this corrective action was
September 12, 1993, but the licensee indicated to the inspeetor that the
change would be implemented by April 30, 1993. The inspector noted that
the form indicated that the procedure for surveillance testing of the
7
monitor did not include instructions for verifying that all fields of
the computer's operating instructions data base were correctly restored
before the monitor is returned to service. Revision of the procedure
was not addressed.
Based on the reviews and discussions conducted during this inspection,
it was concluded that the licensee had not, by the end of the
inspection, committed to comprehensive corrective action toprevent
recurrence of the problem with the Vent Monitoring System. TS 6.4.6
required the licensee to implement, by operating procedures, the program
for control of radioactive effluents as described in Chapter 16 of the
FSAR. Section 16.11-3, Table 16.11-2 of the FSAR specified that Unit
Vent Monitoring System must be operable at all times.. The compensatory
action specified for an inoperable vent monitor was collection and
analysis of grab samples once per eight hours or suspend release of
radioactive material via this pathway. Section 16.11-4, Table 16.11-4 of
the FSAR specified that daily surveillances-must be performed to verify
operabliity of the ventilation system radiation monitors. The computer
logic failed to provide an alarm when the monitor was inoperable and the
licensee failed to recognize that the monitor was inoperable during the
daily surveillance conducted for the period March 12-14, 1993..By
indicating on the control room surveillance logs that the monitor met
the required condition of being on scale, when the monitor was in fact
inoperable and indicating a zero count rate, the licensee failed to.
follow the control room surveillance procedure. This issue has been
deemed to be a violation (VIO 50-269, 270, 287/93-14-02).
One URI and one VIO was identified.
6.
Exit Interview
The inspection scope and results were summarized on April 22, 1993, with
those persons indicated in Paragraph 1. The inspector described the
areas inspected and discussed in detail the inspection results. On
May 21, 1993, the licensee was advised by telephone that the inspection
results were changed from one violation with two examples to one
unresolved item and one violation. No dissenting comments were received
from the licensee. Proprietary information is not contained in this
report.
Item Number
Description and Reference
50-269, 270, 287/93-14-01
URI - Failure to implement compensatory
actions for an inoperable effluent
radiation monitor (Paragraph 5).
50-269, 270, 287/93-14-02
VIO -
Failure to follow control room
surveillance procedure for effluent
radiation monitors (Paragraph,*5).