ML17284A491
| ML17284A491 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/19/1988 |
| From: | Cicotte G, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17284A490 | List: |
| References | |
| 50-397-88-26, IEIN-87-039, IEIN-87-39, IEIN-88-008, IEIN-88-022, IEIN-88-22, IEIN-88-8, TAC-69278, NUDOCS 8809060298 | |
| Download: ML17284A491 (25) | |
See also: IR 05000397/1988026
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
No. 50-397/88-26
Docket No.
50-397
License
No.
Licensee:
Washington Public Power Supply System
P.
0.
Box 968
Richland, Washington
99352
.
Facility Name:
Washington Nuclear Project
No.
2
Inspection at:
WNP-2, Benton County, Washington
Inspection
Conducted:
July 18-22
1988
Inspected
by:
Approved by:
G.
R. Cicotte, Radiation Specialist.
G.
P.
Yu as,
Chief
Emerge
Preparedness
and Radiological
Protection
Branch
8- t't
-RR'ate
Signed
Da
e
igned
~Summar:
Ins ection durin
eriod of Jul
18-22
1988
Re ort No. 50-397/88-26
Areas Ins ected:
Routine unannounced
i'rlspection by a regionally based
inspector of licensee
reported events,
open items, supervisory
awareness,
postings effectiveness,
and tours of the facility.
Inspection procedures
30703,
92700,
92701,
83722,
83724 and 83726 were addressed.
Results:
Of the five areas
addressed,
no violations or deviations
were
identified.
In one area,
an unresolved
item, involving possible fai lure to
take all the samples
required during primary containment venting and purging,
was identified (see
paragraph
5. B).
In addition, continuing concerns
related
to Equipment Operator
knowledge of radiological controls
and control of high
radiation areas,
concerns
as to timeliness of 10 CFR 21 reports,
and in
posting of NRC documents
pursuant to 10 CFR 19. 11, were identified (see
paragraphs
4, 3,
and 6, respectively)
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DETAILS
1.
Persons
Contacted
C
AJ
)hp
"R.
S
- D.
R.
G.
D.
M.
M. Powers,
Plant Manager
W. Baker, Assistant Plant Manager
Bradford, Health Physics
Supervisor
S.
Feldman,
Plant
QA/QC Manager
G. Graybeal,
Health Physics/Chemistry
Manager
L. McKay, Operations
Manager
B. Ottley, Radiological
Services
Supervisor
B. Quay,
General
and Technical
Support Training Manager
E. Shockley,
Health Physics
Support Supervisor
C. Sorensen,
Regulatory Programs'anager
M. Werlau, Training Supervisor
R. Wuestefeld,
Reactor Engineering Supervisor
NRC Personnel
"C. Bosted,
Senior Resident
Inspector
In addition to the individuals identified above,
the inspectors
met and
held discussions
with other members'of
the licensee's
staff and
personnel.
"Denotes
those present at the exit interview held on July 22,
1988.
2.
Onsite Follow-u
of Written
Re orts of Non-Routine Events
A.
Cl osed - Fol 1 owu
50-397/87-11-LO
This refers to a licensee identified failure to have
an operable,
flow measurement
device during operation of the Radwaste
Building
exhaust ventilation.
The licensee attributed the cause to an
inadequate
checklist for deenergization
of the vital bus supplying
power to the device.
Corrective action consisted
of upgrading
power
supply checklists
used for determination of systems
affected.
The
inspector verified the licensee's
actions,
and noted that other
power supplies
had been evaluated
to ensure that similar events
would not occur.
This matter is considered
closed
(50-397/87-11- LO) .
B.
Closed - Fol 1 owu
50-397/88-09-LO
This refers to two missed surveillances
on the standby
gas treatment
(SGT) system.
The licensee
reported that the surveillances
were
missed
when
a Senior Health Physicist failed to pass
the
Surveillance Monitoring System
(SMS) cards
on to the individual
responsible for performance of the Technical Specification
(TS)
surveillances.
Surveillances
PPM 7.4.6.5.3.5,
"Standby
Gas
Treatment
System
DOP Test and Visual Inspection,"
and
7. 4. 6. 5. 3. 6, "Standby
Gas Treatment
System Adsorber Bypass
Leakage
Test," were performed within one week of the 18-month plus
25K late
date.
The licensee identified the failure to pass
the cards
on as having
been
caused
by failure of Health Physics Supervision to utilize the
SMS and status
reports effectively.
In addition to counseling
the responsible
individuals, the licensee
modified procedure
PPM 1.5. 1, "Technical Specification Surveillance
Testing Program," to better
define
due dates.
The inspector
noted
that the Senior Health Physicist
(SHP)
had not received the cards
until February 1, 1988,
when the early date
was in August 1987,
and
the due date
was
November 12,
1987.
The Health Physics/Chemistry
Manager stated that
he had received the cards but had not passed
them on to the
SHP until about February 1, 1988,
and
had not
appropriately pursued status
notices
showing the surveillances
to be
late.
He further stated that action to assign
surveillance
responsibility
more in keeping with who performs the surveillance
had been conducted,
although this was not reflected in the licensee
event report (LER).
The licensee's
analysis
and corrective action
appeared
adequate
to prevent recurrence.
This matter is considered
closed
(50-397/88-09-LO).
No violations or deviations
were identified.
3.
~Fol 1 owo
A.
Information Notices
INs)
The following INs had been received
and disposition initiated by the
licensee:
(Closed)
Chemical
Reactions with Radi'oactive
Waste
Solidification Agents
(Closed)
- Disposal of Sludge
from Onsite
Sewage
Treatment
Facilities at Nuclear Power Stations
(Closed)
Control of Hot Particle Contamination at
Nuclear Power Plants
With respect to IN-87-39, addressed
in Inspection
Report
50-397/88"12,
the inspector
noted that the licensee's
program for
hot particle control
had been fully implemented
and proceduralized,
and appeared
consistent with the recommendations
of IN-87-39 and
with industry standards.
These
items are considered
closed.
B.
0 en Items
50-397/88-01-GC
Closed
The licensee
had received the evaluation
by
NRR of amendment
4 to .the Offsite Dose Calculation
Manual
(ODCM).
The licensee
was preparing
a special
submittal to NRR, in advance of
the second half 1988 Semi-Annual Effluent Release
Report.
The
submittal
appeared
to address
the concerns
not resolved
by Amendment
5.
(See Inspection
Report 50-397/88-12).
This matter is considered
closed
based
on timely response
to
NRR (50-397/88-Ol-GC)
(Closed).
50-397/88-12-PO
Closed
This refers to a 10 CFR 21 report
submitted
as
LER 88-12-00,
dated
June 6, 1988, regarding
a potential
unmonitored release
path from 'the Turbine Building under certain
emergency ventilation conditions, originally discovered
by the
licensee
on May 6, 1988.
The licensee
had informed the
architect-engineer
and
NRC, and
had completed
removal of the release
path,
as that portion of the ventilation system
was not deemed
necessary.
The report contained the information required
by 10 CFR 21.
In reviewing the timeliness of the report, the inspector
made the
following observations:
Region
V first became
awar e of the situation
when
a regionally
based
inspector
was verbally informed, within two days of the
discovery in accordance
with 10 CFR 21, that the potential
existed for a 10 CFR 21 reportable condition, with brief
detai
1 s.
The. licensee
processed .the discovered condition in
accordance'ith
their procedures,
which specify that the Plant
Technical'anager
determines. whether or not the item is reportable
under
This determination is reviewed by the Plant
Operations
Committee
(POC), in accordance
with TS 6.5. 1.6.f,
which. requires
review of all reportable
events.
The potentially reportable
occurrence
(PRO) report was,
according to
POC meeting minutes, first reviewed
by the
on
May 25,
1988.
The
POC determined that more information was
required in order to determine if the,condition"was
reportable
. under
The matter was deferred
unti'1 the
POC meeting
of June 1, 1988, at which'ime it was determined to be
reportable
and
LER 88-12-00
was sent within 5 days thereafter.
The inspector discussed
the time limit of five days for 10 CFR 21
reports with the licensee.
The licensee
was aware of the reporting
requirements
of 10 CFR 21 and stated that the matter was not
determined to be reportable until June
1, 1988,
and was thus
reported within the five day time limit.
The inspector
informed the
licensee that 10 CFR 21 reportable conditions are expected
to
receive the appropriate
level of review, to assure
the time limit is
met,
when items appear to meet the reporting criteria.
The
inspector
noted that
a previous
10 CFR 21 report,
LER 88-002-00,
had
received similar handling, with determination
as to 10 CFR 21
reportability being
made about three
weeks after the discovery of
the condition.
The inspector
informed the licensee that items of
greater safety significance could be expected to receive
more
rigorous scrutiny with respect to reporting responsibilities.
As
the report was submitted within five days of the determination that
it was reportable,
and the deficiency corrected
as of the time of
the inspection, this matter is considered
closed
(50-397/88-12-PO).
No violations or deviations
were identified.
Radiolo ical Postin
Effectiveness
Radiological postings
were discussed
with plant workers
and observed
during facility tours.
Adherence
to posted instructions
appeared
to have
improved (see Inspection
Report 50-397/88-12).
No areas
were observed
to
have
been improperly deposted,
although
two examples
of barriers
being
left open for access
were observed.
Upon entry to the 437'levation of the
Radwaste
Building (RWB), on,July
18, 1988,
Area Radiation Monitor (ARM) CH-27, located
on the wall near
equipment drain tank OEDR-T-5,
was observed to be alarming at about
10
mr/hr.
The licensee
was
aware of the alarming condition,
and stated that
planning for decontamination
of EDR-T-5 was in progress.
The licensee
further st/ted that
ARM CH-27 had been alarming since the previous
day,
when
EDR-T-5 was drained.
(HRA) posting
and
barricade
had been placed
around
EDR-T-5.
Later on July 18,
an Equipment Operator
(EO) was observed
to be dressing
,in,protective clothing, next to the
HRA and the still alarming
CH-27 at
EDR-T-5. 'The licensee
had previously removed the dressing
area
bench,,
but not the shelves of protective clothing, in order to discourage
workers
from dressing
next to EDR-T-5,
a higher dose area.
This had been
done in response
to
NRC ALARA concerns
(see
Inspection
Report
50-397/88-12).
When asked
about the alarming
ARM, the
EO stated that
he
thought
HP personnel
were probably aware of the
ARM alarm,
and that
he
was "just going to quick hang
a tag."
The
EO stated that the area in
which he was dressing
was about
5 mr/hr.
The
ARM meter read
20 mr/hr,
and was further from EDR-T-5 than the
EO.
The inspector
informed the
that
he was standing in an area of about
30 mr/hr, at which'time he went
to a lower dose
area (less
than
1 mr/hr) on the 437'WB to finish
dressing.
The inspector
informed the
HP Supervisor,
who stated that the
matter would be discussed
with the Shift Support Supervisor.
Access control for HRAs was observed
in conjunction with decontamination
of EDR-T-5.
The inspector entered
the 437'WB to read
CH-27, located
a
few feet away from the door.
CH-27 read about
100 mr/hr,
and the
NRC
instrument
read about
250 mr/hr outside the
HRA barricade.
The inspector
immediately turned to exit the vicinity, at which time an
HPT turned to
him to report that this was
an
HRA which he was guarding until a drum of
highly radioactive debris
from EDR-T-5 could be removed.
The inspector
observed that guarding should constitute challenging the presence
of
personnel
before entry to a greater
than
100 mr/hr field.
Dose rates
returned to their previous level
when the drum was
removed
a few minutes
later (the drum had measured
7 R/hr contact with the licensee's
instrument).
The inspector
immediately informed the
HP Supervisor,
who
then counseled
the
HPT.
Radiologically Controlled Area (RCA) status
boards
were observed
on July
18,
1988 to have
been
updated,
with dates
ranging from June
15 to July
15,
1988.
However,
some areas,
including some
HRAs which were verified
to exist,
were not indicated
on the status
boards
(see Inspection, Report
50-397/88-22).
access
control
and radiological posting cognizance
by
plant personnel
were discussed
with the
HP Supervisor.
The
HP Supervisor
and other
HP personnel
stated that compliance with "Contact
HP prior to
entry" inserts in radiological
boundary signs
was running about
95K, and
plant personnel
were being more informative to
HP personnel,
in order.to
provide better work control
and to obtain more thorough
knowledge of
radiological conditions in their work areas.
No violations or deviations
were identified.
Or anization
and
Mana ement Controls
A.
Su ervisor
Controls
The inspector
was informed of projected
changes
in the Health
Physics/Chemistry
(HP/C) organization
by the
HP/C Manager.
The HP/C
Manager stated that the changes
were expected
to result in
additional
management
control,
by releasing
the
HP and Chemistry
Supervisors
from many routine duties through the addition of
Foremen.
He further stated that the
HP Foreman
had
been .selected,
and the Chemistry
Foreman position was expected
to Pe filled i'n the
'.next few months.
I
Tours of the plant by supervisory
and management
personnel
were
observed
to have increased
in frequency.
In particular,
HPTs
were observed to be making tours to ascertain
the activities of
plant workers.
Supervisory personnel
were observed
to be
determining the status of author ized work in the plant.
A personnel
contami,nation incident, involving an
HPT,
was reviewed
to determine if sufficient management
attention is directed toward
prevention of inadve'rtent
uptake or contaminations, .in particular
with regard to root cause
and corrective action.
" The
HP Supe'rvisor
stated that an evaluation
was in the process
of being approved for
submittal.
The inspector briefly reviewed the data
and discussed
the incident with the
HP Supervisor
and the
HPT.
The following
observations
were
made
by the licensee.
The incident occurred
when the
HPT dropped
a
CRO filter, which
resulted in'is becoming contaminated,
and in exceeding
his
administrative
whole body radiation
dose limit.
CRD filters had been left in a drum in the solid waste liner
processing
area,
due to the dose rates.
The filters read
up to
50 R/hr contact.
The location of the
drum caused
unnecessary
dose to workers
on a solid waste liner.
The HPT, with the approval of the
HP Supervisor,
moved the
drum
away from the work area,
and began to move the filters to'
shielded container.
Previous practice
had been to place the
filters in this configuration at the time of removal.
Filters
left from the 1987 outage
had prevented this,
and
no action
was
taken at the time to package
the filters or
use
a drum liner.
When the last filter was being moved, it fell to the floor.
The
HPT stated that it was about this time when his digital
dosimeter
alarmed, at 256 mr.
He stated that
he stayed "just
long enough to stabilize the area,"
by placing the filter in a
container
and wiping up most of the corrosion products which
had
come off the filter.
He stated his digital dosimeter
read
276 mr at that time.
The
HPT was found to have minor facial contamination,
and
a
whole body count and air sample results
from a sample
he
had
taken during the work confirmed minimal internal'ptake.
His
whole body TLD read
380 mr, with an administrative limit of 300
mr.
No other limits were exceeded.
The licensee's
preliminary evaluation
had determined
the following
root causes:
Inadequate
planning for dose to the individual - a small
dose
extension
would have
been warranted in order'to avoid an
administrative
g
Inade'quate
followup on the 1987 outage - the job would not have
been
necessary
had the filters been appropriately
disposed of
by the Radwaste
department at that time.
Inadequate
respiratory protection - the
HPT was not wearing any
respiratory protection device
and
had not made
any effort to
minimize airborne radioactivity,
as
he had erroneously
'concluded that the filters were
damp.
The matter will be examined further upon receipt of a copy of the
evaluation in final form.
Mana ement Controls
The licensee's
methodology for handling of apparent conflicts in the
Technical Specifications
(TS) was reviewed with respect to
interpretations
thereof.
The inspector
noted that licensee
procedure
PPM 1.3.34, "Plant Technical Specification Interpretation
Process,"
Revision 2, dated 10/27/87, called for restricted
distribution among controlled copies of the TS.
The inspector
reviewed
a controlled copy of the
TS in which TS interpretations
(TSIs) were contained.
TSI ¹85-004, related to sampling
and
analysis
during Reactor Building Primary Containment
(PC) purging
and venting, in accordance
with TS 4. 11. 2. 1. 2 and
TS 4. 11. 2.8. 3,
had
concluded that sampling in accordance
with TS 4. 11.2.8.3 precluded
the need for sampling in accordance
with TS 4. 11.2. 1.2.
TS
3/4.11.2.1 states,
in part:
~
~,
"3.11.2.1
The dose rate
due to radioactive materials
released
in
gaseous
effluents
from the site to areas at and beyond the SITE
BOUNDARY (see Figure 5. 1-3) shall
be limited to the following:
a.
For noble gases:
Less than or equal to 500 mrems/yr to the
total
body and less
than or equal to 3000 mrems/yr to the skin,
and
b.
For iodine-131, for iodine-133, for tritium, and for all
radionuclides
in particulate
form with half-lives greater
than
8 days:
Less than or equal to 1500 mrems/yr to any organ.
APPLICABILITY: At all times..."
"4.11.2.1.2
The dose rate
due to iodine-131,
iodine-133, tritium,
and all radionuclides
in particulate
form with half-lives greater
than 8 days in gaseous
effluents shall
be determined
to be within
the above limits in accordance
with the methodology
and parameters
in the
ODCM by obtaining representative
samples
and performing
analyses
in accordance
with the sampling
and analysis
program
specified in Table 4.11-2."
Amendment
5 to the
ODCM states
in part:
"3.2 Gaseous
Effluent Radiation Monitorin
S stem
3.2.1
Main Plant Release
Point
The Main Plant Release
is instrument monitored for gaseous
radioactivity prior to discharge
to the environment via the, main
plant vent release
point.
Particulates
and iodine activity are
accumulated
in filters which will be changed
and analyzed
as per
Technical. Specification 4. 11.2.1.2
and Table 4. 11.2.
The effluent
is supplied from:
the gland seal
exhauster,
mechanical
vacuum
.'umps,
treated off gas,
standby
gas treatment,
and exhaust air
'from'he
entire reactor building's 'ventilation.".
V
The subject
page of the
ODCM, page
34,
was last revised in Amendment
3, dated
February
1986.
TS 3/4. 11. 2. 8 states,
in part:
"3.11.2.8
VENTING or PURGING of the Mark II containment drywell
shall
be through the standby
gas treatment
system or the primary
containment
vent and purge
system.
The first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of any vent
or purge operation shall
be through
one standby
gas treatment
system.
APPLICABILITY:
Whenever the drywell is vented or purged...."
"4. 11. 2. 8. 3
The containment
drywel 1 shall
be sampled
and analyzed
per Table 4. 11-2 of Specification
3. 11.2. 1 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to
the start of and at least
once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during VENTING and
PURGING of the drywell through other than the standby
gas treatment
system."
TS Table 4. 11-2 states,
in part:
"TABLE 4. 11-2"
"RADIOACTIVE GASEOUS
WASTE SAMPLING AND ANALYSIS PROGRAM"
SAMPLING
"GASEOUS
RELEASE TYPE
FREQUENCY
MINIMUM
ANALYSIS
FREQUENCY
TYPE
OF
ACTIVITY ANALYSIS
P
b
A.
Each
PURGE
PURGE
AND VENT
and
VENT
B.
Main Plant Vent
M ',d
Grab
Sample
M
M
Principaf
Gamma
Emitters
P
b
Each
PURGE
Principaf.
Gamma
and
VENT
Emitters
TABLE NOTATIONS"
b'
Sampling
and analysis
shall also
be performed following shutdown,
startup,
or a
THERMAL POWER change
exceeding
15K "of RATED THERMAL
POWER within a 1-hour period."
IId
" Tritium grab samples..."
" The principal
gamma emitters include...in iodine and particulate
releases...."
TS 3. 6 ~ 1. 1 states,
in part:
h
"3.6.1.1
PRIMARY CONTAINMENT INTEGRITY shall
be maintained.
APPLICABILITY:
OPERATIONAL CONDITIONS 1,
2~ and 3."
The TSI stated,
in part:
"The provisions of 4. 11.2.8.3
should
be considered
in evaluating the
requirements
of Specification
3. 11.2. 1 (Table 4. 11-2).
The need for
sampling
and analysing the drywell atmosphere prior to venting and
purging through the
SGT system is specifically excepted
by this
paragraph..."
"...Consequently,
unless
deemed
necessary
by the plant staff,
sampling will not be required prior to or during venting "or purging
through the
SGT system..."
The inspector
concluded that surveillance
TS 4. 11.2. 1.2 was required
to be performed for each vent and/or purge operation
conducted:
that is, whenever the
PC is vented or purged during modes 1, 2, or
3, in accordance
with TS 3.6.1. 1.
The inspector discussed
the TSI
with the
HP/C Manager,
and with the Reactor
Engineering Supervisor,
who had conducted
TSI 885-004.
The HP/C Manager stated that it had
been determined that sampling drywell atmosphere,
when the purge or
vent was conducted
through
SGT, would not provide any additional
level of protection.
The inspector
informed the
HP/C Manager that
TS 4. 11.2.8.3
was designed
to provide an additional level of
monitoring when
SGT is not used,
and that
TS 4. 11.2. 1.2 is required
to be met whenever
SGT is used.
A conflict in interpretation
appeared
to result from the fact that
Table'. 11-2 lists the sampling
and analysis
frequencies
as 'P',
which is defined in Table l. 1 of the
TS as being prior to each
radioactive release,
while the title of the sample point is "Gaseous
Release
Type."
The
ODCM cites
SGT as
an effluent to the main plant
vent (see
above).
Sampling prior to release
would not be possible
if there were
no flow, but it would be possible to sample the Main
Plant Vent (MPV), into which the
SGT discharges,
or to sample
the
PC
atmosphere,
which is
how the licensee
meets
the requirement to
sample in accordance
with TS 4. 11.2.8.3
and
how they met TS
4. 11.2. 1.2 prior to the TSI.
Review of the model
TS for GE
BMRs
revealed that provisions for purging or venting through other than
SGT were not contained therein.
Other licenseesmeet
the sampling
and analysis
requirement either
as
an effluent sample or a priori as
a prior-to-batch-release.
The inspector concluded, after review by regional staff, that two
apparent conflicts 'exist:
1.
Disagreement
as to whether
TS 4. 11. 2. 1.2 is an effluent or a
prior to release
drywell atmosphere
sample.
2.
Disagreement
as to whether
the initial drywell sample time
requirement (within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to start)
as called out in
4. 11.2.8.3 applies in,all cases
or just for those
instances
of
non-SGT vents or purges.
A walkdown of the licensee's
SGT system did not reveal
any installed
sample points between the outlet of the
SGT trains
and the sampling
location for MPV.
The inspector discussed
the above with the
HP/C
Manager,
who stated that the automatic isolation function of the
MPV
would provide adequate
protection,
and that the continuous
monitoring of PC atmosphere
and
MPV obviated the need for grab
samples
of SGT output, or of MPV specifically during venting or
purging through
SGT.
The setpoint for the isolation function of the
MPV is 13 mr/h,
as denoted in TS Table 3.3.2-2,
and is based
on
mitigation of the consequences
of an accident,
not normal effluent
dose rate limitations.
Licensee staff personnel
stated that each of
the three vents, i.e.,
Main Plant, Turbine Building, and Radwaste
Building, is set to alarm (no isolation function) at 200 mrem/year
equivalent count rate for noble gases.
The
ODCM does not specify
a
decontamination
factor for the
SGT.
The inspector
reviewed the process
whereby TSIs are incorporated.
Licensee staff personnel
stated to the inspector that the TSI was
10
requested
due to differences of opinion among Shift Managers
(SMs)
as to the applicability of TS 4. 11. 2. 1. 2.
PPM 1. 3. 34 states,
in
part:
"...This procedure is intended to provide
a mechanism,
where
needed,
to document
Management
approved Technical Specification
interpretations.
It is not intended to provide exceptions
to
Technical Specification requirements,
merely clar ifications where
the law is unclear.
Licensed personnel
are to use the
interpretations
as guidance
but it is recognized that conditions
could exist that render the interpretation
not applicable
or
inconclusive.
Use of the interpretation
and Technical
Specifications is,
as always,
the responsibility of licensed
personnel..."
PPM 1.3.34 further states,
in part:
"8.
Present
the Technical Specification Interpretation to
POC and
process
any required
changes.
The
POC evaluation
may include
a
recommendation
to investigate
a change to the Technical
Specifications
per
PPM 1.4.5."
The procedure's
log indicated that the TSI request
was originated
by
the secretary,
and dated ll/25/85.
The inspector
reviewed
meeting minutes for the
POC meeting conducted
November 27,
1985.
The following observations
were
made regarding the meeting minutes:
TSI ¹85-004
was listed as approved
by the
POC.
The Assistant Plant Manager chaired the
POC meeting, with the
Plant Manager
not listed as attending.
No proposed
change to the
TS was indicated
by the
POC meeting
minutes.
The input to the meeting 'by the Nuclear Safety Assurance
Group
(NSAG), Corporate
Nucleal
Safety
Review Board (CNSRB),
and
Licensing representatives
appeared
to have
been
handled
as
indicated
by the following excerpt from the meeting minutes:
"Prior to approval of this Interpretation,
concerns
were
expressed
by Licensing,
NSAG and the
CNSRB Member present.
Licensing and
NSAG stated that in reviewing similar Technical
Specifications, it was apparent that this wording is only used
when
an alternate
vent and purge path is available (i.e.,
venting and purging is only allowed through Standby
Gas
Treatment).
No sampling frequency is specified in the
Technical Specifications.
This implies that when only the
Standby
Gas Treatment
system is available the sampling
frequency specified in the table (4. 11-2) takes
precedent
(Limerick ¹1,
Susquehanna
¹1,
LaSalle ¹1).
The
CNSRB member's
concern
was that the gaseous
effluent dose
rate specification surveillance
(4. 11.2. 1.2) requires
a minimum
11
sampling
and analysis
program (Table 4.11-2) which is prior to
each release
for purging and venting of primary containment.
The venting or purging specification surveillance
(4. 11. 2. 8. 3)
adds additional
sampling
and analysis
requirements
over the
minimum when
SGT system is not used but says
nothing about when
it is used.
The surveillance of 4. 11. 2. 1. 2 stands
when the
is used.
After analysis
and consideration of the above concerns,
the
Plant Operations
Committee
recommended
approval of the
Interpretation
as presented."
The meeting minutes stated that all comments
from other
than
POC members
were discussed
and resolved
by the
end of the
meeting.
The
NSAG,
CNSRB,
and Licensing persons
were listed as
"other attendees".
The minutes did not indicate whether they
were acting in a voting or advisory capacity,
but the Plant
Manager stated at the exit interview that the decision to
approve the TSI was unanimous.
Licensee
procedures
used for conducting purging, venting,
and for
sampling
and analysis
in accordance
therewith,
were reviewed:
Subsequent
to TSI ¹85-004 approval,
the following procedures
were
revised
as follows.
PPM 2.3. 1, "Primary Containment Venting, Purging,
and
Inerting," was revised
under revision 5.
Under step
2.3. 1.5.A(B), "Drywell and suppression
chamber venting
(purging) via the. Standby
Gas Treatment System,"
the following
was added:
"...Prior to venting or purging the drywell through Standby
Gas
Treatment,
the drywell noble gas monitors shall
be read to
confirm the fol.lowing:
ll
I
a.
Activity levels
have not increased
more than
15%%uo'n the
last hour.
b.
Activity levels are below the noble gas monitor High-High
alarm setpoint
and have
been
below setpoint for at least
the last hour.
If these conditions are satisfied there is
no need to sample
the drywell atmosphere prior to vent or purge.
If they are.not
satisfied,
request
Chemistry to sample per
PPM 7.4. 11.2. 1.2. l."
PPM 7.4. 11.2. 1.2. 1, "Primary Containment
Purge
Sampling
and
Analysis," was revised
under Revision 3.
Under step
7. 4. 11. 2. 1. 2. l. 4,
Procedure,"
the note
"The Primary
.
Containment shall
be sampled
and analyzed prior to purging or
venting" was revised to add at the end of the note:
"...through other than the Standby
Gas Treatment
System."
The
change
was originally made via the licensee's
procedure
deviation process
on December
5, 1985.
The following representative
records
were reviewed to determine
the
frequency of venting and purging of the
PC without the sampling
required
by TS 4.11.2.1.2:
Control
Room Operator's
Log
Chemistry
SMS Log
PPM 7.4. 11.2. 1.2. 1, "Primary Containment
Purge
Sampling
and
Analysis" (results)
PPM 7.4. 11.2. 1.2.3,
"Grab Gas
Sample Following Shutdown,
Startup
and Thermal
(results)
PPM 7. 1. 1, "HP/Chemistry Shift Channel
Checks," (results)
PPM 7. 1.3, "Reactor Building Effluent," (results)
Samples
of the
PC atmosphere,
which the licensee
had
been,
determining were. the appropriate
sample to obtain to meet
TS
4. 11. 2. 1. 2,
and of the
MPV, which is the available
sample point for
SGT output to the exhaust
plenum,
were compared with records of
purges or ventings of the
PC.
The data
was discussed
with the
Chemistry Supervisor,
a Senior Radiochemist,
and the
HP/C Manager.,
From discussions
and the above records,
the following observations
were
made:
'rior to the interpretation,
the Shift Managers
(SMs) were
." inconsistent
as to whether they would request
a sample of
PC
atmosphere if the purge or venting operation
was conducted
through
SGT.
This inconsistency
appeared
to be the motivation
for requesting
the TSI.
The licensee,
from the time of the TSI to the time of the
inspection,
obtained
of PC atmosphere
and the
MPV,
in accordance
with notation
b of TS Table 4. 11-2,
and monthly
for the
MPV.
The licensee typically obtained
samples
in accordance
with TS
4. 11. 2. 8. 3.
I
The licensee
did not obtain grab samples of either
PC
atmosphere
or of gaseous
effluents for purge or venting
operations
conducted
through
SGT, except
as noted to meet
notation
b or for periodic
MPV samples.
13,
The licensee typically vented or purged through
SGT every one to
three
days, for periods of less
than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The following
operations
are considered
representative,
but are not inclusive, of
the operations
conducted
apparently without satisfying
TS
4. 11.2. 1.2.
Examples
from each year since the TSI was approved
are
shown:
Purge
(P)
Vent (V)
Inert (I)
(The licensee
terms venting as through the 2"
SGT lines,
and purging
as through the 30" lines.)
Date
P/V/I
Date
P/V/I
Date
P/V/I
Date
P/V/I
7-20-88
7-19-88
7-15-88
7-10-88
7-09-88
7-08-88
7-07-88
6-28-88
7-28-87
1-12-87
1-11-87
1-10-87
1-07-87
1-03-87
J ~
9-6-86
9-6-86
9-2-86
9"1-86
12-01-85
P
11-30-85
V(2)
11-12-85
V
7-03-85
V
6-30-85
V
The following additional
observations
were
made
as to the nature of
monitoring conducted:
0
,SGT flow is approximately
5X of Reactor
Building plenum exhaust
flow.
MPV is continuously
sampled .for particulates
and iodides in
accordance
with the continuous
sampling requirements
of TS
Table 4.11-2,
Radioactive
Gaseous
Waste Sampling
and Analysis
'rogram."
.
PC atmosphere
is continuously sampled/monitored
in accordance
w'ith TS Table 3.3.7.5-1,
"Accident Monitoring Instrumentation."
The inspector
discussed
the above with the licensee
as information
was obtained
and at the exit interview.
The licensee
stated that
they had
gone through the approved
review process
to obtain the
interpretation.
The inspector
noted the objections of the
NSAG,
CNSRB,
and Licensing,
as described
in the
POC meeting minutes,
and
informed the licensee that the conclusions
drawn by the above
individuals were correct,
and should
have
been incorporated.
The
inspector further informed the licensee that the avenue for
relaxation of a TS surveillance
requirement is to propose
a change
to the TS,
and that this could have
been
done
some years
ago,
when
the licensee first surmized that an apparent conflict existed.
In a telephone
conversation
conducted July 26,
1988, with the
Reactor
Engineering Supervisor
(RES), the
RES stated to the
inspector that the individuals at
NRR who had been instrumental
in
reviewing the original
TSs
had indicated that the intent of the
TS
had been to give credit for the cleanup function of SGT,
and that no
sample
was intended to be required
when
SGT is used.
The
RES was
unable to provide the
name of the individual who had
made the
statement.
The inspector
observed that the TSI,
POC minutes,
and
procedures written prior to the TSI did not indicate
any prior
interpretation.
The above lack of sampling
and analysis
appears
to be an unresolved
item, in that
TS Table 4. 11-2 was not followed as required in TS
4. 11. 2. 1. 2.
This matter will be referred to
NRR for determination
as to whether the licensee violated
TS 4. 11. 2. 1. 2 (50-397/88-26-01)
(unresolved).
An unresolved
item is one about which more information is required in
order to determine if it is an acceptable
item,
a deviation, or a
violation.
No violations or deviations
were identified.
The inspector
conducted
several
tours of radiologically controlled areas
of the Reactor Building (RB), Radwaste
Building (RWB), and the .Turbine
Building (TB).
Independent
radiation
su'rvey's
were conducted
using
an ion
chamber survey instrument
model
R0-2, serial
¹022906,
due for calibration
August 20,
1988.
Discussion of radi.ological postings
noted during the,
tour is contained
in paragraph
5, above;
Housekeeping
appeared typical.
The inspector
noted that the 437'WB was
somewhat cluttered in the area of the truck bay, inclu'ding the area
where
the incident occurred
as discussed
in paragraph
5.A, above.
The
inspector continued to have difficulty in finding gloves which would pass
a leak check - about
30K of gloves tested failed (see Inspection
Report
50-397/88-22,
paragraph
3).
The following instrumentation
problems .were observed:
WPA-RIS-1 detector
broken.
Maintenance
Work Request
(MWR)
submitted.
RRA-RIS-1 same
as
above
MEA-FIS-1A magnehelic
flow meter pegged
high (flow indicator for
WEA-SR-25A,
RWB effluent monitor).
REA"SR-37 bypass
vacuum
pump "on" light not on with pump running
(RB
effluent monitor).
Frisker model ¹L-177 serial
¹137
no daily source
check (548'B
stairwell)-
1
The inspector
informed the
HP Foreman of MEA-FIS-lA and REA-SR-37, of
which he was not previously aware,
and for which
MMRs were then
submitted. 'he
HPT was informed of the frisker, for which he had
already dispatched
an
HPT to perform a source
check.
The rotameter for
15
WEA-FIS-lA indicated proper
sample flow, and
WEA-SUM-1 was operating
properly.
The
ARM strip chart recorder
(see Inspection
Report 50-397/88-22)
was
observed to be operating with each
bank using different colors
as
designed.
However, the individual readings
were difficult to discern
due
to a lack of contrast
between
selected
colors.
During a brief tour of the Plant Support Facility, (PSF)
on July 18,
1988, the bulletin boards for the
PSF,
in particular of the laundry,
calibration,
and other radiological areas,
were noted to have statements
as to where documents
can
be found, pursuant to 10 CFR 19. 11(b).
10 CFR 19.11 reads,
in part:
"(a) Each licensee
shall post current copies of the following documents:
(1)
The regulations
in this part and in Part
20 of this chapter;
(2)
The license...."
"(3)
The operating procedures..."
(4)
Any notice of violation involving radiological worki,ng
~ conditions,
"(b) If posting of a document specified in paragraph
(a) (1), (2) or (3)
of this section is not practicable',
the licensee
may post
a notice
which describes
the document
and states
where it may be examined..."
"(d) Documents,
notices,
or forms posted pursuant to this section shall
appear in a sufficient number of places to permit individuals
engaged
in licensed activities to observe
them on,-the way to or from
any p'articular licensed activity location to which the document
applies,
shall
be conspicuous,
and shall
be replaced if defaced or
altered.
(e)
Commission
documents
posted pursuant to paragraph
(a)(4) of this
section shall
be posted within 2 working days after receipt of the
documents
from the Commission;
All of the bulletin boards
were posted with a description of where
documents
could be viewed, in accordance
wi'th 10 CFR 19. 11(b).
However,
some were noted to have
a statement
to the effect that this applied to 10 CFR 19. 11(a)(4).
A Notice of Violation involving radiological wqrking conditions
was
issued to the licensee,
on June
29,
1988 (see
Inspection
Report
50-397/88-22,
Appendix
A "Notice of Violation").
Discussion with the
licensee
revealed that it had been received
on July 5, 1988,
and posted
in accordance
with licensee
procedure
1. 10;5,
"NRC Required Bulletin
Board Postings,"
Revision 4, dated 8-13-86.
The procedure
did not,
however,
address
areas
where radiological
work and/or licensed activities
take place outside the protected
area.
When informed, the licensee
16
immediately (within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) posted the
PSF with the notice, to comply
with 10
CF R 19. 11(d) .
The inspector attended
respiratory protection training, which the
licensee
conducts
in part to meet the requirements
of 10 CFR 20. 103
"Exposure of individuals to concentrations
of radioactive materials in
air in restricted areas."
and
"Manual of Respiratory
Protection Against Airborne Radioactive Materials."
Some minor errors,
primarily regarding non-radiological
aspects
of self-contained
breathing
apparatus
(SCBA) use,
were corrected
when brought to the attention of the
instructor.
The requirement to provide special training in SCBA use,
pursuant to 10 CFR 20, Appendix A, note k, was discussed
with the
Manager,
General
and Technical
Support Training (GTST),
who acknowledged
the inspector's
concerns
and,stated
that they would be further addressed.
The inspector
inform'ed the
GTST manager of the matters
which had already
, been corrected
by the instructor.
The inspector verified radiological postings within the
RWB,
to be in accordance
with 10 CFR 20.203,
"Caution signs,.labels,
signals
and controls."
The licensee
stated that
MWRs had been submitted to
construct enclosures
for two areas
in the 467'WB east
and west valve
galleries,
which were posted with flasliing yellow lights to indicate high
radiation areas
greater
than
1000 mrem/hr,
pursuant. to TS 6.,12.2.
Mater
was observed" to be flowing slowly across
the cbrner of a posted
contaminated
area into'the unposted
walkway in the west valve gallery.
A
survey by the licensee
indjcated
no spread of contamination into the
clean area.
Frisking of personal
items
and equipment for contamination at the exit
from the radiologically controlled area
(RCA) was observed.
Various
HPTs
were observed,
and survey techniques
were not consistently
thorough.
In
one instance,
a portion of the inspector'.s
hard hat was surveyed with the
wrong side of the detector probe, i.e., with the window pointed
away from
the hat.
The hat was verified to not be contaminated.
The inspector
~ expressed
concern, that 'equipment which 'might be contaminated
could be
released to'nrestricted
areas.
This was discussed
with the
Supervisor,
who immediately ordered
HPTs to improve their technique,
and
authorized
them to discourage
individual workers
from taking extraneous
ot unnecessary
equipment into controlled areas.
No violations or deviations
were identified.
Exit Interview
The inspector
met with those individuals denoted in paragraph
1 at the
conclusion of the inspection
on July 22; 1988..
The scope
and findings of
the inspection
were summarized.
The licensee
acknowledged
the
inspector's
observations.
With regard to the unresolved
item discussed
in paragraph
5.B, the Plant Manager stated that the
had performed the
required'review
process for a TS interpretation,
and expressed
concern
that an ambiguous wording in the
TS might result in a violation.
The
inspecto'r
reminded
him of the concerns
expressed
by NSAG,
CNSRB,
and
Licensing.