ML17291A646
| ML17291A646 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/01/1995 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17291A645 | List: |
| References | |
| 50-397-95-01, 50-397-95-1, NUDOCS 9502150027 | |
| Download: ML17291A646 (27) | |
See also: IR 05000397/1995001
Text
APPENDIX
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-397/95-01
License:
Licensee:
Washington Public Power Supply System
3000 George Washington
Way
P.O.
Box 968,
MD 1023
Richland,
Facility Name:
Washington Nuclear Project-2
Inspection At:
Richland,
Inspection
Conducted:
January
9-12,
1995
Inspector:
J.
B. Nicholas,
Ph;D.,
Senior
Radiation Specialist
Facilities Inspection
Programs
Branch
Approved:
aine
urray,
ie
Facilities Inspection
Program
Branch
ate
Ins ection
Summar
Areas
Ins ected:
Routine,
announced
inspection of the liquid and gaseous
radioactive waste
management
programs
including quality assurance;
radioactive
liquid and gaseous
effluent systems;
reports of radioactive effluents;
engineered-safety-feature
air cleaning ventilation systems;
and
a review of
Licensee
Event Reports 397/94-012,
397/94-019,
and 397/94-021.
Results:
The radioactive waste effluent management
program
was being properly
implemented
(Section
1. 1).
The chemistry department
organizational
structure
and staffing met
requirements
(Section
1. 1).
The chemistry department
had experienced
very low turnover of technical
personnel
(Section
1. 1).
Comprehensive
quality assurance
audit
and assessment
programs of the
radioactive waste effluent program
and Offsite Dose Calculation
Manual
were implemented
(Section
2. 1).
9502l50027
950208
ADOCK 05000397
8
~
The corrective action program
was implemented properly (Section
2. 1).
~
A thorough quality assurance
audit was performed of the contractor
used
to perform the engineered-safety-feature
(ESF) air cleaning
systems'urveillance
tests
(Section
2. 1).
~
Good liquid and gaseous
radioactive waste effluent programs
were being
properly implemented
(Sections
3. 1 and 4. 1).
~
Radioactive Effluent Release
Reports
were submitted in a timely manner
and contained
the required information (Section
5. 1).
~
A good program was established
for testing the high efficiency
particulate air (HEPA) filter and charcoal
adsorption units in the
(ESF)
air cleaning
systems
(Section
6. 1).
Summar
of Ins ection Findin s:
~
Licensee
Event Reports
397/94-012,
397/94-019,
and 397/94-021
were
reviewed
(Section 7).
Attachments:
Attachment
1
Persons
Con'tacted
and Exit
Heeting'ttachment
2.
Attachment 3-
Summation of all Liquid Effluent,Releases
Summation of all Airborne Effluent Releases
Attachment
4 Haximum Annual
Doses
from Gaseous
and Liquid
Effluent Releases
Attachment
5 - Liquid Effluent Release
Summary...
Attachment
6 - Gaseous .Effluent,Release
Summary
-3-
DETAILS
1
ORGANIZATION AND MANAGEMENT CONTROLS
(84750)
The inspector
reviewed the organization
and staffing regarding the radioactive
waste effluent program to determine
agreement
with commitments in the Updated
Safety Analysis Report
and compliance with the requirements
in Technical Specification 6.2.
1. 1
Discussion
The inspector verified that the organizational
structure of the chemistry
department,
which is responsible for the implementation of the radioactive
waste effluent program,
was
as defined in the Updated Safety Analysis Report
and Technical Specifications.
It was noted that the chemistry department
was
assigned
the sole responsibility for implementing the radioactive waste
effluent program effective October
1993.
The chemistry department
organization
had three functional
areas
each
headed
by a supervisor or
technical specialist
who reported directly to the chemistry manager.
One of
these functional
areas
was responsible for implementing the radioactive waste
effluent program.
The assignment
of the chemistry department
placed the
implementation of the radioactive waste effluent program all within one
department
under the operations
department.
Management
control procedures
were reviewed for the assignment
of
responsibilities
for the management
and implementation of the radioactive
waste effluents program.
The chemistry department
was assigned
the
responsibility for preparing radioactive waste release
permits,
evaluating the
radioactive waste effluent releases,
calculating the radiation doses resulting
from the releases to'he environment,
and maintaining the radioactive waste
effluent release
data.
The inspector determined that the duties
and
responsibilities of the chemistry department
specified in the procedures
were
being implemented.
A group of 15 chemistry technicians staffing
6 rotational
shifts within the chemistry operations
functional
area
along with a senior
radiochemist
and technical specialist
assigned
to the radioactive waste
effluents functional
area
were responsible for collecting
and analyzing
radioactive waste effluent samples,
preparing the effluent release
permits,
and implementing the radioactive waste effluents program.
The inspector
interviewed several
of the chemistry staff responsible for the implementation
of the radioactive
waste effluents program
and determined that they were
familiar with the requirements
of the radioactive waste effluents program
and
maintained
a high level of performance.
The inspector
reviewed the staffing of the chemistry department
and determined
it to be adequate
and in accordance
with licensee
commitments.
There
had
been
a very low turnover of personnel
within the chemistry department
since the
previous
NRC inspection of this area in August 1993.
gO
1.2
Conclusions
The chemistry department
organizational
structure
and staffing met Technical
Specification requirements.
The radioactive
waste effluent management
program
was being implemented in accordance
with station procedures.
The chemistry
department
had experienced
a very low turnover of personnel
during the past
17 months.
2
EQUALITY ASSURANCE
PROGRAM (84750)
The inspector
reviewed the quality assurance
audit and assessment
programs
regarding the radioactive waste effluent program activities to determine
agreement
with commitments in the Updated Safety Analysis Report
and
compliance with the requirements
in Technical Specification 6.5.2.8.
2. 1 Discussion
The 'inspector
reviewed the quality assurance
audit schedules
for 1993,
1994,
and
1995; audit plans
and checklists;
and the qualifications of the quality
assurance
auditors
who performed the audits of the radiological
and non-
radiological
environmental
and effluent monitoring programs,
and Offsite Dose
Calculation Manual.
The review of the quality assurance
audit schedules
indicated that the audit of the radiological
environmental
monitoring and
radiological effluent programs
was scheduled
on
a
12 month frequency.
The
quality assurance
audit of the Offsite Dose Calculation
Manual
was scheduled
on
a 24 month frequency.
The audits were scheduled
in compliance with
Technical Specification audit frequency requirements.
Reports of quality assurance
audits performed during the period January
1993
through
December
1994 of the areas
related to the performance of the
radioactive waste effluent program were reviewed for scope,
thoroughness
of
program evaluation,
and timely followup of identified deficiencies.
The
audits
were performed in accordance
with quality assurance
procedures
and
schedules
by qualified auditors.
The reviewed audits of the radiological
and
non-radiological
environmental
and effluent monitoring programs,
and Offsite
Dose Calculation
Manual
and its implementing procedures
were of good quality
and provided satisfactory oversight
and evaluation of the licensee's
performance
in implementing the radioactive waste effluent program
and meeting
the Technical Specification
and Offsite Dose Calculation
Manual requirements.
The inspector
reviewed guality Assurance
Audit Report 293-618,
"Radiological
and Non-Radiological
Environmental
and Effluent Monitoring," dated
November
19,
1993, which was conducted
by an audit team that included
members with
radiochemistry
and radioactive waste effluent program experience.
Regulatory
Guide 4. 15, Revision
1, "guality Assurance for Radiological Monitoring
Programs-Effluent
Streams
and the Environment,"
was used
as the basis for
development of the audit scope
and checklists.
The inspector
reviewed the
audit checklist
and found it to be appropriate
in that it addressed
all
aspects
of the radiological liquid and gaseous
effluent program.
The audit
reviewed the radiological liquid and gaseous
effluent monitoring programs
including sampling,
analyses,
and radiological effluent release
procedures;
instrument calibration (i.e. isotopic calibration of the
new reactor building
elevated
release
point stack monitor);
and procedure
implementation of
Regulatory
Guide 4. 15 and Offsite Dose Calculation
Manual requirements.
The
audit identified two findings which were closed during the audit
and eight
recommendations
for improvement.
No deficiencies
were identified with the
radiological liquid and gaseous
effluent monitoring programs.
The inspector
reviewed guality Assurance
Audit Report 294-066,
"Radiological
and Non-Radiological
Environmental
and Effluent Monitoring Programs,"
dated
November
18,
1994,
which was conducted
by an audit team that included
members
with radiochemistry
and radioactive
waste effluent program experience.
The
audit reviewed,
in part,
the radiological liquid and gaseous
effluent
monitoring programs
and the implementation of Offsite Dose Calculation
Manual
requirements.
The audit results
indicated that the radiological
and non-
radiological
environmental
and effluent monitoring programs
were properly
implemented
and met program
and regulatory requirements.
However, the audit
identified six program deficiencies
which were documented
in Problem
Evaluation
Requests
(the station corrective action document).
Two Problem Evaluation
Requests
(PER 94-0911
and
PER 94-0943)
were initiated
to document identified problems with the timely completion of commitments
associated
with pre-operational
testing of the reactor building stack effluent
monitor.
The two Problem Evaluation Requests
were closed in a timely manner.
PER 94-0926
documented
several
identified activities required
by the Offsite
Dose Calculation
Manual which were associated
with the operation of the
gaseous
radwaste
system,
the land use census,
and atmospheric
dispersion
factors
and were not addressed
in the Plant Procedure
Manual.
The audit noted
that
no procedure
steps
were found which would initiate or implement main
plant vent release
monitor setpoint
changes
in the event of running the
Standby Offgas Treatment
System in the charcoal
bypass
mode.
The audit also
noted that chemistry procedures
did not contain guidance
on evaluating the
Land Use Census results for inclusion in the Radioactive Effluent Release
Report or the Offsite Dose Calculation Manual.
Atmospheric dispersion factors
from the station's
meteorological
tower were to be evaluated
annually;
however,
there
was
no procedure
guidance for performing the annual
evaluation
of the atmospheric
dispersion factors,
and the audit team could not find any
documentation
of the annual
evaluation of the atmospheric
dispersion factors
being performed in 1994.
Responses
to
PER 94-0926 were currently being
prepared
by the chemistry department for evaluation
and acceptance
by the
quality assurance
department for closure of the Problem Evaluation
Request.
PER 94-0927
documented
the findings that
an incorrect reporting format was
used to identify the Process
Control
Program revisions in the
1993 Radioactive
Effluent Release
Report,
and that the chemistry department
person calculating
the
31 day gaseous
effluent dose
was not performing the calculations properly
and did not have
a through understanding
of the
GASPAR II computer code.
Responses
to
PER 94-0927 were currently being prepared
by the chemistry
department for evaluation
and acceptance
by the quality assurance
department
for closure of the Problem Evaluation Request.
The audit team's
review of
Offsite Dose Calculation
Nanual
implementing procedures
resulted in the
issuance
of three suggestions
and
one recommendation
for program procedural
improvements.
The inspector
reviewed guality Assurance
Technical
Assessment
Report 93-006,
"Sulfuric Acid Transfer
To The Circulating Water Basin," dated
June
30,
1993.
Approximately 1000 gallons of concentrated
sulfuric acid were inadvertently
transferred
from the acid storage
tank to the neutralization tank in the
makeup water treatment
system in the basement
of the General
Services
Building.
Neutralization with caustic
was attempted,
but leakage of acid
through fittings prevented
completion of the neutralization with only about
a
third of the acid being neutralized.
The acid was then
pumped to the
circulation water basin
and neutralized with soda
ash.
The technical
assessment
presented
a very through evaluation of the potentially dangerous
situation.
The licensee
used
a contractor to .perform in-place filter testing
and
laboratory charcoal
adsorber
analyses
on the station's
ESF air cleaning
systems.
The licensee
used
an audit of the air cleaning
systems filter
testing contractor
performed
by
a Nuclear Procurement
Issues
Committee audit
team led by the licensee
during the period November 15-17,
1994, to evaluate
the performance of the contractor to perform the required tests
and to retain
his current status
on the licensee's
qualified suppliers list.
The inspector
reviewed the audit performed
on the contractor
and determined that the audit
was satisfactory to evaluate
the contractor's abilities to perform the
Technical Specification required
analyses
and surveillance activities.
The
audit identified three deficiencies
which were documented
in guality Finding
Reports.
Responses
to the guality Finding Reports
were not due from the
contractor until January
20,
1995.
Therefore,
the responses
were not
available for review at the time of the inspection.
The deficiencies did not
directly impact the contractor's
performance of the filter system testing or
the charcoal testing.
The inspector verified that the licensee
had also
performed
annual
evaluations of the contractor's
program
as required to retain
its current status
on the licensee's
qualified suppliers list.
2.2
Conclusions
guality assurance
audits of the radioactive waste effluent program
and Offsite
Dose Calculation
Hanual
were performed
as required.
These audits were
technically comprehensive
and provided
good program evaluation
and management
oversight, identified deficiencies,
and
made recommendations
for program
improvement.
The corrective action program
was
implemented properly.
A good
quality assurance
technical
assessment
which monitored the neutralization of
approximately
1000 gallons of sulfuric acid was performed.
A good audit
and
annual
evaluations
of the contractor
used to perform safety-related
air
cleaning systems'urveillance
testing
and analyses
were performed
as required
to retain the contractor's
current status
on the licensee's
qualified
suppliers list.
3
LIQUID RADIOACTIVE WASTE EFFLUENTS
(84750)
The inspector
reviewed the liquid radioactive
waste effluent program including
liquid waste processing,
liquid waste sampling
and analyses,
procedures
for
control
and release
of radioactive liquid waste effluents,
and surveillance
tests to determine
agreement
with commitments in the Updated Safety Analysis
Report
and compliance with the requirements
in Technical Specifications 6.8. 1,
6.8.4.d,
and 6. 14;
and the Offsite Dose Calculation
Manual Section 6.2. 1 and
Table 6.2.1.1.1-1.
4
3. 1
Discussion
The inspector
reviewed the licensee's
implementation of the liquid radioactive
waste effluent program
and Offsite Dose Calculation
Manual to ensure
compliance with sampling
and analyses
requirements,
analyses
sensitivities,
analytical results,
surveillance tests,
radioactive waste liquid effluent
control procedures,
and offsite dose results
from radioactive liquid
effluents.
The inspector
reviewed selected
procedures
governing the release
of liquid
radioactive waste effluents.
These
procedures
provided for the following:
recirculation
and sampling of the radioactive liquid waste;
radionuclide
analyses
of the radioactive liquid waste prior to release;
calculation of
effluent release
rate, effluent radiation monitor setpoints,
projected offsite
radionuclide concentrations,
and offsite doses prior to release;
and the
verification and recording of effluent discharge
flow rates,
effluent volume
discharged,
effluent discharge radiation monitor readings,
and dilution
parameters
during the release.
The inspector
reviewed
a representative
number of batch radioactive waste
liquid release
permits for the period January
1,
1994 through
December
31,
1994.
It was determined that the processing,
sampling,
and
analyses
of radioactive
waste liquid effluent and the approval
and performance
of batch liquid radioactive waste discharges
were conducted
in accordance
with
Offsite Dose Calculation
Manual requirements.
Quantities of radionuclides
released
in the liquid effluents were within the limits specified in the
Offsite Dose Calculation Manual.
Offsite doses
were calculated
according to
the Offsite Dose Calculation
Manual
and were within the required limits.
The
inspector verified that the licensee
was performing the Offsite Dose
Calculation
Manual required
analyses
on composite
samples of batch radioactive
liquid releases
for gross
alpha, tritium, strontium-89,
and
iron-55.
The inspector
inspected
the chemistry laboratory
and radiochemistry counting
facility and determined that the licensee
had sufficient state-of-the-art
analytical
instrumentation
to perform the required radiochemistry analytical
measurements
of the radioactive waste effluents.
The inspector
inspected
the
radwaste building and the liquid radioactive waste processing
equipment
including the liquid radioactive waste floor drain tank and the two equipment
drain tanks
and the local
sample points at each of the liquid radioactive
waste storage
tanks for collecting representative
samples
from the respective
tanks prior to preparing effluent release
permits.
The liquid l adioactive
waste processing
and storage
systems
were installed
as described
in the
Updated Safety Analysis Report
and operated
in accordance
with station
procedures
to ensure
compliance with Offsite Dose Calculation
Manual
requirements.
The inspector determined that
no design modifications
had
been
made to the
liquid radioactive
waste
management
systems
during 1992,
1993,
and
1994.
3.2
Conclusions
The licensee
was implementing
a liquid radioactive waste effluent program in
accordance
with the Technical Specifications
and the Offsite Dose Calculation
Manual.
The quantities of radionuclides
released
in the liquid radioactive
waste effluents were within the Offsite Dose Calculation
Manual limits.
Offsite doses to the environment
from the liquid radioactive waste effluents
had
been calculated
using Offsite Dose Calculation
Manual methodologies,
and
the dose results
were within Offsite Dose Calculation
Manual limits.
The
licensee
had not made
any major equipment or design modifications to the
radioactive liquid waste
management
systems
during 1992,
1993,
and
1994.
4
GASEOUS
RADIOACTIVE WASTE EFFLUENTS
(84750)
The inspector
reviewed the gaseous
radioactive
waste effluent program
including gaseous
waste processing,
gaseous
waste
sampling
and analyses,
and
procedures
for the control
and release of gaseous
waste effluents to determine
agreement
with commitments in the Updated Safety Analysis Report
and
compliance with the requirements
in Technical Specifications 6.8.1, 6.8.4.d,
and 6. 14;
and the Offsite Dose Calculation
Manual Section 6.2.2
and Table
6.2.2.1.2-1.
4.1
Discussion
The inspector
reviewed the licensee's
implementation of the gaseous
radioactive
waste effluent program
and Offsite Dose Calculation
Manual to
ensure
compliance with sampling
and analyses
requirements,
analyses
sensitivities,
analytical results,
surveillance tests,
radioactive waste
gaseous
effluent control procedures,
and offsite dose results
from radioactive
gaseous
effluents.
The inspector
reviewed selected
procedures
governing the continuous
and batch
releases
of gaseous
radioactive waste effluents.
These
procedures
provided
for the sampling
and analysis of the radioactive
gaseous
waste effluents,
calculation of effluent release
rate, calculation of projected offsite
radionuclide concentrations
and doses,
and calculation
and verification of
gaseous
effluent radiation monitor setpoints prior to release;
recording of
dilution parameters
during the release;
and verification of effluent discharge
flow rates
and effluent volume discharged.
The inspector
reviewed selected
gaseous
waste
sample
analyses
for samples
from
the main plant vent, turbine building vents,
and radwaste building vent
continuous
releases
and selected
gaseous
waste release
permits for batch
releases
for containment
vents
and purges for the period January
1,
1994
through
December
31,
1994.
It was determined that the sampling,
analyses,
and
discharge of the radioactive
gaseous
effluents
and the approval of the
radioactive
gaseous
waste containment
vents
and purges
were conducted
in
accordance
with Offsite Dose Calculation
Manual requirements.
guantities of
gaseous
and particulate radionuclides
released
were within the limits
specified in the Offsite Dose Calculation Manual.
Offsite doses
had
been
calculated
according to Offsite Dose Calculation
Manual methodologies
and were
within required limits.
Particulate effluent composite
sample
analyses
for
gross
alpha,
strontium-89,
and strontium-90
had
been
performed
and met Offsite
Dose Calculation
Manual requirements.
The inspector determined that
no major
equipment or design modifications
had
been
made to the radioactive
gaseous
waste
management
systems
during
1993
and
1994.
/
4.2
Conclusions
The licensee
was implementing
a gaseous
radioactive waste effluent program in
accordance
with the Technical Specifications
and the Offsite Dose Calculation
Manual.
The quantities of radionuclides
released
in the gaseous
radioactive
waste effluents were within the Offsite Dose Calculation
Manual limits.
Offsite doses
to the environment
from the gaseous
radioactive waste effluents
had
been calculated
using Offsite Dose Calculation
Manual methodologies,
and
the dose results
were within Offsite Dose Calculation
Manual limits.
The
licensee
had not made
any major equipment or design modifications to the
radioactive
gaseous
waste
management
systems
during
1993
and 1994.
5
REPORTS
OF RADIOACTIVE EFFLUENTS
(84750)
The inspector
reviewed reports
concerning radioactive
waste
systems
and
effluent releases
to determine
compliance with the requirements
Technical Specifications 6.9. l. 11
and 6. 14,
and the Offsite Dose
Calculation
Hanual
Section 6.4.2.
5. 1
Discussion
/
The inspector
reviewed the Semiannual
Radioactive Effluent Release
Reports for
the time periods January
1,
1992 through June
30,
1992,
and July 1,
1992
through
December
31,
1992,
and the Annual Radioactive Effluent Release
Report
for the time period January
1 through
December
31,
1993.
The reports
were
written in the format described
in NRC Regulatory
Guide 1.21,
Revision
1, June
1974,
and contained
the information required
by the Offsite Dose Calculation
Manual.
During the time period January
1 through
December
31,
1992, the
licensee
performed
161 liquid batch releases,
75 containment
vents,
and
15
containment
purges.
During the time period January
1 through
December 31,
1993,
the licensee
performed
201 liquid batch releases,
52
containment
vents,
and
19 containment
purges.
-10-
The licensee
reported
two abnormal
releases
of radioactive liquid waste during
1992
and
no abnormal effluent releases
during 1993.
Problem Evaluation
Requests
292-0622
and 292-0671
documented
the
1992 abnormal
release
events.
During the performance of the monthly batch release
composite for the month of
May 1992,
one batch release
sample out of 24 batch releases
for that month was
found to be missing.
The missing
sample
was attributed to the fact that the
original entry of the batch release
in the Liquid Release
Log was voided.
The
voided log entry resulted
in the disposal of the sample
as
a terminated
release.
The loss of the sample
had very little impact
on the analytical
results of the monthly and quarterly composite
analyses for tritium, gross
alpha,
strontium-89; strontium-90,
and iron-55.
The inspector
reviewed the
licensee's
description
and followup actions
concerning
the missing
sample
and
determined that the licensee
had determined
the root cause of the event
and
had taken appropriate corrective action.
At no time were
any Offsite Dose
Calculation
Manual
dose or release
concentration limits exceeded.
The second
abnormal
release
event
happened
on June
11,
1992, with a partial
release
of Floor Drain Tank TK-9 before its radioactivity analysis
was
completed.
Using
a release
authorization permit for Equipment Drain Tank
TK-4B, the radwaste
control
room operator mistakenly started to release
Floor
Drain Tank TK-9, which he
knew had
been
sampled.
However, the radioactivity
analysis
and release
authorization for Floor Drain Tank TK-9 had not been
completed.
The radwaste
control
room operator terminated the release
of Floor
Drain Tank TK-9 when
he noted
no decrease
in the Equipment Drain Tank TK-4B
tank level
he thought
he was releasing.
Approximately 11,750 gallons of
radioactive liquid waste effluent were released
from Floor Drain Tank TK-9 to
the river before the release
was terminated.
The inspector reviewed the
licensee's
description
and followup actions concerning the abnormal
release
event
and determined that the licensee
had determined
the root cause of the
event
and
had taken appropriate
corrective action.
At no time were any
Offsite Dose Calculation
Manual
dose or release
concentration limits exceeded.
Both Problem Evaluation
Requests
were closed
by the licensee.
Effluent monitoring instrumentation
had not been out of service in excess of
Technical Specification requirements
during
1992
and
1993.
The inspector
reviewed
changes
(Amendments
11,
12,
13,
14,
15,
and
16) to the
Offsite Dose Calculation Manual, which were
made
and approved
by the Plant
Operations
Committee during
1992
and
1993.
The changes
were well documented
in the Radioactive Effluent Release
Reports
as required
by the Offsite Dose
Calculation Manual.
Summaries of the radioactive liquid and gaseous
effluent releases
and
associated
doses for 1992
and
1993 are presented
in Attachments
2 through
6 to
this inspection report.
5.2
Conclusions
The licensee
had submitted the Radioactive Effluent Release
Reports for 1992
and
1993 in
a timely manner,
and the reports
contained all the required
information presented
in the format described
in
NRC Regulatory
Guide 1.21.
The abnormal
radioactive liquid effluent releases
did not exceed
any Offsite
Dose Calculation
Hanual limits.
Changes
to the Offsite Dose Calculation
Hanual
were properly documented.
6
AIR CLEANING SYSTEMS
(84750)
The inspector
reviewed the engineered-safety-feature
air cleaning
systems
testing
program to determine
agreement
with the commitments
in the Updated
Safety Analysis Report
and compliance with the requirements
in Technical Specifications 4.6.5. 1, 4.6.5.3,
and 4.7.2.
6. 1
Discussion
The inspector
reviewed selected
procedures
and surveillance test results
and
records for the surveillance testing of the
ESF air cleaning
systems
which
contained
HEPA filters and activated
charcoal
adsorbers.
The inspector
verified that the procedures
and surveillance tests
provided for the required
periodic functional checking of the
ESF air cleaning systems'omponents,
evaluation of the
HEPA filters and activated
charcoal
adsorbers,
and the
replacement
and in-place filter testing of the filter systems.
Selected
records
and test results for the time period January
1993 through
December
1994 for the standby
gas treatment
system
and control
room emergency
filtration system
were reviewed.
The in-place filter testing,
activated
charcoal
laboratory tests,
and the control
room emergency filtration system
pressure
testing were performed in accordance
with approved
procedures
by a
contract laboratory
and the licensee,
and the test results
were verified to be
within Technical Specification limits except for the test results
documented
in Licensee
Event Reports94-012,
94-019,
and 94-021.
The inspector noted
that the
ESF air cleaning systems'perating
hours
was being tracked
by the
control
room on the daily shift log to meet the Technical Specification
requirement for testing the two
ESF air cleaning systems'ctivated
charcoal
.
adsorber material
at least every
18 months or after every
720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of
operation.
6.2
Conclusions
The
ESF air cleaning
systems
conformed to the commitments in the Updated
Safety Analysis Report
and met the Technical Specification requirements.
The
ESF air cleaning
systems
were tested
in accordance
with Technical
Specification requirements,
and the test results
were within Technical
Specification limits except for the test results
documented
in Licensee
Event
Reports94-012,
94-019,
and 94-021.
-12-
7
ONSITE REVIEW OF LICENSEE EVENT REPORTS
(92904)
7.1
0 en
Licensee
Event
Re ort 397 94-012:
Control
Room
Emer enc
Filter
WMA-FU-54B Ino erable
Due to Leakin
Delu
e
Su
1
Isolation Valve
On June
23,
1994,
approximately five inches of water was discovered
in the
bottom of the control
room emergency filter unit, WMA-FU-54B.
The water
came
from leakage
past
a deluge
system isolation valve (FP-V-WMA/21), which had
been
observed to be leaking in March 1994 but had not been repaired.
This
caused
the control
room emergency filter unit's charcoal filter to be
Spring-loaded
check valves installed in the filter unit's bottom
drain lines trapped
the water in the filter unit wetting the charcoal filter
bed
and causing it to be not available to perform its design safety function.
Immediate corrective action taken
by the licensee
included replacing the
leaking deluge
system isolation valve, cleaning the filter unit,
and replacing
and testing the charcoal filter bed.
The inspector reviewed the licensee's
corrective actions
and the safety
significance of the event.
In the event of an accident,
the filter unit
actuates
to protect the control
room personnel
from airborne particulate
and
iodine radioactivity by pressurizing
the control
room with filtered air.
Because five inches of water had collected in the bottom of the filter unit,
the iodine removal efficiency of the charcoal filter bed
was significantly
reduced,
and the charcoal filter unit was not able to perform its design
safety function.
The inspector
reviewed the radiological
dose significance of
the event in the case of an accident during the time the filter unit was not
available to filter and remove radioactive iodine from the incoming air to the
control
room and the subsequent
radiation
dose to the control
room personnel.
As described
below, the inspector
reviewed the licensee's
radiological
dose
calculations
performed to determine
the safety significance
and potential
radiological
consequences
as
a result of the event.
Formal resolution
and
closure of this event will be documented
in
NRC Inspection
Report
50-397/94-34.
7.2
0 en
Licensee
Event
Re ort 397 94-019:
Gasket Missin
From Main
Control
Room Air Handler
WMA-AH-51B Precludes
Associated
Emer enc
Fan
WMA-FN-54B From Sufficientl
Pressurizin
The Control
Room
On November 21,
1994, with the plant at
100 percent
power, control
room
emergency
fan unit WMA-FN-54B failed to pressurize
the main control
room
sufficiently to meet Technical Specification surveillance
requirements.
A
missing gasket,
removed October
26,
1994,
from access
door
3 of the main
control
room air handling unit WMA-AH-54B, caused air leakage
around the door
with the missing gasket
and precluded sufficient main control
room
pressurization
to meet Technical Specification surveillance
requirements.
Pressurization
of the main control
room during the event of an accident is
part of the design function of the control
room emergency air handling unit to
protect control
room personnel
and maintain control
room habitability.
During
a loss of coolant accident,
a protection signal automatically isolates
the
-13-
normal'control
room ventilation system
and initiates emergency pressurization
of the control
room.
Technical Specifications
require that each
emergency
fan
unit be capable of pressurizing
the main control
room to 0. 125 inches of water
column with respect to adjacent
areas
to prevent unfiltered air inleakage.
During the surveillance testing of control
room emergency
fan unit WHA-FN-54B,
the emergency
fan unit only pressurized
the main control
room to 0.05 inches
of water column failing the surveillance test.
A new door gasket
was
installed
on access
door 3 on November 22,
1994,
and the main control
room air
handling unit WMA-AH-54B and associated
emergency
fan unit WHA-FN-54B were
retested
on November
23,
1994.
The main control
room air handling unit again
failed its surveillance pressurization
test
due to an unrelated
work activity
performed
on November
22,
1994,
as described
in Licensee
Event Report 94-021.
As described
below, the inspector
reviewed the safety significance
and
potential radiological
consequences
as
a result of the event.
Formal
resolution
and closure of this event will be documented
in
NRC inspection
report 50-397/94-34.
7.3
0 en
Licensee
Event
Re ort 397 94-021:
Holes Cut In Main Control
Room
Floor Penetration
5016 Precludes
Redundant
Emer enc
Fans
WMA-FN-54A B
From Pressurizin
The Control
Room Sufficientl
To Meet The
A licable
Surveillance
On November 23,
1994, with the plant at
100 percent
power, it was determined
during the performance of a routine pressurization
surveillance test of the
main control
room that
a flow path created
by a barrier impairment in the main
control
room floor to the cable spreading
room through penetration
5016
located
under instrument
panel
H13-P682 prevented
emergency
fan unit
WHA-FN-54B from pressurizing
the main control
room sufficiently to meet
Technical Specification requirements.
The main control
room barrier
impairment
was caused
by two holes cut in the main control
room floor into the
cable spreading
room below the main control
room on November 22,
1994.
This
event prevented
both redundant
control
room emergency
fans,
WHA-FN-54A(B),
from pressurizing
the main control
room sufficiently to meet Technical
Specification surveillance
requirements.
The licensee's
assessment
of the
surveillance test results
indicated that the main control
room still would
have
been
amply pressurized
to prevent infiltration of air during
a postulated
accident involving a radioactive release.
The two holes in penetration
5016
were sealed
approximately
one hour after the failure of the initial
pressurization
surveillance test of the main control
room.
The main control
room pressurization
surveillance test
was performed,
and the main control
room
pressurization
capability by both emergency
fans
WHA-FN-54A(B) was verified.
As described
below, the inspector
reviewed the safety significance
and
potential radiological
consequences
as
a result of the event.
Formal
resolution
and closure of this event will be documented
in
NRC inspection
report 50-397/94-34.
'h
During the inspection,
the inspector reviewed the design
and operation of the
main control
room emergency air handling
and associated filtration units
identified in the three related
Licensee
Event Reports
summarized
above.
The
inspector interviewed the system engineer responsible for the main control
room emergency air handling units,
performed
a walkdown of the main control
room emergency air handling units
and inspected
the failed equipment
identified in the Licensee
Event Reports for repair
and operability.
The
inspector also reviewed
how the failed equipment affected the designed
performance of the main control
emergency air handing units
and the
consequences
its failure caused
in radiologically protecting the control
room
personnel
and maintaining control
room habitability in the event of an
accident.
As
a result of the first event reported in Licensee
Event Report 94-012,
inoperability of the charcoal filter bed in the main control
room filter unit
WMA-FU-54B, the licensee
performed
an evaluation to determine
the radioactive
iodine dose to control
room personnel
from a hypothetical
dropped fuel bundle
accident during the time the main control
room emergency air handing unit
charcoal filter bed
was not available to perform its design function.
The
licensee'sed
the postulated
dropped fuel bundle design basis
accident
scenario
to evaluate
the radiological
consequences
to the control
room
personnel
since the reactor
had
been in cold shutdown for a maintenance
outage
since April 26,
1994.
The licensee
used the computer
code
"PADD" with design
basis
source
term input of the isotopic concentrations
of iodines
and noble
gases
taken from the Updated Safety Analysis Report,
Table 15.7-20 for
airborne radioactivity in the secondary
containment
due to a fuel handling
accident,
to perform the radiological
dose calculations for the postulated
scenario.
The results of the evaluation,
assuming that the accident
happened
35 days after shutdown of the reactor
and
no filtration was available,
indicated that the 30 day integrated radiation dose to the control
room
personnel
would be quite low.
The calculated radiation
dose results
indicated
that the whole body 30 day integrated
dose to control
room personnel
would be
approximately 2.6 E-04
Rem,
and the 30 day integrated thyroid dose would be
approximately 2.7 E-03
Rem.
The inspector postulated
a "worst case"
accident
which could have
happened
while the reactor
was at
100 percent
power prior to the shutdown April 26,
1994,
since there
was indication of leakage
past the deluge valve in March
1994.
The inspector requested
the licensee
to perform radiation
dose
calculations
based
on the postulated
designed
basis loss of coolant accident
scenario
as
an additional evaluation of the radiological
consequences
resulting from the events
described
in the above
Licensee
Event Reports.
The
licensee
used the computer
code
"PADD" with source
term input of the isotopic
concentrations
of iodines
and noble gases
taken from design basis
source
term
calculations
performed
by the computer
code
ORIGIN which very closely
approximated
the iodine and noble gas isotopic airborne radioactivity isotopic
concentrations
presented
in the Updated Safety Analysis Report,
Table 15.6-13
for airborne radioactivity in the primary containment
due to
a design basis
loss of coolant accident,
to perform the radiological
dose calculations for
the postulated
scenario.
The calculated radiation
dose result indicated that
-15-
the 30-day integrated thyroid dose would be approximately 8.6
Rem based
on the
assumptions
of no main control
room air filtration, a primary containment to
secondary
containment leak rate of 0.05 percent
per day,
and
a secondary
containment
bypass
leak rate of 0.33 standard
cubic feet per hour as measured
during the plant's eighth refueling outage
in the
summer of 1993.
These
values
were below the General
Design Criterion
19 of Appendix A, to
10 CFR Part 50, values of 5
Rem whole body
gamma dose,
30
Rem beta skin dose,
and
30
Rem thyroid dose
from exposure to direct radiation from external
sources
and
from airborne radioactivity within the control
room to control
room personnel.
Therefore,
a significant, but not an overexposure,
thyroid radiation dose
could have
been received
by control
room personnel
during the time the main
control
room air filtration unit was possibly inoperable
and the reactor
was
operating at
100 percent
power and all other redundant safety
systems
were
also inoperable
and not available.
ATTACHMENT 1
1
PERSONS
CONTACTED
1. 1
Licensee
Personnel
- J. Parrish,
Vice President,
Nuclear Operations
J.
P. Albers, Radiation Protection
Manager
- A. L. Alexander,
Lead Effluents Technical Specialist,
Chemistry
R. J.
Barbee,
Manager,
Technical
Services
A. S. Barber,
Technical Specialist, guality Assessments
- P.
R.
Bemis,
Manager,
Regulatory
Programs
- D. A. Bennett,
Acting Chemistry Manager
I. H. Borland, Technical Specialist,
guality Assessments
- W. S. Davison,
Manager,
Plant Support Assessments
- K. B. Lewis, Compliance
Engineer,
Regulatory
Programs
- H, P.
Hedges,
Corporate
Chemist
R. L. Koenigs,
Manager,
Design Engineering
C.
R. Madden,
Technical Specialist,
guality Assessments
- R. D. Madden,
Technical Specialist,
guality Assessments
J.
W. Massey,
Technical Specialist,
Operations
Event Analysis Resolution
- J. J. Muth, Hanager,
Plant Assessments
- L. H. Nolan,
Radwaste
Supervisor
- J. H. Pedro,
Compliance
Engineer,
Regulatory
Programs
C. J.
Schwarz,
Operations
Manager
J.
D. Snyder,
Plant Support Engineering
- J. H. Swailes,
Plant Manager
- D. A. Swank,
Licensing Manager,
Regulatory
Programs
B. L. Twitty, Principal
Engineer,
guality Assessments
J.
C. Wiles, Technical Specialist,
guality Assessments
C. J.
Zimmer,
System Engineer
1.2
NRC Personnel
R. Barr, Senior Resident
Inspector
D. Prouix, Resident
Inspector
In addition to the personnel
listed above,
the inspector contacted
other
personnel
during the inspection.
- Denotes
personnel
that attended
the exit meeting
on January
12,
1995.
2
EXIT MEETING
An exit meeting
was conducted on'anuary
12,
1995.
During this meeting,
the
inspector reviewed the scope
and findings of the report.
The licensee did not
express
a position
on the inspection findings documented
in this report.
The
licensee
did not identify as proprietary,
any information provided to, or
reviewed by, the inspector during the inspection.
ATTACHMENT2
SNHATION OF ALL LI UIO EFFLUENT RELEASES
QUARTER
1
QUARTER 2
QUARTER 3
QUARTER 4
QUARTER
1
QUARTER 2
QUARTER 3
QUARTER 4
1.
Number of Batch
Releases
2. Fission
8 Activation
Products
(Curies)
3. Tritium (Curies)
4. Oissolved
8 Entrained
Noble Gases
(Curies)
5. Waste Volume Released
(liters)
16
4.7 E-03
4.5 E-01
<5.0 E-04
9.2 E+05
53
6.5 E-02
2.6 E+00
<1.1 E-04
3.0 E+06
70
2.2 E-02
4.9 E+00
1.0 E-03
4.0 E+06
22
3.0 E-03
2.8 E+00
1.3 E-03
1.3 E+06
28
7.0 E-03
1.3 E+Ol
<2.3 E-04
1.6 E+06
41
6.8 E-02
7.7 E+00
1.2 E-04
2.4 E+06
77
1.1 E-01
7.9 E+00
3.4 E-03
4.4 E+06
55
1.8 E-02
5.6 E+00
1.4 E-03
3.1 E+06
A%IACHMENT3
SUHHATION OF ALL AIRBORNE EFFLUENT RELEASES
QUARTER I
QUARTER 2
QUARTER 3
QUARTER 4
QUARTER
1
QUARTER 2
QUARTER 3
QUARTER 4
1.
Number of Vents/Purges
Released
2. Fission
8 Activation
Products
(Curies)
3. Total Iodine-131
(Curies)
4. Particulates
with Half
Lives > 8 days (Curies)
5. Tritium (Curies)
7.8 E+01
2.4 E-03
2.3 E-02
6.4 E+00
33/2
6.6 E+00
2.1 E-03
4.5 E-03
2.3 E+00
3.3 E+01
1.4 E-03
2.4 E-03
1.4 E+01
42/13
3.3 E+01
2.6 E-03
5.8 E-03
2.6 E+01
4.3 E+01
8.4 E-03
3.5 E-03
5.1
E+01
9.2 E+00
2.5 E-03
2.3 E-03
4.8 E+01
52/19
7.8 E+01
1.4 E-03
4.2 E-03
3.7 E+01
1.2 E+01
7.0 E-04
1.3 E-02
1.5 E+01
ATTACHMENT4
HAXIHIIIANNUAL DOSES
FROH GASEOUS AND LI UID EFFLUENT RELEASES
Liquid Effluents
Mhole Body
Organ (Liver)
Gaseous
Effluents
Noble Gas
Ganea (Air Dose)
Beta (Ail Dose)
0.03 mrem
0.04 mrem
0.12 mrad
0.11 mrad
3 mrBll
10 mrem
10 mrad
20 mrad
I.IX
0.4X
1.20K
0.53K
Iodine-133,
Tritium, and
Particulates
with Half Lives > 8 days
0.14 mrem
15 mrem
0.92K
.'.;P>:."'..",,'"',".'.",'.":g>:.:,.Ile~t;'.,'.'of,-'.kgmlta'"'.5'.': .";,.:,:<<@i
Liquid Effluents
'Mhole Body
Organ (Liver)
Gaseous
Effluents
Noble Gas
Gama (Air Dose)
Beta (Air Dose)
Iodine-133,
Tritium, and
Particulates
with Half Lives > 8 days
0.12 mrem
0.19 mrem
0.10 mrad
0.07 mrad
0.18 mrem
3 mrem
10 mrem
10 mrad
20 mrad
15 mrem
4. 01<<
1.9X
1.02K
0.34K
1.19K
ATTACHMENT5
LI UID EFFLUEKT RELEASE SUMMARY
Kumber of Batch Releases
Total Fission and Activation
Products
Released
(Curies)
Total Tritium Released
(Curies)
Total Dissolved and Entrained
Gases
Released
(Curies)
Total Gross Alpha Released
(Curies)
Waste
Volume Released (liters)
Total Whole Body Dose
(mrem)
Maximum Organ Dose
(mrem)
161
9.5 E-02
1.1
E+01
2.3 E-03
0.0 E+00
9.2 E+06
3.3 E-02
4.0 E-02
201
2.1 E-01
3.4
E+01
5.0 E-03
5.2 E-10
1.1
E+07
1.2 E-01
1.9 E-01
ATTACHMENT6
GASEOUS EFFLUENT RELEASE SUHHARY
Number of Vents 5 Purges
Total Fission and Activation
Products
Released
(Curies)
Total Iodine-131 Released
(Curies)
Total Particulates with Half
Lives )8 Days Released
(Curies)
Total Gross Alpha Released
(Curies)
Total Tritium Released
(Curies)
Garana Air Dose
(mrad)
Beta Air Dose (mrad)
Haximum Organ
Dose
(mrem)
88
1.5 E+02
8.3 E-03
3.6 E-02
0.0 E+00
4.9
E+01
0.12E+00
0.11E+00
0.14E+00
71
1.4 E+02
1.3 E-02
2.3 E-02
1.3 E-10
1.3 E+02
0.10E+00
0.07E+00
0. 18E+00