ML17352A116
| ML17352A116 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/28/1993 |
| From: | Decker T, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17352A115 | List: |
| References | |
| 50-250-93-16, 50-251-93-16, NUDOCS 9308060035 | |
| Download: ML17352A116 (25) | |
See also: IR 05000250/1993016
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900
ATLANTA,GEORGIA 303234199
JUL 28
I993
Report Nos.:
50-250/93-16
and 50-251/93-16
Licensee:
Florida Power
and Light Company
9250 West Flagler Street
Hiami,
FL
33102
Docket Nos.:
50-250
and 50-251
Facility Name:
Turkey Point Units
3 and
4
License Nos.:
and
Inspection
Conducted:
June 7-11,
and June
28,
1993
Inspector:
G.
B.
zo,
Se ior Radiation Specialist
Date Signed
Accompany Personnel:
N. Stinson,
NRC RII
Approved by:4/<>>~
T.
R. Decker,'hief
DQ
Sip ed
Radiological Effluents
and Chemistry Section
Radiological Protection
and
Emergency
Preparedness
Branch
Division of Radiation Safety
and Safeguards
SUHHARY
Scope:
This routine announced
inspection
involved selected
review of licensee
radiation protection
(RP) programs for meteorological
and environmental
monitoring,
remote sampling
system
measurement
accuracy,
and airborne effluent
control
and monitoring;
and review of NRC Information Notices (INs),
and
previously identified issues
tracked
by the
NRC as inspector followup items
(IFIs).
Results:
Program strengths
included meteorological
tower equipment
hand facility
upgrades,
and supplemental
monitoring initiatives within the Radiological
Environmental Honitoring Program
(REHP).
Weaknesses
within these
areas
included
a minimum of trained personnel
and procedural
guidance within the
meteorological
program,
and the failure to include supplemental
REHP data in
the annual
environmental
report.
Selected
gaseous
effluent process
monitor
instrumentation calibrations
and ventilation system
High Efficiency Particular
Airborne
(HEPA) and charcoal filter surveillances
were performance-tested
properly and results
met the appropriate
Technical Specification
(TS)
9308060035
930728
ADOCK 05000250
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requirements.
An identified weakness
associated
with the ventilation systems
involved the failure to complete daily Auxiliary Building exhaust
HEPA filter
differential pressure
(Zq) surveillances.
In addition,
a potential
concern
regarding the adequacy of grab sample
measurements
for particulate radioactive
material concentrations
used to evaluate radiological
hazards
associated
with
initial "at power" containment entries
was identified.
The following non-cited violation (NCV) and unresolved
item (URI) were
identified.
URI regarding
adequacy of licensee Unit-3/Unit-4 remote containment
sampling
systems
to accurately
measure
sample
volume; and subsequently,
to quantify adequately
radioactive airborne concentrations
(Paragraph
4.a).
Unresolved
pending final review of sample
system
configuration
and licensee
NRC-identified
NCV for failure to conduct surveillances
of differential
pressure
readings
across Auxiliary Building exhaust
HEPA filters
(Paragraph
S.b).
NCV of TS 6.8. 1 with corrective actions initiated
prior to the end of the onsite inspection.
REPORT DETAILS
Persons
Contacted
Licensee
Employees
- T
p.
¹ S.
- J
¹*J.
- H.
- J
- L
- K.
- T
- D
R.
- R.
¹*R.
- E
Abbatiello, Manager, guality Assurance
Bailey, Health Physicist,
Corporate Office
Blitchington, Instrument Supervisor,
Health Physics
Danek,
Manager,
Corporate
Health Physics
Garozzo,
Site Engineer
Johnson,
Superintendent,
Operations
Lindsay, Supervisor,
Health Physics
Pearce,
Plant Manager
Peterson,
Land Utilization
Plunkett,
Vice President
Powell,
Manager,
Services
Rowe, Senior Engineer,
Health Physics
Steinke,
Supervisor,
Chemistry
Tomonto,
Engineer,
Licensing
Weinkam,
Manager,
Licensing
Other licensee
employees
contacted
included engineers,
technicians,
operators,
and office personnel.
Nuclear Regulatory
Commission
- G. Salyers,
RII Inspector
- L. Trocine, Resident
Inspector
- Attended June ll, 1993 Exit Meeting
¹Participated
in June
28,
1993 teleconference
Meteorological Monitoring Program
(84750)
The current status of the licensee's
meteorological
measurement
capabilities for use in assessing
routine
and non-routine airborne
effluent releases
were reviewed
and discussed
with cognizant licensee
individuals.
10 CFR 50.54(q) requires that
a licensee
authorized to possess
and
operate
a nuclear
power reactor follow and maintain in effect emergency
plans which meet the standards
and the requirements
of Appendix
E of this part.
10 CFR 50.47(b)(9) requires that adequate
methods,
systems
and equipment
for assessing
and monitoring actual
or potential offsite consequences
of
a radiological
emergency condition be in use.
10 CFR 50, Appendix E, IV.E.2 requires that Emergency
Plans
include
adequate
equipment for determining the magnitude of and for continuously
assessing
the impact of the release of radioactive materials to the
environment.
Section
5. 1.3,of the
Emergency
Plan, Heteorological
Systems,
states
that
meteorological
data is collected at the Turkey Point Land Utilization
Site Tower,
and the South
Dade Site Tower,
and the '..oral
Gables National
Oceanic
and Atmospheric Administration
(NOAA) Headquarters facility.
a ~
Neteorological
Instrumentation
During the onsite inspection, operability of the Turkey Point
Nuclear
(TPN) facility meteorological
stations
and the associated
Control
Room equipment
were reviewed
and verified.
On June
9,
1993, the inspector toured both the South
Dade Site
and
the
Land Utilization Site meteorological
tower locations.
During
the tours,
program procedures
were discussed
and equipment
operability was verified.
The program
was
compared
against
the
details of Regulatory
Guide
(RG) 1.23, Meteorological
Programs
in
Support of Nuclear
Power Plants.
As
a result of the tours
and
discussions
with licensee
representatives,
the following
observations
were made.
South
Dade Site meteorological
tower.
Equipment
was in
place for monitoring the meteorological
parameters
at both
the
10 and
60 meter
(m) elevations
in accordance
with
Regulatory
Guide 1.23, at the time of the onsite inspection..
Excluding temperature
instrumentation
which was undergoing
repair, all meteorological
equipment
wa. functioning
properly.
Associated
support
equipment
included redundant
recorders
- a Data
Log CR10 recorder
and
a Strip Chart
recorder (to be operable
by June
31, 1993); redundant
power
supplies
- two onsite generators
and
an uninterruptable
power source to supply backup power; redundant transfer
electrical
switch boxes
- one primary and another that
functions
as the backup.
All electrical
and auxiliary power
supply equipment
have
now been located within a concrete
building.
In addition, licensee
representatives
stated that
additional portable generators
were available to provide
power.
Land Utilization Site.
The inspector
observed that the Land
Utilization Site meteorological
tower was equipped with only
one onsite generator
and
one transfer switch box.
All
electric equipment
was operable
and maintained in a concrete
building.
At the time of the inspection the licensee
was
constructing
a concrete
room to house the generator.
'
Control
Room.
The inspector
reviewed
and discussed
with
selected
operators
meteorological
and effluent monitoring
instruments utilized during evaluations of potential offsite
effluent release
scenarios.
In addition, the inspector
discussed
with knowledgeable
personnel
integration of
meteorological
and effluent release
data into the
Emergency
Plan Implementing Procedure
20126,
dated April 7,
1992.
Operators
were knowledgeable
regarding procedural
requirements
and of the equipment
and its use.
Selected
meteorological
instrumentation/displays
were verified to be
in service.
Licensee representatives
stated that the supplemental
power
supplies
and electrical
switching equipment
were upgraded
in
response
to issues identified following the August 28,
1992
hurricane.
Additional initiatives included enclosure of vital
equipment
and power supplies
at both locations to prevent
potential missile
damage during storms.
The inspector identified
the noted
upgrades
associated
with the meteorological
tower
equipment
and facilities as program strengths.
No violations or deviations
were identified.
Procedure
and Record
Review
Licensee
procedural
guidance for detailing program responsibility
and for verifying meteorological
equipment operability and
accuracy
was evaluated.
The following procedures
associated
with
the offsite meteorological
monitoring program were reviewed
and
discussed
with licensee
representatives.
Environmental Affairs Department
Procedure
A-10, Turkey
Point Nuclear Plant Meteorological Monitoring Program
Responsibilities
and
Flow of Data,
dated April 14,
1992
Turkey Point Plant Procedure,
Outside Plant Meteorological
Equipment Calibration,
dated July 1991
The procedures
described responsibilities
and data flow for
coordination of meteorological
monitoring activities
and provided
detailed instructions for calibration of the meteorological
systems
located outside the plant site.
From review of the procedures
and discussions
with cognizant
personnel
regarding offsite meteorological
instrument calibration
activities, the following issues identified as needing additional
followup actions
were reviewed
and discussed
with licensee
representatives.
The calibration procedure
guidance
was minimal
and consisted
mainly of data sheets.
The procedure
provided appropriate
guidance for well-trained personnel
familiar with the
present
system but would be difficult for an inexperienced
person to follow without extensive training and review of
the current system.
The availability of trained individuals responsible for the
offsite meteorological
program implementation
were limited.
At the time of the inspection,
one individual was
responsible for conducting maintenance activities
and
calibrations for offsite meteorological
instrumentation.
This individual was identified as the only person currently
knowledgeable of the procedural
requirements.
Additionally,
this individual was identified as the only worker trained
on
the procedure
who had performed actual calibrations required
for the offsite equipment.
From discussions
with licensee
representatives,
the inspector
noted that the procedures
currently were being rewritten to be
more descriptive.
In addition, the licensee
stated that the need
to have additional staff knowledgeable
of the calibration
procedures
also would be evaluated.
In addition, the inspector
reviewed
and discussed
the default
meteorological
categories
specified in the Emergency
Plan
Implementing Procedure
20126,
dated April 7,
1992.
In part'icular,
use of the procedure specified default stability categories
of D
and
E for daytime
and nighttime conditions, respectively,
in
manual calculations
were reviewed.
Reviews of the annual
summary of 1992 meteorological
data required
by TS 6.6. 1.4, indicated that the predominant
wind directions
were
ESE and
E with a predominant
Pasquill stability category of
E
listed for the data presented.
The inspector noted that the use
of the
E stability category rather than the
D category specified
in the procedure
would result in more conservative
dose estimates.
Following discussions
of the stability categories,
licensee
representatives
stated that additional evaluations
regarding
use
of the more conservative
E stability category
as the default value
in manual calculation of offsite dose
assessments
would be
conducted.
No violations or deviations
were identified.
Records
In addition, selected
licensee
meteorological
tower maintenance
records,
instrumentation calibration data
and inspections
conducted
since
September
2,
1992, for equipment at both the South
Dade
and
Land Utilization site were reviewed.
Instrument
calibrations
were conducted
semi-annually
and
the results
were
~
'
within the tolerances
as specified in the calibration procedure.
The records
included re-calibrations
conducted following equipment
malfunctions during December
17,
1992,
March 21,
1993,
and June 3,
1993.
No concerns
were noted for the data reviewed.
No violations or deviations
were identified.
Environmental
and Monitoring Programs
(84750)
The licensee's
environmental
monitoring program activities were reviewed
and discussed
with cognizant licensee
individuals.
a ~
Radiological
Environmental
Monitoring Program
(REHP)
TS 3/4. 12 details the specifications for conducting radiological
environmental
monitoring activities at the
TPN facility.
Required
exposure
pathways
and/or
samples for analysis
include direct
radiation,
airborne radioiodine
and particulates,
surface water,
sediments,
fish and invertebrates,
and broad leaf vegetation.
Table 3. 12-1, Notation (1) allows deviations to the sampling
schedule if specimens
are unobtainable
due to circumstances
such
as hazardous
conditions,
seasonal
unavailability,
and malfunction
of automatic
sampling equipment or other legitimate reasons.
For
malfunctioning sampling equipment,
corrective actions
are required
to be taken prior to the next sampling period.
TS 6.9. 1.3 requires that the Annual Report
be submitted prior to
Hay 1, of the following year.
TS 6.9.1.3 also details the format
and content requirements
for the report.
The report is to include
the results of analysis of all radiological environmental
samples
and of all environmental
radiation measurements
taken during the
period pursuant to the table
and figures in the Offsite Dose
Calculation
Manual
(ODCM).
During discussions
with licensee
representatives
regarding the
radiological
environmental
monitoring program
(REHP), the
inspector
was informed that, in addition to the samples
collected
to meet
TS 3.4. 12. 1 requirements
at the locations specified in
Appendix
C of the
ODCH, supplemental
sampling
and monitoring for
selected
environmental
matrices
are conducted
on
a routine basis.
Cognizant licensee
representatives
informed the inspector that the
supplemental
sampling
and monitoring for the
REHP was developed
in
agreement
with the Florida Department of Health
and Rehabilitative
Services,
Office of Radiation Control.
Supplemental
sample
matrices
included direct radiation (four thermoluminescent
dosimeter
[TLD] stations),
airborne
(one particulate air sampler),
surface water (three locations),
sediment
(10 locations)
and
ingestion
(one location for milk and fish samples,
respectively).
In general,
sampling frequencies for the supplemental
matrices
were similar to those required
by REHP TSs
and delineated
in the
ODCH.
The inspector reviewed
and discussed
with cognizant licensee
representatives,
the third and fourth quarter
REMP supplemental
sampling results
as detailed in reports to L. Pearce,
TPN, Plant
Manager,
dated
November 30,
1992,
and February
23,
1993,
respectively.
The majority of missing data were for direct
radiation readings
and air particulate
measurements
resulting from
missing thermoluminescent
dosimeters
(TLDs) and
damaged air
sampling equipment,
respectively,
as
a result of Hurricane Andrew
on August 28,
1992.
Licensee representatives
stated that recent
changes
to the supplemental
REMP monitoring included changing the
collection period for the
10 sediment
samples within the cooling
canal
perimeter
from the third to first quarter.
For supplemental
samples
similar to those matrices specified in TS Table 3.12-1,
all specified lower limits of detection
(LLDs) were attained.
However,
a milk sample,
Iodine-131 (I-131) value
was reported
as
less
than
6 picocuries
per liter (pCi/1).
The inspector
noted
that this value was
above the
LLD of
1 pCi/1 specified in the TSs.
Licensee representatives
stated that milk sampling
was not
required
by TS Table 3-12. 1, but continued to be collected in the
supplemental
program.
Following discussions
regarding the
difficulty in conducting analyses
to attain the TSs
LLD for this
sample type and the State of Florida's intent to collect and
analyze this sample type for screening
purposes
only, the
inspector
agreed that the
LLD values specified in Table 3. 12-2,
were not applicable.
For the supplemental
environmental
samples collected, all results
were less than reporting values specified in the applicable
TSs.
Results
were similar to values listed for previous
sampling
periods with no measured
results
above
background
and/or differing
significantly from previous results at
a specific location.
Measurable
radionuclides
reported for selected
environmental
matrices
and discussed
with licensee
representatives
included
and cesium-137
(Cs-137) in sediments.
Maximum H-3 concentrations,
approximately
4000 pCi/1
(13 percent
of the
TS reporting values),
were for samples collected within the
cooling canals.
Concentrations
of Cs-137 in sediments
from the
cooling canals
ranged
from 32 to 595 picocuries
per kilogram
(pCi/kg) dry weight.
The areas
are not accessible
to members of
the general
public.
The inspector
agreed with the licensee's
assessment
that the supplemental
REMP data verified that facility
operation
had minimal effects
on the radiation
and exposure levels
in the surrounding environs.
The inspector noted that the supplemental
REMP monitoring data
were not included nor referenced
in the Annual Environmental
Monitoring Report.
Following discussions
regarding potential
confusion in conducting
supplemental
environmental
monitoring but
not reporting the results,
licensee
representatives
stated that
~
~
integration of the supplemental
RENP data or appropriate
summary
information into the Annual Radiological
Environmental
Operating
Report would be evaluated.
No violations or deviations
were identified.
Remote Sampling Airborne Monitoring Accuracy Concerns
(84750)
10 CFR 20.201(b) requires
the licensee
to make or cause to be
made
such
surveys
as
(1)
may be necessary
to comply with the regulations
in this
part,
and (2) are reasonable
under the circumstances
to evaluate
the
extent of radiation hazards that may be present.
defines
survey
as
an evaluation of radiation hazards
incident to the
production,
use,
release,
disposal,
or presence
of radioactive materials
or other sources
of radiation under
a specific set of conditions.
During the onsite inspection,
concerns
regarding the accuracy of
flowrate measurements
used in determination of sample
volumes for remote
(grab)
sampling of airborne radionuclides
were identified.
The concern
involved the use of long sample lines leading to the particulate filter
housings
and the need to adjust in-line flowrate instrument
(rotometer)
measurement
results for associated
pressure
drops within the system.
These flowrate measurement
devices
are calibrated normally, at standard
atmospheric
temperature
and pressure
conditions.
When used in a sample
line at reduced
pressures,
the equipment over-estimates
the actual
volume of air sampled.
For any particulate radionuclides collected,
this results
in a non-conservative
bias relative to the actual
radionuclide concentrations
present.
The inspector noted that this
issue
was identified and documented
Corrections for Sample Conditions for Air and
Gas Honitoring, dated
December
8,
1982.
During tours of the Auxiliary Building, the inspector
observed
the
configuration of the remote sampling equipment
used to to take U-3 and
U-4 containment
atmosphere
The sampling is conducted
in
accordance
with O-HPS-022,
Airborne Contamination
Surveys,
dated
July 23,
1993,
and the results
are
used for preliminary evaluations of
airborne particulate
and gaseous
radionuclide concentrations
in
containment prior to personnel
making
an initial entry "at power."
From
direct observation of each
remote sampling system,
the longest
sampling
line was for the U-3 system
and
was estimated
to exceed
30 feet in
length, at
a minimum.
The inspector noted that the sampling
systems
were equipped with variable area rotometers
but without permanent
in-
line pressure
measurement
devices.
From review of the applicable
procedure
and discussions
with licensee
representatives,
the inspector
verified that pressure
drop measurements
and associated
flowrate
adjustments
were not made during sampling,
nor had
an evaluation of the
pressure
drop in the line been
conducted previously.
The inspector
requested
licensee
representatives
to conduct
a preliminary evaluation
of the pressure
drop in the U-3 containment
sample line.
The results
were to be used to evaluate
the accuracy of the flowrate measurements
required to determine radionuclide concentrations
in airborne
samples
collected for personnel
containment entries
in accordance
with the
requirements
specified in 10 CFR 20.201(b).
Preliminary evaluation results
presented
by licensee
representatives
at
the June ll, 1993 Exit Interview (Paragraph
7) indicated
a pressure
drop
of approximately
16 inches
(Hg) in the U-3 sample line
resulting in a 33 percent under-estimation
of the sample
volume
calculated
from flowrate measurements.
However, licensee
representatives
stated that additional evaluations
were continuing.
The
issue
was identified as
an unresolved
item (URI) pending completion of
licensee
evaluations
(URI 70-250-251/93-16-01).
In response
to initial concerns
regarding the potential
measurement
inaccuracies
with the sampling system,
the inspector
reviewed results
for 11 grab samples
collected
between April 27 through June
9,
1993,
which were
used to evaluate potential
airborne
hazards
associated
with
U-3 and U-4 containment entries.
Assuming
a worst case
scenario, i.e.,
adjusting the reported concentration
values for a potential
33 percent
under-estimation
in the reported
sample
volume, all values
were less
than concentrations
requiring changes
in respiratory protection and/or
other engineering
controls specified for entry based
on the airborne
maximum permissible
concentration
(MPC.) values listed in 10 CFR Part 20, Appendix B, Table 1.
Typical radionuclide concentration
values
reported for the U-3 containment air sample results
when adjusted for
the noted bias ranged
from approximately 4E-ll to lE-8 microcuries per
cubic centimeter.
No concerns
regarding
use of res,"iratory protective
equipment or engineering
controls to minimize potential internal
exposure
were noted.
During
a June
28,
1993 teleconference
between
Mr. R. Tomoto,
Licensing
Engineer,
TPN and Mr. G. Kuzo,
NRC RII, additional results of pressure
drop measurements
in both the U-3 and U-4 containment
sample lines which
could affect radionuclide concentration
measurement
accuracy
were
reviewed
and discussed.
The supplemental
evaluations
indicated
a
maximum sampling error of 4.7 percent for analyses
conducted
on the U-3
and U-4 sampling
systems.
Significant differences
noted
between
the
original error estimates
provided at the June
11,
1993 Exit Interview
and the current error values
were attributed to placement of the
pressure
measurement
equipment.
During the initial evaluations,
the
pressure
drop was measured
downstream of the particulate filter which
accounted for the large pressure
drop reported.
However, licensee
representatives
noted that the rotometer
was located
upstream of the
filter in the system.
Subsequent
placement of the pressure
upstream of the filter and adjacent to the rotometer resulted in the
lower pressure
drop
and resultant error estimate.
The inspector
agreed
that the monitoring change resulted in a more accurate
measurement
of
the flowrate.
However, the inspector noted that the description of the
sample line, filter, and flow measuring
device configuration was
contrary to guidance
provided in ANSI N13. 1,
The American National
Guide
to Sampling Airborne Radioactive Materials in Nuclear Facilities,
dated
February
19,
1969,
which states
that flow measuring
instruments
should
in every case
possible
be located
on the downstream
side of the
collector.
The inspector
informed licensee
representatives
that
as
a
result of these additional
concerns
regarding the sampling
system
adequacy,
the issue
would remain
an
URI pending further onsite review
and discussion of the system
One
URI regarding
adequacy of licensee
containment
remote airborne grab
sampling
systems
was identified.
Airborne Effluent Control
and Monitoring (84750)
During the onsite inspection,
selected
RP program activities associated
with ventilation system operability and with the licensee's
gaseous
(airborne) effluents monitoring program were reviewed
and discussed
with
cognizant licensee
representatives.
The inspector toured
and observed
facility operations;
evaluated
selected
procedures;
and reviewed records
associated
with emergency ventilation system surveillances
and airborne
effluent monitoring calibrations.
a 0
Airborne Filtration System Surveillances
TS 4.7.5., 4.6.3
and 4.6.6 detail, in part, the
18 month
surveillance tests
and acceptance
criteria required to demonstrate
operability of the Control
Room Emergency Ventilation, the
Emergency
Containment Filtering,
and the Post Accident Containment
Vent Systems,
respectively.
TS 4.6.6.a requires
a system walkdown at least
once per 31 days to
verify that each accessible
manual
valve for the Post Accident
Containment
Vent System is in the correct position.
The following procedures
were reviewed
and discussed
with licensee
representatives.
O-OSP-025.2,
Control
Room Emergency Ventilation System
Filter Performance
Test,
dated July 28,
1992
0-0SP-025.3,
Control
Room Emergency Ventilation Filter
Charcoal
Sample Analysis
O-OSP-051.7,
Post Accident Containment
Vent System Filter
Performance
Test,
dated October
15,
1991.
O-OSP-051.9,
Post Accident Containment
Vent Charcoal
Sample
Analysis, dated
October
17,
1991
3-OSP-051. 13,
Post Accident Containment
Vent Flowpath
Verification, dated
December
17,
1992
10
3/4-0-0SP-056.2,
Emergency
Containment Filter System
Performance
Test,
dated January
7,
1992,
and September
27,
1991, respectively
3/4-0-0SP-056.3,
Emergency
Containment Filter Charcoal
Sample,
dated August
13 and August 9,
1991, respectively
The procedural
guidance
was compared
against
the applicable
TS
requirements;
No concerns
were identified.
From discussion
with
licensee
personnel,
the inspector
noted that responsible
individuals were knowledgeable of the procedural
guidance
and
acceptance
criteria.
No concerns
were identified regarding the
guidance
provided.
From review of selected
records of ventilation system
surveillances
conducted
since January
15,
1991, the inspector
verified completion of the in-place dioctyl-phthalate
(DOP)
and bypass
leakage testing required
by TS.
Results
for all data reviewed indicated that the systems
met the
99
percent
DOP removal efficiency acceptance
criteria specified in
the applicable
TSs.
Further, all representative
samples
were collected
and tested for methyl iodine removal efficiency.
The inspector verified that sample results
not meeting the
TS
acceptance
criteria for methyl iodine removal resulted
in
replacement
of the charcoal within the affected ventilation
system.
In addition, the inspector discussed
and reviewed
applicable records for the specified review period to verify
completion of selected
monthly post accident containment
system
flow path operability system walk-downs.
No violations or deviations
were identified.
Ventilation
HEPA Filter Differential Pressure
Surveillances
TS 6.8. 1 requires written procedures
to be established,
implemented,
and maintained covering the applicable
procedures
recommended
in Appendix A of Regulatory
Guide 1.33,
Revision 2,
February
1978
Appendix A requires,
in part,
procedures for operation of
Auxiliary Building heating
and ventilation.
During the onsite inspection,
selected ventilation systems
located
within the Auxiliary Building and the Unit-3 (U-3) and Unit 4 (U-
4) Spent
Fuel
Pool locations
were toured
by the inspector.
To
assist
in evaluating the implementation
and effectiveness
of the
licensee's
RP program in the areas
reviewed, facility operations
and selected
surveillance activities were reviewed
and discussed
with cognizant personnel.
Licensee
procedure
0-0SP-201.2,
Senior Nuclear Plant Operator
(SNPO) Daily Logs, dated
February
11,
1993, requires,
in part,
that all spaces
in the log be filled in for equipment/systems
which are in service
and operating.
Actual readings
are to be
recorded.
Out-of-service
equipment
can
be logged
as
Equipment Out
of Service
(EOOS)
on the log sheet.
During tours of the Auxiliary Building on June
10,
1993, the
inspector noted that the differential pressure
(M) across
the "B"
filter bank for the ventilation system
exceeded
the procedural
acceptance
criteria of 2.5 inches
gauge water specified in the
SNOP logs.
Review of selected
SNOP logs from Hay 31 through
June
8,
1993, indicated that on June
6,
1993, the system
exceeded
the specified
acceptance
criteria.
The inspector
expressed
concerns
regarding potential
degradation
of system operability
when the acceptance criteria were exceeded,
and time delays in
issuing
a Plant
Work Order
(PWO) to initiate corrective
maintenance.
Licensee representatives
informed the inspector that
the guidance .in the associated
system procedure,
O-OP-060,
Auxiliary Building HVAC, dated
November
19,
1992, detail that
filters "should"
be changed
at 2.5 inches hP and the system
remained
Further,
a review of applicable
documentation
noted that
a work request to complete preventative
maintenance
activities was initiated on June 8,
1993.
However,
as
a result of
upcoming scheduled
preventative
maintenance
on the Auxiliary
Building ventilation system,
the licensee
decided to delay issuing
a
PWO for the referenced
system.
Licensee representatives
provided documentation
specifying that the maintenance
would be
completed
by the end of the month.
During review of the
SNOP logs regarding the Auxiliary Building
ventilation system ZP surveillances,
the inspector
noted that the
"B" filter train was logged
as in a "standby"
(S/B)
mode from Hay
31 through June
6,
1993.
Subsequent
review of the current
system
operation indicated that inlet air ductwork had
a
common plenum
supplying both filter banks
and that inlet dampers to both sets of
filters were blocked open.
As configured
and with either the
"A"/"B" or both exhaust
fans running, the ZP reading
across
the
filters needed to be checked
and the results
documented
to meet
the specified surveillance.
The inspector noted that the failure
to document the ZP for the "B" filter train between
Hay 31 through
June
6,
1993;
was
a violation of TS 6.8.1
(50-250,
251/93-16-02).
Prior to the end of the onsite inspection,
licensee
representatives
issued
the following corrective actions for the
identified procedural
noncompliance.
Operators
were instructed
on
the current operating
mode of the system
and were informed that
both filter train hP readings for the Auxiliary Building
ventilation system
were to be recorded
on the
SNOP logs.
An "On
the Spot Change"
(OTSC) to the procedure
was issued for actions to
take for ventilation systems
exceeding
normal values
and to
clarify use of equipment
notes
on the logs.
A training Brief was
issued
on the systems
describing
and illustrating the system
design.
Plant drawings of other ventilation systems
were reviewed
and
no other discrepancies
were noted.
Additional training
12
instruction regarding ventilation systems
was requested
from the
Training Manager.
The inspector
informed licensee
representatives
that
as
a result of the low safety significance of the issue
and
completed corrective actions,
the violation met the criteria
specified in Section VII.B of the Enforcement Policy and would not
be cited.
During tours of the U-3 and
U-4 SFP facilities,
no similar
concerns
were noted for the ventilation systems.
One NRC-identified
NCV of TS 6.8. 1 for failure to conduct
surveillances of hP readings
across Auxiliary Building exhaust
HEPA filters was identified.
C.
Effluent Monitor Calibrations
TS 3/4.3.3.6 details the limiting conditions for operation
and
surveillance
requirements for the radioactive
gaseous
effluent
monitoring instrumentation.
The inspector discussed
and reviewed selected calibrations
associated
with the System Particulate
Iodine Noble Gas-4
(SPING 4) detector located in the Auxiliary Building Fan
Room.
In
particular,
guidance
and calibration results
as specified in 0-
PMA-067.9,
Process
Radiation Monitoring System
SPING Calibration
Procedure,
dated
September
30,
1991 were reviewed.
No concerns
were identified regarding the procedural
requirements.
The
inspector verified from review of records that calibrations
had
been
conducted
in accordance
with the applicable
TSs.
No violations or deviations
were identified.
Followup Items
(92701)
The following NRC Information Notices (INs) and previously identified
issues
tracked
as Inspector
Followup Items (IFIs) were reviewed
and
discussed
with cognizant licensee
representatives.
a ~
INs
b.
The inspector provided the following IN to the licensee,
and
verified that it was reviewed for applicability,
and distributed
to appropriate
personnel
for action,
as applicable.
Corrections for Sample Conditions for Air and
Gas
Monitoring
IFIs
The following previously identified issues
tracked
as IFIs were
reviewed
and discussed
with licensee
representatives.
13
(Closed)
URI 50-250,
251/92-21-01:
Determine the adequacy
of licensee
surveys for receipt of packages
shipped
by
exclusive
use vehicle.
This issue
concerned
the adequacy of licensee
surveys
conducted
in association
with the receipt of two "exclusive
use" radioactive materials
shipments.
Licensee routine
actions following receipt of an "exclusive use" vehicle
shipment included conducting preliminary surveys of direct
radiation
and contamination levels
on the outside of the
vehicle
and trailer.
Radiological
surveys of any individual
packages
contained within the trailer were not made until
the contents
were to be unloaded.
10 CFR 20.205 requires
individual packages
containing
more than the exempt
quantities specified in the table in the paragraph
to be
monitored for radioactive contamination
caused
by leakage of
the contents,
no later than three
hours after the package is
received during normal working hours.
However, the
inspector
noted that the referenced
table specifies
Transport
Groups which are
no longer defined in the
applicable regulations.
At the time of the inspection the
issue
was considered
an unresolved
item (URI) pending
determination of the radionuclides within each transport
group
and comparison with radionuclides
types
and quantities
listed
on the shipping papers for the subject
consignments.
Subsequent
to review of the issue onsite,
the inspector
noted the
NRC position detailed in
NRC Inspection
Procedure
86740,
dated April ll, 1984, regarding this issue.
The
position specified that
as
a result of the transport
group
being deleted
from the regulations
in both
10
CFR and
49 CFR, compliance with 10 CFR 20.205 is based
on the basis
of quantity limits expressed
in terms of A, and A, as
specified in Table A-1 of 10 CFR 71 or 49
CFR 173.435.
The inspector
reviewed radionuclides
and associated
quantities of each in the packages
contained
in the original
shipments
reviewed.
All reported nuclides
and quantities
in the packages
were verified to be less
than
the A, quantities requiring monitoring.
Based
on the current evaluation
and continued licensee
actions regarding
"exclusive use" shipment monitoring as
described
in Inspection
Report 50-250,
251/92-21,
dated
November
13,
1992,
the inspector
informed licensee
representatives
that this issue
would be considered
closed.
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7.
Exit Interview
The inspection
scope
and results
were summarized
on June ll, 1993, with
those
persons
indicated in Paragraph
1 above.
The general
RP program
areas
evaluated
and the associated
strengths
and weaknesses
were
reviewed
and discussed.
The specific issues
identified during the
inspection
and listed below were reviewed
and discussed
in detail.
The
inspector
noted that based
on corrective actions initiated and planned,
the procedural violation regarding the failure to conduct Auxiliary
Building HEPA lP surveillances
would be considered for issuance
as
a
NCV.
A concern regarding
containment
remote
sample
measurement
accuracy
was identified as
an
URI pending completion of sample line pressure
drop
evaluations.
Licensee representatives
presented
preliminary results
but
stated that additional evaluations
were to be conducted.
The inspector
requested
licensee
representatives
to complete the evaluation
and send
the results to the
NRC RII Office for review by July 16,
1992.
In
addition, licensee
representatives
were informed that pending
NRC RII
management
evaluation review, the previously identified
NRC item
detailed in Paragraph
6.b would be closed
as
a result of reviews
conducted
during this inspection.
Licensee representatives
acknowledged
the inspector's
comments
and
no dissenting
comments
were received.
During a June
28,
1993 teleconference
between
Mr. R. Tomoto, Licensing
Engineer,
TPN and Mr. G. Kuzo,
NRC RII, additional results of pressure
drop measurements
in U-3 and U-4 containment
remote
sample lines which
could affect radionuclide concentration
measurement
accuracy
were
reviewed
and discussed.
The supplemental
results verified that errors
associated
with the containment
were minimal
and within
acceptable
tolerances.
However,
based
on
a description of the sample
line, filter, and flow meter configuration the inspector
noted that the
remote sampling
system configuration
was contrary to the standard
sampling
system configurations outlined in the applicable
ANSI standard.
The inspector noted that the item would remain
an
URI pending further
review of licensee
systems
and potential regulatory commitments.
Item Number
Descri tion and Reference
50-250,
251/93-16-01
50-250,
251/93-16-02
URI - Determine
adequacy of U-3/U-4
containment
atmosphere
remote sampling
systems
configuration
(Paragraph
4.a).
Unresolved
pending onsite review of system
configuration.
NCV - Failure to conduct surveillances
of
differential pressure
readings
across
Auxiliary Building exhaust
HEPA filters
(Paragraph
5.b).
corrective actions initiated prior to end
of onsite inspection.
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