ML18009A770
| ML18009A770 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/28/1990 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-739 NUDOCS 9101070012 | |
| Download: ML18009A770 (12) | |
Text
, ACCELERATED'ISTRIBUTION DEMONSTRATION SYSTEM l
REGULATORY INFORMATXON DISTRIBUTION SYSTEM (RIDS)
SSION NBR:9101070012 DOC.DATE: 90/12/28 NOTARIZED: NO IL:50-400 Shearon'Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION RICHEY,R.B..
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Responds to NRC 901130 ltr re violations noted in Insp Rept 50-400/90-21.Corrective actions:acid addition step in Procedure RCP-660 "Sample Preparation for Determination of Radioactivity" emphasized. Disagrees w/categorization.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIXB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRZS/DIR NRR/PMAS/ILRB12 OE DI RE ILE 02 EXTERNAL: EG&G/BRYCE,J.H.
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RECIPIENT XD CODE/NAME BECKER,D AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24
Carolina Power & Ljght Company P. O. Box t65 ~ New Hill,N. C. 27562 R. B. RICHEY Vice President Harris Nuclear Project DEC 2 6,1990 Letter Number.'H0-900206 (0)
Doc'ument Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-739 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO ~ NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen.
In reference to your letter of November 30,
- 1990, referring to I.E. Report RII:
50-400/90-21, the attached is Carolina Power and Light Company's reply to the violations identified in Enclosure 1.
Although the violations are
- admitted, Carolina Power and Light Company disagrees with the severity level assigned to violation C.
We do not believe 'that this identified violation meets the criteria of a severity level IV as described in 10CFR2 Appendix C,
Supplement I
D, and that assignment of a
severity level V is 'more appropriate.
This is based on our interpretation that the violation has no safety or environmental significance.
I Thank you for your consideration in this matter.
Very truly yours, R. B. Richey Vice President Harris Nuclear Project MGW:mbr Attachment cc:
Mr. R. A. Becker (NRC)
Mr. S.
D. Ebneter (NRC RII)
Mr. J.
E. Tedrow (NRC -- SHNPP) 9101070012 901228 PDR ADOCK 05000400 9
e lg
'1
Attachment to CP&L Letter of Res onse to NRC I.E.
Re ort RII:
50-400/90-21 Re orted Violation.'.
Technical Specification 6.8.1.a requires that written procedures be established and implemented covering procedures outlined in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, paragraph 10, requires that written procedures be provided for radiochemical analysis.
Radiochemistry Procedure RCP-660, Sample Preparation for Determination of Radioactivity, Steps 10.3.1.2.2 and 10.3.1.1.3, specify that nitric acid be added to the sample prior to the analysis for radioactivity.
Contrary to the
- above, on October 24 and October 26,
- 1990, procedure RCP-660 was not properly implemented in that nitric acid was not added to an "A"
Steam Generator sample and a
- sample, respectively, prior to radioactivity analysis.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for Violation'.
The violation is correct as stated.
On October 24 and again on October 26, 1990, two different Environmental 6
Chemistry (E6C) technicians were observed by an NRC inspector to not add nitric acid to samples being prepared for activity analysis, as required by RCP-660, Steps 10.3.1.2.2 and 10.1.3.3.
The cause of this event was personnel error in that the technicians failed to follow the procedure.
The technicians recognize that the purpose for the nitric acid is to serve as a preservative for samples intended for long-term storage.
This is a standard lab practice.
The acid helps to avoid plate-out of the activity on the sides of the sample container.
Plate-out could affect the validity of analyses done on samples that have been in storage.
Since the individual samples in question were to be analyzed right away, the technicians did not perceive the need for any preservative to be added.
Instead the acid was being added to the container used for compositing the individual samples for long-term storage.
Technically, this is appropriate but is not consistent with the exact wording of the procedure.
MEM/HO-9002060/2/OS1
h
'S Corrective Ste s Taken and Results Achieved:
The effect of not adding acid to samples being analyzed right away is"not known but has been assumed to be negligible.
The practice is generally recognized as applicable for samples that will be analyzed at some time in the future, but even the significance of failing to add acid to long-term samples is unknown.
To investigate
- this, CP6Ls Corporate Radiochemistry Laboratory has been requested to perform a
study to determine the impact of not adding acid to samples, both long-term and short"term.
Corrective Ste s Taken to Avoid Further Violations'.
The acid addition step in RCP-660 was emphasized to EKC technicians through their "Required Reading" program.
Date When Pull Com liance Will Be Achieved:
The procedure is now being followed.
The study to determine the impact of not adding acid to samples, both long-term and short-term', is expected to be complete by January 31, 1991.
The results of the study will determine the necessity of a procedure revision.
Re orted Violation.'.
- requires, in part, that the licensee shall maintain records of changes in the facility from that'escribed in the safety analysis report and that these records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
j The Final Safety Analysis Report (FSAR) Table 11.1.7-1 lists the design concentrations of specific activity for various nuclides in the spent fuel pools.
Section ll.l.l of the FSAR further states that these maximum activities have been used in the design basis
'for shielding and facilities design and for calculating the
,consequences of postulated accidents.
Contrary to the above, a sample taken on October 12,
- 1990, found that the specific activities of manganese and cobalt in the spent fuel pools exceeded the design concentrations listed in the FSAR by as much as 5000 times and the licensee failed to provide a written safety evaluation for an unreviewed safety question determination.
This is a Severity Level IV violation (Supplement I).
MEM/HO-9002060/3/OS1
Denial or Admission and Reason for the Violation'.
The violation is correct as stated.
The shipment of spent fuel from the Brunswick Nuclear Project (BNP) to the Harris Nuclear Project (HNP) has introduced a large volume of iron oxide crud to the spent fuel pools and transfer canals at HNP.
This crud has a loose fluffy layer that is falling off the fuel assemblies to the floor of the fuel pools and canals.
This additional material has caused the activity of Mn-54 and Co-60 to exceed the values listed in table 11.1.7-1 of the FSAR Section 11.1.7.
Exceeding Table 11.1.7-1 values without the required documented 10CFR50.59 Safety Evaluation is potentially a change to the facility as described in the FSAR.
There have been (17) seventeen cask loads of spent BWR fuel, consisting of (18) eighteen assemblies
- each, shipped to the HNP from the BNP.
These shipments began in July of 1989 'and the most recent one was in October of 1990.
In January
- 1990, the Manager (EERC) assessed the potential impact of "crud" and the resulting increase in spent fuel pool activities.
It was concluded that (1) the significant amount of insoluble particulates collecting in the pools should not be allowed to enter the spent fuel skimmer system or else the dose rates around unshielded components and piping would become unacceptable, and (2) the nuclide composition of the "crud" by itself, would not prevent shipment or burial of the material.
On this basis, it was recommended to not utilize the skimmer system for vacuuming the particulate material from the pools and to investigate use of alternate filtration systems for removing and shipping the "crud" for burial.
In early 1990 the E6RC Unit evaluated the presence of significant amounts of crud in the fuel pools to determine if increased dose rates to personnel working in the Fuel Handling Building (FHB) were significant.
The FSAR assumptions used for estimating dose rates in the vicinity of the pools were reviewed (FSAR Section 12.3.2.13).
It was concluded that the FSAR analysis considered the dose rates due to dissolved or suspended radioactivity to be negligible compared to that from the spent fuel.
After review of this it was decided that no FSAR changes were necessary due to any increase in dissolved or suspended material.
In February-March of 1990, after the position of Manager Spent Nuclear Fuel was established, this
- manager, a certified Senior Reactor Operator and qualified Safety
- Reviewer, concluded with respect to FSAR Section 11.1.7 that an increase in fuel pool activity due to crud did not constitute an unreviewed safety question.
- This, however, was an undocumented management assessment, not a
formal safety revie~.
He deemed any increase in pool activity to be primarily an
- ALARA, and possibly a process system design question.
Since the crud problem was under investigation, he decided that an FSAR change would be required but should be delayed until the extent of the problem and the impact of potential solutions was fully understood.
4lEM/HO-9002060/4/OSl
L 0
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After documenting this matter on Significant Operational Occurrence Report (SOOR)
$90-148 (October 27, 1990)
E&RC reviewed the impact of the crud on the validity of the Technical Specification setpoint calculations for the FHB area monitors.
It was determined that elevated general area dose rates tend to make the setpoints more conservative and thus no changes would be needed.
In summary, neither manager required or verified that a formal 10CFR50.59 evaluation was done nor that a
sampling "trigger" was in place to flag when spent fuel pool activities exceeded Table 11.1.7-1 values.
Corrective Ste s Taken and Results Achieved:
Formal 10CFR50.59 evaluations of the elevated activity levels present in the fuel pools were performed and reviewed by the Plant Nuclear Safety Committee (PNSC).
The evaluations documented that no unreviewed safety question 'exists.
Corrective Ste s Taken to Avoid Further Violations:
l.
An effort is underway to clarify the regulatory significance of "descriptive" information in the FSAR, especially with respect to what must be reflected and/or monitored in plant procedures and what comprises "The Facility as Described in the FSAR" for 10CFR50.59 purposes.
Once clarification is
- obtained, as appropriate, the following actions will be taken:
a.
Needed revisions will be made to the 50.59 program manual.
b.
Additional training for management and qualified safety reviewers will be conducted.
2.
Additional review of the design basis for the Fuel Handling Building and supporting systems will be conducted to assess the broader impact of higher than FSAR activities in the fuel pool water.
Date When Full Com liance Will Be Achieved:
Full compliance is expected to be achieved by June 30,
- 1991, upon completion of the actions stated above.
Re orted Violation:
C.
10CFR50.74 requires, in part, that the licensee notify the NRC in writing within 30 days of the termination of any licensed senior operator.
Contrary to the above, the NRC was not notified of the termination of a licensed senior
- operator, Docket No. 20019, which occurred on September 8,
1989.
This is a Severity Level IV violation (Supplement I).
MEM/HO-9002060/5/OS1
'I I'
f
Denial or Admission and Reason for the Violation.
The violation is correct as stated.
The violation occurred due to a
lack of procedural guidance which emphasized the responsibilities of licensed personnel/supervision regarding 10CFR50.74.notification requirements.
Corrective Ste s Taken and Results Achieved:
On October 16,
- 1990, a
letter (H0-900151(0))
was transmitted to NRC Region II formally requesting that the subject license be terminated.
A complete review of Reactor and Senior Reactor Operator licenses was conducted.
This review identified five other licensed operators for which no documentation of termination notification to the NRC could be found.
On December 17,
- 1990, a letter (HO-900203(0))
was transmitted to NRC Region II formally requesting that these additional licenses be terminated.
Corrective Ste s Taken to Avoid Further Violations'.
Procedural guidance will be developed which will emphasize the Harris Project's responsibilities regarding 10CFR50.74.
Date When Full Com liance Will Be Achieved:
Full compliance is expected to be obtained by January 31,
- 1991, upon the development of procedural guidance as stated above.
MEM/HO"9002060/6/OSl