ML18009A908

Technical Specification (TS) 6.8.4.e

samples.

The status

of procedure

development,

training procedures,

as well

, as further examination

of knowledgeability of NUREG-0737 criteria were areas

needing

improvement.

9105Z90097

910327

PDR

ADOCK 05000400

G

PDR

REPORT

DETAILS

Persons

Contacted

. Licensee

Employees

G.

D.

M

C

S.

B

R

G

C

M,

D.

B

M.

F

D.

M

T.

W

Baker, Nuclear Assessment

Department

(NAD)

Boley, Technician,

Environmental

and Chemistry

(EKC)

Elkins, Shipment Director, Spent Nuclear Fuel

Hamby, Project Specialist,

Regulatory

Compliance

Hinnant, Plant General

Manager

Johnson,

Chemistry

Foreman

Meyer, Manager,

Environmental

and Radiation Control

(ESRC)

Morgan, Manager,

Nuclear Assessment

Nathan,

Senior Specialist,

EKRC

Olexi k, Manager,

Regulatory

Compliance

Pate,

Manager, Training, Harris Energy and Environmental

Center

(ESEC)

Redmond, Technician,

ESC

Sears,

Foreman,

E&C

Station, Site Representative,

Power Agency

Strehle,

Manager, guality Assurance

Engineering

Tysinger, Technician,

EEC

Wallace, Senior Specialist,

Regulatory Compliance

Williams, Manager,

Health Physics

and Chemistry Training,

ELEC

Wilson, Manager,

Spent Nuclear

Fuel

Other

licensee

employees

contacted

during this

inspection

included

engineers,

operators,

technicians,

and administrative

personnel.

NRC Inspectors

M.'hannon,

Resident

Inspector

W. Stansberry

Attended exit interview

Acronyms

and Initialisms

used

throughout this report

are listed in the

last paragraph.

Post Accident Sampling

System

(PASS)

(84750)

NUREG-0737, Criterion

2a provides specifications for the establishment

of

'nsite

radiological

analysis

capabilities

to provide quantification of

noble

gases,

iodines,

and non-volatile

radionuclides

in the

reactor

coolant

system

(RCS)

and containment

atmosphere.

requires

that

a

program

be established,

implemented

and

maintained

to ensure

the capability to obtain and analyze,

.under accident

conditions, reactor coolant, radioactive

iodines

and particulates

in 'plant

gaseous

effluents,

and

containment,

atmosphere

samples.

The

should

provide

these

capabilities,

and

should

enable

the licensee

to obtain

information critical to the efforts to assess

and control the course

and

effects of an accident.

Pursuant

to

these

specifications,

the

inspector

reviewed

portions of,

selected

procedures

for the operation,

maintenance,

and testing of the

PASS,

and

di.scussed

system operation,

performance testing,

and analytical

capabilities of the

PASS with the licensee.

The inspector also observed

EKC technicians

obtain

PASS samples.

The inspector

reviewed

selected

portions of two procedures

dealing with

the

operation

and

maintenance

of the

These

procedures

were

No.

CRC-821, entitled "Postaccident

RCS/RHR Sampling," dated

May 9,

1989;

and

No.

CRC-830,

entitled

"Periodic

Maintenance

and

Operability

Verification of the

PASS,"

dated

May 20,

1988.

The portions reviewed were

adequate for their intended

purpose.

The inspector

determined

through discussions

with the license'e,

that

as

part of operation of the

PASS,

the capability existed for the collection

of

a post-accident,

undiluted,

ten milliliter, liquid reactor

coolant

'ample

in an shielded

container

or "pig." This sample

could s'erve several

functions. It could

be sent to

an off-site vendor, still in the pig, for

isotopic

or chloride analysis,

or it could

be

analyzed

on site for

chlorides

by the li'censee,

after

a thirty day decay time.

The inspectors

determined,

at the time of this inspection, that the licensee

did not have

a procedure for the removal of this sample

from the pig.

The inspector

considered

the lack of this procedure

to be

a violation of

TS 6.8. 1 a,

which requires

that written procedures

be established

and

implemented.

Since this is

an anticipated

sampling

point following an

accident,

the inspectors

believe that

a procedure

covering the sampling,

including the

removal of the

sample

from the pig, should

be developed

and

tested.

Due to the nature

and timing of this sample, it could

be expected

to have

a very high activity level. Considering this, the use of "generic"

site

procedures

for handling radioactive materials

might not ensure

the

safety of the technician

who would

have to

remove this sample, for the

first time ever, with little prior training and with instructions that had

not

been verified

as effective.

The inspectors

did not consider

the

possibility of developing this procedure

during the thirty day decay time

as

appropriate.

The

reduction

or elimination

of

any

unnecessary

uncertainties

following an accident

would obviously increase

the overall

effectiveness

of the licensee's

program for dealing with an accident.

Another

consideration

was

the

possible

importance

of

sample

volume

changes

and/or dilution factors that

may

be associated

with the

removal

of this

sample

from the pig.

This

knowledge, if needed,

would help

ensure

that

the

licensee

could

accurately

quantify

chosen

sample

parameters

upon analysis.

Site

management,

durino the exit interview,

committed to the

development

of

a procedure

to

r'emove this

sample

from

the pig (Violation 50-400/91-03-01).

3

The

inspector

also

reviewed

the training that

the

ETC technicians

received

on the

This included interviews with the licensee,

and

a

document

review.

The

inspectors

determined

that'ew,

or previously

untrained,

technicians

would initially receive eight hours of training on

the

PASS, with annual

retraining of two hours

a year thereafter.

This

training

was

not

"hands-on,"

training.

The- hands-on

training

was

accomplished

during the required quarterly operability verification of the

The inspector

determined that there

were nineteen

ETC technicians;

twelve

of these

technicians

were qualified to operate

the

PASS (i.e.

had received

the initial and

annual

retraining)

and

were

also respirator qualified

(which would

be required

to operate

the

during

an emergency).

A

review of records for 1988,

1989,

1990

and

1991 to date,

indicated that

only

a small portion of these technicians

were receiving opportunities to

operate

the

PASS during the quarterly

checks.

Two of the technicians

operated

the

a majority of the time, five had operated

the

PASS once

or twice,

and five of the technicians

had not received

the opportunity to

'perate

the

PASS during the quarterly checks.

During discussions

with the inspector,

the licensee

indicated that

any

one of the qualified technicians

could be required to obtain

a

sample

following an accident.

The inspectors

also

determined that the licensee

was

not tracking'his

type of training for the technicians,

as this

information

was

not readily available

when

requested,

and

had to

be

generated

from several

different

documents.

The licensee

was also not

aware that

CPSL

had committed,

in

a letter to headquarters

dated

Yiay 18,

1986, to semiannual

retraining of the technicians

who could

be required to

operate

the

PASS. This retraining

was to be performed in conjunction with

the quarterly operability verification testing of the

The inspectors

considered

the failure to meet this

commitment

a deviation

(Deviation

50-400/91-03-02).

The inspector

discussed

this with the licensee,

and the licensee verbally

committed to tracking the training of their technicians

to ensure that the

semiannual

retraining

commitment

on the

PASS would be met.

The licensee

also

indicated

that

they

might specify

which technicians

would

be

considered

qualified to operate

the

PASS system,

thus reducing the number

of technicians

who would require

semiannual

retraining

on the

The

effect of this proposed

reduction in the

number of technicians

qualified

to operate

the

PASS, if implemented,

would

be

examined

by regional

inspectors

in terms of the safety significance

and effectiveness

of the

PASS program,

during

subsequent

inspections.

As part of the

review,

the

inspectors

also

examined

PASS quarterly

-Operability Yerification Test Results for 1987,

1988,

1989,

1990,

and

1991

to date.

These

records

summarized

the results of the quarterly tests

in

terms of passing

or fai ling the

comparisons

between

analyses

and

routine

sampling,

as

detailed

in

NUREG-0737

Criteri'on

10

and-

Attachment

No ~

1 to the Generic Letter.

These

analyses

included:

boron,

isotopic activity,

and

chlorides

for diluted

RCS liquid; dissolved

hydrogen

and isotopic activity for'stripped

RCS gas; in-line pH, in-line

dissolved

oxygen,

and in-line hydrogen;

and

gas activity and

iodine

activity for containment air.

Inspection

Report

No.

50-400/90-12-

had

previously detailed

a poor history of meeting the

PASS acceptance

criteria

for several

of these tests,

and

had indicated

a continuing problem with

the stripped

gas results

and with the in-line pH, dissolved

oxygen

and

hydrogen.

At the time of this inspection

several

of these

problems

had

been eliminated;

however, there were continuing problems with stripped

gas

isotopic results.

The inspectors

determined that the

was continuing

to receive

attention

and

support,

from the

system engineer

and Technical

Support organization.

The

inspectors

questioned

the

usefulness

of comparing

the

isotopic

activity of a highly diluted

sample to

a

much less diluted, primary

reactor

coolant

sample,

as

a

means

to determine

PASS operability.

The

point of this comparison is to verify that the

PASS system operates,

and

that

the dilution ratios

and

sample

volumes

have

been

accurately

determined.

In cases

where the fuel integrity was high,

as at Harris, the

highly diluted

samples

may

not contain

enough activity to

be

detected.

This results in comparisons

being performed

between

samples with

activity levels below the "lower limit of detection" with samples

from the

primary

RCS,

which

have

measurable

activity.

The

licensee

agreed

to

investigate

the possibility of improving the

comparisons,

by either

increasing

the volume of the

PASS sample,

or by increasing

the count time.

The inspectors

also

observed

two

EKC technicians

obtain

PASS samples,

and

one

E&C technician

obtain

a

primary

sample.

In

each

case,

the

appropriate

procedures

were

followed,

proper

sampling

techniques

and

health

physics

practices

were

observed,

and

the

technicians

seemed

knowledgeable

and competent.

The sampling

and analysis of the

PASS samples

were accomplished

in under three hours,

meeting the criteria in NUREG 0737

for the

time limit on sampling

and analysis.

The analysis for boron

was

not performed

because

the level of boron in the

was

72 parts

per

billion (ppb).

The tremendous

dilution of the liquid- PASS sample

(1000: 1)

prevents

boron analysis if the

boron level is

below

500 ppb.

The

stripped

gas isotopic activity results

did not meet

NUREG 0737 acceptance

criteria.

All other

parameters

passed.

The inspectors

determined

that

there

was

an ongoing effort by the system engineer to determine

the cause

of this

disagreement.

The inspectors

did not observe

containment air

sampling.

The inspectors

also discussed,

with the system engineer,

the ability to

provide

an alternate

source of power to the

PASS, in the event of the loss

of site

power during

an accident.

The

system

engineer

indicated,

on at

least

two occasions,

that this capability did not exist.

The inspectors

discussed

this with site

management,

and

pointed- out that

an alternate

power source

was required

by the criteria of NUREG 0737.

The licensee

then

'determined,

and

discussed

with the inspectors,

that

an alternate

power

source

did exist, in that the

PASS could

be

powered

by the site diesels.

The inspectors

discussed

the procedure

by which this would be accomplished

with the licensee

by telephone

on March 6,

1991.

The inspectors

considered

the