ML19263C454

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IE Insp Rept 50-302/78-30 on 781211-15.Noncompliance Noted: Failure to Review & Approve Vendor Liquid Waste Processing Procedures
ML19263C454
Person / Time
Site: Crystal River 
Issue date: 01/09/1979
From: Ewald S, Gibson A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19263C451 List:
References
50-302-78-30, NUDOCS 7902220271
Download: ML19263C454 (8)


See also: IR 05000302/1978030

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Report No.:

50-302/78-30

Docket No.-

50-302

Licensee: Florida Power Corporation

Facility Name:

Crystal River, Unit Three

Inspection at:

Crystal River Site,

Crystal River, Florida

Inspection conducted:

December 11-15, 1978

Inspector:

S. C. Ewald

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Reviewed by:

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A. F. Gibson, Chief

Date

Radiation Support Section

Fuel Facility and Materials Safety Branch

Inspection Summary

Inspection on December 11-15, 1978 (Report No. 50-302/78-30)

Areas Inspected: Routine, unannounced inspection of liquid radioactive

effluents, semi-annual effluent report, radioactive effluent monitoring,

effluent procedures, liquid waste processing, licensee event reports,

and previously identified items.

The inspection involved 40 inspector-

hours on-site by one NRC inspector.

Results: Of the seven areas inspected, no items of noncompliance or

deviations were identified in six areas.

One apparent item of non-

compliance was identified in one area (deficiency-failure to review and

approve vendor liquid waste processing procedures paragraph 4).

7 9 0 2 2 2 0A7/4

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RII Rpt. No. 50-302/78-30

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DETAILS I

Prepared by:

_ Date

S. C. Ewald, Radiation Specialist

Radiation Support Section

'l91Fuel Facility and Materials

Safety Branch

Dates of Inspectio -

ec ber 11-15, 1978

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Reviewed by:

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A. F. Gibson, Chief

Date

Radiation Support Section

Fuel Facility and Materials

Safety Branch

1.

Persons Contacted

G. P. Beatty, Jr., Nuclear Plant Manager

P. F. McKee, Technical Services Superintendent

  • J. Cooper, Compliance Engineer
  • J. R. Wright, Chemical and Radiation Protection Engineer
  • G. H. Ruszala, Radwaste Management Supervisor

G. D. Perkins, Health Physics Supervisor

  • R.

E. Fuller, Plant Engineer

G. M. Williams, Compliance Plant Engineer

  • G. R. Westafer, Maintenance Superintendent
  • Denotes those present at the exit interview.

2.

Licensee Action On Previous Inspection Findings

a.

(Closed) Open Item (77-22-04) Maintenance of Gaseous Release Records

The training program for chem-rad technicians discussed in RII

Reports 50-302/78-1 and 50-302/77-22 have been implemented. Training

sessions are recorded and the recordings maintained for those staff

members unable to attend a particular session. The inspector noted

the new computer codes for sample analysis, originally discussed as

one of the corrective measures with regard to missing records, is

being held up due to anticipated changes in effluert technical

specifications.

The various measures implemented by the licensee

apparently have been effective in controlling waste records. The

inspector had no further questions.

.

RII Rpt. No. 50-302/78-30

1-2

b.

(Closed) Infraction (78-09-02) Security Guard Retraining

The inspector reviewed training records of four security guard

staff members requiring (biennial) radiation protection retraining.

The four guards received retraining in May 1978. The inspector had

no further questions.

.

c.

(0 pen) Open Item (78-22-03) Spent Fuel Pool Ventilation Monitor

Licensee representatives stated, based on their review, they intend

to provide the local ventilation monitor (RMA-4) with alarm trip

functions to isolate the spent fuel pool ventilation system separate

f rom the auxiliary building system.

3.

Unresolved Items

Unresolved items are matters about which more it. formation is required to

ascertain whether they are acceptable items, items of noncompliance, or

deviations.

(78-30-02) Radiation Monitor Interlock Operability

During the inspection, questions relative to radiation monitor interlock

operability were raised. This item is discussed further in paragraph 9.

(78-30-03) Quarterly Calibration of Radwaste Monitors

A review of radiation monitor calibration records indicate the quarterly

calibration due in July 1978, may not have been performed. This item is

discussed further in paragraph 8.

4.

Licensee Event Reports (LER's)

a.

(Closed) LER No. 78-25/04T:

This event involved an unplanned

release of radioactive gases via a valve associated with the

Miscellaneous Waste Evaporator.

Recent modifications to the waste

gas system (Unresolved Item 77-22-03) resulted in valve WDV-476

serving as isolation between the waste gas header and the vaste

evaporator room. The inspector examined the line downstream of the

valve and verified it had been permanently sealed. Licensee repre-

sentatives stated a similar problem existed with the Reactor Coolant

Evaporator and that line had also been capped off. The inspector

had no further questions.

b.

(Closed) LER No. 78-46/03L: This event involved the failure of a

capacitor in the Auxiliary Building Ventilation Monitor interlock

circuit. This item is discussed in detail in paragraph 9.

.

RII Rpt. No. 50-302/78-30

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c.

(Closed) LER No. 78-47/03L:

This event involved the inoperability

of a gas chromatograph due to a failed column. The LER stated

spare columns would be ordered to avoid similar problems in the

future. Licensee representatives stated spare columns were ordered

in November and were due to be shipped by mid-December. The inspector

had no further questions.

d.

(Closed) LER No. 78-51/03L: This event involved a flow controller

being out of adjustment on the Reactor Building Air Sampler-Monitor.

The flow controller was promptly readjusted. The inspector discussed

the event with licensee representatives and had no questions.

5.

Procedures

a.

Technical Specification 6.8.1

requires various procedures be

established, maintained, and implemented including those procedures

listed in Appendix A of Regulatory Guide 1.33, November 1972.

Section 7 of Appendix A includes procedures for liquid, solid, and

gaseous waste sys ter:s .

Technical Specification 6.8.2 requires

those precedures specified in 6.8.1 be reviewed by the Plant Review

Committee (PRC) and approved by the Nuclear Plant Manager prior to

implementation.

b.

The inspector reviewed the following procedures, revised or

implemented since . January 1978, relating to radioactive ef fluents.

SP-443 (12/04/78), " Master Surveillance"

SP-701

(02/16/78), " Radiation Monitoring Instrument Calibration"

SP-335

(01/12/78), " Radiation Monitoring Instrument Functional Test"

CH-280L (05/18/78), " Radiation Monitoring System Operating Parameters"

CH-269 is currently being revised. The inspector stated the revised

procedure would be reviewed upon review and approval as per Technical

Specificaiton 6.8.2.

Specific comments relative to implementation

of the surveillance procedures are discussed in paragraph 8.

c.

CH-280L,

" Radiation Monitoring System Operating Parameters",

provides the bases, administrative control, and quality control for

radiation monitor alarm setpoints.

Other documents referenced by

CH-280L are the Setpoint Logbook and OP-505, "Setpoint Changes"

A review of several follow-up reports (FUR) and Nonconforming

Operation Reports (NCOR) revealed three instances in the last two

months where the weekly setpoint check has identified improper

monitor setpoints.

The inspector verified all setpoints matched

the setpoint log on December 13.

The inspector discussed the

apparent failures to control setpoints as per procedures with

.

RII Rpt. No. 50-302/78-30

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licensee representatives.

Licensee representatives acknowledged

the inspector's concerns relative to this item and the inspector

stated any corrective actions would be reviewed during future

inspections (78-30-05),

d.

Discussion with licem ee representatives revealed a vendor supplied

demineralization system had been in use since September for routine

processing of liquid radioactive waste. The inspector examined the

system and noted the use of reinforced flexible lines, verified

proper posting, labeling, and control of the area where the demin-

eralizers are used. The inspector questioned licensee representatives

whether the demineralizer system operating procedures had been

reviewed and approved as required by Technical Specification 6.8.2.

The Radwaste Management Supervisor stated the procedures were

available but had not hun treated as site prowdures.

The inspector discussed this item with licensee representatives and

stated that, even though the demineralizer system and its assocuted

procedures were supplied by a vendor, the licensee maintains authority

and responsibility for the system when operated on-site.

The

inspector stated that failure to review and approve the demineralizer

system prccedures was in noncompliante with Technical Specification 6.8.2

(78-30-01).

6.

Semi-Annual Effluent Report

The inspector reviewed the facility effluent report for the period

January through June 1978, for compliance with Technical Snecification

5.6.1 (content), and Technical Specification 2.4.1 and 2.4.2 (quarterly

and yearly release limits). No items of noncompliance were revealed.

7.

Liquid Releases

Technical Specification 2.4.1 details the various limits, monitoring and

sampling requirements for liquid effluents. The inspector reviewed 108

individual release records fer January, February, September, October,

and November, 1978 for compliance with instantaneous release rate and

concentration limits (2.4.1.A), single tank curie limits (2.4.1.G) and

sampling and analysis requirements (2.4.1.J, 2.4.1.K, and Table 2.4-1).

No items of noncompliance were revealed. The inspector also observed

the operation and recording of liquid activity and flow monitors required

by Technical Specifications 2.4.1.L, 2.4.1.M, and 2.4.1.P.

8.

Effluent Monitor Surveillance

a.

Technical Specifications 2.4.1.N

and 2.4.2.I

require quarterly

calibrations and monthly tests of liquid and gaseous monitors

respectively.

These requirements are implemented by facility

.

RII Rpt. No. 50-302/78-30

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Surveillance Procedures (SP's) SP-701 (calibrations) and SP-335

(functional tests). The inspector reviewed current copies of these

procedures and had no questions.

b.

The inspector reviewed monthly test records for 1978.

The

inspector noted that frequently SP-335 reveals some problems with

one or more of the 43 monitors tested and the interlock tests

required by Specifications 2.4.1.E and 2.4.2.D.

The inspector had

some questions relative to documentation of maintenance or other

corrective action and full completion of SP-335.

The inspector

noted several SP-335 records had work request numbers handwritten

on the coversheet, but, due to a change in the work request numbering

sequence; these were difficult to trace. Licensee representatives

stated a new policy was being implemented to dccument corrective

action and completion of SP's.

The inspector discussed these plans

with licensee representatives and stated documentation relative to

SP-335 would be reviewed during subsequent inspections to evaluate

the ef fectiveness of licensee proposals (78-30-04).

c.

The inspector reviewed records of quarterly calibrations performed

as per SP-701.

Specific records reviewed were of calibrations

performed October 18, 1977, January 10, 1978, April 15, 1978, and

October 9, 1978. No records of SP-701 performed in July 1978, were

on file.

SP-443, Master Surveillance Log, records indicated the

calibration should have been performed July 7, 1978, and was signed

off en the SP-443 record sheet for that date. Licensee representatives

stated the master surveillance sign-of f may only indicate that

operatinns personnel notified chem-rad staf f that the calibrations

were due, not that they were completed.

Licensee representatives

stated they would conduct a reuiew to determine if SP-701 was

performed or not, and locate any relevant records. The inspector

stated this item would be unresolved pending the results of the

licensee's review (78-30-03).

9.

Radiation Monitor Interlocks

a.

On September 14, 1978, during performance of monthly tests (SP-335),

the Auxiliary Building Ventilation Monitor (RM-A2) interlocks

simulated high radiation alarm. The event

failed to respond to

a

was reported as per Technical Specification 6.9.1.9.b as LER 78-046/03L,

and was tracked on-site as Nonconforming Operation Report (NCOR)

No. 257. The cause of the interlock failure was tracea to a shorted

surge suppressor in the interlock electronics that blew a fuse.

The components were promptly replaced and the monitor tested and

declared operational on September 14.

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RII Ept. h. 50-302/78-30

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b.

The inspector discussed the LER and NCOR with licensee representatives

and expressed concern that the monitor interlocks mig,ht have been

inoperable for as long as a month since the means of detection was

the routine monthly test. The previous test was performed August 10,

_

1978, and the inspector examined RM-A2 strip chart recordings for

the period August 10 to September li and verified no releases that

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might have resulted in alarm actuation apparently occurred while the

interlocks were potentially inoperable.

c.

The inspector reviewed monitor interlock schematics with licensee

representatives and determined the basic problem with the system is

that the alarm interlock relays are non fail-safe. The system was

designed this way to allow frequent (daily) source checks of various

.

radiation monitors without actuating the interlock functions by

installation of a bypass switch. Based on this review, discussion

with licensee representatives, and confirmatory tests performed by

the licensee, the inspector determined that should one of the

interlock relays f ail, the monitors alarm functions would be degraded

with no indication of any problem.

It should be noted that this

problem applies only to the alarm interlock functions (i.e. , audible

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alarms, damper and valve closure). The monitor and monitor recorder

will remain functional.

d.

This design problem is common to all radiation monitors with alarm

interlock functions including the reactor purge monitor (a safety

system) and the liquid effluent monitor. Licensee representatives

implemented a Short Term Instruction to provide increased surveillance

while more permanent corrective action can be developed and implemented.

Licensee representatives stated a prompt review of the problem

would be performed and necessary corrective action to assure inter-

lock operability would be implemented. The inspector stated this

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item would be unresolved (78-30-02) pending completion of recommended

corrective actions.

The inspector emphasized that even though

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significant changes to the interlock electronics might be necessary,

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prompt corrective action would be required. Licensee representatives

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acknowledged the inspector's comments and agreed to keep the inspector

advised of progress on a solution of this item.

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RII Rpt. No. 50-302/78-30

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10.

Exit Interview

At the conclusion of the inspection on December 15, 1978, the inspector

met with licensee representatives (denoted in paragraph 1). The inspector

summarized the scope and findings of the inspection.

Items discussed

included one item of noncompliance and two new unresolved items. With

regard to the item of noncompliance (failure to review and approve

vendor system procedures - paragraph 5), licensee representatives stated

that they believed specification 6.8.2 was not intended to require

review and approval of vendor system procedures and stated they would

review the matter further. With regard to the unresolved item concerning

the radiation monitor interlocks (paragraph 9), licensee representatives

stated some type of prompt, possibly temporary, corrective action would

be developed during the following week.

The inspector requested he be

xept advised of licensee plans with respect to this item.