ML19294B116

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IE Insp Rept 50-265/79-27 on 791211-14.Noncompliance Noted: Failure to Follow Temporary & Radiation Control Procedures & to Continuously Monitor Unplanned Radioactive Liquid Release
ML19294B116
Person / Time
Site: Quad Cities Constellation icon.png
Issue date: 01/17/1980
From: Chrissotimos N, Hueter L, Spessard R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19294B112 List:
References
50-265-79-27, NUDOCS 8002270163
Download: ML19294B116 (8)


See also: IR 05000265/1979027

Text

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-265/79-27

Docket No. 50-265

License No. DPR-30

Licensee: Commonwealth Edison Company

P. O. Box 767

Chicago, IL

60690

Facility Name:

Quad-Cities Nuclear Power Station, Unit 2

Inspection At:

Quad-Cities Site, Cordova, IL

Inspection Conducted:

December 11-14, 1979

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Inspectors:

L. J. Hueter

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N. J. Chrissotimostec

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Approved By:

R. L. S essard, Chief

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Reactor Projects Section 1

Inspection Summary

Inspection on December 11-14, 1979 (Report No. 50-265/79-27)

Areas Inspected:

Special, inspection of unplanned radiological effluent

release.

The inspection involved 39 inspector-hours onsite by two NRC

inspectors.

Results: Three items of noncompliance (infraction-failure to follow a

temporary procedure-Details I, Paragraph 3, infraction-failure to follow

a radiation control procedure-Details II, Paragraph 6, and infraction-

failure to continuously monitor an unplanned radioactive liquid release

from the facility-Details II, Paragaph 6) were identified.

b * o 2 27 0143

.

DETAILS I

1.

Persons Contacted

  • N.

Kalivianakis, Superintendent

T. Tamlyn, Assistant Superintendet Operations

  • K. Graesser, Assistant Superintendent Administrative
  • L. Gerner, Technical Staff Supervisor
  • J. Heilman, Quality Assurance Operations

2.

General

This inspection was conducted to examine the operational aspects of

the unplanned radioactive liquid effluent release on December 9, 1979.

3.

Unit 2 is currently in a refueling outage and the service water side

of the RHR Heat Exchanger was to be drained so as to initiate a minor

modification.

Draining of the heat exchanger was estimated to take

approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> and normally would have been to the radwaste

system via the floor drain system.

However, the licensee did not

elect to use this system due to the currently large inventory of

water in the radioactive waste system and due to recent uncyctainty

in disposal of waste generated in processing liquid in the system,

thus Temporary Procedure 1261 was issued to drain to an outside

storm drain. The Procedure was issued in accordance with Station

Procedures QAP 1100-5 and QAP 1100-7.

l

The first shift foreman, who is senior licensed, began imp ementing

this procedure at approximately 4:30 a.m. on Sunday, December 9, 1979.

At this time the drain hose was connected to an instrument manifold.

This manifold has other instrument tap offs to primary system water

which passes thru the manifold on occassion, and is a possible source

of contamination. This connection was contrary to Step F26 of Tempor-

ary Procedure 1261 which states in part " connect a hose to the differ-

ential pressure switch instrument line DPS 2-1001-78A (2-1001-78B)".

This operation continued until approximately 6:30 a.m. at which time

it was ceased pending shift turnover.

At 9:00 a.m., the oncomite equipment attendant was requested to re-

sume draining operations.

Upon arrival at the instrument panel, the

attendant was not sure as to what was to be done. The equipment

attendant then asked the second shift foreman, who is also senior

licensed, for further instructions. The foreman indicated to the

equipment attendant to open the remaining instrument valves on the

manifold. Opening of these valves allowed primary water to be dis-

charged to the storm sewer for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, before the

unit operating engineer discovered it and stopped the discharge.

These actions (opening additional instrument valves) were contrary to

aay of the steps containec in Temporary Procedure 1261.

-2-

.

Temporary Procedure 1261 in the prerequisites states in part "to

extend a hose from the integrated leak rate connector outside of

Unit I reactor building to the storm sewer".

Contrary to this

requirement, the hose connection was not made and effluent was

discharged onto the blacktop pavement and allowed to drain by gra-

vity to the storm drain approximately 30 feet away. This resulted

in contamination of an area of the blacktop pavement.

The preceeding actions, as directed by the two shift foreman, were

contrary to approved Temporary Procedure 1261 and is an item of

noncompliance with Technical Specification 6.2.A. (265/79-27-01)

-3-

DETAILS

.

Section II

Prepared by

L. J. Hueter

W W' [w

Reviewed by

W. L. Fisher, Chief

Fuel Facility Projects and

Radiation Support Section

1.

Persons Contacted

R. Flessner, Rad-Chem Supervisor

M. Whitemore, Chemistry laboratory Foreman

R. Robie, U-2 Operating Engineer

2.

General

This inspection, whict

an ' sut 10:00 a.m. on recember 11, 1979,

was conducted to examins

ensee's compliance with regulatory

requirements in the areas

v.

..,uid radwaste and radiation protec-

tion management programs related to an unplanned radioactive liquid

effluent release while intending to drain only the service water

side of the 2B RHR Heat Exchanger on December 9, 1979.

3.

Cause of Unplanned Radioactive Liquid Release

The draining of the service water side of the 2B RHR Heat Exchanger

to the storm sewer was intended to involve release only of nonradio-

active liquid. Further, the procedure prepared for this operation,

Temporary Procedure 1261

" Draining Unit 2 RHR Service Water Piping,"

first required draining some of the liquid into a container and then

sampling and analyzing this liquid to verify the presence of only

background levels of activity before release to the storm ecom.

This sampling and analysis was conducted before beginning the release

and the analysis identified no activity above background levels.

If

Temporary Procedure 1261 had been followed, the unplanned release of

radioactive liquid would not have occurred.

4.

The Release Pathway

The effluent was pumped through the integrated leak rate connector

to the outside (east side) of the Unit 1 Reactor Building, discharged

onto the blacktop pavement and allowed to flow by gravity to the storm

sewer drain about 30 feet east of the Reactor Building. The storm

sewer carried this effluent south past two additional surface drains.

A fourth surface drain is located where the storm sewer makes a right

angle turn to the west at a location southeast of the Service Building.

A fifth drain is located on this line where the eff. ent (nonradio-

active) from the Waste Water Treatment Plant (kW P) enters the storm

'

sewer by an underground connection.

A sixth drain is located shortly

before the effluent enters the Unit 1 Oil Separator Tank, a 30,000

gallon tank that normally remains full and overflows to the discharge

bay, across from and slightly to the downstream side of the north and

south River Diffusers. The south River Diffuser was partially open

throughout this release to permit balancing the water level in the

cooling system with only one of the two reactor Units in operation.

Of the total 550,000 gpm estimated flow rate in the discharge bay,

the licensee determined that the discharge to the river via the south

River Diffuser was about 180,000 gpm.

Radioactivity not promptly

released from the discharge bay to the south River Diffuser would be

lifted by the two operating lift pumps to the spray canal. Here the

liquid would make a circuit in this approximate 160 million gallon

body of water every seven or eight hours before it, and river make-up

water, perform their cooling function and enter the discharge bay,

where about one third of this cooling water is released to the river

via the south Rive;

J Fme r .

5.

Magnitude of Unplanned Release

The release rate from the instrument manifold system (open to both

primary system water and service system water) was determined by the

licensee to be about 5 gpm. This release continued for a maximum cf

14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> (10:00 a.m. to midnight on December 9, 1979), resulting ir-

about a 4200 gallon release. Of the various samples collected in the

release path following the discovery and termination of the unplanned

radioactive release, the highest activity concentration measured was

2.4E-03 nCi/ml based on gamma isotopic analysis. This was in a small

pool of water in one of the surface drains (manholes) before the in-

fluent (15 gpm) f rom the WrP. This garama isotopic analysis indicat-

ed a slightly higher total activity concentration than the gross

beta gamma analysis.

This concentration in 4200 gallons would indicate a to al activity of

38 millicuries released from the instrument manifold. Howaver, only

about 25 millicuries of this total was released to the discharge bay

and ultimately to the Mississippi River as an unplanned release. The

remainder was isolated in the storm sewer and Oil Separator Tank sys-

tem when input to the storm sewer from the WfP was stopped by plug-

ging the drain line at 11:00 a.m. on December 10, 1979, about 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />

after the initial radioactive release began from the instrument mani-

fold. The contents of the Oil Separator Tank were later released on

a planned batch basis meeting release requirements by performing pre-

requisite sampling and analysis, and pumping through a flow meter to

the South River Diffuser where a compositer sampler was placed in

operation for the planned release.

The contiminated blacktop surface

subsequently was flushed to the storm sewer and the storm sewer in

turn was flushed to the Oil Separator Tank with water from fire hoset

2-

after which a similar planned release was made. Continued flushing

and planned batch release (s) were to continue if concentratior.s were

not dovr. to background levels. The isotopic analysis showed the

activity to be comprised of about 67% cobalt 60, 15% iodine 131, 4%

manatanese 54, and lesser amounts of cobalt 58, cesium 134, cesium

137, technetium 99m, and zinc 65.

Technical Specification 3.8 D.2.a limits the maximum permissible

concentration (MPC) of gross radioactivity (above backgreund), ex-

cluding tritium, in the discharge bay to IE-07 eCi/ml unless the

discharge is controlled on a radionuclide basis in accordance with

Appendix B, Table II, Column 2 of 10 CFR 20 and note 1 thereto. If

one were to make the conservative assumption that the 5 gpm from the

instrument manifold at the maximum measured concentration (before

dilution) of 2.4 E-03 uCi/ml entered the discharge bay directly (with-

out dilution of 15 gpm from the WWTP and dilution in the 30,000 gal-

lon Oil Separator Tank) and was diluted with it's 550,000 gpm, the

maximum concentration in the discharge bay and out the South Diffuser

would have been 2.2E-08 xCi/ml or 22% of the Technical Specification

limit.

If, based on after-the-fact isotopic analysis, this discharge

had been controlled on a radionuclide basis in accordance with 10 CFR

Appendix B, Table II, Column 2 and note 1 thereto, calculation shows

that the concentration was only about 1% of the MPC, using the same

conservative dilution analysis described above. Therefore, it is

concluded that this unplanned release did not exceed any release rate

limits.

6.

Other Findings Associated With Unplanned Release

Technical Specification 6.2.B requires that radiation control pro-

cedures be maintained and adhered to.

Radiation Protection Surveil-

lance Procedure QRS 300-1 titled " Station Liquid Discharge Records"

states in Paragraph E, " Limitations and Actions," " Measurements

shall be made on a representative sample of each batch released and

station records retained of the activity (mci) and concentration

pCi/ml of gross radioactivity and volume (gallons) of each batch of

liquid effluent released and estimates made of the water flow (gpm)

used to dilute the liquid effluent prior to release from the re-

stricted area."

A liquid sample from the 2B RHR Heat Exchanger was collected and

analyzed before initial draining of the heat exchanger began.

This

sample showed no activity above background levels.

No further samp-

les were taken during the release.

Technical Specification 3.8.D.1 states " Radioactive liquid released

from the facility shall be continuously monitored. To accomplish

this, either the radiation monitor on the discharge line or the dis-

charge bay sampler shall be operable or grab samples shall be taken

in the discharge bay during the course of the discharge."

-3-

Contrary to this requirement, the unplanned radioactive liquid re-

lease from the instrument manifold which began about 10:00 a.m. on

December 9, 1979, was not continuously monitored, in that:

(1) the

release path was not via the discharge line on which the radiation

monitor is located; (2) the compositer sampler on the ' south River

Diffuser line (the path from the discharge bay to the river during

this release) was not placed in operation; and (3) grat samples were

not collected from the discharge bay during the discharge.

(265/79-27-02)

Technical Specification 6.2.B requires that radiation control proce-

dures be maintained and adhered to. Radiation Control Prccedure QRP

100-1 titled " Radiation Control Standards" states in Paragraph F.16.

A.2.,

"Except as noted, a Special Work Permit (SWP) will be required

when personnel may or are expected to exceed a daily wholi body dose

of 50 millirem.

If however, a Radiation Protection man it in contin-

uous attendance at the job site while a job is in progress, he may

authorize a daily whole body dose of up to 100 millirem per day with-

out requiring an SWP."

A review of daily exposure records for Deceaber 9, 1979, for per-

sonnel involved in the operation in which the unplanned release oc-

curred showed an Equipment Attendant (EA) received a dose of 15 mrem

for the day and the Shift Foreman (SF) received a dose of 130 mron

for the day. The EA received about 15 mrem of his dose at the Rad-

waste Facility and the remaining 60 mrem dose he attributed to work

in the radiation field around the instrument manifold.

The SF in-

dicated he spent very little time near the instrument manifold, but

received nearly all of his 130 mrem in overseeing the draining of a

Reactor Recirculation Pump. The licensee provided no evidence that

either worker was working under an SWP or under continaous H.P. sur-

veillance. Workers exceeding 50 mrem of exposure in a day without

approved authorization is an apparent item of noncompliance.

(265/79-27-03)

As an immediate corrective action for the unplanned release, the

licensee discontinued the release of any RHR draining as nenradio-

active waste and is directing all such drainage be sent to t.he

Radwaste System.

Smearable activity of the blacktop surface, which remains restricted

by rope barricadgs and signs, initially ranged from about 2,000 t

2

11,000 dpm/100cm except for one smear showing about 90,000 dpm/100cm

near the point of release on the blacktop surface. As noted earlier,

the initial flush had been completed during the inspection.

Informa-

tion on reduction of contamination levels by the flushing was not

obtained by the inspector. The licensee had not finalized the decen-

tamination plan for the blacktop surface.

-4-

.

7.

Apparent Leak in the Unit IB RHR Heat Exchanger

The Residual Heat Removal (RHR) System is normally used for a few

days in the early stages of an outage to cool primary system water.

At other times, surveillance tests of the RHR system are conducted

at specified intervals to demonstrate operability.

Normally the

surveillance tests are conducted monthly, except that daily tests

are required of all remaining components if a component is known to

be out of service.

For a period of about two months in September

and October, 1979, the Unit IB RHR system was surveillance tested

daily while repairing a Service Water Pump. During this testing,

spikes which coincided with initiation of the RHR system began ap-

pearing on the Service Water Monitor Chart. A review of the chart

covering the period September 3 through October 5, 1979, showed the

spikes in early September were on the order of 70 net counts /sec

(cps), but increased with a few spikes in the range of 3000 to 6800

net cps in late September through early October. The three final

spikes on the chart ranged from 350 to 1000 net cps.

The service

water side of the heat exchanger is at a higher pressure than the

primary side when the heat exchanger is operating, but is at a lower

pressure when the Service Water Pump is not operating. The licensee

had not quantified the releases indicated by these spikes or deter-

mined the significance or lack of significance of these spikes. The

heat exchanger leak was being repaired at the time of the inspection,

and during the exit interview the licensee agreed to evaluate the

significance of the leak for review during a future inspection. The

licensee has identified previous leaks and made repairs of RHR heat

exchangers, including this same Unit IB heat exchanger in 1973, the

Unit 2B heat exchanger in 1975, and the Unit 2A heat exchanger in 1977.

However, daily testing during this leak period tends to increase the

significance of the release. Also, the Service Water Monitor has been

moved to a location with lower background radiation. The change in

location may have affected the monitor's sensitivity. This matter is

considered an unresolved item and will be reviewed during a future

inspection. (265/79-27-04)

8.

Unresolved Item

Unresolved items are matters about which more information is requir-

ed in order to ascertain whether they are acceptable items, items

of noncompliance, or deviations. An unresolved item disclosed during

this inspection is discussed in Paragraph 7.

Exit Interview

The incpectors met with licensee representatives (Denoted in Paragraph 1

of Details 1 and 2) at the conclusion of the inspection on December 14,

1979, and summarized the scope and findings of the inspection activities,

including the items of noncompliance and the unresolved items. The licen-

see acknowledged the inspectors comments and stated that the event occur-

red solely as a result of the failure to follow the apporved Temporary

Procedure.

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