ML19322B743

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IE Insp Repts 50-269/76-02,50-270/76-02 & 50-287/76-02 on 760223-27 & 0302-04.Noncompliance Noted:Expected Readings for Liquid Waste Not Compared W/Expected Monitor Readings & Control Monitors Not Set for Automatic Alarm
ML19322B743
Person / Time
Site: Oconee  
Issue date: 03/17/1976
From: Burnett P, Epps T, Robert Lewis
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19322B737 List:
References
50-269-76-02, 50-269-76-2, 50-270-76-02, 50-270-76-2, 50-287-76-02, 50-287-76-2, NUDOCS 7912050742
Download: ML19322B743 (20)


See also: IR 05000269/1976002

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IE Inspection Report Nos. 50-269/76-2, 50-270/76-2 and 50-287/76-2

Licensee:

Duke Power Coapany

Power Building

422 South Church Street

Charlotte, North Carolina

28201

Facility Name: Oconee Units 1, 2 and 3

Docket Nos.:

50-269, 50-270 and 50-287

License Nos.:

DPR-38, DPR-47 and DPR-55

Category:

C,C,C

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,

Location:

Seneca, South Carolina

Type of License:

B&W, PWR, 2568, Mwt

Type of Inspection:

Routine, Announced

Dates of Inspection:

February 23-27 and March 2-4, 1976

Dates of Previous Inspection:

February 3-6 and 10-13, 1976

Principal Inspector:

T. N. Epps, Reactor Inspector

Reactor Projects Section No. 2

Reactor Operations and Nuclear

Support Branch

.

Accompanying Inspectors:

P. T. Burnett, Reactor InEpector (March 2-4, 1976)

Nuclear Support Section

Reactor Operations and Nuclear

Support Branch

W. W. Peery, Radiation Specialist (February 23-27, 1976

Radiation Support Section

Fuel Facilities and Materials Safety

Branch

A. D. Kowalczuk, Radiation

Specialist (February 23-27, 1976)

Radiation Support GeqLion

Fuel Facilities .at Ma;crials Safety

Branch

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K. R. Kingsley, Environmental

Engineer (CO-OP) (February 23-27, 1976)

Radiation Support Section

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Fuel Facilities and Materia 1_s Safety

Branch

W. L. Britz, Radiation Specialist (February 26-27, 19761

Radiation Support Section

Fuel Facilities and Materials Safety

Branch

Principal Inspector:

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T. N. Epps, React'or Inspector

Date

Reactor Projects' Section No. 2

Reactor Operations and Nuclear

Support Branch

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Reactor Projects Section No. 2

Reactor Operations and Nuclear

Support Branch

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'IE Rpt. Nos. 50-269/76-2,

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50-270/76-2 and 50-287/76-2

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SUMMARY OF FINDINGS

I.

Enforcement Items

Infractions

1.

Contrary to Technical Specification 3.9.6 liquid waste effluent

monitor readings were not compared with expected readings for

liquid waste releases76-111 and three batches released in

February, 1976.

(Details III, paragraph 2)

2.

Contrary to Technical Specification 3.9.7, the effluent

control monitor was not set to alarm or automatically close

the waste discharge valve to assure that appropriate require-

ments were met for liquid waste releases made during February,

1976.

(Details III, paragraph 3)

3.

Contrary to the survey requirements of 10 CFR 20.201(h),

surveys, the inspectors found on February 23, 1976, that the

interim waste building vent gas monitor, RIA-52, was not

operating.

(Details III, paragraph 4)

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4.

Contrary to Technical Specification 4.11.1, analysis of

environmental samples has not been performed to the sensi-

tivities listed in Table 4.11-3 for all water and milk samples

as evidenced by analysis results in the licensce's semi-annual

report of January to June 1975 and verified by the inspectors

with licensee personnel during the inspection.

(Details III,

paragraph 5)

.

II.

Licensee Action on Previousiv Identified Enforcement liatters

Not inspected.

III.

New Unresolved Items

76-2/1

Process and Effluent Monitor Calibrations and Functional

checks

Monitor calibration and functional check procedures were

inadequate in the areas of setpoints, response correla-

tions, source checks and alarm status.

(Details III,

,

paragraph 6)

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50-270/76-2 and 50-287/76-2

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IV.

Status of Previously Reported Unresolved Items Oconee 1 (50-269)

73-12/1

Calibration of Effluent Monitors

Not inspected.

74-3/3

Training of Unlicensed Utility operators

The licensee has not fully developed this program.

The

item remains open.

Oconee 3 (50-287)

.

74-13/2

Reactor Coolant Flow Anomaly

This problem has been referred to the Office of Reactor

Regulation (Licensing).

It remains open pending further

verification that no problem exists.

74-14/2

Ventilation Control Between Auxiliary and Turbine Buildings

.

This item remains open.

I

Oconee 1, 2 and 3 (50-269, 50-270 and 50-287)

.

74-10, 08, 11/4

SRC Quorum

Not inspected.

.

74-10, 08, 11/5

Procedure Changes

,

Not inspected.

75-12, 13, 14/1

Fire Protection Program Weaknesses

This item remains open pending installation of

reflash on fire alarms to be done by June 1,

1976.

(Details I, paragraph 4)

76-1/1

Instrument Calibration

A program of scheduled periodic calibrations had not

been established for instrumentation associated with

safety-related systems but not identified as requiring

calibration in the Technical Specification surveillance

requirements.

Not reviewed during this inspection.

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76-1/2

Electrical Equipment Caliter. tion

Administrative control for coordinating and scheduling

  • periodic calibration and preventive maintenance on

safety-related relays and breakers will be transferred to

the station maintenance group by August 1, 1976.

Not

reviewed during this inspection.

V.

Other Significant Findings

Unit 1 refueling is in progress.

VI.

Management Interview

A management meeting was held by W. W. Peery, W. L. Britz,

A. D. Kowalczuk and K. R. Kingsley on February 27, 1976, with

J. E. Smith and members of the Oconee staff.

Items discussed

included the infractions in Section I and the new unresovled item

in Section III of this summary.

'

A second management meeting was held by T. N. Epps and P. T. Burnett

on March 4, 1976, with J. E. Smith and members of the Oconee staff.

Subjects discussed included the Unit 1 refueling outage, status of

IE Bulletins 75-04, 04A, 04B and 08, and unresolved items 75-12,

13, 14/1, and the surveillance speciman holder tube problem.

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50-270/76-2, and 50-287/76-2

DETAILS I

Prepared by:

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T. N. Epps, Re;(ytor Inspector

Date

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Reactor Projedt[s Section No. 2

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Reactor Operations and Nuclear

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Support Branch

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Dates of Inspection:

February 23-27 and March 2-4, 1976

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Reviewed by:

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R. C. Lewis, Chief

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Date

Reactor Projects Section No. 2

Reactor Operations and Nuclear

Support Branch

1.

Individuals Contacted

Duke Power Company (DPC)

Site Personnel

J. E. Smith - Manager, Oconee Nuclear Station

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L. E. Schmid - Superintendent of Operations

O. S. Bradham - Superintendent of Operations

R. M. Koehler - Superintendent of Technical Services

T. S. Barr - Technical Engineer

R. T. Bond - Fucis Manar,ement Engineer

J. Iten - Safety Supervisor

.

Operations Personnel

2.

IE Bulletin 75-08 - RCS Temperature / Pressure Instrumentation

IE Bulletin 75-08 requested information describing reactor coolant

system temperature and pressure instrumentation used to record

verification of adherence to the temperature / pressure limitations

in Technical Specifications.

The inspector reviewed the licensee's response dated January 12,

1976, and compared information in the response with instrumentation

'

in the Oconce control rooms.

It was determined that the information

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in the licensee's response was incomplete in that the outlet water

temgerature from the core is recorded with a range from 520 F -

620 F and this instrumentation was not identified in the response.

The inspector cautioned the licensee to assure that information

in response to IE Bulletins is completed.

The inspector had no

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further questions.

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IE Rpt. Nos. 50-269/76-2'

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3.

IE Bulletins 75-04, 04A and 04B Cable Fire At Browns Ferry

The inspector conducted additional followup on IE Bulletins 75-04,

04A and 04B.

This review included verification of the following

items.

'

Construction personnel activities are controlled by the site

a.

maintenance organization.

b.

Licensee maintenance procedures define floor and wall electrical

penetration materials.

c.

Control of ignition sources is covered by administrative pro-

cedure No. 38 approved December 17, 1975.

d.

The licensee's policy is to defer maintenance and modifica-

tions, which would impact safety, until shutdowns where

possible.

e.

Administrative Procedure number 38 requires inspection of work

areas for fire hazards where cutting or welding is done.

f.

Ignition sources are not allowed in areas where flamable

materials exist.

g.

Information requcsted in IE Bulletin 75-043 was provided on

December 16, 1976.

The inspector had no further questions on the abo,ve bulletins.

4.

Unresolved Item 75-12, 13, 14/1 Fire Protection Program Weaknesses

Commitments made by the licensee on this subject are complete except

a modification to install a reflash mechanism on the control room

fire alarms.

A licensee representative stated that equipment necessary

to accomplish this task has not been received.

The modification is

to be completed by June 1, 1976.

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DETAILS II

Prepared by: [ /

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P. T. Burnett, lleactor Inspector

Date

Nuclear Support Section

Reactor Operations and Nuclear

,

Support Branch

Dates of Inspection: March 2-4, 1976

Reviewed by:

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H.' C. Dance, Chief

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Nuclear Support Section

Reactor Operations and Nuclear

Support Branch

1.

Personnel Contacted

.

J. E. Smith - Plant Manager

O. S. Bradham - Maintenance Superintendent

R. M. Koehler - Superintendent of Technical Services

N. Pope - Operating Engineer

L. E. Schmid - Operations Superintendent

R. Adams - I&C Supervisor

,

R. T. Bond - Fuels Management Engineer

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T. S. Barr - Technical Engineer

Various SRO's, RO's and utili'ty operators

2.

Preparation for Refueling

An approved copy of the procedure, OP/1/A/1502/02, " Refueling

(Cycle 3)," was reviewed in the office about two weeks before the

on-site inspection.

An inspector-identified error in the statis-

tical analysis used to confirm operability of the neutron monitors

was discussed over the telephone with licensee personnel. They

in turn committed to make the appropriate changes in the procedure

,

prior to using it.

Timely implementation of the procedure change was verified during

the on-site inspection.

In addition, the inspector independently

analyzed two sets of data from the neutron monitors and confirmed

the results of the licensee's chi-square analyses.

3.

Pre-Fuel Handling Activities

The completed copy of procedure OP/0/A/1503/01, " Preparation for

Refueling," was reviewed.

This procedure assures that refueling

equipment and refueling system interlocks (Technical Specification

Table 4.1-2, item 4) are functional prior to use.

Iue licensee was

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IE Rpt. No. 50-269/76-02

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unable to make the cast up-ender in the refueling pool operable.

Hence, the refueling procedure was revised to use only the west up-

ender.

The control room working copy of procedure OP/1/A/1502/02, "Re-

fueling (Cycle 3)," was reviewed to confirm that operability of

radiation monitors (T/S 3.8.1) and communication systems (T/S 3.8.5)

was established prior to beginning refueling activities.

The completed copy of OP/l&2/A/1104/06, " Checkout of Spent Fuel

Pool Coolant System," was reviewed and found complete.

The licensee has no specific requirements for ventilation of the

reactor building or of the spent fuel pool area.

4.

Fuel Handling Activities

The inspector observed that fuel handling was being directed by a

SRO whose duties were limited to that acti"ity.

The composition of

the station crew for the 1600 to 2400 shifc on March 2, 1976, was

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found to exceed the requirements of Technical Specification 6.1.

.

All requirements of Technical Specification 3.8, " Fuel Loading and

Refueling," are addressed directly in OP/1/A/1502/02, except for

items 3.8.8 and 3.8.11.

Physical arrangement of the fuel handling

equipment and the sequence of operations specified by the procedure

appear to preclude violation of 3.8.8.

Licensee personnel stated

that it was physically impossible to initiate fuel handling ac-

tivities in less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after shutdown; hence, there is littic

potential for violating 3.8.11.

Conformance to this section of

Technical Specifications was confirmed by observations made in the

control room and reactor building, and by review of logs of boron

concentrations, valve alignments and neutron monitor count data.

The licensee had experienced considerable equipment and procedural

dif ficulties during the outage.

Between the time the refueling

procedure was approved, February 13, 1976, and the time the in-

spector arrived on site, March 2, 1976, fifteen approved changes

had been made in'the procedure, most to accommodate these dif-

ficulties and the concomitant changes in the fuel shuffling se-

quence.

Two attempts were made to observe fuel handling activities during

an evening shift.

The first was aborted by a mechanical failure in

one of the neutron monitoring systems.

On the next day, the

inspector witnessed two hours of effort to remove an assembly that

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hung up on every attempt to raise it more than 2-3 feet. Once it

became obvious that a procedure change would be required, a time

consuming process on a back shift, the inspector left the reactor

buihling.

It was observed that the configuration of the startup source and

NI-2 was such that there was no fuel, except for the assembly

containing the source, between the detector and the source. Removal

of a partially consumed assembly from a position adjacent to the

source assembly and insertion of a fresh assembly in the vacated

position, 0-13, were observed from the control room.

The chart

"

recorder for NI-2 indicated an increase in count rate when the

first assembly was removed, and then a decrease to near the original

rate upon addition of the fresh assembly.

However, analysis of

digital data did not indicate a significant change in the count

rate of either monitor as a result of the exchange. Digital data

were not recorded during the time position 0-13 was without fuel.

The source monitor configuration was discussed with plant personnel.

They took the position that the function of the detector was to

monitor boron concentration and that they did not expect to obtain

useful reactivity measurement from the monitors with the system

I

heavily borated and rodded.

This subject was discussed further

i

during the exit interview.

It was pointed out to management that

the configuration could preclude the use of the detector as a

reactivity monitor, and that this was contrary to the thinking that

established the monitor level as a trigger for the reactor building

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evacuation alarm.

The inspector also stated that the inverse-multi-

plication curve derived from MI-2 during the approach to critical

might be difficult to interpret.

The licensee agreed to re-evaluate

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the source location prior to restart.

Source location is not

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addressed in Technical Specifications or in the FSAR.

.

5.

Fuel Examinations

The post-irradiation examination (PIE) program for this outage had

been completed by contractor personnel by the time the inspector

arrived on site. Licensee personnel reported that only one anomaly

had been observed in the inspection:

A v-shaped piece about 1-inch

on a side had been removed from the top of the spacer grid on the

lower end fitting of one assembly.

They speculated that this was a

result of brittle chipping.

The inspector was told that the SRC

,

had consulted with the fuel vendor, reviewed the inspection results,

including a video tape showing the chipped area, and had concluded

that the assembly could be reused.

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6.

Personnel Training for Fuel Handling

From discussions with plant personnel, it was learned that retrain-

ing of experienced personnel was limited to participation in the

checkout of fuel handling equipment such as up-enders and bridges.

New operators were trained on the job.

No up-to-date list of

qualified bridge operators is maintained, but the shift supervisor

and SRO (tefueling) are expected to know which personnel are qualified.

This subject was discussed in the exit interview, and the licensee

agreed to prepare a list of qualified operators.

7.

Hoisting and Rigging Equipment

During the previous inspection the licensee committed to implement

a program to control and inspect slings and rigging equipment.

Implementation for equipment to be used during the refueling outage

was to precede the outage and full implementation was to be obtained

by July 15, 1976.

From a review of directions issued by the licensee

and discussion with his personnel, it was concluded that acticn to

date was limited to inspection.

The licensee agreed to increase

his effort on control, and reiterated his commitment to full

implementation by July 15, 1976.

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DETAILS III

Prepared by:

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W. W. Peery, Radl/ation Specialist

'Date

Radiation Support Section

Fuel Facility and Materials Safety

Branch

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A. D. Kow9 czuk, Radiation Specialist

Date

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Radiatio ( Support Section

Fuel Facility and Materials Safety

Branch

Dates of Inspection:

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23-27, 1976

Reviewed by: /

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A. F. Gibs 6n, Chief

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Radiation Support Section

Fuel Facility and Materials Safety

Branch

All information in these details applies equally to Units 1, 2 and 3.

,

1.

Individuals Contacted

J. E. Smith - Manager, Oconee Nuclear Station

J. W. Hampton - Director, Administrative Services

L. E. Schmid - Operating Superintendent

O. S. Bradham - Maintenance Superintendent

,

"

R. M. Koehler - Technical Service Superintendent

T. S. Barr - Technical Service Engineer

R. C. Adams - Instrument and Controls Engideer

C. Yongue - Health Physics Supervisor

J. R. Leonard - Assistant Health Physics Supervisor

D. L. Davidson - Assistant Health Physics Supervisor

J. A. Long - Health Physics Labman

P. Deal - Health Physics Labman

D. C. Smith - Chemist

R. L. Wilson - P.crformance Engineer

L. L. Lewis - System Herlth Physicist, Charlotte Office

i

M. Burch - Health Physicist - Charlotte Office

2.

Liquid Waste Monitor Response

Technical Specification 3.9.6 requires the liquid waste effluent

monitor readings to be compared with expected conitor readings for

each batch discharged.

Expected readings are currently determined

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50-270/76-2, and 50-287/76-2

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from vendor supplied calibration curves.

Each calibration curve is

.

based on a specific radionuclide and gives-the net counts per

minute of response expected for various specific radioactivity

concentrations, normally in units of microcuries per milliliter.

Records of Liquid Waste Release 76-111 were examined by the inspectors

during the period February 23-25, 1976. The recorded fission and

corrogion product activity based on a laboratory analysis was 1.18

x 10

microcuries per milliliter.

At this concentration RIA 33,

the low range monitor, is expected to be on scale; however, the

The RIA-34, high range monitor,

record showed it was over-rangedy

response was recorded as 2 x 10

microcuries per milliliter.

Recorder chart records were examined to verify the above conditions.

At least three additional liquid waste release records for February,

1976, reflected similar discrepancies.

Discussion with management

representatives did not reveal any notice of the above response

dfscrepancies or any planned corrective action.

The net monitor

response (response excluding background) in counts per minute is

not recorded on the liquid waste release form nor do the calibration

procedures or functional checks for the monitors include comparisons

of monitor response uith the actual liquid being monitored.

3.

Liquid Waste Monitor Setpoint

Technical Specification 3.9.7 requires the effluent control mon-

itors to be set to alarm and automatically close waste discharge

valves so that the appropriate requirements of the specification

are met.

On February 23, 1976, the inspectors examined the liquid

waste release form for LWR 76-111 and several additional liquid

waste release forms for releases made in February, 1976.

Instructions

on the LWR Form state that the alarm point on the high range

monitor is to be set one-half decade above the detector reading.

Actuation of the alarm initiates the isolation function required by

T.S. 3.9.7.

When set according to the above instruction, the

monitor will not be set to limit the instantaneous concentration of

radioactivity to a value less than or equal to that given in

Technical Specification 3.9.3 when a high background condition

exists.

Management rcpresentatives and chart recorder records

confirmed the existence of high background conditions due to

contamination of the monitor.

A comparable item of noncompliance

was identified in Inspection Report Nos. 50-269/75-3, 50-270/75-3

and 50-287/75-3.

4.

Radiation Surveys

On February 23, 1976, the inspectors found that the interim waste

building vent gas monitor, RIA-52, was not operating.

This instru-

ment would monitor all waste building airborne radioactivities in

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the building ventilation system prior to release to the atmosphere.

The inspectors also observed that the RIA-52 monitor did not apparently

have monitoring capability for particulates or iodine.

Licensee

representatives apparently were unable to provide a record of cali-

bration of the monitor.

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5.

Environmental Monitoring Sample Analysis Sensitivities

Technical Specification 4.11.1 for Oconee requires that environmental

samples be analyzed for radioactivities to the sensitivit ies listed

in Table 4.11-3 of the Technical Specifications.

The table lists

sensitivities for gross beta of 0.03 picocuries per liter and

0.5 picocuries per liter for iodine im all water and milk samples.

Review of the licensee Semiannual Report for January through

June, 1975, revealed a number of instances in which the analyses

results for water and milk samples did not meet the applicable

sensitivities of Table 4.11-3.

Examples of the inadequate sensi-

tivities are as follows:

Water

gross beta, range of <0.81 to <0.94 picocuries per liter.

iodine-131, range of <7.3 to <312 picoeuries per liter.

,

Milk

iodine-131, 11.7 to <322 picocuries per liter.

The apparent failure to meet the sensitivity requirements in Table

4.11-3 was verified with licensee representatives during the in-

spection and discussed during the management exit interview.

6.

Process and Effluent Monitor Calibrations and Functional Checks

Calibration data and procedures for the following process and

effluent monitors were reviewed by the inspectors during the period

February 23-27, 1976:

RIA 33

RIA 37

RIA 45

RIA 51

RIA 34

RIA 44

RIA 32

Management representatives were unable to locate the calibration

records for RIA-52.

Functional check procedure PT/0/A/230/01 and

functional check data were also reviewed during the above period.

Calibration procedures typically refer to establishing setpoints at

oce-half decade above background and in some instances no setpoint

is specified.

The above setpoint criteria conflict with setpoints

specified by PT/0/A/230/01 and are not related to radioactivity

levels of safety significance.

Setpoints related to limits in

Technical Specifications, 10 CFR 20, or other official or technically

recognized documents are appropriate.

Neither calibration or

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functional check procedures include comparison of net monitor

response to radioactivity concentration in the actual fluids and

particulates being monitored.

Monitors are in an alarmed condition

when no apparent off-standard or unsafe condition exists.

Based on

discussions of monitor indications and meaning of the indications

with operations, health physics personnel and management representa-

tives, the above conditions appear to be resulting in interpreta-

tions of monitor readings that are inaccurate and inability to make

an interpretation of monitor indications.

Functional checks on

iodine monitors do not use the Barium-133 check source response

determined during calibration to establish the acceptability of

responses observed at subsequent check intervals.

The iodine moni-

tors are designed and adjusted to preferentially select pulses in

the gamma energy range of Ba-133 and I-131.

Licensee representatives

stated that the procedures will be revised to correct the problem.

7.

Gas Monitors

The normal and high WD gas monitors for Units 1 and 2 were in an

alarmed condition for several days during the period February 23-

27, 1976.

Operators stated the alarms were due to residual radio-

(

active gas remaining in the monitors after a release was completed.

'

Modification record ID No. ON-0396 indicated that a purge line had

been installed for the Unit 3 monitors and that purge lines were to

be installed for the Unit 1 and 2 monitors.

The inspectors observed

that the Unit 3 monitors were not alarmed.

8.

Calibration Records

.

Calibration records for level instrume: ation on the condensate

monitor tanks could not be located by management representatives

4

during the period February 26-27, 1976.

A greater than 30% disagree-

ment in volumes derived from tank level records in conjunction with

the tank curve and the liquid waste discharge flow integrator data

recorded on Liquid Waste Release 76-111 was identified.

Comparable

differences were noted on several LWR records examined by the

inspectors.

Management representatives stated that the level

'

instrumentation calibration would be checked.

Review of liquid

waste discharge flow integrator calibration records and further

comparisons of integrator data with level changes in other tanks

appeared to verify the integrator data.

9.

Radiological Environmental Analysis Data

i

Data for stations 004.1 and 006.1 in semiannual reports does not

distinguish between raw and finished water samples taken from the

water supplies. Management representatives stated that tritium and

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gamma analysis data are from finished water and that gross activit3

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data is from raw water and that future reports would distinguish

between raw and finished water.

10.

Radioactive Release Ouantities and Volume

The volume of liquid waste released fr a the plant and the radio-

activity content of the liquid released has exceeded the amounts

projected by the licensee's environmental impact assessments and

the Final Environmental Statement while the fuci defect percentage

is less than was projected.

The causes of this situation were

discussed with management representatives. Marginal evaporator

performance and a greater number of startups and shutdowns than

anticipated appear to be the primary causes.

An interim waste

processing facility has been backfitted to the plant and is in

operation.

An assessment of environmental radiation doses resulting

from various exposure pathways as a result of the 1975 radioactivity

,

releases was made by the licensee.

The results of the dose assessment

indicate that the design objectives in sections 3.9 and 3.10 of the

Technical Specifications have been met.

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11.

Milk Sampics

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The Semiannual Report for January through June, 1975 submitted by

the licensec, indicates that no milk samples were obtained from

family cows within a five mile radius of the plant site. Management

representatives stated that the families were unwilling to provide

!

weekly samples of the size needed to obtain the 0.5 picoeuries per

liter analytical sensitivity required by Technical Specifications.

The inspectors commented that the families might be approached to

provide samples on a less frequent basis and commented that an

offer to replace the milk used for samples might induce the families

to be more cooperative.

Management representatives stated that

they would make further attempts to obtain the samples.

12.

Environmental Pathway Dose Calculation

Clemson University has a dairy downstream of the plant.

The dairy

cows are estimated to obtain about one half of their drinking water

from the Hartwell Reservoir.

Plant discharges flow into the reservoir.

No assessment of the cow-milk-child exposure pathway using drinking

water as the source of iodine-131 in milk had been made in previous

analyses.

The dairy is currently being relocated and this pathway

will have no future significance with respect to the Clemson Dairy.

Neverthclcss, licensee representatives stated that they would

evaluate the above pathway.

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13.

Personnel Familiarity with Radiation Monitor Indications

As noted in other sections of this report, the inspectors examined

process and effluent radiation monitor records and discussed the

'

operation of the monitors with operators, health physics personnel,'

instrumentation personnel and management representatives. 'It was

apparent to the inspectors that most of the personnel contacted -

were weak in their understanding of monitor functions and monitor-

,

indications, and that there was a general inability to relate-

monitor indications and alarms to radioactivity levels, Regulations

and Technical Specifications.

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14.

Routine Secondary Radioactivity Detection and Monitorine Program

By memorandum dated November 19, 1975, the licensee corporate staff

'

recommended an expanded program of sampling and analyses for normally

nonradioactive and low level radioactive effluents.

The majority

of the samples were already being collected and analyzed; however,

the recommendation specified type analysis and frequency for specific

points such that all nonradioactive and all possible environmental-

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release points are being adequately monitored.

This inspection

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effort verified that the program has been instituted as recommended.

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15.

Radioactive Shipments

"

The NRC was notified by letter from a licensee dated February 11,

'

1976, that a shipment of radioactive material had been received

i

from Oconce which had an external radiation reading greater by

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their survey than was recorded on the Oconee shipping documents.

Oconee representatives stated that they had concluded that the

higher reading may have been caused by slight movement in transit

i

of the radioactive material (flux wires) inside the shield.- This

was a sole use vehicle and no regulatory requirements were apparently

violated. Oconee supervision had already issued an instruction to

appropriate personnel to emphasize care in accurately surveying

radioactive shipments.

In addition, discussions were held by the

inspector with Oconee personnel concerning emphasis in packaging of

shipments to prevent movement of the radioactive material inside

the shipping container.

This item was discussed during the exit

interview and concurrence indicated by management.

,

'16.

Filter Testing

The inspector noted that licensee approved procedure No. 110-5,

Inplace Testing of HEPA Filters and Inplace Charcoal Adsorbers,

contained acceptance criteria for percent efficient different from

the acceptance criteria in the Technical Specifications.

A licensee

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representative stated that the procedure was that of the testing

company and the acceptance criteria being used was the Technical

Specific.ation requirement.

The licensee representative stated that

the procedure would be revised to reflect the use of the Technical

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Specification acceptance criteria and management concurred during

the exit interview.

17.

Other Areas Inspected

Other than the items discussed in the above paragraphs, additional

areas inspected about which the inspectors had no further questions

included the following:

abnormal occurrence reports, liquid and

.

gaseous effluent records, routine semiannual reports, instrument

j

calibrations and tests, licensee procedures for the control of

effluent releases, tests of containment air cleaning and tests of

reactor coolant water quality.

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DETAILS IV

Prepared by:

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W. L. Britz, Radiation Specialist

Date

Environmental and Special Projects Section

Fuel Facility and Materials Safety Branch

Dates of Inspection:

February 26-27, 1976

Reviewed by: [ I.

8d,t<.a>

3//.2/76

R. L. Bangart,fChief

'Date

Environmental and Special Projects Section

Fuel Facility and Materials Safety Branch

1.

Individuals Contacted

J. E. Smith - Station Manager

R. M. Kochler - Technical Service Superintendent

J. L. Dunlop - Assisrant Quality Assurance Engineer

J. R. Leonard - Assistant Health Physics Supervisor

2.

Quality Control of Analytical Measurements

The quality assurance and control of analytical measurements was

inspected.

The radiation counting room equipment and procedures

are not included in the plant quality assurance program.

A letter

from the corporate office to the plant staff delineates a quality

control of counting measurements program by periodic instrument

checks.

The instrument records of these checks were inspected.

Recommendations for improving the forms were made.

The licensee

stated these forms were in the process of being revised.

The

merits of having the radiation counting room equipment and

procedures included as a regular audit in.the qualitp assurance

program was discussed.

The inspector had no further questions.

3.

Confirnatory Measurements

a.

Scope

The licensee is required to measure the quantities and

concentrations of radioactive material in effluents from

his facility to assure that they are within the limits

specified in his license and the NRC Regulations.

This

inspection consisted of testing the licensee's measurements

of radioactivity in prepared test standards by comparing

his measurements with those of the NRC's reference

laboratory.

The results of previous split samples and

test standards were discussed.

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b.

Comparison of Analytical Results

(1)

Liquid and Gas Radwaste Split Samples, May, 1975

Fifteen measurements were compared on the samples.

Ten were in agreement, one in possible agreement,

and four in disagreement.

The disagreements were

on the gross beta and three gamma isotopes on the

liquid sample.

Liquid test standards were sent to

the licensee to analyze and resolve these disagree-

ments.

The gas bulbs sent to the NRC's reference

lab were broken and thus no comparison made on them.

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(2)

Liquid Test Standards, September, 1975

Liquid test standards were sent to the licensee to

resolve the May disagreements.

There were five measure-

ment comparisons for gross beta and gamma isotopic analysis.

All results were in agreement.

The previous disagreements

4

are now resolved.

(3)

Liquid and Gas Radwaste Split Samples, September, 1975

Eleven measurements were compared on the samples.

Five

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were in agreement, three in possible agreement, and

t

three in disagreement.

The disagreements were on tritium

and cobalt-60 in the liquid sample, and krypton-85 in the

gas sample.

Krypton-85 was present in concentrations which

were not seen on the licensee's analysis due to the back-

ground and counting time.

Recommendations for using a

'

longer count time for these comparisons and a good determina-

tion of background at the 511 key peak area were recommended.

The licensee stated a shield to provide a lower background

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will be installed in the future.

The cobalt-60 measurement

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is considered resolved by the acceptable test standard

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measurement completed about the same time.

The licensee's

tritium measurement was high and thus conservative.

This

measurement will be reevaluated in the ne:.:t sample comparison.

(4)

Particblate Filter and Charcoal Adsorber, Test Standard,

February, 1976

Two particulate filters and one charcoal adsorber test

standard were analyzed during this inspection. Ten

measurements were compared on the samples.

Eight were

in agreement, one in possible agreement, and one in

disagreement.

The disagreement was on manganese-54 and

is in the process of being resolved.

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