05000219/LER-1982-016, Responds to NRC Re Violations Noted in IE Insp Rept 50-219/82-17.Corrective Actions:Utilization of Drain Path for Release of Radioactive Water Discontinued.Forwards Re Future Corrective Actions & LER 82-016/03L-0

Responds to NRC Re Violations Noted in IE Insp Rept 50-219/82-17.Corrective Actions:Utilization of Drain Path for Release of Radioactive Water Discontinued.Forwards Re Future Corrective Actions & LER 82-016/03L-0

ML20027B305
Person / Time
Site:	Oyster Creek
Issue date:	08/20/1982
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20027B303	List: 05000219/LER-1982-016, Responds to NRC Re Violations Noted in IE Insp Rept 50-219/82-17.Corrective Actions:Utilization of Drain Path for Release of Radioactive Water Discontinued.Forwards Re Future Corrective Actions & LER 82-016/03L-0 IR 05000219/1982017
References
NUDOCS 8209200256
Download: ML20027B305 (2)

LER-1982-016, Responds to NRC Re Violations Noted in IE Insp Rept 50-219/82-17.Corrective Actions:Utilization of Drain Path for Release of Radioactive Water Discontinued.Forwards Re Future Corrective Actions & LER 82-016/03L-0

Event date:
Report date:
2191982016R00 - NRC Website

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l GPU Nuclear o ked ive, New Jersey 08731 609-693-6000 Writer's Direct Dial Number:

August 20, 1982 f

i Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I l

631 Park Avenue l

King of Prussia, PA 19406 l

Dear Mr. Starostecki:

Subj ect: Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report No. 82-17 This letter is submitted in response to your letter of July 22, 1982, regarding the findings of the June 2 - July 5,1982, routine inspection by Mr. J. Thomas of your staff.

In accordance with 10 CFR 2.201, enclosed is our response to the Notice of Violation. If there are any questions regarding the supplied information, please contact me or Mr. Michael Laggart of my staff at (609) 971-4643 Very truly yours, Peter B. Fiedler Vice President and Director Oyster Creek PBF:MWL:lse Enclosure cc:

Mr. Ronald C. Haynes, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 8209200256 820910 PDR ADOCK 05000219 O

PDR GPU Nuclear is a part of the General Pubhc Utilities System

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VIOLATION:

Technical Specification 3 6.B.(2), requires that radioactive liquid effluents, being released to the discharge canal be continuously monitored.

Contrary to the above, from June 12, 1982 to June 14,1982', about 300 gallons of water with a total activity of 70 5 millicuries was released to the discharge canal via the storm sewer system and was not continuously monitored.

RESPONSE

The violation is correct as stated above. As identified in the inspection report, the drain path utilized on June 12,13, and 14,1992, was thought to lead to a radwaste collection sump. Upon discovery by an employee that the drain path actually led to the environment via storn catch basins,. the utilization of the drain path was discontinued. Full compliance was achieved at this time.

a With regard to future corrective actions, two previcus submittals have been made to the NRC regarding the subject violation. On July 14, 1982, Reportablo Occurrence No. 50-219/82-16/03L was submitted; and on July 20, 1982, a letter was submitted detailing future corrective actions. Both submittals are being included as attachments to this response. The corrective. actions detailed, adequately address the concerns of the violation.

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CPU fluclear a '. a Forked River, New Jersey 08731 609-693-6000 Writer's Direct Dial Number.

July 20, 1982 Mr. Ronald-C. Haynes, Administ rator Region I U.S. Nuclear Regulatory Conmission 631 Park Avenue King of Pressia, PA 19406

Dear Sir:

Subj ec t: Oyster Creek Nuclear Generating Station Docket No. 50-219 Contamination Control On June 11, 1982, the New Radwaste service air system at Oyster Creek was contaminated with radioactive water from a resin transfer tank. The contamination resulted from a failure of a check valve to isolate at a cross-connection of the two systems.

While d raining the contaminated water from the service air system, an inadvertant release to the environment occurred.

The drain path utilized was thought to Icad to a radwaste collection sump; however, it was discovered that it actually led to the environment via storm catch basins.

Ai tsched to this letter is a copy of Reportable Occurrence No. 82-16, submitted on July 14, 1982.

The LER describes the above events in more detail; however, we feel the format of the report does not convey how serious GPU Wuclear regards this matter.

This letter is being submitted to inform the NRC as to how management intends to allocate its resources in matters of this nature.

Although the radioactivity released during this event did not endanger the public health and safety, we realize that a potential for future releases may exist due to intersystem cross-connects. In addition to the corrective actions listed in the attached Reportable Occurrence, we plan to undertake the following in order to prevent recurrence:

1.

Perform a documented review of all plant floor and roof drain systems including, where feasible, a field verification of drawings to identify the discharge points. Conspicuously mark all such drains to clearly differentiate those that discharge to nomally contaminated systems from those that discharEe to the environment or cican collection systems.

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GPU Nuclear is a port of the General Pubhc Utilities System

Mr. Bons 1d C. Haynes Page 2 July 20, 1982 2.

For floor drains or hub drains inside the radiation controlled area or other potentially contaminated areas that are found,to discharge to the enviromsent or clean collection systems, provide suitable plugs or shutoff devices, where feasible, that will be procedurally controlled to preclude inadvertant discharge of contaminated caterial.

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3 Identify all cross-connect psths to clean systems that may result from nor. mal opera tion, valving errors, valve 1cakage, or check valve Icakage.

Encure that appropriate procedural controls exist on the intentional use of these croc -connects to n.Ssare that cross contamination does not occur.

4.

For all system or component draining evolutions using temporary pipe or hose connections, establish procedural controls to verify the discharGo point of the drain path before commencing the evolution.

5 For systems or component drain paths determined to discharge to the environment or cican systems, evaluate, on an individual basis, the feasibility and desirability of redirecting the drain Isth to a contaminated collection system.

The above actions are scheduled for cocpletion prior to 2/1/83 If there are any questions, please feel free to call me or Mr. Michael Laggart of my staff at (609) 971-4643 Very truly yours,

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Peter'B. Fiedler Vice President and Director Oyster Creek PEF:MWL:Ise cc: KRC Recident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731

GPU Nuclear r,

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Forked River New Jersey 08731 609 693-6000 Writer's Direct Dia! Number:

July 14, 1982 Mr. Ronal'd C. Haynes, Administrator Ragion 1 U.S. !;uclear Eeculatory Ccrcicsion 631 Psrk Avenue King of Prussia, PA 19406

Dear Mr. Haynes:

Subject:

Oyster Creek ?:uclear Generating Station Docke t !io. 50-219 Licensee Event Report Reportable Occurrence io. 50-219/82-16/03L This letter forwards three copies of a Licensee Event Esport to report Reportable Occurrence No. 50-219/82-16/03L.in ccapliance ith paragraph 6 9 2.b.4 of the Technical Specifications.

Very truly yours, I'

We Peter S. Fiedler Vice President and Pirector Oyster Creek PBF:1se Enclosures cc: Director (40 copies)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Director (3)

Office of Manage::,ent Information and Program Control U.S. Nuclear Regulatory Commission Washington, D.C.

20555 NRC Resident Inspector Oyster Creek Nuclear Cenerating Station Forked River, NJ 08731 lK2 m--

OnvDH30T"J GPU Nuc! ear es a part of :ne Gene al Puche Utm: es S*s:em

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OYSTER CREEK NUCLEAR GENERATING STATION Forked River, New Jersey 08731 Licensee Event Report Reportable Occurrence No. 50-219/82-16/03L Report Date-July 14, 1982 Decur rence Dat e_

June 11, 1982 Identification of Occurrence An unconitored release of radioactive water occurred due to contamination of service air piping in the New Radwaste Building. In one instance the leakage was to the discharge canal via the drainage system, and in two other instances, the leakage was to the soil.

This event is considered to be a reportable occurrence as defined in the Technical Specifications, paragraph 6.9.2.b.4.

J Conditions Prior to Occurrence 4

The plant was at steady state operation.

l Power Levels:

Reactor 1621 MWt Generator 540 MWe i

Mode Switch R,u n Description of Occurrence

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On Friday, June 11, 1982 at approximately 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, New Radwaste Operations j

personnel were preparing to transfer spent resins from the storage tank into a shipping cask.

Prior to the actual. resin transfer operation, the tank was filled with condensate water to create a slurry and was then mixed using air at approximately 30 psig. With the air still mixing t,e tank contents, condensate h

water was used to backflush the resin transfer line into the tank.

It was during this backflush that the vent line became plugged, (attributed to a blinded resin screen on the vent) which resulted in pressurizing the tank from i

l the condensate transfer system. Water was forced back into the air line, through the pressure regulator and the in-line check valve (condensate water pressure at the tank is greater than air system pressure).

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Licensee Event Report Page 2 Report able Occurrence No. 50-219/82-16/03L The first evidence of a problem was when the backflush line pressure did not decrease as expected.

Further indications received later were an area high radiation ala rm near the air receiver tank, and the discovery of radioactive fluid leaking f rom a moisture trap in the air line.

The resin tank was isolated and all necessary safety and radiological concerns were promptly a leaking addressed. During the investigation into the extent of the problem, hose connection in an air line outside of the ::ew Radwaste Soilding was discovered. Total leakage to the soil was estimated at appr. imately 10 m1, with a gross radioactivity of 0.62 microcuries.

The air system geometry is such that most of the contaminated water remained in the bottom of the air receiver tank (thus preventing the accumulation in the a ir compre s sor a nd a f ter c ooler f rom becoming cont amina ted). The air receiver is automatically blown down through a drain line which has a filter and a trap in the line. The available data suggests this feature was inoperabic at the time of this event.

During the pri=ary decontamination of the air receiver, it was flushed with water several times via an alternate route utilizing a bypass around the filter / trap assembly.

It was realized on June 21, 1982, that the drain line from the air receiver leads to the storm drain which discharges directly to the discharge canal.

It total of approximately 300 gallons was discharged, with was estimated that a gross radioactivity o f 6.21 E-2 microcurie s/ml. This correlates to a total of 0.0705 curies.

Upon discovery of this event, the affected catch basins, s to rm drains, a~ d the air receiver drain line were isolated.

During the secondary decontamination of the air receiver using a hydrolazer, water (less than 5 gallons) leaked to the soil outside the building.

Approximately 30 f t of soil (3 f t.

x 10 ft. x 1 f t, deep) was collected and sampled; based on the sample results, all of the soil was returned to the original area.

Apparent Cause of Occurrence The cause of the event was attributed to a blocked vent line from the spent resin tank.

Si nc e the resin-water mixture level in the tank was above the level of the screen on the vent line, the air pressure in the tank apparently trapped enough resins against the screen to prevent the venting of the tank.

The vent valve in the line was checked af ter the event, and both the remote valve indication and valve operation checked out satisfactorily.

In addition, the check valve in the air system did not provide effective isolation of the spent resin tank from the Service Air System.

Analysis of Occurrence The first of the three interrelated events was the leak from the hose connection. All surveys taken of the soil from this leak (estimated at 10 ml) showed no appreciable readings above backgrout.d ievels.

Licensee Event Report Page 3 Report able Occurence No. 50-219/82-16/03L The second of these events was the leakage from the building to the soil.

Several soil samples were examined before returning the soil back to its location. The maximum concentrations of the two detetable isotopes, Mn 54 and Co 60, were 7.09 E-5 and 3.71 E-4 microcuries/gm, respectively.

Both of these values are within the limits set forth in 10 CFR 20 and 10 CFR 30 (10 CFR 30 is used to determine concentrations in the soil based on 1 gram.) Total volume leakage was estimated at approximately five (5) gallons.

The third of these events is the drainage to the discharge canal.

Total volume leakage was estimated at 300 gallons.

The isotopic analysis showed the following maximum concentrations:

Mn 54 9.46 E-3 microcurie s/ml Co 60 5.76 E-2 microcuries/ml Although these releases occurred during 3 separate flushes of the air receiver, the following analysis assumes that all 300 gallons were released in 15 m inu t e s.

It also assumes a minimum dilution flow of 460,000 gpm, even though actual dilution flow was higher.

Based on this, the concentrations of each isotope in the discharge are as follows, with their associated 10 CFR 20 limit:

Mn 54 4.11 x 10-7 microcuries/ml, limit 1.0 E-4 meirocuries/ml Co 60 2.29 x 10-6 microcuries/ml, limit 5.0 E-5 microcuries/ml

Corrective Action

The immediate corrective actions were to first isolate the affected spent resin tank and then prevent as much of the air system as possible from becoming

. contaminated. The air compressor was kept in operation, in order to prevent the syphoning of water into unaffected piping. A direct frisk was made of the ground under the total length of hose outside the building, and all readings 3 of soil outside the vere at or below background levels.

Approximately 30 f t building, af fected by the leak during flushing, was collected, sampled, and i

then returned once sample results were analyzed and it was determined that no 10 CFR 20 or 10 CFR 30 limits were exceeded.

The check valve in the air line to the spent resin tank was examined and no f ailures were detected.

The af fected storm drains and catch basins in the drainage system were decontaminated and the radiation levels in the air receiver have been reduced to background levels.

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Licensee Event Report Page 4 Report able Occurrence No. 50-219/82-16/03L In addition to these ef forts, the procedure for the transfer of spent resins has been reviewed, and has been changed to reflect two (2) important concepts:

1) the air mixing operation will be halted prior to starting the backflushing operation, so that air and condensate water are not being forced into the tank at the same time; 2) prior to transferring resins from the tank, the level in the tank will be lowered to insure that the resin slurry is below the screen on the vent line (i.e., prevent inadvertant vent line blockage).

An evaluation will be conducted to determine what constitutes acceptable isolation of noncontaminated systems from contaminated systems.

Based on the re sults' of this determination, modification of existing systems will be considered to prevent future incidents of contamination entering " clean" systems through designed interc onnections.

in all Additionally, procedural controls will be established to assure that nonroutine draining evolutions, the discharge point of the drain path will be verified prior to commencing the evolution. As an aid to implementing this requirement, a system of unique definition of noncontaminated drains will be evaluated.

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