ML20038B689
| ML20038B689 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/16/1981 |
| From: | Book H, North H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20038B686 | List: |
| References | |
| 50-312-81-28, NUDOCS 8112090030 | |
| Download: ML20038B689 (11) | |
See also: IR 05000312/1981028
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S.- NUCLEAR RECUL\\ TORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
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REGION V
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Report No. 81-28
Docket No. 50-312
License No.
Safeguards croup
I.icens ee : Sacramento Municipal Utility District
P. O. Box 15830
Sacramento, California 95813
Rancho Seco
Facility Name:
Inspection at: Clay Station and Sacramento, California
59ptember 21-22, 24-25 and October 6-9, 1981
Inspection conducte :
Inspectors:
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H. d. Hartn, KaolaL100 dpec i d l i n
fate Signed
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Date Signed
Date - S igned
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Approved by:
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F. A.
nslawski, hief, Reactor Radiation Safety dection
taed' S igned
Approved by:
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H. E. Book, Chief, Radiological Saf ety brancn
Date Signed
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Summary:
Inspection on September 21-22, 24-25 and October 6-9, 1981 (Report No. 50-312/81-28)
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Areas Inspected: Routine unannounced inspection by a regionally based inspector
of radiation protection organization and staffing, radioactive waste systems,
liquid and gaseous radioactive effluent releases, abnormal radioactivity
releases, procedures for controlling release of effluents, testing of air
cleaning systems, tests of reactor coolant water quality, tests of secondary
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system activity, sampling and analysis frequency, solid radioactive waste,
followup on reportable occurances, and inspection report followup items.
The inspection involved 59 inspector hours on site by one inspector.
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Results: Of the twelve areas inspected, no items of noncompliance were
found in ten areas; items of apparent noncompliance were found in two areas;
failure to notify the NRC of an unexpected release of xenon-133 pursuant
to 10 CFR 50.72, (a)(8) Severity Level IV Violation (Paragraph 6) and failure
to continuously measure and record the flow from the auxiliary and reactor
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building stacks as required by Tcchnical Specification, Appendix B, Section
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2.6.4.B (Severity Level IV Violation)(Paragraph 5).
Rv Form 719 (2)
8112090030 811117
PDR ADOCK 05000312
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DETAILS
1.
Licensee Personnel Contacted
+*R. Rodriguez, Nuclear 0perations Manager
- P. Oubre', Plant ' Superintendent
- R. Columbo, Technical Assistant
+ R.~ Miller, Chemistry and Radiation Supervisor (CRS)
M. Bua, Senior Chemical and Radiation Assistant (SCRA)
D. Gardiner, SCRA
S. Nicolls, SCRA
W. Wilson, SCRA
+D. Whitr.ey, Supervisor, Engineering and Quality Control
R. Wichert, Plant Mechanical Engineer
J. Price, Engineering Technician
R. Low, Senior I&C Engineer
D. Weils,. I&C Foreman
+*D. Blachley, Operations Supervisor
J. King, Shift Supervisor
- W. Spencer, Shift Supervisor
A. Fraser, Senior Reactor Operator
M. Cooper, Reactor Operator
- T. Perry, QA Supervisor
+Q. Coleman, QA Inspector
W. Weaver, Safety Technician
- S. Crunk, Assistant Nuclear Engineer on Technical Assistant's Staff
P. Mayo, Senior Utility Clerk
D. Bird, ALARA Coordinator (Corporate Staff)
R. Knierim, Assistant Environmental Specialist (Corporate Staff)
+ Denotes attendance at exit interview on September 25, 1981.
- Denotes attendance at exit interview on October 9, 1981.
2.
Radiation Protection - Staffing
The licensee has added two Chemical and Radiation Assistants (CRA)
to the plant. staff. One unfilled CRA position remains in the full
complement CRA staff of 16. The Health Physicist and Nuclear Chemist
positions, which were vacated on October 3, 1980 and March 9, 1981
respectively, remain unfilled.
The licensee's efforts'to recruit
a Health Physicist have been unsuccessful. 'The Nuclear Chemist position
had not been posted at the time of the inspection.
No items of noncompliance were identified.
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3.
Radioactive Waste Systems - 10 CFR 50, Appendix I and 40 CFR 190
The licensee submitted the 1981 semiannual, Radiation Ex]osure, Environmental
Protection, Effluent and Waste Disposai Report required
)y Technical
Specification (T.S.) Appendix B, Section 5.6.1.B. in a timely fashion.
The report as well as the annual reports for 1980 and 1979 required
by T.S. Appendix B, Section 5. 6.1. A. were examined for obvious mistakes,
anomalous data, trends or missing information.
ND significant items
were identified with the following exceptions:
(A) The 1981 semiannual report contained information relating to
an unexpected release of gaseous activity when the reactor vessel
head was initially lifted for the fourth refueling outage, this
occurrence is discussed in greater detail in paragraph 5
of this report.
(B) The Rancho Seco facility has historically been operated as a
nominally zero radioactive liquid waste release facility. During
the period following the steam generator tube failure of May 16,
1981 significant quantities of low level liquid radioactive waste
were released offsite. This resulted in an increase in the calculated
offsite dose.
Calculated exposures based on liquid waste releases
Time Period
Resident Maximum Individual (mrem)
50 mile population (man rem)
Total body
liver
Total body
thyroid
Jan - June 1981
1,46
1.99
29
128
Jan - Dec 1980
0.11
0.15
0.08
0.05
Jan - Dec 1979
No liquid releases
(C)
It was noted that the values for the maximum exposed individual
listed in the report text due to gaseous effluent were a factor
of 10 higher than the same values reported in Table 5B of the
1981 semiannual report. The licensee stated that the Table value
was correct and that the text value was a factor of 10 high.
The licensee's representative stated that a corrected page to
the report would be submitted.
The seniannual and annual reports were discussed with licensee representatives
during the inspection.
The responsibility for offsite dose calculation
is assigned to District office personnel.
Data from Rancho Seco consisting
of liquid and gas decay tank batch releases and continuous gaseous
releases and meteorological data tapes, are collected from the site
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at weekly intervals. Offsite doses are calculated for each batch
release and for continuous releases. The licensee uses the LADTAP
program for liquid releases and the X0QD0Q program and GASPAR code
for gaseous releases which are all considered to be at ground level.
The licensee experiences a delay of 30-45 days between the release
of waste and the completion of the calculations of offsite dose due
to delays in data processing at the site, data transmission and data
reduction at the District office.
Segmental population values are based on 1970 census data extrapolated
to 1985.
Data from the 1980 census will be broken down by radial segments
and projected to 1985 and the projected values of the 1970 and 1980
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cenws compared.
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At the time of the inspection the licens_ee was. achieving a 98% recovery
of raeteorological. data.
In cases where magnetic tape records are
unavailable, a multipoint recorder' chart record and teletype records
of hourly averages of wind speed,, direction and 33 and 200 foot differential
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temperatures are available.- The ons'ite meteo'rologi. cal _ instrumentation
was discussed with representatives of the onsite I and'C, group who
are responsible for surveillanceand calibrati n of the equipment.
The licensee is planning to replace the meteorol6gical tower instrumentation
in the near future and is also planning an onsite computing capability
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for essentially live time offsite ' dose calculations.
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Based on discussions 1with licensee personnel' and review of. the results
of the licensee's evaluation of offsite doses, it appears that the
licensee has demonstrated compliance with 40 CFR 190 by showing compliance
with both 10 CFR 20 and Appendix I, of 10 CFR 50 as described in NUREG-0543.
No items of noncompliance were identified.
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Radioactive Effluent Releases - Liquids
The licensee's records of liqJid waste releases were examined for
the years 1979, 1980 and 1931.
No radioactive liquid releases were
made in 1979, five occurred during 1980 and 156 in 1981 to the date
of the inspection. The significant increase in the release of liquid
waste resulted from the large volume of contaminated water generated
during the steam generator tube failure (IE Inspection Report No.
50-312/81-16). The inspector verified by examination of release permits
and analytical records that releases complied with T.S., Appendix B,
Section 2.6.1 in the following respects:
Concentrations of radioactive materials in liquid wastes were less than
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10 CFR 20, Appendix B, Table II, Column 2 values.
Fractional MPC's for
specific nuclides identified were summed by the licensee to verify that
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the requirements contained in the " Note to Appendix B" were satisfied.
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Total release of liquid waste was less than 10 curies / reactor / calendar
quarter and 20 curies / reactor in any 12 consecutive months, excluding
tritium and dissolved gases. The liquid releases totaled 0.0038 curies
during 1980 and 0.892 and 0.352 curies respectively during the second
and third quarters of 1981 to the date of the inspection.
The licensee used the installed liquid waste processing system to
minimize releases from the site. During the recovery from the steam
generator tube failure the maximum radioactivity contained in a tank
directly releaseable to the environment was less than 10 curies.
In addition the licensee has calculated the maximum specific activity
which may be contained any tank directly releaseable to the environs
without exceeding the 10 curie limit.
During the second and third
quarter of 1981 to the date of the inspection, releases were less
than one curie in any quarter excluding tritium and dissolved gases.
The licensee maintained detailed records of liquid radioactive waste
concentration both before and after dilution and of the average dilution
flow and duration.
Cumulative records of liquid releases were reported
in a timely fashion as required in annual and semiannual reports in
accordance with T.S. Appendix B, Section 5.6.1.
Sampling and analysis
conformed to the requirements of T.S. Appendix B, Section 2.6.2.B,
C and table 2.6-1.
T.S. Appendix B, Section 2.6.2.D. requiring continuous
monitoring during discharge was amended for the period June 6-30,
1981.
During this period the licensee complied with the revised T.S.
requirements.
Release of the liquid waste was monitored and flows
of waste and dilution water measured and recorded. Records were maintained
of monthly functional tests and quarterly calibrations which were
conducted in accordance with procedures I-603, Liquid Radiation Monitor
Calibration and I-605 Radiation Monitor System Monthly Test.
Calibrations
were performed using monitoring system vendor supplied Cs-137 and
Ba-133 sealed sources. Records of tests and calibrations for the
period January - August 1981 were examined.
No items of noncompliance were identified.
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Radioactive Effluent Releases - Gases
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T.S. Appendix B, Sections 2.6.4.B and C identify <as gaseous release
points from the plant, the auxiliary building stack (ABS), reactor
building stack (RBS), radwaste service area fan (EF-A-9), condenser
air ejector (CAE) and gland seal exhaust (GSE).
The CAE and GSE have
been rerouted and discharge through the ABS. The radwaste service
area fan (EF-A-9) has not been in service for a period of years. A new
fan, HEPA and charcoal filter housing is on site awaiting installation.
Releases from the facility consist of continuous releases and waste
gas decay tank (WGDT) batch releases through the ABS. The ABS services
the fuel handling building as well as the auxiliary building. Reactor
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building purges (or ventings) are c'onsidered batch releases through
the RBS. During 1981 through~the date of,the inspection 12 WGDT and
26 reactor building purges had occurred. An examination of all 1981,
ABS and RBS release per_mits estab~11shed that the releases were in
accordance with the, limits of T.S. Appendix B, Section 2.6.3.
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licensee has calculated the maximum gaseous activity resulting from
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0.1% and 1% failed fuel and concluded that a single WGDf containing
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135,000 curies as Xe-133 could not be achieved. The licensee samples
WGDTs quarterly and prior to release. 'The licensee maintains records
of analyses and monitoring for gaseous, ' iodine, particulate and tritium-
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releases and has submitted annual and semiannual reports in a, timely
fashion as required by T.S. Appendix B, Section 5.6.1.
The licensee's
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1981 records to the date of the inspection for monthly functional
tests and quarterly calibrations of gas, particulate and iodine monitors'
which are covered by procedures, I-604, Gas Radiation Monitor Calibration,
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and I-606, Reactor Building Purge / Radiation Monitoring System Interlock,
were examined.
Cs-137 and Ba-133 sealed sources supplied by the monitoring
system vendor are used for calibration. The licensee's sampling and
analysis program for airborne releases was in accordance with the
requirements of T.S. Appendix B, Table 2.6-2.
T.S. Appendix B, Section 2.6.4.B. states in part that, " Gaseous releases
to the environment, ... shall be continuously monitored for gross
radioactivity, and the flow measured and recorded." Flow measuring
devices have been installed on the ABS and RBS however the indicated
flows are not recorded. According to plant personnel flow measuring
devices were not initially irstalled in the plant. The devices which
were installed at a later date are not serviceable and have not been
accepted for operations by the plant staff.
The licensee stated that
during refueling outages following the HEPA and charcoal filter testing,
a hot wire anemometer measurement is made on the exit side of each
HEPA filter and the flows through each system calculated from the flows
through the individual filters. These calculated flows are used during
the period between refuelings to calculate continuous releases. The.
licensee's representatives stated that this method of release calculation
is conservative in that flows through the filtered system can be expected
to fall as filters plug. This method of flow measurement does not
satisfy the requirements stated in T.S.-Appendix B, Section 2.6.4.B.
(81-28-01).
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6.
Abnormal Radioactivity Releases
The 1981 semiannual Effluent and Waste Disposal Repor_t_ identified
three abnormal releases of gaseous activity during the report period.
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Two of these occurrences had been previously reported to the Comission.
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These two releases of Xe-133 involved 7.53 curies due to valve leakage
in the hydrogen header and 4.41 curies due to the. steam generator
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tube' failure. A third occurrence on February 11, 1981, involving the
release of 241.33 curies of Xe-133, approximately 85% of the Technical
Specification instantaneous release limit, was not promptly reported
to the Commission.
The licensee's semiannual report described the
release as unexpected.
The release occurred when the reactor vessel head was lifted at the-
commencement of the fourth refueling outage.
Licensee-representatives
stated that release of gaseous activity is expected during this evolution
but that a release of this magnitude was unexpected. The personnel
in the reactor building had been limited to those individuals required
for the activity. At the time the vessel head was renoved, at approximately
1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br />, a reactor building purge was in progress. The reactor
building gas monitor, which increased from 400 to 20,000 counts per
minute in 10 minutes, tripped the reactor building purge. The auxiliary
building stack monitor increased from slightly above 100 counts per
minute at 1440, to approximately 10,000 counts per minute by 1505.
The licensee subsequently determined that the radioactive gas in the
reactor building was released from the site not only through the reactor
building stack pathway but also through the open fuel transfer tube,
a previously unidentified ventilation pathway, to the spent fuel building
and subsequently through the' monitored auxiliary building stack.
At 1555 personnel in the spent fuel building were asked to evacuate
the area and at 1610 all persons were out of the reactor building.
Reactor building air samples collected before and after the release
confinned that the release consisted of noble gases, . principally Xe-133,
with no significant change in the iodine airborne activity. The reactor
building purge was restarted at 1635.
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The Xe-133 concentrations measured'(m) or~ estimated (e) from recorded
monitor readings for Reactor Buildiry Stack .(RBS) and Auxiliary Building
Stack (ABS) were as follows:
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Time
Occurance
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RBS( Ci/cc)
ABS ( Ci/cc)
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1500
Peak RBS value upon purge' termination . 1.6-1.75E-3(e)
1505
Peak ABS value
8.6E-4(m)
1635
Purge Restart
2.6E-4(e)
Reactor Building
1.1E-3(m)
1640
Af ter Purge Restart
8.0E-5(e)
1800
Stack sample
1.8E-6(m)
1840
Reactor Building sample
2.1E-4(m)
A Reportable Occurrence Report was submitted to plant management on February 12,
1981, who determined that the occurrence was not reportable pursuant
to the Technical Specifications. No personnel exposures in excess
of 10 CFR 20.103 limits occurred.
The licensee's evaluation of the
total release, summarized the releases by various pathways as follows:
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Date/ Time
Pathway
_C_uries released
2/11/81-1440-1450
Reactor Building Stack
19.1
2/11/81-1440-1635
Auxiliary Building Stack
85.8
2/11/81-1635-1800
Auxiliary Building Stack
4.63
2/11/81/1635-2230
Reactor Building Stack
_118
2/11/81-2230 -
Reactor Building Stack
13.8
2/12/81-0125
Total release
241.33
The licensee's failure to promptly notify the NRC of this occurrence
appears to constitute noncompliance with 10 CFR 50.72(a)(8) which
specifies in part that, "(a) Each licensee...shall notify the NRC
Operations Center as soon as possible and in all cases within one
hour by telephone of the occurrence of any of the following significant
events and shall identify that the event is being reported pursuant
to this section:...(8) Any accidental, unplanned or uncontrolled radioactive
release.
(Normal or expected releases from maintenance or other operational
activities are not included)."
(81-28-02)
7.
Procedures for Controlling Release of Effluents
The subject procedures included: AP-305-10 Radioactive Waste Disposal,
In Plant, Rev. 6 (6/15/81); AP-305-12A Shipments of Radioactive Materials
Offsite, Rev. 6 (6/19/81); AP-305-13 Environmental Releases of Liquid
Radioactivity Rev. 9 (6/30/81)_and AP-305-14 Environmental Releases-
of Airborne Radioactivity, Rev. 4 (5/6/80). Records of procedure
revisions-and reviews of changes and approval by the PRC are documented
and were exami6ed during the inspection. The changes to procedures
afforded the same or an improved level of control of radioactive releases.
Radioactive Liquid Waste Discharge Per_mits (1980 and 81),_Reactg
Building Atmosphere Release Permits (1981) and Waste Gas Decay Tank
Discharge Permits (1981) were examined.
No items of noncompliance were identified.
8.
Testing of Air Cleaning Systems
T.S. Appendix A, Sections 4.10, 4.11 and 4.12 identify three air cleaning
systems requiring testing of the HEPA and/or charcoal filters at refueling
intervals; Emergency Control Room Filtering System, Reactor Building
Purge Filtering System and_ Reactor Bui_1_ ding Emergency Filtering System.
Testing is performed by a' contractor using standard-test methods and
00P and Freon-112 as,the testing. materials.
In addition T.S. Appendix A,
Section 4.10 requires quarterl .operatingjtests of,the Emergency Control
Room Filtering System. Records of the required charcoal -and filter
tests from 1978 and required operating l tests from' January 1979 through
the date of the-inspection were~ examined.
No items of noncompliance were' identified.-
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Tests of Reactor Coolant Water Quality
LC0's and required testing is specified in T.S. Appendix A, Sections
3.1.4 Reactor Coolant System Activity, and Table 4.1-3 Minimum Sampling
Frequency. Records including reports of radiochemical analysis, gross
activity, tritium concentration, and chloride, oxygen and fluoride
concentratior.s were examined for the period February 26, 1979 - June 30,
1979 and December 24, 1981 - August 28, 1981. All results were within
specifications both as to limits and test frequency.
E determinations
while not required pursuant to note (5) of T.S. Appendix A, Table 4.1-3
were routinely performed at approximately semiannual intervals during
the period November 8, 1978 - May 28, 1981.
No items of noncompliance were identified.
10. Tests of Secondary System Activity
T.S. Appendix A, Section' 3.10 Secondary System Activity and Table
4.1-3 Minimum Sample Frequency, require gross _.activ_ity and iodine
analyses at weekly int (.rvals. Records of required' weekly, analyses were
examined for the period 1979 through September 10, 1981. Tests were performed
at the required frequency. The T.S. limit of 0.2ftCi/cc iodine activity
in the secondary coolant'was nat exceeded. The maximum value noted
was 3.4E-3pCi/cc at the time of the 1981 steam generator tube leak.
No items of noncompliance were identified.
11.
Sampling and Analysis Frequency
T.S. Appendix A, Table 4.1-3 identifies samples and analyses required
in addition to those specified in report paragraphs 9 and 10 above,
specifically, borated water storage tank, core flood tank, spent fuel
storage pool and cooling tower blowdown. Records of analytical results
for the years 1979 through 1981 were examined. The licensee's sampling
schedule exceeded the requirements of the T.S.
No items of noncompliance were identified.
12. Solid Radioactive Waste
T.S. Appendix B, Section 2.6.5, states requirements for solid waste
handling and disposal. The licensee presently disposes of solid waste
consisting of drums and boxes of compacted and urcompacted radioactive
waste. The licensee has on hand approximately 100 drums of used charcoal
from charcoal filters which are awaiting disposal following receipt
of guidance requested from NRC headquarters.
In addition, approximately
10 drums of mixed oil and water contaminated with Cs-134, 137 are
on hand. The licensee had received but not installed a new " Stock
Equipment Company" solid waste compactor which will provide substantially
increased compaction pressure.
The compactor incorporates a HEPA
filtered, 600 cfm exhaust system.
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The licensee determines the isotopic content of solid waste based on the
analysis of smear samples collected at the work site where-the waste
is generated or on smears or samples from solid waste being disposed.
Procedure AP 305-10.-Radioactive Waste Disposal In-Plant, Rev. 6,
6/5/81, includes calculation procedures for conversion of dose rate
measurements to curie contents based on the previously determined
isotopic composition.
The procedure provides shielding correction
factors for a number of different type of shielded and unshielded
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drums. The radioactive contents of all containers shipped offsite'
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were determined and records of individual containers and their contents
were maintained. The licensee uses the services of a contractor for
the solidification of liquid waste.
It is the licensee's intent to
maintain the policy of not releasing liquid radioactive waste to the
environment. This policy had been followed prior to the steam generator
tube failure of May 1981. During recovery from that event such releases
became necessary, however, the licensee plans to resume the practice
of liquid waste solidification and transfer. The last waste solidification
effort was conducted in the fall of 1980. The licensee has reported
in a timely fashion; solid waste shipments, volumes, principal isotoper
and total curie contents, semi annually and annually as required by
T.S.
The SCRA responsible for radioactive waste attended consultant
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provided seminars on radioactive waste management during 1980 and
1981.
No items of noncompliance were identified.
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13. Followup on Reportable Occurances
The licensee submitted Licensee Event Reports (LER) (81-30 & 81-36)
in accordance with T.S. Appendix B Section.5.6.2.C concerning occasions
when plant effluent exceeded pH limits specified in T.S. Appendix B,
Section 2.4.
These matters are considered closed (81-30-EO, 81-36-E0).
No items of noncompliance were identified.
14.
Inspection Report Followup-Items
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t3reathing Air Compresso'r
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IE Inspection Report No.' 50-312/80-19 identified concerns related
to the operation and maintenance of a MAK0 air.' compressor system.
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The subject compressor has been installed in a small ' separate building
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away from sources of air contamination. Procedure'AP-305-32, Operating
Procedure For The MAKO Air Compressor System (2/28/81), has been prepared
and approved.
Station. safety personnel, who maintain breathing air
supplies for fire response' personnel, and the ACRS-have.been trained
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on the system using the procedure. Training'of additional Chemistry-
Radiation Protection personnel will be conducted wh'en the training
program, now in preparatio'n, is complete. Maintenance of the compressor
is to be performed in accordance with the manufacturers recommendations.
The system incorporates a carbon monoxide monitor and permits either
direct or cascade cylinder charging. This matter is considered closed
(80-19-03).
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NUREG-0'578, TMI-2 Lessons Learned
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IE Inspection Reports Nos. 50-312/80-36 and 50-312/81-13 noted that
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one procedure, SP 201.12B Waste Gas System Leak Test Surveillance
Procedure, required by NUREG-0578 item 2.1.6.a Integrity of Systems
Outside Containment Likely to Contain Radioactive Materials, had not
been completed.
In accordance with licensee commitments the procedure
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was prepared and approved prior to start up following the fourth refueling
outage.
This matter is considered closed (81-13-02).
Independent Measurement
IE Inspection Report No. 50-312/81-16 reported the collection by the
inspector of a sample of diluted liquid waste released from the plant
for independent analysis. The applicable liquid waste batch from
which the sample was collected was incorrectly identified as LWR 81-14.
The release sampled was actually LWR 81-13 which was released between
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2302, June 1, 1981 and 0835, June 3, 1981.
The independent analysis showed that all identified nuclides were at
concentrations two to three orders of magnitude below the applicable
values of 10 CFR 20, Appendix B, Table II, Column 2.
In all cases the
licensee's values were more conservative than NRC measurements of
the same nuclide. This matter is considered closed (81-16-01).
No items of noncompliance were identified.
15.
Exit Interview
The inspector met with the-licensee representatives (denoted in paragraph 1)
at the conclusion of inspection on September:25 and October 9, 1981.
The scope of the inspection and the findings were sunmarized. The
possible items of noncompliance identified in the Notice of Violation
were discussed. With respect to the possible items of noncompliance
the licensee's representatives stated:
10 CFR 50.72(a)(8), the release of noble gas was in fact an expected
release due to a planned maintenance activity and was therefore
specifically exempt from the reporting requirements.
Technical Specification, Appendix B, Section 2.6.4.B., the specification
language did not necessarily lead to an interpretation requiring
continuous measurement and recordin'g of flow from the identified
stacks or vents only'to continuous measurement and ' recording
of gross radioactivity.
In addition, the licensee _ stated that the method ~nsed, e.g. , measurement
of flow at refueling intervals, was conservative.
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