ML20056D226
| ML20056D226 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/23/1993 |
| From: | Decker T, Mcneill N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056D205 | List: |
| References | |
| 50-348-93-12, 50-364-93-12, NUDOCS 9308050099 | |
| Download: ML20056D226 (12) | |
See also: IR 05000348/1993012
Text
~
~.-c
,
. .
,
a
6
@" "D
UNITED STATES
,#p
Q[o
WUCLEAR REGULATORY COMMISslON
I
-
g
y'
n
REGION li'
i
5
,$
101 MARIETTA STREET, N.W.
'*
's
ATLANTA, GEORGI A 30323
'
j'
.....
JUL 2 31993
Report Nos:
50-348/93-12 and 50-364/93-12
i
Licensee: Alabama Power Company
600 North 18th Street
Birmingham, AL 35291-0400
Docket Nos.:
50-348 and 50-364
Facility Name:
Farley 1 and 2
-!
I
Inspection Conducted:, June 21 - 25, 1993
Inspector:
i/
d h <' t
1.
7
3 d3
N. G. McNeill
g
Date' Signed
Approved by:
Y
/
k' i' :
7[5/73
T. R. Decker, Chief
Date' Signed
!
Radiological Effluents and Chemistry Section
i
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
.;
-i
SUMMARY
Scope:
?
This routine, announced in_spection was conducted in the areas of personnel-
training and qualification, plant water chemistry, process and effluent
monitors, Effluent Monitor Incident Reports as filed by the licensee with the
Resident Inspector, proposed zinc addition system changes to the Radiological
Effluent Technical Specifications, the new pressurized demineralyzer radwaste'
,
system, and liquid batch releases as performed during the inspection.
'
Results:
The licensee's Training of Chemistry Department and radioactive material
processing and shipping personnel satisfied Technical Specification (TS)
!
requirements (Paragraph 2).
Plant water chemistry was maintained well within limits specified by the TSs
(Paragraph 3).
The licensee had reported an Incident Report, relative to effluent releases,
,
to the Resident Inspector, one of which resulted in a Notice of Violation
'
(NOV) (Paragraph 4).
The licensee had in place a good program for the monitoring and evaluation of
.
potential gaseous effluents (Paragraph 5).
,
,
.
9308050099 930723
t
ADOCK 0500034G
O
PDR--
!
_
__
__ _. -. J
- .
i
.
.
!
!
The licensee _is considering a program to add zine to the primary coolant
system. This is a relatively new process and the progress will be followed by
5
Regional personnel (Paragraph 6).
P
The licensee had made several changes to the Radiological. Effluent Technical
'
Specifications in accordance with NRC Generic Letter 89-01 (Paragraph 7).
l
The Radwaste Handling group had installed a new pressurized demineralizer
,
system which appeared to offer improvements over the previous system
(Paragraph 8).
.
I
I
k
b
i
1
l
>
>
'
,
t
,
b
r
>
i
.
4
REPORT DETAILS
1.
Persons Contacted
,
Licensee Employees
W. Bayne, Safety Audit and Engineering Review (SAER) Auditor
- C. Black, Technical Manager
'
- S. Fulmer, Superintendent, Operations Support
0. Graves, Radwaste' Supervisor
,
- R. Hamm, Engineer, ' Chemistry and Environmental
- R. Hill, General Manager - Nuclear Plant
'
- J. Kale, Superintendent, Chemistry and Environmental
i
- R. Livingston, Environmental Supervisor
t
M. Mitchell, HP Superintendent
N. McGilvray, Nuclear Specialist I
,
C. Nesbitt, Manager, Operations
- J. Osterholtz, Technical Manager
- L. Stinson, Assistant General Manager of Operations
l
G. Terry, Safety Audit and Engineering Review (SAER) Auditor
'
R. Wood, Chemistry Supervisor
l
Other licensee employees contacted during this inspection included
,
engineers, operators, technicians, and administrative personnel.
Nuclear Regulatory Commission
- M. Morgan, Resident Inspector
- Attended exit interview
Acronyms and Initialisms used throughout this report are listed in the
last paragraph.
2.
Training and Qualification
(84750)
+
,
TS 6.4.1 requires the licensee to maintain a training program for the
plant staff to assure that the minimum education and experience
requirements of Section 5.5 of ANSI N18.1-1971 and Appendix A of
'
10 CFR 55 and the supplemental requirements specified in Sections A and
C of Enclosure 1 of the March 28, 1980 NRC letter to all licensees are
'
met before a person can be considered to be qualified to perform his
duties independently. The program shall include familiarization with
-
the relevant operational experience.
The inspector interviewed the licensee's Technical Training Supervisor
i
about the Training / Qualification Program in general and more
specifically in the areas of Chemistry and Environmental. There had
essentially been no changes to the training program since the last
inspection which would adversely affect the licensee's ability to
,
perform the requirements of the program. In particular the inspector
. - -
-
-
--
.
.
.
T
2
reviewed the qualifications of those personnel who were qualified to
perform Liquid Batch Release Permits and the required analysis of
i
samples relative to those permits.
,
The inspector noted that qualifications were kept up to date and
)
maintained for those personnel. The levels of experience for those
i
qualified ranged from two months to five years for each person's initial
qualification for performance of the two requisite procedures.
In
addition, the procedures required to be performed for certification were
1
reviewed. These procedures included:
)
Chemistry Qualification Record for CHM-705, " Prepare a Liquid
-
Waste Release Permit"
Chemistry Qualification Record for CHM-618, " Perform Gamma
-
Isotopic Analysis"
While the procedures appear to meet the minimum requirements for
operation of the system, some idiosyncracies of the system are not
addressed and appear to be learned more by the on-the-job operation of
.
the system.
These peculiarities of the operation of the gamma analysis
j
system are addressed in more detail in the following paragraph
concerning the aforementioned Incident Report.
No violations or deviations were identified.
3.
Plant Water Chemistry (84750)
TS 3.4.8 specifies that the concentrations of dissolved oxygen (D0),
1
chlorido, and fluoride in the Reactor. Coolant System (RCS) be maintained
below 0.10 parts per million (ppm), 0.15 ppm, and 0.15 ppm,
respectively. TS 3.4.9 specifies that the specific activity of the
primary coolant be limited to less than or equal to 1.0 microcurie / gram
(uCi/g) dose equivalent iodine (DEI).
These parameters are related to corrosion resistance and fuel integrity.
The oxygen parameter is based on maintaining levels sufficiently low to
prevent general and localized corrosion. The chloride and fluoride
parameters are based on providing protection from halide stress
corrosion. The activity parameter is based on minimizing personnel
radiation exposure during operation and maintenance.
Pursuant to these requirements, the inspector reviewed tabular daily
summaries which correlated reactor power output to chloride, fluoride,
and dissolved oxygen concentrations of the reactor coolant for the
period of August 31, 1992 to the present date, and determined that the
parameters were maintained well below TS limits.
Typical values for D0,
chloride, and fluoride were less than 10 parts per billion (ppb), less
than 20 ppb, and less than 10 ppb, respectively, for both units.
_
_
-
.
!
'
.
,
3
'
The inspector concluded that the Plant Water Chemistry was being
maintained well within the TS requirements and that the frequency of the
)
sampling was also being met.
,
No violations or deviations were identified.
4.
Process and Effluent Monitors (84750)
TSs 3/4.3.3.1, 3/4.3.3.10, and 3/4.3.3.11- define the operation and
surveillance requirements for monitors of radioactive-(or potentially
,
'
radioactive) streams. This instrumentation is provided to monitor and
control the releases of radioactive materials during normal and abnormal
plant conditions as well as in effluents during effluent releases. The
alarm / trip setpoints for the effluent are calculated in accordance with
the procedures in the Process Control Program (PCP) to ensure that the
alarm / trip will occur prior to exceeding the limits of 10 CFR 20. The
alarm / trip setpoints for the process monitors are specified by the TSs.
An' Incident Report ~(IR) was received by the Resident Inspector and was
reviewed by the inspector upon arrival at the site. The IR is discussed
as follows:
IR 1/93/97
" Number 2 Waste Monitor Tank released on 4/15/93
-
without a Pre-Release Analysis"
In this incident, a sample was counted for dissolved ionic and
'
particulate isotopes to be used for dose calculations required for
preparation of the Liquid Waste Release Permit (LWRP). Additionally,
the same sample was used to determine dissolved gas content which is
required by TSs once a month. The sample was analyzed once to produce a
l
gamma spectrum of ionic, particulate, and gaseous nuclides and a listing
,
l
of associated Principle Gamma Emitters Lower Limits of Detection (LLD)-
I
for the nuclides. In order to obtain a separate printout of gases for
the monthly TS dissolved gases, the technician reanalyzed the spectrum
,
l
using a library which identified only gases. The technician
l
inadvertently coded the computer to automatically supersede the old
gamma spectrum with the new " gas only" spectrum. When the Computer
l
Generated LWRP was prepared, the computer calculated doses for the
4
release based on ZERO particulates.
The technician reviewed and signed the LWRP allowing the tank contents
to be released without an accurate calculation of the dose at the time
,
!
of release. Both the pre-release LWRP and the post-release LWRP were
reviewed by Counting Room personnel.
Both reviews failed to disclose
'
l
the error. Upon signing off the Surveillance, personnel in the Counting
Room noticed disparity between the reported activity and the LLDs
listed. Notifications were made to the Shift Supervisor and the On-Call
l
Chemistry Supervisor. Subsequently, the dose calculations were
{
corrected and updated.
i
$'
-
l
!
l
4
-
,
i
A Root Cause Investigation perforraed by the licensee shortly after the
,
incident identified the abovementioned facts and other factors involved
l
in the release. Several factors identified raised concern with the
1
operation of the system and the routine Release Permit preparation. The
~
procedures do not exclude the use of SRAN (Sample Reanalysis), which was
responsible for superseding the previous spectrum, nor do_ they provide
'
cautions or guidance explaining the possible problem. The procedures
also do not specifically address the sampling and analysis of monthly
dissolved gas samples. The procedure is also misleading in that it
directs the prompt " Transfer to 0DCM" be answered "YES" for Waste
!
Monitor Tanks and it does not exclude this statement for SRAN as it
applies to analyzing monthly dissolved gas samples.
It was also
,
determined that seteral different methods were used to complete the
monthly Waste Monitor Tank surveillances which raises the concern that
the barrier for the Counting Room Work Practices is weak.
To further analyze the steps involved in the Release Permit procedure,
the inspector observed another routine Liquid Radioactive Waste Release
,
Permit (LWRP #2-93-230), a Unit 2 Waste Monitor Tank release, being
performed. The procedures used included:
'
FNP-0-CCP-212, " Liquid Waste Release Program"
-
FNP-0-CCP-647, " Operation and Calibration of the Multichar.nel
-
Analyzer Systems"
FNP-0-CCP-214, " Administrative Management of Radioactive Liquids
-
in FNP Systems"
FNP-0-CCP-714, " Waste Monitor Tank Surveillance"
-
1
FNP-0-AP-5, " Surveillance Program Administrative Control"
l
-
The primary procedures involved in the incident as related above are
FNP-0-CCP-212 and FNP-0-CCP-647.
Some procedural changes were being
'
instituted for these two titles during the time of the inspection. The
licensee also formed a Task Force to look into the incident and
prevention of further recurrence as the inspedian was progressing.
While the corrective actions taken by the licensee are a start to
prevent the recurrence of the event and subsequent reanalysis showed
that no limits were exceeded, the fact remains that the release was made
without proper identification of all radionuclides. TS 4.11.1.1.1
requires that the radioactivity content of each batch of radioactive
liquid waste be determined by sampling and analysis in accordance with
Table 4.11-1.
Table 4.11-1 states that all principal _ gamma emitters
(including particulates) be identified.
This event is furthermore very similar to a previous Incident Report in
which the same analysis system and procedures misidentified Cobalt-60 in
a liquid release, although different procedural steps were involved.
)
i
.
-
-
i
!
i
5
The previous incident, Incident Report No. 2/92/282, NRC Report No. 92-
32, resulted in the identification of a Non-cited Violation (NCV). The
,
subsequent incident occurred within six months of the first.
On the basis of this review of the facts surrounding the
,
misidentification of particulate radionuclides in the Liquid
Radioactive Waste Release Permit one NOV was identified.
One violation was identified.
,
5.
Gaseous Effluent Sampling (84750)
l
TS 3.121.1.1 states the requirements for liquid effluent
concentrations. TSs 4.11.1.1.1, 4.11.1.1.2, and 4.11.1.1.3 define
l
the surveillance requirements for the associated sampling and
analysis program. TSs 3.11.2.1, 3.11.2.2, and 3.11.2.3 state
-
requirements for dose rates due to radioactive materials and noble
gases released in gaseous effluents from the site, as well as dose
i
rates from radioiodines and radioactive materials in particulate
form and radionuclides with half-lives greater than eight days in
gaseous effluents released.
TSs 4.11.2.1, 4.11.2.2, and 4.11.2.3
,
'
define the surveillance requirements for dose rate calculations.
The inspector observed the activities associated with Unit 2
Weekly Gaseous Updates. These are sampling procedures performed
on a weekly basis and are intended to sample for gases at
potential radiological effluent points. The sampling stations
included: the Containment Purge Vent sampling point (Air Filter
.
Cartridge, Particulate Filter, one liter Gas Marinelli, and a
Tritium sample); the Vent Stack sample (Air Filter Cartridge and
l
Particulate Filter); and the Steam Jet Air Ejector-Turbine
Building sample (Air Filter Cartridge and Particulate Filter).
The procedures which were followed were:
Chemical-Radiochemical Control Procedure, FNP-2-CCP-643, " Sampling
-
Points for Potential Radiological Effluents"
Surveillance Test Procedure, FNP-2-STP-720, " Containment Purge
-
Surveillance"
Surveillance Test Procedure, FNP-2-STP-716, "rndenser Steam Jet
-
Air Ejector Surveillance"
Surveillance Test Procedure, FNP-2-STP-728, " Plant Vent Stack
-
Surveillance"
.
These procedures specified where and how to taka samples as well as the
steps required to correctly handle the samples and sampling hardware.
The inspector observed the technicians as the) obtained the sample and
noted that good technique was used. The tech sicians took the samples
directly to the laboratory to be analyzed.
,
..
._
.
-
_
.
.
6
)
The technicians conducted their activities in a competent, professional
l
manner. All technical and procedural aspects of the procedures were
I
followed and a high degree of proficiency was shown by the technicians
performing the collections.
i
The inspector concluded that the licensee's gaseous effluent sampling
program was adequate to assure that gaseous releases were within
regulatcry limits.
No violations or deviations were identified.
6.
Proposed Zinc Addition System (86750)
!
The inspector was notified during the inspection that the licensee was
studying the possibility of instituting a zinc injection system for the
Primary Reactor Coolant System. The licensee was discussing the
!
potential benefits of the proposed Zinc Addition and Monitoring System
!
(ZAMS) with the vendor. The system and the associated proposal
!
submitted _ outline the potential benefits of adding low concentrations of
!
zinc (about 40 parts per billion) added as zinc borate to the primary
reactor coolant of a Pressurized Water Reactor (PWR).
l
The potential benefits are listed as:
reduced general corrosion rates
of most materials of construction, reduction of both initiation and
propagation of Primary Water Stress Corrosion Cracking (PWSCC) in
'
Alloy 600 and other primary system materials, and reduced radiation
levels due to reduced corrosion product transport. The possible problems
,
associated with Zinc-65 radioactivity, as experienced in Boiling Water
.
Reactors (BWRs), are addressed in the proposal.
The lesser radiological
hazards of th Zinc-65 as opposed to the Cobalt-60 and Cobalt-58 are key
in the rede tion of potential radiological hazards.
!
Tha Ustem is now being considered by the licensee and-the possible
cenefits and drawbacks of implementation are being reviewed by
management. The licensee was notified that the progress on this
proposal would be reviewed in future inspections and would be followed
i
'
with interest.
No violations or deviations were identified.
!
7.
Radiological Effluents Technical Specifications (84750)
i
The licensee submitted a license amendment request regarding
!
Radiological Effluent Technical Specific 3tions (RETS) changes. The
i
i
request concerned implementation of the new 10 CFR 20 requirements as
well as the reporting requirements for the TSs which contained
references to the Semiannual Radioactive Effluent Release Report. The
NRC amended the regulations as noticed in 57 FR 39353, dated August 31,
!
1992. Specifically,10 CFR 50.36(a), regarding TSs on effluents from
.l
nuclear power reactors, was concerned with the frequency of reporting
i
!
!
.
-
. .
.
-
.
--
. -__.
..
..
7
the quantity of each of the principal radionuclides released to
unrestricted areas in liquid and gaseous effluents.
The frequency
requirement was changed from semiannual to annual.
The inspector reviewed the proposed changes as submitted by the licensee
concerning the Unit I and Unit 2 TSs.
Changes involved submittal of an
Annual Radioactive ' Effluent Release Report in lieu of the current
semiannual report.
The inspector concluded that there were no significant changes to the
report other than the frequency of the submittal.
No violations or deviations were identified.
8.
Radiological Waste Handling and Processing (84750)
10 CFR 71.5(a) requires that each licensee who transfers licensed
material outside the confines of its plant or other place of use, or who
delivers licensed material to a carrier for transport, shall comply with
the applicable requirements of the regulations appropriate to the mode
of transport of the Department of Transportation (DOT) in 49 CFR, Parts
170 through 189.
Pursuant to these requirements, the inspector reviewed the licensee's
activities affiliated with these requirements, to determine whether the
licensee effectively processes, packages, and stores radioactive
materials.
Of particular interest was the replacement of the SEG Transfix
Pressurized Demineralizer System which had been used for the last six
months of 1992. This system utilized six 20 ft* vessels with a cuno
roughing filter upstream and an optional micro filtration filter skid
downstream of the vessels. The system appeared to perform well except
l
when colloidal sized particulates were present.
In those instances the
front mixed charcoal filter media did not work as well as expected.
This resulted in higher than expected radwaste volumes for filters and
reduction of the flos rate yielding much lower radwaste volumes being
l
processed.
A CNSI Pressurized Domineralizer System was installed in March 1993. The
new system utilizes a chemical treatment process called polyelectrolyte
injection in the influent stream. This process coagulates small
,
'
particles into larger particles (floculation) thus enhancing filtration.
The new vessels are 50 ft* in size.
1he first is va:sclc, with
charcoal, act as a deep bed filter. The third vessel. contains 42 ft* of
mixed bed organic resin to remove ionic components from the waste
stream. The fourth and final vessel is available to add ion specific
media as needed. The system also has a top sluice capability which
should enable the upper portion of the charcoal bed in service until the
media is fully utilized. The licensee is currently evaluating the
second system.
.
.
8
The licensee stated that a decision on a permanently installed system
will be made in the future based upon the performance of the current
system.
The inspector concluded that the licensee is taking a proactive and
thorough approach to radwaste handling and processing. The inspector
informed the licensee that the performance of the system will be
reviewed in future inspections.
No violations or deviations were identified.
9.
Exit Interview
The inspection scope and results were summarized on June 25, 1993, with
those persons indicated in Paragraph 1.
The inspector described the
areas inspected and discussed the inspection results, including likely
informational content of the inspection report with regard to documents
and/or processes reviewed during the inspection. The licensee did not
identify any such documents or processes as proprietary other than the
relative prices on the radwaste handling systems as outlined in
Paragraph 8.
One NOV 93-12-01 was identified. Dissenting comments were
not received from the licensee.
10.
Acronyms and Initialisms
ANSI - American National Standards Institute, Inc.
C&E - Chemistry and Environmental
CFR - Code of Federal Regulations
Ci - curie
DEI - Dose Equivalent Iodine
DO - Dissolved Oxygen
DOT - Department of Transportation
FNP - Farley Nuclear Plant
FSAR - Final Safety Analysis Report
IR - Incident Report
1 - liter
LLD - Lower Level of Detection
LLW - Low Level Radwaste
LWRP - Liquid Radwaste Release Permit
mg - milligram
mrem - millirem
NCV - Noncited Violation
No. - Number
,
NRC - Nuclear Regulatory Commission
ODCM - Offsite Dose Calculation Manual
ppb - parts per billion
ppm - parts per million
PWSCC - Primary Water Stress Corrosion Cracking
.
QR - Qualification Records
.
. . . -
.
.m,
m
.
_.
_
.
.
._
_
_
_ .._ _ - _ _._ - . .___-- _ ___ .
l
-
..
.
9
RETS - Radiological Effluent Technical Specifications
'
TS - Technical Specification
uCi - micro-Curie (1.0E-6 Ci)
.
ZAMS - Zine Addition and Monitoring System
i
l
l
?
l
'
l
i
l
1
l
l
l-
!
l
l
l
l
l.
.
l
-
F
+ + + + = -
7
-
- -rw
3
m
.
r-
F
ge
1
eae-
.
'
l.
F
l
7,c4omm
SPECIFY CATEGORY (Check One) Page _ of __.
u s wucuan noui.4 tom e--
i
-~ ~ ~= aa= "
- --r'-"as*-o
IFS Data Entry Form
"
' * ' * *
Revowed er:
h 8*888*'t WS opte 2
LEM home ys optean si
Daw Q hthh
!*1 FM:
E.mer u n wwn r
mob
La ist om:
Site /Name'
u.a.o
a...e =~ as op- e.
geoort Tranammal Date. ktMr N
{
C""' EVM:
'
f
- esponemeOrg Code:lM IIlI
Report End Date: dihtM
Repon:
Leas inspecer:
Report NBR
Docket MR
' Docket Nome
13 -ID
60'N
A
'
3 -1
50-364
B
C
Uocate ? (Y/N): Y
Openec tR/LER/P21 LOG /lFS Nurneer:
'
- Sequence NBR: 001
Item Type: \\/ t 0
" Severity: TC
" Supplement: 4,
Status
- UPD t/R ' Prof. Clossout ' Actual Clomeout
to CFR
Tie Down
i
A-
c
o ,zs,43
t
,
r
l
8
!
9 ,_
!
!
C
!
! ,,.
I
!
Titie: FAttarth 40 Ink 4tfiN A(+ OA010AltAbtADM (N
A- vvn 06tf#4sser ,ecier.weg
'Cteseout Org: 7M'6
- Closeout EMP: MN
'Cornacs EMP:M78'> ' Procedure: MM6
'Funen Area:
,
'Cause CD:
3, _,,,,,.
"EA Nurnber:
"NOVMNC issue Date:
/
/
SkN N MA N lb DI M ID M N MM M M E_DW NOI @ 6 N Ib M M d
Text:
TA/SlOALktG4 %%ILAvL 'fo PektotL4 HC\\/ ' Foil %% MGatD dh4%
4244A% *PIGEMrf hyAIAS I6
Update? (Y/N):
Openeo IR/LER/P211.OG/1FS Numcor:
'" Sequence NBR:
ttem Type:
" Severity:
" Supplement:
.
Status
'UPD 1/R
'Prol. Cloecout ' Actual Conecut
10 CFR
La
Tae Down
A
_I
I
I
I
E
I
I
I
I
C
I
!
!
!
True:
(55 character werg
- Qoseout Org:
' Closeout EMP:
'Cornact EMP:
' Procedure:
'Funen Area:
.
- Cause CD:
"EA Nurnber:
"NOV/NNC lssue Date:
I
/
{
-
_ .._
Tert:
- Opeonal Feids.
" Severity, Suppement, and NOWNCC orty a& lor Vlotators: EA Nutriber onty aWmNa lor Apparent Vlotetors.
1
1
-- sequence NBR is rd appleatne lor dochet renameP21,11R, or forH$ocket sotated hema.
-
ITDiS CONTINUED 7 (YlN): N
.
.
-
-
.
_
._
-
-.
-