ML20056D226

Insp Repts 50-348/93-12 & 50-364/93-12 on 930621-25. Violations Noted.Major Areas Inspected:Personnel Training & Qualification,Plant Water Chemistry & Process & Effluent Monitors

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: ML20056D199 ML20056D214 ML20056D226
References
50-348-93-12, 50-364-93-12, NUDOCS 9308050099
Download: ML20056D226 (12)

See also: IR 05000348/1993012

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JUL 2 31993

Report Nos: 50-348/93-12 and 50-364/93-12

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Licensee: Alabama Power Company

600 North 18th Street

Birmingham, AL 35291-0400  ;

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8  !

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Facility Name: Farley 1 and 2 -!

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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 .;

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SUMMARY

Scope:  ?

This routine, announced in_spection was conducted in the areas of personnel- I

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). ,

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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).

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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).

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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) +

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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

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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.

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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: )

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Chemistry Qualification Record for CHM-705, " Prepare a Liquid

Waste Release Permit"

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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.

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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 I

as follows:

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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

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the monthly TS dissolved gases, the technician reanalyzed the spectrum l

l using a library which identified only gases. The technician

l inadvertently coded the computer to automatically supersede the old

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gamma spectrum with the new " gas only" spectrum. When the Computer

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

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corrected and updated.

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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

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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: '

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FNP-0-CCP-212, " Liquid Waste Release Program"

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FNP-0-CCP-647, " Operation and Calibration of the Multichar.nel

Analyzer Systems"

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FNP-0-CCP-214, " Administrative Management of Radioactive Liquids

in FNP Systems"

- FNP-0-CCP-714, " Waste Monitor Tank Surveillance" l

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FNP-0-AP-5, " Surveillance Program Administrative Control" l

The primary procedures involved in the incident as related above are

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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.  !

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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:

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Chemical-Radiochemical Control Procedure, FNP-2-CCP-643, " Sampling

Points for Potential Radiological Effluents"

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Surveillance Test Procedure, FNP-2-STP-720, " Containment Purge

Surveillance"

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Surveillance Test Procedure, FNP-2-STP-716, "rndenser Steam Jet

Air Ejector Surveillance"

- Surveillance Test Procedure, FNP-2-STP-728, " Plant Vent Stack

Surveillance"

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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.

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The technicians conducted their activities in a competent, professional l

manner. All technical and procedural aspects of the procedures were

followed and a high degree of proficiency was shown by the technicians I

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)

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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

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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

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with interest.

No violations or deviations were identified.

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7. Radiological Effluents Technical Specifications (84750) i

The licensee submitted a license amendment request regarding  !

Radiological Effluent Technical Specific 3tions (RETS) changes. The i

request concerned implementation of the new 10 CFR 20 requirements as i

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  ;

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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

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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

processed.

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A CNSI Pressurized Domineralizer System was installed in March 1993. The

new system utilizes a chemical treatment process called polyelectrolyte

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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.

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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

, NOV - Notice of Violation

NRC - Nuclear Regulatory Commission

ODCM - Offsite Dose Calculation Manual

PCP - Process Control Program

ppb - parts per billion

ppm - parts per million

PWSCC - Primary Water Stress Corrosion Cracking

. QR - Qualification Records

RCS - Reactor Coolant System

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RETS - Radiological Effluent Technical Specifications

TS - Technical Specification

uCi - micro-Curie (1.0E-6 Ci) .

ZAMS - Zine Addition and Monitoring System i

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