IR 05000423/1985042

Insp Rept 50-423/85-42 on 850805-09.No Violations Noted. Major Areas Inspected:Chemistry & Radioactive Effluent Control Programs

ML20132D833
Person / Time
Site:	Millstone
Issue date:	09/20/1985
From:	Shanbaky M, Struckmeyer R, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20132D815	List: IR 05000423/1985042 ML20132D811
References
50-423-85-42, NUDOCS 8509300305
Download: ML20132D833 (15)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-42 Docket N License N CPPR-113 Category C

. Licensee: Northeast Nuclear Energy Company

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P.O. Box 270

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Hartford, Connecticut 06101

, Facility Name: Millstone Nuclear Power Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conducted: August 5-9, 1985

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Inspectors: 7 d[ b wp- 9 7 5 R. K. Struckmeyer, P di gion Specialist dat'e

$ $ {LY, ., - 917f85~~

A. eado ,~ a n Specialist date Approved by: . s [ W~

M./. Shanbaky, Chi'et, PWR dite '

Madiation Safety Section Inspection Summary: Inspection on August 5-9, 1985 (Recort No. 50-423/85-42)

Areas Inspected: Routine, announced, pre-operational inspection of the chemis-try and radioactive effluent control programs. Areas reviewed included: organ-ization and staffing, training and qualification program, facilities and equip-ment, and plans and procedures. The inspection involved 76 inspector hours on-site by two NRC region-based inspector Results: No violations were identifie ..

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DETAILS Individual Contacted

• G. Basilesco - Engineer, Stone and Webster Engineering Company R. Beckman - Instrument Specialist M. Brown - I&C Supervisor

• F. Casella - NRC Resident Inspector G. Dodge - Service Engineer, KAMAN Instruments

• R. Enoch - Assistant I&C Supervisor

" Gentry - Assistant Startup Supervisor R. Gresbach - Startup Engineer T. Lane - Startup Engineer

• R. Langer - Assistant Chemistry Supervisor D. Miller - Startup Manager D. Powers - Startup Engineer T. Rebelowski - NRC Sr. Resident Inspector

• Romberg - Station Superintendent

• Sachatello - Radiation Protection Supervisor A. Stengel - Startup Engineer H. Thompson - Startup Engineer M. Venable - Startup Engineer

• J. Waters - Chemistry Supervisor

• Denotes those present at exit meeting on August 9, 1985. Status of Previously Identified Items (0 pen) Inspector Followup Item (50-423/85-19-01): Status of Radiation Monitoring System (RMS). All but four monitors have been turned over, and most have been field tested. Integrated system (Phase II) testing has not yet begu Monitor status is given in Attachment 1 to this repor (0 pen) Inspector Followup Item (50-423/85-19-02):. Status of RMS pro-cedure developmen Development of these procedures is continuin Their status is given in Attachments 2 and . Organization and Staffing The inspectors reviewed the licensee's organization with respect to staffing and management structure in the areas of chemistry and radio-active effluent control. The licensee's chemistry department is respon-sible for in plant chemistry and radiochemistry, as well as for analyses related to liquid and gaseous radioactive effluents. The organization parallels that of Units 1 and An Assistant Chemistry Supervisor for Unit 3 reports to the Station Chem-istry Supervisor, who is responsible for all chemistry at Units 1, 2, and 3. The department also has a chemist and ten technicians, and plans to use five contractor technicians during start-up.

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. 3 The inspectors reviewed the qualifications of Northeast Nuclear Energy Company (NNECO) chemistry technicians, and noted that one individual had not met all the criteria of ANSI N18.1. The licensee stated that this had been identified by an internal QA audit, and that appro,priate restrictions had been placed on the technician, prohibiting him from doing radiochem-ical analyses as prescribed by the surveillance requirements of Technical Specifications, untti he becomes qualified to all of the ANSI N18.1 cri-teri The inspectors reviewed the results of an INPO audit conducted April '8-12, 1985, and noted a recommendation that NNECO develop and im-plement a training and qualification program for chemistry personne Since that time the licensee has made plans for conducting a training program for NNECO chemistry technicians, and has hired three trainers specifically to conduct this program. These individuals are developing the lessons plans and course materials. Some specialized training has already been provided to technicians identified (by testing) as lacking certain skills (e.g., math), but plans for training of contractor tech-nicians have not yet been formalize Training of NNECO chemistry tech-nicians, and training and qualifications of contractor technicians, will

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be reviewed in a subsequent inspection (50-423/85-42-01).

The licensee's Instrumentation and Controls (I&C) department is responsi-ble for the procurement, calibration, and maintenance of all process, effluent, and radiation monitors in the facility. The department is headed by the I&C Supervisor, who reports to the Unit 3 Superintenden An Assistant I&C Supervisor has been assigned the primary responsibility for the radiation monitor calibrations and development of procedure Within the department there are twenty-four permanent technicians, and an additional twenty-five contractor technicians will be used during start-up operation The licensee stated that the NNECO (permanent) technicians have an average of 9h years experience, and that approximately one-third come from the Navy, one-third from technical schools, r.nd one-third from in-dustry. The contractor technicians have or will have a minimum of f.ive years experience, and will be required to pass a four-hour written exam-ination administered by the licensee before being permitted to work at the facility. The training and qualifications of NNECO and contractor I&C technicians will be reviewed in a subsequent inspection (50-423/

85-42-02).

A technician provided by the RMS vendor is currently on-site and will remain through start-u . Facilities and Equipment The inspectors toured the facility including the chemistry laboratory, the counting room, the primary system and secondary system sampling stations, the liquid radwaste treatment system, the gaseous radwaste handling sys .

tem, liquid and gaseous process and effluent monitors, and various ventil-

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atton systems (with emphasis on the HEPA and charcoal filtration hous-ings). Construction has been completed on all of these systems, and they have been turned over from the contractor to the licensee. The inspectors noted that virtually all necessary equipment for the Chemistry lab and counting room was installed and operable. The Ge(Li) detectors had been calibrated, but procedures for.using them have not been completed. The primary and secondary sampling stations have been installed, and some component (Phase I) testing has been performed. The liquid and gaseous radwaste systems and the ventilation systems are also undergoing tests of various components. The inspectors accompanied licensee personnel on walk-downs of portions of these systems to verify that components were in-stalled as described on Piping and Instrument Diagrams (P& ids). The filter housings are ready to. receive the various filtration components (HEPA, charcoal, and pre-filters), but these will not be installed until all painting and use of chemicals have been completed in areas served by these ventilations systems, in order to prevent their contamination prior to start-u The status of these systems will again be reviewed during a subsequent in-spection (50-423/85-42-03).

4.1 Radiation Monitoring System The Radiation Monitoring System (RMS) was reviewed in NRC Inspection Re-port 85-19, which included a brief system description and reported the status in terms of operability and testing of equipment, and development of procedures. The licensee's Instrumentation and Control (I&C) group has responsibility for the testing, calibration, and maintenance of the RMS, and for development of surveillance procedure The purpose of this review of the RMS was to update the status of the licensee's progress in making the system operational, and to review mon-itor calibration procedures and dat Operability As of August 7, 1985, the operational status of the RMS was as depicted in Attachment Most process, effluent, and area radiation monitors have been installed and tested individually; however, the integrated system tests (Phase II) have not yet been performed. The inspectors stated that the status of the RMS would again be examined during a subsequent inspec-tion (50-423/85-19-01).

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Calibration The inspectors reviewed the following procedures and calibration data to assess the adequacy of the licensee's RMS monitor calibra-tion program:

GPIC 20.4, " Initial Startup of the KAMAN Liquid Radiation Monitor".

GPIC 20.03, " Initial Startup of the KAMAN Particulate and Gaseous Radiation Monitor".

GPIC 20.08, "KAMAN Science KMA HR RAD Monitor".

KAMAN Instrumentation Procedure 18-60, " Transfer Calibration".

Loop Calibration Report (LCR) 3LWC-055, " Liquid Regenerant Dis-charge to Circulation Water Control and Alarm".

LCR 3HVQ-049, "ESF Building Ventilation Outlet Radiation Monitor".

LCR T3319CIE29, "LWC Radiation Monitor.".

LCR 3SSR-008, " Steam Generator Blowdown Monitor".

The licensee's calibration of the RMS monitors is performed by counting a secondary radioactive source which is provided by the vendor. The detec-tor response to the source is then related to an energy dependence cali-bration conducted by.the vendor by multiplying response by a derived cal-ibration factor. The original energy dependence calibration conducted by the licensee is performed on a " generic" or " type" detector, not on the detector provided to the license The calibration documentation listed above was complete and work was per-formed in compliance with licensee procedures. The inspectors noted, however, that licensee calibration procedures contained no acceptance

• criteria to evaluate detector response to the source. The response is used in a ratio to derive a new calibration factor to link detector re-sponse with the primary energy dependence curv The inspectors stated that apparently no evaluation of detector efficiency was being performed in the calibratio The licensee stated that detector efficiency was being evaluated by per-forming the three point linearity check included in the calibration pro-

-cedures. Additionally, for the ion chamber type area radiation monitors, a " keep alive" check source is included with the monitor and response to this source is evaluated by the license _

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The inspectors noted that no evaluation or accept / reject criteria for ion chamber response to the " keep alive" source was currently included in the calibration procedure. The inspectors also noted that a linearity check by itself may not be an adequate indicator of detector response; detector efficiency could decrease linearly and not be noted by the license The adequacy of the licensee's RMS calibration procedures is considered unresolved pending additional investigation of this area (50-423/85-42-04).

5.0 Plans and Procedures The inspectors discussed with the licensee the procedures for pre-oper-ational testing of liquid and gaseous radwaste systems, ventilation systems, and radiation monitoring system. The inspectors noted that virtually all procedures for individual component (Phase I) testing had been written and approved, and that roughly half of the prescribed tests had been performed. Procedures for integrated system (Phase II) testing have been written and approved for the following systems: primary system sampling station, gaseous radwaste processing system and ventilation sys-tems (for those which may contain radioactivity during normal operations).

Those under development include: liquid radwaste system, charcoal and HEPA filter tests, and radiation monitoring syste Approximately 70 percent of chemistry procedures, including those for most laboratory analyses, liquid and gaseous tritium sampling, primary and secondary sample sink operation, and liquid waste sample sink oper-ation have been written and approved. Chemistry is also responsible for developing and implementing about 24 to 26 Surveillance Procedures, all of which were still in various stages of development at the time of this inspectio The inspectors reviewed the current status of Radiation Monitoring System (RMS) surveillance procedures, for operation, testing, and calibration of RMS units that are expected to be addressed by Technical Specification ~ Attachments 2 and 3 depict the status of these procedures as of August 8, 198 ~The status of the following procedures will continue to be followed in subsequent inspections of this area:

Chemistry analytical and surveillance procedures (50-423/85-42-05).

• RMS surveillance procedures (50-423/85-19-02).

• Phase II start-up procedures for liquid and gaseous radwaste systems and ventilation systems (50-423/85-42-06).

• Filtration system (HEPA and charcoal) surveillance testing (50-423/

85-42-07).

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6.0 Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on August 9,1985, and summarized the purpose and scope of the inspection and the inspection finding At no time during this inspection was written material provided to the licensee by the inspecto _

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a ATTACHMENT 1 Radiation Monitoring System Status Instrument Turned Field Communications Number (Mark No.) Over Tested Loop Established Comments

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Ventilation / Gas Monitors 3HVRRE10A/B 1-2 mos. before testing 3HVRRE19A/ mos. before testing 3HVRRE11A/B X X X '

3HVRRE12A/B X X X 3HVRRE13A/B X X X 3HVRRE14A/B X X 3HVRRE15A/B X X X

, 3HVRRE16A/B X X X 3HVRRE17A/B X X X 3HVRRE18A/B' X X 3HVCRE91A/B X X Communications estab-lished in 1 port only

- 3CMSRE22A/B X X I

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3HVZRE09A/B Mounting plates missing 3HVQRE49A/B X X f

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ATTACHMENT 1, Continued Radiation Monitoring System Status Instrument Turned Field Communications Number (Mark No.) Over Tested Loop Established Comments Liquid Process Monitors 3CHSRE69 X X 3CCPRE31 X X 3CNARE47 X X Conductivity meter failed 3DASRE50 X X 3LWSRE70 X X 3LWCRE65 X X X 3CNDRE07 X X X 3SSRRE08 X X 35WPRE60A/B X X 3GWSRE48 3ARCRE21 X X 3MSSRE75 X X 3MSSRE76 X Connector failed, to be replaced 3MSSRE77 X X Communications estab-lished in 1 port only 3MSSRE78 X X Communications estab-lished in 1 port only 3MSSRE79 X Connector failed, part on order i

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ATTACHMENT 1, Continued Radiation Monitoring System Status Instrument Turned Field Communications Number (Mark No.) Over Tested Loop Established Comments Area Monitors 3RMSRE16 X X 3RMSRE17 X X X 3RMSRE18 X X X 3RMSRE19 X X X 3RMSRE20 X X l 3RMSRE21' X X X 3RMSRE22 X X X Temporary fix, part on order 3RMSRE24 X X X 3RMSRE25 X X X 3RMSRE28 X X X 3RMSRE29 X X X 3RMSRE31 X X Communications estab-lished in 1 port only 3RMSRE32 X X Communications estab-lished in 1 port only 3RMSRE33 X X Missing part 3RMSRE34 X X 3RMSRE35 X X Communications estab-lished in 1 port only 3RMSRE36 X X X 3RMSRE37 X X X

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ATTACHMENT 1, Continued i Radiation Monitoring System Status Instrument Turned Field Communications Number (Mark No.) Over Tested Loop Established Comments Area Monitors 3RMSRE04* X 3RMSRE05* X 3RMSRE41* X 3RMSRE42* X 3RMSRE01 X X Communications estab-lished in 1 port only 3RMSRE02 X X Communications estab-lished in 1 port only 3RMSRE03 X X Communications estab-lished in 1 port only 3RMSRE06 X X X 3RMSRE07 X X' X 3RMSRE08' X X X 3RMSRE09 X X X 3RMSRE10 X X X

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3RMSRE11 X X X 3RMSRE12 X X X 3RMSRE13 X X X 3RMSRE14- X X X 3RMSREIS- X X 3RMSRE38 X X X 3RMSRE52 X

• Category 1E Monitors

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ATTACHMENT II RMS Surveillance Procedure Summary Procedure Number Monitor Identification Status / Comment 3449B01 3HVR-RE19A/B SLCRS Part/ Gas Cal. Pro Draft 3450F01 3CND-RE07 Waste Neut. Sump Rad. Monitor Ca Draft 3450J01 3LWC-RE65 Regen. Evap. Rad. Monitor Ca Draft 3450K01 3SSR-RE08 S/G Blowdown Rad. Monitor Ca Draft 3449J01 3HVQ-RE49 ESF Part & Gas Rad. Monitor Ca Draft 3449H01 3RMS-RE04/05 Cont. HR Inter. 51'4" CTM Cal. Pro Draft 3449G01 3HVC-RE16A/B Control Bldg. Inlet Cal. Pro Draft 3449A11 3HVR-RE10A/B Vent Part/ Gas 66'6" Aux Bld In Development Oper. Tes HVR-RE19A/B SLCRS Part/ Gas Oper. Test'

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In Development 3449D11 35WR-RE60A/B Cont. Recirc. Cool Outlet Draft Oper. Test 3449E11 3RMS-RE41/42 Fuel Drop Monitor 51'4" Ope In Development Test 3449G11 3HVC-RE16A/B Control Bldg. Inlet Oper. Test Draft 3449H11 3RMS-RE04/05 Cont. HR Inter. 51'4" CTM Oper. Test Draft 3450F11 3CND-RE07 Waste Neut. Sump Rad. Monitor Draft Oper. Test 3450G11 3DAS-RE50 Turb. Weldg. Floor Drains Ra Draft Monitor Oper. Test 3450H11 -3LWS-RE70 Liquid Waste Rad. Monitor Ope Draft Test 3450J11 3LWC-RE65 Regen. Evap. Rad. Monitor Ope Draft

!- Test

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ATTACHMENT II, Continued RMS Surveillance Procedure Summary Procedure Number Monitor Identification Status / Comment 3450K11 3SSR-RE08 S/G Blowdown Rad. Monitor Ope Draft Test 3449A01 3HVR-RE10A/B Vent Part/ Gas 66'6" Aux Bld Draft Cal. Pro C01 3 CMS-RE22A/B CTMT At.nos. Part/ Gas Cal . Pro Draft 3449C11 -3 CMS-RE22A/B CTMT Atmos. Part/ Gas Oper. Test In Development 3449001 '35WP-RE60A/B TM Recirc. Coc1 Outlet Cal. Pro Draft 3449E01 3RMS-RE41/42 Fuel Drop Monitor 51'4" Cal. Pro Draft 3449E21 Fuel Pool Storage Criticality Monitor Ca PORC Approved-Rev.0, Rev.1 to be sub-mitted for PORC ap-proval on 8-23-85 3449E31 Fuel Pool Storage Crit. Monitor Oper. Test Draft Rev.0 to be submitted for PORC approval 8-23-85 3449F01 3HVZ-RE09A/B Recom. Cub. A/B Exh. 7'6" Cal. Pro Draft 3449F11 3HVZ-RE09A/B Recom. Cub. A/B Exh. 7'6" .

Oper. Test Draft 3449J11 3HVQ-RE49 ESD Part & Gas Rad. Monitor In Development 3450001 3 MSS-RE75, 76, 77, 78 Main Stm. Rel. Line Draft A-D Cal. Pro MSS-RE75, 76, 77, 78 Main Stm. Rel. Line Draft A-D Oper. Test 3450E01 '3 MMS-RE79-Turb. Drv. Aux. FDW Pump Dsc Draft Cal. Pro l 3450E11 3 MMS-RE79 Turb. Drv. Aux. Fdw. Pmp. Dsc Draft Oper. Test l

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. i ATTACHMENT II, Continued RMS Surveillance Procedure Summary Procedure Number Monitor Identification Status / Comment-l 3450G01 '3DAS-RE50 Turb. Bldg. Floor Orains Ra Draft Rev.0 to be Monitor Ca submitted for PORC

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approval 8-23-85 3450H0 LWS-RE70 Liquid Waste Rad. Monitor Ca Draft

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ATTACHMENT III RMS Generic Procedure Summary Generic I&C Monitor No (GPIC) Procedure N Identification Status / Comment 20.01 3490B01 Kaman Science (KMG-HRN) Radiation Draft Rev. O Monitor 20.02 3490B02 Kaman Science (KMG-HRH) Radiation Draft Rev. O Monitor 20.03 3490B03 Kaman Science (KMPG) Radiation Approved *

Monitor Rev. 0

- 20.04 3490B04 Kaman Science (KML) Radiation Approved *

Monitor Rev. O Draft Rev. 1 20.0 B05 Kaman Science (KMG) Radiation Draft Monitor

- 20.06 3490B06 Kaman Science Hydrogen Vent Draft Monitor 20.07 3490B07 Kaman Science Hydrogen Recombiner In Development Monitor

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' 20.08 3490B08 Kaman Science (KMA-HR) Radiatio' In Review Monitor

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20.09 3490B09 Kaman Science (KMA-MR) Radiation In Review-May Monitor be deleted 20.10 3490816 Kaman Science (KMA) Radiation Approved *

Monitor Rev. 0

- 20.11 3490B11 Kaman Science Fuel Failure Monitor In Review 20.12 3490812 Kaman Science Service Water In Review Effluent Monitor 20.13 ECl-4 Eberline Radiation Monitor In Development

• Approval of these procedures is by the I&C Department Supervisor and the Startup' Manager.

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