ML20133C562

Insp Repts 50-454/85-38 & 50-455/85-42 on 850828-29. Violation Noted:Failure to Follow Liquid Radwaste Release Procedures & to Take Timely Action When Tech Spec Release Limit Exceeded

ML20133C562
Person / Time
Site:	Byron
Issue date:	09/30/1985
From:	Hueter L, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133C517	List: ML20133C513 ML20133C538 ML20133C562
References
50-454-85-38, 50-455-85-42, NUDOCS 8510070427
Download: ML20133C562 (7)

See also: IR 05000454/1985038

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/85038(DRSS);.50-455/85042(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131

Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, Illinois 60690

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Facility Name: Byron Nuclear Station ,.

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Inspection At: Byron Nuclear Station, Units 1 and 2

Inspection Conducted: August 28-29, 1985 , .

Inspector:

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L. J. Hueter

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Approved By: M. C. Schumacher, Chief-

Independent Measurements and 1

Date

Environmental Protection Section

Inspection Summary

Inspection on August 28-29, 1985 (Reports No. 50-454/85038(DRSS);

50-455/85042(DRSS))

-Areas Inspected: Nonroutine, announced inspection of an occurrence involving

initiation of a liquid radwaste release without required dilution prior to

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release to an unrestricted area. Also inspected was the gaseous and liquid

radwaste startup program for Unit l' 'The inspection involved 15 inspector-

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hours onsite by one NRC inspector.

Results: Two violations were identified (failure to follow liquid radwaste

release procedures - Section 2 and failure to take timely action when a

Technical Specification LC0 release limit was exceeded - Section 2).

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DETAILS

1. Persons Contacted

1A. Chernick, Compliance Supervisor

1J. Langan, Compliance

1R. Pleniewicz, Assistant Superintendent, Operation

R. Querio, Byron Station Superintendent

A. Scott, Health Physicist

l 1J. VanLaere, Rad-Chem Supervisor

1234K. Weaver, Station Health Physicist

l 1F. Willich, QA Inspector

P. Brochman, NRC Resident Inspector I

1J. Hinds, Jr. , NRC Senior Resident Inspector l

1 Attended the August 29, 1985 exit meeting. l

2 Telephone conversation September 3, 1985.

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3 Telephone conversation September 5, 1985.

4 Telephone conversation September 20, 1985.

2. Liquid Radwaste Release Incident - August 22-23, 1985

On the afternoon of August 22, 1985, steps were taken to initiate a batch

release, Release No. 50489, from a liquid radwaste tank. The prerequisites,

including sampling, chemical and radioactivity analyses, radwaste and

dilution flow rates, monitor alarm / isolation setpoint determinations, and

associated paperwork with verification / approvals required by procedures

were initiated. The principal procedure for liquid releases is BCP 400-T50,

Revision 3, " Liquid Radwaste Release Form", which has a number of temporary

changes in effect.

The release was initially started at 19:22 on August 22 with a release

rate of 315 gpm and circulating water blowdown rate (dilution) of

24,000 gp"i. However, the release was stopped 40 minutes later at 20:02

(tank level at 58%) at the request of the Station Control Room Engineer

(SCRE) due to the need to stop circulating water blowdown flow because of

the lowering water level in the circulating water flume. Following the

termination of the release, the circulating blowdown flow was terminated

to allow the circulating water level in the flume to rise to the desired

level. After reaching the desired level it was planned to restart the

circulating water blowdown flow but at a lower release rate (15,000 gpm)

and then restart the liquid radwaste batch release. A new procedure

package was initiated for this renewal of Release No. 50489.

Portions of the procedure which required no change were signed off with

the notation " performed previously."

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In Section F, " Operating Department Responsibility - Discharging Release

Tank to Circulating Water Blowdown Line," of procedure BCP 400-T50,

Step 1.c. has provisions for date and initials of both the radwaste

operator and radwaste foreman for verification that the circulating water

blowdown rate is equal to or greater than the minimum rate stated in

Section C, Step 3 (determined by health physics personnel) which was

15,000 gpm for the renewal of Release No. 50489.

At 23:28, at the request of the radwaste foreman, the radwaste operator

made a telephone call to the center desk operator (nuclear station

operator (NS0)) in the reactor control room to verify the circulating

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water blowdown rate was at least 15,000 gpm. The NS0's initial response

was " Blowdown? We don't have any blowdown going." However, while still

on the line he asked another occupant of the control room a question

which the radwaste operator could not hear well. When the NSO came back

on the line, the radwaste operator understood him to say that the blowdown

rate is 15,000 gpm on the low end after which the radwaste operator asked

"15,000 gpm?" and the NSO states "Yes." (However, the NSO in a written

statement, said he told the radwaste operator that 15,000 gpm was the

flow rate that would be established when blowdown was started). The

radwaste operator proceeded to log the erroneous verification (due to

miscommunication of established circulating water blowdown rate) in

release procedure BCP 400-T50 in preparation for restarting the release

of Release No. 50489. Following the telecon between the radwaste operator

and the NSO, the radwaste foreman asked the radwaste operator for the'

rate of circulating water blowdown and he was told 15,000 gpm on the low

end. The radwaste foreman also proceeded to log the erroneous verifica-

tion of established circulating water blowdown rate in release procedure

BCP 400-T50. Following completion of several more steps on the release

procedure, the release tank outlet valve / isolation valve was unlocked and

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opened following which the discharge flow control value was slowly opened

at 23:59 on August 22, to the release rate of 300 gpm (within the 350 gpm

allowed in Step 3 of Section C of the release procedure). This action

initiated a liquid radwaste release into the circulating water blowdown

line (which drains to the Rock River) without operation of the circulating

water blowdown flow to provide required dilution before release to an

unrestricted area. Procedure OBCS 11.1.1.1-1, Revision 1, which requires

the release tank to be released with the circulating water blowdown system

flow rate as specified in the Liquid Radwaste Release Tank Form

BCP 400-T50, was not followed. Failure to positively verify that

circulating water blowdown flow rate existed before initiating the

liquid radwaste release and failure to have the circulating water

blowdown flow rate specified in Release Procedure BCP 400-T50 while

making a release from the radwaste release tank were identified by the

inspector as a violation of Technical Specification 6.8.1.a which

requires implementation of procedures for effluent discharges

(Violation 454/85038-01).

The circulating water blowdown line monitor alarmed in the reactor control

and was observed / acknowledged by the NSO within the first minute after the

release from the radwaste tank was initiated. The NSO discussed the alarm

condition with the SCRE. Unaware that a radwaste release had been

initiated, they initially believed it might be a spurious alarm. The NSO

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then made a phone call to notify the shift engineer (SE). The SE asked the

NSO to call the radwaste operator to ask if any radwaste release was in

i progress. The NS0 then called the radwaste operator and was informed that

! a radwaste release was in progress. The NSO informed the operator that

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circulating water blowdown flow had not been established and instructed the

! radwaste operator to terminate the release which he did at 00:09 on

August 23, ten minutes after the release had been initiated. During the

ten minutes, about 2700 gallons of liquid radwaste containing a

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radionuclide mixture with a concentration of about 30 times the limit

specified in 10 CFR Part 20, Appendix B, Table II, Column 2, was released

l from the radwaste release tank into the circulating water blowdown line

which drains to the Rock River. During this release, the circulating water

blowdown flow rate (intended at 15,000 gpm) had not been established to

provide necessary dilution Action a. of Technical Specification

3.11.1.1 requires that when the concentration of radioactive material

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released in liquid effluents to unrestricted areas exceeds the

concentrations specified in 10 CFR Part 20, Appendix B, Table II, Column 2,

the concentration shall be immediately restored to within the above limits.

The nine minute delay between the actuation of the blowdown monitor alarm

and termination of the release appears inordinate and does not meet the

immediacy requirement of the technical specification. This was identified

by the inspector as a violation of Technical Specification 3.11.1.1 which

requires immediate restoration to within the limits for release to an

unrestricted area (Violation 454/85038-02).

} The circulating water blowdown line is basically a 30 inch diameter pipe

about 13,000 feet long, common to both units. It connects to the

circulating water system a short distance downstream of the condenser

water box of each unit and travels over several small hills and valleys

before splitting into two pipes that discharge into a small canal about

300 yards long that flows into the Rock River. The blowdown flow is

normally controlled by a valve near the beginning of the blowdown line of

each unit before the blowdown lines combine into a common line. The

motive force is supplied by the circulating water pumps on the the

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circulating water system. Valves are also located on each of the two

( pipes at the end of the blowdown line.

The ten minute release into the circulating water blowdown line was

terminated at 00:09 on August 23. This situation was discussed between

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operations personnel and onsite radiation protection personnel and it was

decided to open the upper blowdown valve and close the lower blowdown

valves in an attempt to fill up the blowdown line for the benefit of

whatever mixing and dilution could be obtained before release into the

canal and Rock River.

At 00:15, six minutes after termination of the release, the upper

blowdown valve was opened. At 00:23 and 00:29, the first and second

valves respectively on the lower end of the blowdown line were closed.

The latter two valves are located about five miles from the plant by

road. Calculations indicate that closure at the end of the blowdown line

should have occurred several minutes before the bolus containing the

activity could have been released.

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A dip sample was collected at 00:50 from the canal at the discharge from

the blowdown line and subsequently analyzed. At 00:56 both valves on the

lower end of the blowdown line were reopened to reestablish circulating

water blowdown release to the canal / river. Additional grab sample were

collected near the end of the blowdown via the composite sampler flow

path at 01:10, 01:30 and 01:50 and subsequently analyzed.

The concentration in the release tank was approximately 30 times the

unrestricted area release level based on observed concentrations of Co-58

(1.2E-3 pCi/ml), Co-60 (1.0E-4 pCi/ml), Mn-54 (1.0E-4 pCi/ml), and I-131

(3.6E-6 pCi/ml). The radionuclides identified in the grab samples and

their respective concentrations are as follows:

Time of Sample Radionuclide Concentration (pCi/ml)

00:56 Co-58 1.7E-7

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01:10 Co-58 2.8E-7

Mn-54 5.5E-8

01:30 Co-58 4.2E-7

01:50 Co-58 7.2E-8

Although these samples show dilute concentrations (unrestricted area

maximum permissible concentration (MPC) for Co-58 is 9E-5 pCi/ml), it is

noted that if the activity in the blowdown line were not well diluted the

bolus containing the bulk of the activity could have been released in a

period of a few seconds, between grab samples.

The licensee's evaluation concluded that the maximum instantaneous

concentration reaching the unrestricted area could not be determined but

was probably between 10 MPC and.the release tank concentration of 30 MPC.

On this basis the licensee plans to provide a 30 day written report

pursuant to 10 CFR 20.405(a)(1)(v) as noted in the licensee's Deviation

Report, 6-1-85-262, covering this event. The licensee calculated the

dose to a member of the public from radioactive materials in this liquid

effluent release. The dose was not significant in comparison with the

dose limits specified in Technical Specification 3.11.1.2.

The remainder of the water in the release tank was released without

incident beginning at 06:07 on August 23rd with proper circulating water

blowdown flow established to provide dilution. A new procedure package

was not initiated for this third part of Release No. 50489. The procedure

package used for the second part of the release was reused with new data

and new " sign offs" and the words "3rd Start" handwritten above or below

the data for the release procedure for the second part of the release.

This reuse of the release form together with handwritten temporary changes

gave a very cluttered appearance to the release procedure. Although

apparently not contributing to this event, this clutter could increase

the potential for personnel error in following the release procedure.

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The licensee is conducting an investigation / evaluation of the event to

determine the cause, to take measures to prevent recurrence and to

improve the release procedures and control of releases. As of the

inspection date it was concluded that the cause was a communications

problem and that the procedure for verification of circulating water

blowdown flow rate was a contributing factor. A temporary procedure

change has been implemented to preclude recurrence which now requires

verification (initials and date) by a member of the reactor control room

(SCRE or RS0) as well as the radwaste foreman that the circulating water

flow rate is established at or above the minimum calculated rate needed

to provide adequate dilution before the control room SE or SR0 authorizes

the release. This should preclude verification of dilution flow based

solely on telephone conversation. A placard has also been prepared for

placing at the circulating water blowdown flow control valve while

releases are in progress. The placard states " Release in Progress."

The placard's placement and removal are covered by procedure change.

To eliminate clutter and to enhance ease of following the radwaste release

procedure, it has been retyped to include all the temporary changes and

policy has been made to require use of a new procedure to continue release

from a tank once the release has been terminated. Under consideration is

total review of the procedure for possible simplification and introduction

of a greater safety factor in the concentration planned for release to an

unrestricted area. Also under consideration is a modification that would

have an isolation function on the radwaste release tank upon reduction or

loss of circulating water blowdown flow rate needed for dilution purposes.

Two violations were identified.

3. Startup - Comcarison of Effluent Monitor Readings Against Known Effluent

Concentrations

The licensee has conducted tests involving laboratory analysis of gaseous

and liquid effluent samples and comparison of the results with respective

effluent monitor readings. Good agreement was observed with the mcnitors

responding slightly on the high side (conservative).

No violations were identified.

4. Startup - Demonstrate that Gaseous and Liquid Radioactive Waste Systems

Operate Per Design

The licensee has demonstrated that gaseous and liquid radioactive waste

processing, storage, and release systems operate in accordance with the

design with the exception of the boric acid evaporator and the radwaste

evaporator. These two evaporators are in the final stages of beir.g made

operable and testing. In the interim, a vendor resin system (covered by

a 10 CFR 50.59 review) has been used for water cleanup. Operability is

not imminent for the licensee's volume reduction system (incinerator),

which involves primarily solids but also has provisions for treating liquid

in the form of contaminated oil.

No violations were identified.

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5. Startup - Nonradioactive Process and Effluent Streams Checked for

Unanticipated Radioactivity

The licensee has established a progrr.m for gamma isotopic analysis of

quarterly samples from normally not.adioactive process and effluent

streams including the auxiliary steam system, station heating system,

diesel generator cooling system and the makeup demineralizer system.

No detectable activity has been identified.

Inspection Reports No. 50-454/85037; 50-455/85041 cover an occurrence

involving a recent identification by the licensee of slight contamination

(apparently from Unit-1) on vendor supplied resins used to purify flush

l water in Unit 2 piping systems, in preparation for preop testing.

6. Exit Interview

The inspector summarized the scope and findings of the inspection with

licensee representatives (Section 1) at the conclusion of the inspection

on August 29, 1985. The inspector discussed the likely informational

content of the inspection report with regard to documents or processes

reviewed by the inspector during the inspection. The licensee did not

identify such documents or processes as proprietary.

Licensee representatives acknowledged the inspector's identification of a

violation to follow adequate procedures and a violation of technical

specification requirements, These matters were discussed in subsequent

telephone conversations with various licensee representatives on

September 3, 5, and 20. On September 20, the violations were reaffirmed.

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