IR 05000482/1997001

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Insp Rept 50-482/97-01 on 970113-17.No Violations Noted. Major Areas Inspected:Engineering & Plant Support
ML20135C464
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 02/24/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135C460 List:
References
50-482-97-01, 50-482-97-1, NUDOCS 9703040059
Download: ML20135C464 (23)
v • d • e


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. 1 ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nv.: 50-482 License No.: NPF-42 Report No.: 50-482/97-01 Licensee: Wolf Creek Nuclear Operating Corporation !

Facility: Wolf Creek Nuclear Station  ;

Location: 1550 Oxen Lane, NE l Burlington, Kansas l Dates: January 13-17,1997 Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental information l

9703040059 970224 PDR O ADOCK 05000482 PDR .

2-EXECUTIVE SUMMARY Wolf Creek Nuclear Station i NRC Inspection Report 50-482/97-01 1 l

This routine, announced inspection focused on the licensee's radiological waste effluent l management progra !

Enaineerina

  • Reviewed practices, procedures, and parameters were consistent with Updated Safety Analysis Report commitments (Section E2.1).

Plant Suocort

  • The liquid and gaseous radioactive waste effluent management programs were properly implemented (Section R1.1).
  • Good sample handling techniques were used while collecting and handling samples (Section R1.1).
  • Between 1992 and 1994, the licensee was in the fourth quartile (worst) for airbome gas and liquid tritium for operating pressurized water reactors. However, the licensee was in the first quartile (best) for airborne iodine /particulates and near the average for airborne tritium and liquid mixed isotopes for operating pressurized !

water reactors (Section R1.2). l

  • The engineered-safety-feature air cleaning ventilation systems were properly maintained and tested (Section R1.3). ,

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  • The radiochemistry counting room was equipped with state-of-the-art analytical instrumentation which was properly maintained, tested, and calibrated (Section R2.1).
  • Liquid and gaseous radioactive waste management systems were properly installed l and operated (Section R2.1). l l

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  • All liquid and gaseous effluent radiation monitoring instrumentation were operable and properly maintained, tested, and calibrated (Section R2.2).
  • Implementing procedures for the liquid and gaseous radioactive waste effluent management programs provided proper guidance. An excellent Annual Radioactive Effluent Release Report for 1995 was submitted in a timely manner (Section R3.1).

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  • Chemistry personnel and radwaste operators had an excellent understanding of the radioactive liquid and gaseous waste management procedures, Offsite Dose Calculation Manual requirements, and regulatory requirements (Section R4).
  • Training and qualification programs for chemistry technicians, radwaste operators, j and nuclear equipment operators were properly implemented. A trained and qualified staff for conducting radioactive waste effluent processing and release operations was maintained (Section R5). ,
  • The chemistry technician and radwaste staffs experienced very little change during ]

the past 1-1/2 years (Section R6). l

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  • Oversight of the radioactive waste effluent management prograra was good. The quality assurance audits and surveillances of the radiological wine effluent management program activities were technically comprehensive and provided good program evaluation and oversight (Section R7.1).
  • A good self-assessment was performed by the chemistry department concerning the implementation of the radioactive release permits program. This was an enhancement to the required quality assurance audit program (Section R7.1).
  • Two contractor laboratories were evaluated by review of audits that were comprehensive and provided good evaluation and oversight of the contractors'

performance (Section R7.2).

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ReDort Details

j Summary of Plant Status

. The plant was operating at power during the entire inspection. There were no operational occurrences that impacted the inspection.

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E2 Engineering Support of Facilities and Equipment

, E Updated Safety Analvsis Report Review i Insoection Scope

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The inspector reviewed selected topics presented in the Updated Safety Analysis l Report to ensure agreement with any commitments contained therein that pertained to the inspection.

a Observations and Findinas i

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While performing the inspection discussed in this report, the inspector reviewed the applicable portions of the Updated Safety Analysis Report that related to the areas inspected. The inspector did not note any discrepancy between the Updated Safety Analysis Report wording and the observed plant practices, procedures, and/or parameter Conclusion Reviewed practices, procedures, and parameters were consistent with Updated Safety Analysis Report commitment IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Radioloaical Waste Effluent Manaaement Proarams Insoection Scope (84750)

Implementation of the liquid and gaseous radioactive waste effluent management programs, as described in the Technical Specifications and the Offsite Dose Calculation Manual, were reviewed. This review included:

  • radioactive effluent waste processing

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  • radioactive effluent waste sampling and analyses
  • analytical sensitivities and results
  • offsite dose results
  • performance of required surveillance tests b. Observations and Findinas The inspector reviewed ten batch radioactive liquid waste effluent release permits for the period January through December 1996. The inspector determined that the following activities were conducted in accordance with Offsite Dose Calculation Manual requirements: (1) processing, sampling, and analyses of radioactive liquid waste effluents, (2) approval and performance of batch radioactive liquid waste discharges, and (3) monitoring of continuous liquid waste effluents .

Quantities of radionuclides released in the radioactive liquid waste effluents were within the limits specified in the Offsite Dose Calculation Manual. Offsite doses were calculated according to Offsite Dose Calculation Manual methodologies and were within regulatory limits. Required analyses of monthly and quarterly composite samples of batch radioactive liquid waste effluent releases for gross alpha, tritium, iron-55, strontium-89, and strontium-90 were performed in accordance with Offsite Dose Calculation Manual requirement The inspector reviewed five batch radioactive gaseous waste effluent release permits for the period January through December 1996. Selected gaseous waste effluent sample analyses for samples from the unit vent stack and the radwaste building vent stack continuous releases for the period January through December 1996 were reviewed. The inspector verified that the sampling, analyses, and monitoring of the batch and continuous discharges of radioactive gaseous effluents were conducted in accordance with Offsite Dose Calculation Manual requirement Quantties of gaseous and airborne particulate radionuclides released were within the !.mits specified in the Offsite Dose Calculation Manual. Offsite doses were calculated according to Offsite Dose Calculation Manual methodologies and were within regulatory limits. Noble gas samples were collected and analyzed for principal gamma emitters and tritium in compliance with Offsite Dose Calculation Manual requirements. Particulate effluent composite sample analyses for principal gamma emitters, gross alpha, strontium-89, and strontium-90 were performed for each vent pathway in accordance with Offsite Dose Calculation Manual requirement The inspector observed a chemistry technician collect air particulate filter samples, iodine charcoal cartridge samples, noble gas, and tritium samples of the unit vent

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from the radiation monitor sample point (GT-RE-21) on January 14,1997, for analyses and update of the continuous release permit for the unit vent. The inspector noted that the chemistry technician cairied, seferred to, and followed the appropriate sampling procedures while performing the sample collections. The inspector noted that the chemist used good sample handling technique The inspector observed a chemistry technician perform the radiochemistry analyses (principal gamma omitters and tritium) on the samples in the radiochemistry counting room. All aspects of the sample collections and analyses were performed in accordance with approved station procedures, Conclusions The liquid ar.d gaseous radioactive waste effluent managerrent programs were properly implemented. Good sample handling techniques were used by the licensee while collecting and handling samples. Quantities of radionuclides released in the

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liquid and gaseous radioactive waste effluents were within the Offsite Dose Calculation Manuallimits. Offsite doses to the environment from the liquid and gaseous radi'sactive waste effluents were calculated using Offsite Dose Calculation

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Manual metnodologie R1.2 Radioactive Waste Effluent Data insoectionycoce (84750)

The inspector evaluated the radioactive waste effluent data and the licensee's effectiveness in identifying, resolving. and preventing problems in the processing and treatment of radwaste effluents.

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9-7-j Observations and Findinas The following table presents the radioactive effluent data for 1992,1993, and 1994 ,

with a 3 year average as released to the environmen l l

l Environmental 1992 1993 1994 3-Year Percentile *

Releases Average (Industry)

Airborne Gas 308 521 584 492 78 I (curies)

Airborne lodine & 1.8 E-05 6.98E-04 3.41 E-04 4.05E-04 29 I Par (curies) l Airborne Tritium 1 .7 2 .8 44 (curies) I Liquid Mixed 0.291 0.705 0.947 0.457 46 l Isotopes (curies)

Liquid Tritium 451 999 974 895 98 (curies)

Population Dose 0.790 0.850 5.500 3.165 89 (89,90,91)

  • A 78 percentile equates to 78 percent of the plants did better than the license From the data tabulated above between 1992 and 1994, the licensee wes in the fourth quartile (worst) for airborne gas, in the first quartile (best) for airbo ne iodine /particulatt.s, near the average and in the second quartile for airborne tritium, near the average and in the third quartile for liquid . nixed isotopes, in the fourth quartile (worst) for liquid tritium, and in the fourth quartile (worst) for the population dos The radioactive effluent data was discussed with the licensee. The licensee informed the inspector that they were aware of their status in the industry relative to their effluent discharges and stated that improvement in this area had been given a high priority. The inspector also noted that the quality assurance audit of chemistry and radiochemistry control noted that the demineralization skid used for processing and sampling for liquid radioactive waste should be improved to provide a safer means to collect representative samples and better meet good radiation protection considerations during samplin .

8- Conclusions Between 1992 and 1994, the licensee was in the fourtn quartile (worst) for airborne gas and liquid tritium for operating pressurized water reactors. However, the licensee was in the first quartile (best) for airborne iodine /particulates and near the average for airborne tritium and liquid mixed isotopes for operating pressurized water reactor R1.3 Enaineered-Safetv-Feature Air Cleanino Systems Insoection Scooe (84750)

Surveillance and test results for the engineered-safety-feature air cleaning ventilation s'istems testing program were reviewed to determine agreement with the commitments in the Updated Safety Analysis Report and compliance with the requirements in Technical Specifications 4.7.6, 4.7.7, and 4.9.1 j Observations and Findinas The inspector verified that required surveillance tests were performed regarding periodic functional checking and testing of the engineered-safety-feature air cleaning ventilation systems' components, evaluation of the high efficiency particulate air filters and activated charcoal adsorbers, and the in-place filter testing of the control room emergency ventilation system (FGK-01 A and 0111),

emergency exhaust system - auxiliary building (FGG-02A and 028), and emergency )

exhaust system - fuel building (FGG-02A and 02B). Since some of the surveillance )

tests were only required to be performed at an 18-month frequency, the inspector

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reviewed the last surveillance tests' results for each of the safety-related air cleaning ventilation systems named above and verified that the previous two surveillances were performed at the required 18-month frequency. The in-place filter testing was performed by the licensee. The activated charcoal laboratory surveillance tests were performed by an offsite contract laboratory. All test results were verified to be within Technical Specification limit The inspector noted that the Technical Specification requirement for testing the ;

various air cleaning ventilation systems' activated charcoal adsorber material after i every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation following previous laboratory testing was being l tracked by the control room on Surveillance Test Procedure STS PE-056, " Filter 1 Adsorber Unit Charcoal Adsorber Bed Run Time Tracking Log-Safety Related Units."

The inspector performed a walkdown visual inspection with the system engineer of the following ventilation systems: the control room emergency ventilation system and the emergency exhaust system. The walkdown externalinspection of the  ;

identified ventilation systems indicated no visual problems with the systems' l housing and ducts, local instrumentation, and filter unit components. All doors were bolted tightly closed and all gaskets were in place and not leaking. All filter f

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housings and ducts were well maintained. The areas surrounding the ventilation units were clean, free of debris, and adequately lighted to provide for visual l inspection of housings c 7d component l I Conclusions

- l The engineered-safety-feature air cleaning ventilation systems conformed to the commitments in the Updated Safety Analysis Report and met the Technical Specification requirements. An excellent engineered-safety-feature air cleaning systems surveillance program was implemented. All surveillance test results met Technical Specification requirement R2 Status of Chemistry and Radiological Waste Effluents Facilities and Equipment R2.1 Radiochemistrv Countina Room and Radioactive Waste Effluent Processina Systems Insoection Scoce (84750)

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The radiochemistry counting roorn and associated analytical instrumentation were inspected to verify if adequate calibration and quality control programs were ;

implemented. The radioactive liquid and gaseous waste processing equipment were !

inspected to ensure agreement with the Updated Safety Analysis Repor l Equipment inspected in the radwaste building included the waste monitor tanks, the I secondary liquid waste monitor tanks, and the liquid waste effluent processing l equipment and the waste gas decay tank j d _ Observations and Findinas  ;

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The radiochemistry counting room maintained sufficient state-of-the-art analytical instrumentation to perform the required radiochemistry analytical measurements of the radioactive waste effluents. The analyticalinstrumentation was properly maintained and calibrate The liquid radioactive waste processing and storage systems were installed as described in the Updated Safety Analysis Report and were operated in accordance l with station procedures.

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i The gaseous radioactive waste processing and storage system was installed as l described in the Updated Safety Analysis Report and was operated in accordance with station procedure No major equipment or design modifications were made to the liquid or gaseous radioactive waste management systems during 1995 and 199 I l

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- 10-i Conclusions The radiochemistry counting room was equipped with state-of-the-art analytica! l instrumentation. The analytical instrumentation was properly maintained, tested, I and calibrated. Liquid and gaseous radioactive waste management systems were installed and operated properl R2.2 Liauid and Gaseous Effluent Radiation Monitors  ! Insoection Scoce (84750)

The liquid and gaseous effluent radiation monitors were inspected for operation, calibration, and reliability in accordance with the surveillance requirements specified in Offsite Dose Calculation Manual Tables 2-3 and 3- Observations and Findinas The inspector reviewed the liquid and gaseous radioactive waste effluent radiation monitor source check, channel check, channel operational test, and channel calibration records, for the pc.riod of January 1995 through December 1996. All records and surveillance tests reviewed indicated that the liquid and gaseous ;

radioactive waste effluent monitoring instrumentation was properly maintained, tested, and calibrated in compliance with the surveillance requirements specified in the Offsite Dose Calculation Manua Conclusion All liquid and gaseous effluent radiation monitoring instrumentation was operable and properly maintained, tested, and calibrated in compliance with the surveillance requirements specified in the Offsite Dose Calculation Manua R3 Radioactive Waste Effluent and Chemistry Procedures and Documentation R 3.1 Radioactive Waste Effluent Procedures Offsite Dose Calculation Manual, and Annual Radioactive Effluent Release Reports Inspection Scope (84750)

Procedures for the sampling, analysis, and release of radioactive liquid and gaseous waste effluents were reviewed. Revisions to the Offsite Dose Calculation Manual were reviewed. Annual reports concerning radioactive waste effluent releases were reviewe .

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b. Observations and Findinas The inspector verified that the procedures for batch release of liquid and gaseous radioactive waste effluents provided proper guidance regarding sampling, tank recirculation, analyses, release limits, monitoring, and approval The radioactive waste effluent program's implementing procedures described the responsibilities for collection and analyses of liquid and gaseous radioactive waste effluent samples. The procedures were written with sufficient detail to effectively conduct the required radioactive waste effluent program activities. The inspector reviewed the sample collection procedures and identified nu concem The Annual Radioactive Effluent Release Report for 1995 included a summary of the quantities of radioactive liquid and gaseous waste effluents, a summary of meteorological data concurrent with the release of airborne effluents, an assessment of the radiation doses from the radioactive liquid and gaseous effluents released to the environment during each calendar quarter and changes to the Offsite Dose Calculation Manual. The Annual Radioactive Effluent Release Report was written in the format described in NRC Regulatory Guide 1.21, Revision 1, June 1974, and contained the information required by the Offsite Dose Calculation Manua No unplanned releases of radioactive liquid or gaseous waste were reported during 1995 and 199 c. Conclusions Implementing procedures for the liquid and gaseous radioactive waste effluent management programs provided proper guidance. Changes to the Offsite Dose Calculation Manual were properly documented. An excellent Annual Radioactive Effluent Release Report for 1995 was submitted in a timely manner and contained the required information presented in the required forma R4 Staff Knowledge and Performance a. Inspection Scope (84750)

The chemistry personnel and radwaste operators were interviewed with regard to regulatory and Offsite Dose Calculation Manual requirements for the implementation of the liquid and gaseous radioactive waste effluent management programs, Observations and Findinas Chemistry personnel and radwaste operators were knowledgeable of the programmatic procedures, Offsite Dose Calculation Manual requirements, regulatory requirements, and maintained a high level of performance. Batch radioactive liquid

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O-12-and gaseous waste effluent releases and continuous radioactive liquid and gaseous waste effluent releases were properly performed during the time of 1995 and 1996, c. Conclusion Chemistry personnel and radwaste ONrators had an excellent understanding of the radioactive liquid and gaseous war'.e management procedures, Offsite Dose Calculation Manual, and regulatory requirement R5 Staff Training and Qualification a. Insoection Scoce (84750)

Training and qualification programs for chemistry technicians and radwaste operators involved with conducting the radioactive waste effluent management programs were reviewed. Training and qualifications of the chemistry technicians, radwaste operators, and nuclear station operators were verifie b. Observations and Findinas The inspector verified that all chemistry technicians (14), but one recently hired chemistry technician, had completed all of the training required to be sNft qualified and, therefore, were qualified to perform all radioactive waste effluent management program activitie The inspector verified that five radwaste operators and at least one nuclear station operator on each of the six operating shift crews were trained and qualified to conduct radioactive waste liquid and gaseous effluent batch releases and operate the radioactive waste processing equipmen c. Conclusions Training and qualification programs for chemistry technicians, radwaste operators, and nuclear station operators were properly implemented. The chemistry department and the operations department had well trained and qualified staffs for conducting radioactive waste liquid and gaseous effluent processing and release operation R6 Chemistry Organization and Administration a. Insoection Scoce (84750)

The organization, staffing, and assignment of the radioactive waste effluent management program responsibilities were reviewed. Administrative and chemistry departmental procedures were rev:ewed for the assignment of responsibilities for

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i-13-the management and implementation of the radioactive waste effluent management program, Observations and Findinas The inspector verified that the chemistry and operations organizations and staff were responsible for the implementation of the radioactive waste effluent management progra The inspector reviewed the staffing of the chemistry and radwaste operations organizations and determined that they were adequately staffed. There had been very little change in the chemistry technician staff during the past 1-1/2 years. The chemistry department had lost one chemistry technician to the training department, who has not been replaced; one chemistry technician was made a part-time chemistry specialist; and one new chemistry technician was hired to fill a vacant ,

chemistry technician position. The radwaste operator staff of five operators had not '

changed during the past 1-1/2 year Conclusions The chemistry and radwaste operations organizations and staffing met Technical Specification requirements. The chemistry technician and radwaste operator staffs i experienced very little change during the past 1-1/2 year {

l R7 Quality Assurance in Chemistry and Radiological Waste Effluents Activities  !

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R7.1 Radioactive Waste Effluent Quality Assurance Prooram Insoection Scope (84750)

The quality assurance audit, surveillance, and self-assessment programs of the radioactive waste effluent management program activities were reviewed for scope, thoroughness of program evaluation, and timely followup of identified deficiencie The review included the audits, surveillances, and self-assessment performed during 1994-199 Observations and Findinas The review of the quality assurance biennial audit schedule dated November 19, 1993, indicated that the audit of the radiological environmental monitoring program was scheduled on a 12-month frequency in compliance with Technical Specification 6.5.2.8.g, and the audit of the Offsite Dose Calculation Manual and implementing procedures was scheduled on a 24-month frequency to be performed during even numbered years in compliance with Technical Specification 6.5.2. '

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i Reports of the quality assurance audits and surveillances, performed during the period January 1995 through December 1996 of the areas related to the j performance of the radioactive waste effluent management program, were l

performed in accordance with the quality assurance procedures by qualified auditors !

and assisted by technical specialists. The audits and surveillances of the radioactive waste effluent management program were of good quality, technically comprehensive, and provided good oversight and evaluation of the licensee's performance in implementing the radioactive waste effluent management program and met the Technical Specification requirement The inspector reviewed Self-Assessment 95-038, "Use of Radioactive Release Permits," conducted by the chemistry department during August 1995. The self-assessment provided detailed observations and evaluations in a specified program area. This self-assessment was an enhancement to the required quality assurance audit progra Conclusions Oversight of the radioactive waste effluent management program was good. The quality assurance audits and surveillances of the radiological waste effluent management program activities were technically comprehensive and provided good j program evaluation and oversight. A good self-assessment of the radioactive '

release permit program was performed and was an enhancement to the quality assurance audit progra R7.2 Quality Assurance Proaram for Contractors Insoection Scooe (84750)

The quality assurance audit program regarding contractors performing surveillance activities involving the radioactive waste effluent program and safety-related air cleaning ventilation systems was reviewe Observations and Findinas The licensee used a contractor laboratory to perform required radiochemistry analyses of radioactive waste effluent composite samples. The licensee used another contrar to perform laboratory charcoal adsorber analyses on the station's engineered-safety-feature air cleaning ventilation systems. The licensee obtained Nuclear Procurement issues Committee (NUPIC) audits regarding the two contractors responsible for performing radiochemistry and charcoal adsorber analyses. The licensee used these audits to evaluate the performance of the two contractors in performing the surveillance testing requirements and to retain its current status on the licensee's routine suppliers list. The inspector reviewed the audits performed on the two contractors and determined that the audits were

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i-15-satisf actory to evaluate the contractor's abilities to perform the Technical Specification required testing and surveillance activities, Conclusion Two contractor laboratories were evaluated by review of audits that were comprehensive and provided good evaluation and oversight of the contractors'

performanc R8 Miscellaneous Radio!ogical Protection and Chemistry issues R8.1 (Closed) Licensee Event Reoort 50-482/96-019 " Historical Failure to Comolv with Radioloaical Effluent Technical Specifications" On December 6,1996, chemistry personnel identified that the direction provided by Forms APF 02-007-06, APF 02-007-07, and APF 02-007-08 of Administrative Procedure AP 02-007," Chemistry Turnover and Abnormal Conditions Guidelines,"

Revision 0, was in conflict with Attachment A, Item 7, of Administrative Procedure AP 07B-003,"Offsite Dose Calculation Manual," Revision O. As a result of this

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conflict, sampling and analyses required by the Offsite Dose Calculation Manual l were not performed as required. The programmatic conflict resulted from chemistry management misunderstanding the requirements of Offsite Dose Calculation

, Manual, Attachment A, Item 7. This misunderstanding was in effect from June l l 1985 % + m smber 6,1996. Although the time in which this misunderstanding was l in a <, N t.ffsite Dose Calculation Manual was a part of the Technical i Sp> ' wm. irom June 1985 through March 1991. Therefore, during this period,

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the ceena was in violation of the Radiological Effluent Technical l Specifications /Offsite Dose Calculation Manual requirement for sampling and I analyses each time the unique conditions requiring the sampling and analyses l occurred.

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Attachment A, Item 7, of the Offsite Dose Calculation Manual requires in part, that, for the unit vent, particulate and iodine sampling be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for at least 7 days following each shutdown, startup, or thermal power change exceeding 15 percent of rated thermal power within a 1-hour period. It also requires that the analyses of these samples be completed within a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> perio Item 7 also states that the above requirements in item 7 do ngt apply if:

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increased by more than a factor of three, AND The unit vent noble gas menitor shows that effluent activity has not increased by more than a factor of thre .

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-16-Thus, as long as there was less than or equal to a factor of 3 increase in both the dose equivalent iodine reactor coolant concentration and the effluent activity, the samplit,g and analyses requirements of item 7 did not appl Conversely, if this factor of 3 increase is exceeded for either one or both of the dose equivalent iodine reactor coolant concentration or the effluent activity, the required sampling and analyses must be performed since both of the conditions must be met to preclude samplin The inspector verified that the corrective actions described in the licensee event report corrective actions dated January 3,1997, to change the forms APF 02-007-06, APF 02-007-07, and APF 02-007-08 to correctly reflect the sampling and analyses requirements in the Offsite Dose Calculation Manual, were implemented. No similar problems were identifie However, chemistry management originally misinterpreted the wording and intent of the Radiological Effluent Technical Specification /Offsite Dose Calculation Manual requirement in June 1985, stipulating that both the dose equivalent iodine and effluent activity increases had to be in excess of the factor of 3 before sampling and analyses were required. Thus, the Radiological Effluent Technical Specification /Offsite Dose Calculation Manual requires 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sampling and analyses in 3 of 4 possible plant conditica scenarios, but form APF 02-007-06 originally required the sampling and analyses in only 1 of 4 possible scenario During the review of the licensee event report, the inspector requested the number of times this sampling and analyses infraction had occurred between June 1985 and December 6,1996. The licensee's response was that they had not estimated an exact number of events, but that the lack of sampling and analyses had occurred following each shutdown, startup, or thermal power change exceeding 15 percent of rated thermal power within a 1-hour period between June 1985 and December 6, 1996. The lack of sampling and analyses of the unit vent at the increased frequency would have not affected the dose calculations reported in the annual radioactive effluent release reports because the doses were calculated from the routine sampling and analyses results obtained from the unit vent radiation monitor which was operating continuously during the times in question. The more frequent sampling and analyses were required for detailed tracking of any increase by a factor of three in the dose equivalent iodine or noble gases in the unit vent. These analytical results would not have affected the week's analytical data as determined by the routine sampling and analyses of the unit vent samples and the resulting dose calculations reporte The inspector determined that the f ailure to sample and analyze the unit vent per Attat.nment A, item 7, due to a misinterpretation was a violation of the Technical Specification during the penod of June 1985 through March 1991 and a violation of Offsite Dose Calculation Manual, Attachment A, item 7, during the time of March 1991 through December 6,1996. Therefore, this licensee-identified and

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-17-corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-482/9701-01).

V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the results of the inspection to members of licensee -

management at the conclusion of the inspection on January 17,1997. The licensee acknowledged the findings presente The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie i

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ATTACHMENT SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED  !

Licensee i M. Blow, Superintendent, Chemistry G. Boyer, Director, Site Support i S. Burkdoll, Supervising Instructor, Chemistry i T. Damashek, Supervisor, Nuclear Engineering Safety and Licensing K. Davison, Supervisor, Operations Support R. Denton, Quality Specialist, Quality Evaluations S. Devena, System Engineer D. Dow, instrumentation and Controls Technician  ;

D. Fehr, Manager, Training  !

R. Flannigan, Manager, Nuclear Engineenng Safety and Licensing M. Kline, Staff Health Physicist S. Koenig, Supervisor, Quality Evaluations j D. Loewe, Supervisor Maintenance, Instrumentation and Controls B. McKinney, Plant Manager T. Morrill, Assistant to Vice President of Engineering W. Norton, Manager, Performance improvement and Assessment .

C. Palmer, Supervisor, Chemistry l R. Parker, Supervisor, Chemistry i C. Reekie, Engineering Specialist, Nuclear Engineering Safety and Licensing D. Stone, Chemistry Technician H. Stubby, Supervisor, Technical Training T. Wilson, Supervisor, Operations Treatment Systems C. Younie, Manager, Operations I

NRC F. Ringwald, Senior Resident inspector LIST OF INSPECTION PROCEDURES USED IP 84750 Radioactive Waste Systems: Water Chemistry; Confirmatory Measurements and Radiological Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED  !

Open 50-482/9701-01 NCV LER 96-019

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-2-Closed 50-482/9701-01 NCV LER 96-019 LIST OF DOCUMENTS REVIEWED Oraanization Charts Chemistry Department - November 26,1996 Operating Crews - November 7,1996 Operations Planning & Projects - November 26,1996 Quality Assurance Documents

~ Quality Evaluations Biennial Audit Schedule, Revision 12, dated November 19,1993 Audit Planning Guide 7, "Offsite Dose Calculation Manual and implementing Procedures,"

Revision 2, dated March 22,1993 Quality Assurance Audits Quality Evaluations Audit Report K15-002 K-436, " Environmental Protection Program,"

conducted May 1-31,1995 l

Quality Evaluations Audit Report K15-002 K-458, " Environmental Management l (REMP/ODCM/EEMP)," conducted May 1-31,1996 i

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Quality Evaluations Audit Report K15-002 K-470, " Chemistry and Radiochemistry Control,"

conducted October 1 through December 31,1996 Quality Assurance Surveillances Quality Assurance Surveillance Report K15-003 S-3068," Review of Radiological Environmental Monitoring Program Data," conducted January 19-27,1995 j Plant Evaluation Checklist OB 96-0354," Radiation Monitor GTRE-21B Calibration,"

conducted September 11,1996 Vendor Audits NUPIC Joint Quality Assurance Audit of NCS Corporation, conducted November 15-17, i 1994

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l1-3-NUPIC Joint Quality Assurance Audit of Teledyne Brown Engineering Environmental Services, conducted August 26-30,1996 Self Assessment Self Assessment Report SEL 95-038,"Use of Radioactive Release Permits," dated August 18,1995 Procedures Administrative Procedures GEN 00-020 " Liquid Waste Processing," Revision 12, January 14,1997 ADM 04-001 " Chemistry Group Organization," Revision 14, December 22,1993 ADM 08-807 "l&C Group Surveillance Testing," Revision 10, March 10,1994 ,

ADM 08-818 " Update of the Radiation Monitoring System (RMS) Calibration Data l Document," Revision 1, April 21,1993

AP 02-002 " Chemistry Surveillence Program," Revision 3, December 13,1996 AP 02E-001 " Chemistry Calibration Program," Revision 4, October 1,1996 AP 078-001 " Radioactive Releases," Revision 2, September 12,1996 AP 17C-009 " Nuclear Station Operator Qualifications and Responsibilities," Revision 2, November 25,1996 AP 17C-017 " Superintendent Chemistry Duties and Responsibilities," Revision 1, May 10,1996 AP 20A-001 " Auditing Performance Assessment Division Activities," Revision 1, April 14,1995 AP 20A-003 " Audit / Surveillance Scheduling," Revision 1, June 14,1995 AP 20A-004 " Audit Procedure," Revision 2, January 23,1996 AP 30B-002 " Nuclear Station Operator (NSO) Requalification Training," Revision 1, September 22,1995 AP 30D-006 " Chemistry Technician Training Program," Revision 1, May 2,1996 AP 31 A-200 " Radioactive Waste Program," Revision 0, August 24,1995

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e-4-Administrative Instructions Al 078-018 " Manual Preparation of a Radioactive Liquid Release Permit," Revision 1, September 12,1996 Al 07B-019 " Effluent Management System (EMS) Instructions for Liquid Release Permits," Revision 5, May 3,1996 Al 078-020 " Instructions for Composite Preparation," Revision 4, June 19,1996 Al 078-021 " Instructions for the Preparation of Waste Gas Release Permit, Manual Method," Revision 0, March 6,1995 Al 07B-022 " Effluent Management System (EMS) instructions for Gas Decay Tank Permits," Revision 2, March 26,1996 Al 07B-024 " Effluent Management System (EMS) Instructions for Containment Purge Permits," Revision 2, October 1,1996 Al 078-025 " Instructions for the Preparation of Vent Release Permit, Manual Method,"

Revision 0, March 6,1995 Al 07B-026 " Effluent Management System (EMS) Instructions for Unit and Radwaste ;

Vent Permits," Revision 1, December 13,1995 i

Al 07B-027 " Instructions for Updating the Effluent Management System (EMS) with l Isotopic Composite Results," Revision 0, February 5,1996 l Al 07B-028 " Instructions for Calculation of the Low Setpoint for Gaseous Effluent l Monitors," Revision 0, February 22,1996 Al 078-032 " Chemistry Radioactive Release Reports," Revision 1, September 12,1996 Al 26A-OO2 " Annual Radioactive Effluent Release Report Instructions," Revision 0, September 26,1995 Chemistry Procedures CHM 03-129 " Chemistry Use of the RM-11," Revision 1, April 8,1994 CHM 03-130 " Comparison of Gaseous Radiation Monitor Readings to Grab Sample Results," Revision 1, June 29,1993 CHM 03-161 " Preparation of Radioactive Gas Release Permit for Containment Purges,"

Revision 11, April 29,1993

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CHA RC-001 " Gross Alpha Measurement," Revision 0, May 31,1996 CHA RC-003 " Tritium Analysis," Revision 1, January 16,1996 CHA RC-004 " Gamma Isotopic Analysis," Revision 1, May 14,1996 i CHS AX-G01 " Sampling of the Unit and Radwaste Vents for Radioactive Gas and Tritium,"

Revision 1, April 2,1996

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CHS AX-G02 " Exchange of Radioactive Gaseous Monitor Particulate and lodine Filters,"

Revision 4, August 8,1996 Trainino Documentation CKL WQ-006 "Radwaste Operator Watch Qualification Card," Revision 6, dated

August 11,1994

Surveillance Tests STN SP-018 " Analog Channel Operational Test Liquid Radwaste Discharge Radiation Monitor HBRE18," Revision 8, July 10,1996 STN SP-045 " Analog Channel Operational Test Secondary Liquid Waste System Radiation Monitor HFRE45," Revision 5, February 22,1996 STN SP-052 " Analog Channel Operational Test Steam Generator Blowdown Discharge Radiation Monitor BMRE52," Revision 5, February 20,1996

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STN SP-059 " Analog Channel Operational Test Turbine Building Drain Radiation Monitor LERE59," Revision 6, March 23,1996 STN SP-095 " Analog Channel Calibration Test High and Low TDS Discharge to Waste Water Treatment Radiation Monitor HFRE95," Revision 7, February 23,1996 STN SP-110A " Channel Calibration Radwaste Building Vent Radiation Monitor GHRE10A," Revision 2, February 11,1994 STN SP-110B " Channel Calibration Radwaste Building Vent Radiation Monitor GHRE10B,"

Revision 3, August 24,1995 STN SP-118 " Channel Calibration Liquid Radwaste Discharge Radiation Monitor HBRE18,"

Revision 2, October 31,1995 STN SP-122 " Channel Calibration Containment Purge System Radiation Monitor GTRE22,"

Revision 5, November 21,1994

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STN SP-? 33 " Channel Calibration Containment Purge System Radiation Monitor GTRE33,"

4 Revision 4, December 9,1994 ,

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I STN SP-145 " Channel Calibration Secondary Liquid Waste Radiation Monitor HFRE45," !

Revision 3, December 15,1995

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, STN SP-152 " Channel Calibration Steam Generator Blowdown Discharge Radiation Monitor BMRE52," Revision 1, November 10,1995 ,

STN SP-159 " Channel Calibration Turbine Building Effluent Radiation Monitor LERE59,"

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Revision 2, December 8,1995 i STN SP-195 " Channel Calibration Hi/Lo TDS Discharge to Waste Water Treatment Radiation Monitor HFRE95," Revision 2, November 30,1995 STS IC-474B " Channel Calibration Unit Ventilation System Radiation Monitor GTRE21B,"

. Revision 7, August 24,1995

STN CH-011 " Calibration of the Particulate Detector for Gaseous Monitors," Revision 1, July 18,1991 STN CH-012 " Calibration of the lodine Detector for Gaseous Monitors," Revision 1, July 23,1991 STN CH-013 " Calibration of the Gaseous Detector for Gaseous Radiation Monitors,"

Revision 2, February 19,1992 Miscellaneous Documents Selected Liquid and Gaseous Radioactive Waste Batch Release Permits Annual Operating Radioactive Effluent Report - 1995 l AP 07B-003 "Offsite Dose Calculation Manual," Revision 0, dated December 12.1996

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