IR 05000327/1986002

Insp Repts 50-327/86-02 & 50-328/86-02 on 860106-10.No Violation or Deviation Noted.Major Areas Inspected:Gaseous & Liquid Radwaste Sys,Radiological Effluent Accountability & Reactor Coolant & Secondary Water Tech Spec Requirements

ML20137S779
Person / Time
Site:	Sequoyah
Issue date:	02/06/1986
From:	Cline W, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137S763	List: IR 05000327/1986002 ML20137S754
References
50-327-86-02, 50-327-86-2, 50-328-86-02, 50-328-86-2, NUDOCS 8602180117
Download: ML20137S779 (8)

Text

M E!u . UNITE 3 STATES

[k . 'o . NUCLEAR REGULATORY COMMISSION REGloN 11

[" 3 101 MARIETTA STREET,N.W.

$ Ij

• 2 ATLANTA, GEORGI A 30323

%,******/ FEB 111986 Report Nos.: 50-327/86-02 and 50-328/86-02 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facilitiy Name: Sequoyah Nuclear Plant Inspection Conducted: January 6-10, 1986 Inspector: 14 O / 3Fdum, l180 G. B. Kuto 1 Date[ Signed Approved by: 4 NG[T4 W. E. Cline, Section Chi'ef_ Date Signed Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection entailed 45 inspector-hours onsite in the areas of gaseous and liquid radwaste systems; radiological effluent accountability; reactor coolant and secondary water Technical Specification chemistry requirements; and review of selected inspector followup item Results: No violations or deviations were identifie PDR ADOCK 0 % y7 G

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REPORT DETAILS Persons Contacted Licensee Employees

'*P. R.- Wallace, Plant Manager

• J. M. Anthony, Operations Group Supervisor M. R. Harding, Engineering Group Supervisor

• R. W. Fortenberry, Engineering Section Supervisor

~*W..L.; Williams, Chemistry Unit Supervisor

• D. G. Amos, Chemistry. Engineer

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• J. D. ' Pierce, Radiation Chemistry Laboratory Supervisor

• G. B. Kirk, Compliance Supervisor

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• R. C. Birchell,. Compliance, Mechanical Engineer D..C. Craven, QA Staff Supervisor

• D. E. Crawley, Health Physics Supervisor H. R. Rogers, Compliance Engineer J. M. Hereford, Instrument Engineer

• J. A. McPherson, Engineering & Test Unit Supervisor

• H D. Elkins, Jr. , Group Supervisor,. Instrument Maintenance M. Cooper,.Mechanica1' Engineer M. Eddings, Engineering Associate

R..M. Sexton, QA Evaluator R. J. Griffin, NSRS Site Representative

• J. M. Qualls, Radwaste Controller

• S. W. Stevens, Chemical Engineer Other licensee employees contacted included engineers, technicians, operators, and office personne * Attended exit interview Exit Interview The inspection scope and findings were summarized on January 10, 1986, with those persons indicated in Paragraph 1 above. The inspector discussed a potential unresolved item regarding Technical Specification (TS) Semiannual Radiological Effluent reports (Paragraph 6.b). In addition, one inspector followup item concerning methyl iodide retention testing of ventilation charcoal Ladsorber was discussed (Paragraph 5.b). On January 16, 1986, NRC Region II representatives informed cognizant licensee personnel that

. proposed changes to the Semiannual Effluent Report to better meet the intent of TS requirements would be considered an inspector followup item instead of an unresolved item (Paragraph 6.b). Licensee representatives acknowledged the inspector's comments. The licensee did not identify as proprietary any of the materials - provided to or reviewed by the inspector during this inspection.

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3. Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

4. Audits (84723, 84724)

Technical Specification (TS) 6.5.2.8 states audits of unit activities shall be performed under the cogniza.!ce of the Nuclear Safety Review Board (NSRB)

encompassing conformance of unit operation to provisions contained within the TS's and applicable license conditions at least once per 12 months; the Radiological Environmental Monitoring Program and the results thereof at least once per 12 months; the Offsite Dose Calculation Manual (ODCM) and implementing procedures at least once per 24 months; and the performance of activities required by the Quality Assurance (QA) Program to meet the criteria of Regulatory Guide 4.15, December 1977 at least once per 12 months. The inspector reviewed the following audit report (a) QSS-A-85-0016 Environmental Monitoring and RARC, Radiological Effluent Monitoring, ALARA Program, September 23 - November 20, 198 (b) CH-8400-18 Radiological Effluent Monitoring, Environmental Dose Assessment, and Radiological Assessment Review Committee (RARC),

August 20 - September 7, 198 (c) CH-8300-05 Radiological Effluent Monitoring, Radiological Environmental Monitor Environmental Dose Assessment, and Radiological Assessment Review Committees, September 26 - October 14, 198 The inspector noted that the radiological effluent measurement program areas were audited against the Final Safety Analysis Report (FSAR); Technical Specifications; Regulatory Guides 1.21,1.33, and 4.15; applicable sections of 10 CFR; TVA Division of Nuclear Power and Office of Power Operations QA Manuals; and approved plant procedure The inspector noted that the most recent audit did not identify any concerns regarding the scope of this inspectio The inspector reviewed and discussed with licensee representatives corrective actions and/or evaluations regcrding a previously identified deviation regarding radioactive effluent release reporting requirements detailed in the 1984 audit report. This item is discussed in Paragraph 6.b. The inspector informed licensee representatives that the audit program for effluent measurements was adequat No violations or deviations were identified. Procedures and Manuals (84723, 84724) Technical Specification 6.8.1 requires written procedures to be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978 and the Quality Assurance Program for Effluent Monitoring, using the guidance contained in Regulatory Guide 4.15,

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December 197 The inspector reviewed selected portions of the following procedures: TI-9 Test Methods for Nuclear Aircleaning Systems, Rev. 5, 10/9/85 .TI-50 Air Flow measurement Methods, Rev. 4, 9/5/8 . SI-82 Functional Tests for Radiation Monitoring Systems, Rev.11, 6/21/8 . SI-83 Channel Calibration for Radiation Monitoring System, Rev. 12 11/7/8 . SI-132 Auxiliary Building Gas Treatment System Filter Train Test, Rev. 15, 10/24/8 . SI-142 Emergency Gas Treatment System Filter Train Test, Rev.10, 2/1/8 . SI-143 Control Building Emergency Air Cleanup System Filter Train Test Requirements, Rev. 9, 12/21/8 . SI-141 Functional Test for . the Radiation Monitoring System, Rev. 15, 8/14/8 . SI-204 Functional Test for the Radiation Monitoring System, Rev. 15, 8/14/8 . SI-205 Channel Calibration for Radiation Monitoring Systems, Rev. 11, 7/16/8 The inspector discussed TS ventilation testing procedures in detail with cognizant licensee representatives. The inspector noted that'in accordance with current plant technical ' specifications ~ laboratory analysis of representative ventilation system carbon samples for methyl iodide retention is required to meet the testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 197 The documented testing criteria (ANSI 510-1975)- require testing at a temperature of 80 C and at a relative humidity of 95' The inspector informed licensee representatives that for these test specifications organic contaminants may be removed, and the charcoal effectively regenerated, thus resulting in erroneously high methyl iodide efficiency rating The inspector stated that the most recent standard, ANSI 510-1980, references ASTM D3803, Radiciodine Testing of Nuclear-Grade Gas-Phase Adsorbents, which is now the recommended test methodolog The inspector informed licensee representatives that testing of carbon for methyl iodide retention should be conducted in accordance with this procedure and the test conditions selected, i.e.,

temperature and relative humidity, should reflect expected operational conditions for the individual ventilation system Licensee l representatives ~ informed the inspector that they would evaluate the new

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testing methodology for each TS ventilation sy s tem.- The inspector informed licensee representatives that this area would be considered an inspector followup item. and would be reviewed during a subsequent inspection (50-327/86-02-01, 50-328/85-02-01).

No violations or deviations were identified. Records and Reports (84723, 84724) The inspector reviewed selected portions of the following records:

' Chemistry Trend Charts (Units 1 & 2) for the following chemical and radiochemical parameters: Chloride, Fluoride, Baron, Silica, pH, Specific Conductivity, Gross Activity, I-13 . Ventilation Test Performance Results of HEPA and Carbon Bed Filters for the Auxiliary Building Gas Treatment System and Control Room Emergency Air Cleanup System (January 1983 -

January 1986) for the following surveillance tests: Visual Inspection HEPA Filter Leak Test Air Velocity Test Charcoal Bed Methyl Iodide Retention Test Charcoal Bed Penetration Test Delta Pressure Tes . Liquid Radiation Monitor Monthly and Quarterly Performance Checks and 18 month Calibrations (1984 - 1986) for the following: Liquid Radwaste Monitor R-90-122 Turbine Building Sump R-90-212

. Condensate Demineralizer Lines R-90-225' Auxiliary Building Noble Gas Monitor R-90-1018 Service Building Noble Gas Monitor R-190-132B Containment Building Purge R-90-130 The inspector reviewed selected surveillance tests with cognizant .

individuals. Tests were conducted within the required intervals and test results were adequate, TS 6.9.1.8 requires radioactive effluent release reports covering operation of the unit during the previous six months of operation to be submitted within 60 days after January 1 and July 1 of each year. TS 6.9.1.9 requires the content and format of the reports to follow the guidance of Regulatory Guide 1.21, a_nd also requires the radioactive effluent release report submitted 60 days after January 1 of each year to include an assessment of radiation doses due to the radioactive liquid and gaseous effluents released from the unit or station during the previous calendar year. The inspector reviewed the following reports:

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1) Effluent & Waste Disposal Semiannual Report, Supplemental Information, First Half 1985.

2) Effluent & Waste Disposal Semiannual Report, Supplemental Information, Second Half 198 ) Effluent & Waste Disposal Semiannual Report, Supplemental Information, First Half 1984.

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4) Effluent & Waste Disposal Semiannual Report, Supplemental Information, Second Half 198 ) Effluent & Waste Disposal Semiannual Report, Supplemental Information, First Half 198 ) Radiological Impact Assessment, Sequayah Nuclear Plant, January -

December 198 The ' inspector discussed the. Effluent Release reports with . licensee representatives. Cognizant licensee representatives . state'd that there were no abnormal releases for the 1985 second half reporting perio For 1984, the total dose to the -maximum exposed individual was calculated to be 1.1 mrem. The inspector noted there were no significant trends between successive years (1983 - 1985) for the following: abnormal releases,1-2 per year; number of releases, liquid (approximately 200 '- 350 per 6 months) and gases (approximately 350 -

450 per 6 months); gaseous activity released, approximately 2 to 4E+3'

curies Noble' Gas per 6 months, 2E-4 to 2E-3 curies Iodine per 6 months, and 7E+1 to 6E+2 curies tritium per 6 month In addition, the inspector discussed the four liquio radwaste effluent release pathways monitored for effluent accountability (Liquid Radwaste, Condensate Demineralizer, Turbine Building Sump, Steam Generator Blowdown). The inspector noted that wastes from the condensate demineralizer (CD)

radwaste is batched released normally to the Cooling Tower Blowdown (CTBD) system. However, low level CD waste'(less than 0.2 MPC) can be released to the Turbine Building Sump (TBS). Prior to entering the TBS, . a composite sample is made of the CD effluent. The inspector noted that the release from the TBS also is grab sampled and thus provides the potential for remeasurement of effluents from the CD system thereby resulting in an overestimation of nuclide releases as reported in the Semiannual reports. Licensee representatives agreed to evaluate this are The inspector also discussed with licensee representatives reporting requirements for the Semiannual Effluent Release Report as specified by TS and Regulatory Guide (RG) 1.2 The inspector noted that RG 1.21 specifies that the term, not detected, should not be used in report The inspector noted that this item also was identified in corporate audit report CH-830 Licensee representatives provided a plant Technical Specification interpretation of TS 6.9.1.9 and also informed the inspector that guidance regarding this reporting requirement was

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documented in a previous inspection report (50-327/80-08 and 50-328/80-05). The licensee informed the inspector that a decision was made to' report 0.00E0 for, less than, values in the Semiannual Effluent Release report The inspector stated that the li_censee's TS interpretation and previous irispection report would be reviewed by Region II management for detailed evaluation and interpretatio In addition, the inspector noted that the TS' required dose assessments

were being provided in a separate report issued by the TVA Western Area Radiological Laboratory. (WARL) Radiological Health grou The inspector stated that this report should be provided and issued with the required TS report and not as a separate documen Licensee representatives agreed to evaluate the inspector's commen The inspector informed licensee representatives that the format of the ef fluent release reports, i .e. , reporting of 0.00 E0 for, less than, values would be considered an unresolved item pending further review by Region II managemen On January 16, 1986, NRC Region II representatives informed licensee representatives by telephone that NRC Region II management did not agree with the Sequoyah Nuclear Plant .TS interpretation of TS 6.9. The inspector informed licensee representatives that following review and discussion of RG 1.21, TVA TS interpretation of TS 6.9.1.9, and review of a previous NRC guidance (IE report 50-327/80-08, 50-328/80-05) that (1) whenever a nuclide is detected in an effluent sample, it will be reported, even if the sensitivity limit is below required TS limits and (2) whenever an analysis for a nuclide yields a, less than, number, that less than number will not be used in' quantifying the release nor in calculating doses from the effluents. However a reference to a range of' detection limits, i.e., the less than number, will be contained within the report. The inspector informed licensee representatives that proposed changes to the semiannual radiological effluent reports would be considered an inspector followup item (50-327/86-02-02, 50-328/86-02-02).

No violations or deviations were identified. Inspector Followup Items (92701) (Closed) 50-327/84-28-01, 50-328/84-28-01 IFI: Provide Evaluation of Licensee Initiated Major Changes to Liquid Radwaste System Per TS 6.15.1. The inspector reviewed FSAR changes for the Condensate Demineralizer Waste Evaporator (CDWE) system. and the required 10 CFR 50.59(a) safety evaluation of the documented changes. This safety evaluation was documented in the Sequoyah Nuclear Plant Monthly Operating Report - July 1985. The required safety evaluation was adequat . . --

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b. -(0 pen)-50-327/85-38-01, 50-328/SS-38-01 IFI: Review of LLD Calculation .

Formula for Environmental Samples. The licensee was not prepared'fo NRC review regarding this ite s c. -(0 pen) 50-327/85-38-0'., 50-328/85-02 IFI: Improved ~ Availability of Meteorological Instrumentation. Calibration Records' on. Site. The licensee was not prepared for NRC review regarding this ite (0 pen) 50-327/85-38-03, 50-328/85-38-03 IFI: Improved. Surveillance of all -Environmental Monitoring Stations to Ensure Adequate Operabilit The licensee was not prepared for NRC review regarding this item.