ML20137X819
| ML20137X819 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/20/1985 |
| From: | Cillis M, Cook R, Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20137X739 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-312-85-28, TAC-60632, NUDOCS 8512100641 | |
| Download: ML20137X819 (29) | |
See also: IR 05000312/1985028
Text
{{#Wiki_filter:_ _ _ _ _ _ _ e . . [.. U. S. NUCLEAR REGULATORY COMMISSION REGION V 7 ' Report No. 50-312/85-28 Docket No. 50-312 License No. DPR-54 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station and Sacramento, California Inspection conducted: September 23-27, 1985, October 7-15, 1985 and telephone discussions of October 18, 21, 22, 23 and 24, 1985 Inspectors: bh uN. ch Ul20.94~ M. Cilli , adiation 5 p ciaTist Date 31gned uh ch 3 20 Td5* C Hooke diation Sp list Dabe digned k ont - u) 20/fis* u R. Cook, R tionSpecia}st Date Signed . __ pfj()/g Approved By: - v G{P .' Chief,, Facilities Radiological Date Signed Protection Section - ,. . ' .- ., i Summary: ' . , , , , Inspection on September'23-27, 1 85, O ober 7-15, 1984 and telephone discussions of October 18 21, 22,,23, and 24, 1985 (Report No. 50-312/85-28) a , , Areas Inspected: Routine unannounced inspection by regionally based inspectors ofzunresolved items '(NUREG-0737, II.B.3 - Post-Accident Sampling System (PASS) and II.F.1 -; Additional' Accident-Monitoring Instrumentation), chemistry and radiation protection organization, liquid and gaseous waste management, audits, licensee action on previous inspection findings, tests of air cleaning systems,. radioactive materials source control, and a tour of the facility. During this inspection, Inspection Procedures 25565, 83722, 84723, 83724, 92701, and 92702 were performed. The inspection involved a total of 140 hours onsite by three inspectors. 0512100641 851122 ADOCK 050 g 2 PDR 0 - __-_ - .--_- _- _ _ _ _ _ - _
_ __ _ ._-_ _ - _ _ _ _ __ ~ e . 2- . Results: Of the ten areas inspected, one violation involving failure to adhere to procedures as required in Technical Specifications, Section 6.11 (see paragraph 13), and one violation involving failure to perform a proper calibration of the flow rate monitoring devices in the reactor building purge vent and auxiliary building stack flow effluent radiation monitors pursuant to l TS Table 4.20-1 and Section 1.5.4 (see paragraph 10) were identified. Four deviations related to the unresolved item involving the licensee's failure to implement written commitments made to the NRC with respect to NUREG-0737 Items II.B.3 and II.F.1 (see paragraph 3.IV) were also identified. t . 4 9 4 % 4 4 I 9 6 . . . . . . . . . . . . ---
,- . , , , - - - _ _ _ _ . _ _ _ _ _ _ _ _ _. ... . . . , .. . 4 - , ' , 1 DETAILS 1. Persons Contacted l A. Licensee Personnel
- 0. Coward, Plant Manager
- S. Redeker, Operations Manager
+*F. Kellie, Acting Chemistry and Radiation Protection Superintendent +*R. Columbo, Regulatory Compliance Supervisor
- J. McColligan, Assistant Plant Manager, Nuclear Operations
+*H. L. Canter, QA Operations Surveillance Supervisor J. Sullivan, QA Engineering Supervisor +*S. Nico11a, Senior Chemistry Radiation Assistant (SCRA) +*E. Bradley, Supervising Health Physicist +*W. Spencer, Nuclear Operations Superintendent +*N. C. Brock, I&C Superintendent . +W. Wilson, SCRA S. Hanofsky, SCRA +*J. Reese, Plant Health Physicist +*J. Field, Technical Support Superintendent R. Thomas, Senior Nuclear Operations Engineer D. Wiles, I&C Supervisor H. Hardin, I&C Engineering Technician +R. Fraser, Senior Nuclear Operations Engineer , D. Cox, Senior Nuclear Engineer '
- A. Alvi, Principal Chemical Engineer
- R. Roehler, Licensing Engineer
F. Thompson, Training Superintendent +*H. Bua, Training Supervisor J. Dickenson, Chemistry Radiation Assistant (CRA) P. Howard, CRA 0. Martin, CRA R. Heyers, Emergency Preparedness Supervisor P. Wagner, I&C Engineer D. Talmm, CRA E. Madamoa, CRA W. Hampton, CRA D. Price, Training Instructor ! R. Bowser, SCRA J. Bower, Training Supervisor S. Carmichael, I&C Associated Engineer +R. Lowrence, Maintenance Superintendent B. Non-Licensee Personnel Applicd _ Ra_diologica1 Cont rols_ (ARC) R. Hewalt, Supervisor, Senior Hadiation Protection Technician !!.. Carter, Senior Chemistry and Radiation Protection Technician ' . e t 6 j r s - . - . - . . - . . - - - . - .
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_- . 2 Impell Corporation W. Hellums, Health Physicist +*P. I,avely, Health Physicist Bechtel Corporation
- J. Shelter, Outage Manager
C. Nuclear Regulatory Commission
- J. Eckhardt, Senior Resident Inspector
- G. Perez, Resident Inspector
- Denotes attendance at exit interview conducted on September 27, 1985.
+ Denotes attendance at exit interview on October 11, 1985. In addition to the individuals identified above, the inspector met, with and held discussions with other members of the licensee's and contractors staff. 2. Oraanization and Qualifications , Inspection Report 50-312/85-12, paragraph 3(b) identified that the site Chemistry and Radiation Protection Superintendent (C&RPS) position was vacated and the possibility that the Chemistry and Radiation Protection (C&RP) group would be re-organized. Discussions related to the C&RPS replacement and re-organization of the facility C&RP group were held with the licensee's staff during this inspection. The Manager of Nuclear Operations indicated that changes in the facility organization and the C&RP group were in the process of being implemented. These changes are based on the recommendations of two independent evaluations performed by I.RS and General Dynamics. The Hanager of Nuclear Operations informed the inspector that an individual has been selected to fill the vacated C&RPS's position. He added that recommendations made by the two independent evaluations were currently being evaluated by the licensee's staff and it was too soon to state whether or not all of the recommendations would be implemented. He expected that it would take at least six to twelve months before the final reorganizational plan would be determined. . The inspector noted that the preliminary reorganizational plans differ from what is currently prescribed in Technical Specifications, Section 6.2, " Organization". The proposed changes appear to indicate that the Chemistry and Radiation Protection group will be split into two separate groups (i.e. Chemistry as one group and Radiation Protection as another). Enhancement of the Radiation Protection staff is also , expected., The examination disclosed that position responsibilities and job titles are expected to change. The CARPS title is expected to change to Radiation Protection Manager (RPH). The inspector noted that the Chemistry, Radiation' Protection, Fire Protection, and Operations Supervisors will be reporting to the Operations Manager. Previously. -. . . - . -- - - -
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both Chemistry and Radiation Protection Supervisors reported directly to the Plant Superintendent. The inspector was informed that the RPM position will be able to report directly to the Plant Manager (e.g. dotted line) if deemed necessary. The new RPM is expected to report for duty on or before January 1, 1986. A review of his resume was conducted. It appears that the selected RPM's training (education) and qualifications are consistent with the requirements prescribed in Technical Specifications, Section 6.3, " Facility Staff Qualifications". The individual has approximately sixteen years associated with radiation protection activities at commercial and naval nuclear plants. The examination further disclosed that the acting C&RPS has been authorized to increase the current Chemistry and Radiation Protection technician staff from twenty-four slots to thirty-six slots. At the time of this inspection twenty-seven positions were accounted for. Twenty-one of the technicians were on hand at the time of this inspection. Eighteen of the twenty-one currently meet the qualifications prescribed in TS, Section 6.3. Other portions of the Chemistry and Radiation Protection organization remain unchanged from that described in Inspection Report 50-312/85-12. No violations or deviations were identified. I 3. Unresolved item (Unresolved, 83-24-01) Inspection Report 50-312/83-24, paragraph 9 identified as an unresolved item, whether the licensee had fully met the , intent expressed in NUREG-0737, Section II.B.3, Post-Accident Sampling System (PASS) and II.F.1, " Additional Accident Monitoring Instrumentation". Inspection Report 50-312/84-08, paragraph 2.V provided a summary of matters that remained unresolved. The NRC letter dated July 30, 1984 transmitting the inspection report requested the licensee to carefully review the report and take appropriate action to correct the basic cause of the conditions ident.ified. A subsequent written response with respect to the concerns identified in Inspection Report 50-312/84-08 was submitted to the NRC Region V office in a SMUD letter RJR 84-343, dated August 30, 1984. It should be noted that a Commission Order dated March 14, 1983, required that NUREG-0737 items II.H.3 and II.F.1 be implemented by February 1983. The Order states in part: "It. is hereby ordered immediately that the licensee shalt: Implement and m.iintair, the specific items described in the Attachments to this Order in the manner described in the licensee's submittain noted in Section III herein no later than the dates in the Attachments." The purpose of this inspection was to verify that the licensee's impicmentation of NUREG-0737 items 11.11.3 and II.F.1 van consistent with the order and the licensee's previous commitments. The examination included a review of NRC's Safety Evaluation Reports (SERs) related to Rancho Seco's PASS. The SERs were dated February 15, 1983, and
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b - 4 . . , , September 2, 1983. Rancho Seco's correspondence used as a basis for the ' preparation of the SERs was also reviewed. Additional information .. related to this matter is contained in Region V Inspection Reports ': 50-312/83-16 and 50-312/83-26. + 7 I. General Observations On April 26, 1984, a licensee task force was assigned by SMUD management to resolve all outstanding items associated with PASS. Members of the task force included a Principal Chemical Engineer, I&C Engineer, Maintenance Engineer, and Senior Chem-Rad Assistant. The Principal Chemical Engineer is the Task Force Chairman. . Discussions with the group disclosed that they have not met as a group for approximately one year or longer. Three members assumed that Task Force assignment had been disbanded. The discussions further revealed that the group does not maintain a full awareness of concerns identified in NRC Inspection Reports and of previous commitments made to the NRC. The inspector observed that there appears to be little or no direct management involvement in assuring resolutions are accomplished in a timely manner. The task force does not maintain a tracking system for assuring previous inspection findings and commiitments are resolved or are being implemented. The inspector also noted that the licensee's normal tracking system does not maintain records of prior inspection findings or commitments made with respect to PASS. The results of the examination are discussed in subsequent paragraphs. II. Summary of Matters Remaining Unresolved Inspection Report 50-312/84-08 ide.*.ified the below listed items as unresolved. The licensee's respon e pertaining to these items provided in the August 30, 1984 let.ter and the actual status based on this-inspection are as follows: , 6 .,- - , ~a. NRC' Concern " Sample Shields.kere not yet available. An Engineering Change Notice'(ECN) had been generated (Unresolved)". ' , . .C. ...s , , Licensee Response < ,. , "An-engineering change. notice (ECN) was not generated; however, - the District has contacted the only known supplier of such shields'., The detailed design information on the shields has '^ 'bcen requested for our review to determine the feasibility of , .the shields at Ran~cho Seco. At this time, the District will ' actively pursue the possibility of an in-house design for the sample shields. In either case, a final decision to purchase or design the shields will be made. The District will submit a schedule by October 26, 1984, for either an in-house design and fabrication or the procurement of vendor supplied shields to be at the Rancho Seco site." . - - - - -
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s .. , , , ' . s'. Current Status p , , Incomplete ab 'of September 27, 1985. No schedule was submitted
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for procurement and/or design and fabrication 'of the shields. , ~ ' y ' Licenspe's Comments
.- i The licensee's staff std.ed that, this itentwas delayed because f s of other prioritics. Ttle licensee is currently in the process , of negotiating the prprurement pf a vendor supplied shielded ,; ' collection system. .hodificat_ ions of the PASS will be required ~ to inco'fparate the 6se of a' vendor supplied shielded collection ' system. ,- ' sb. NRCEoncern'
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" Reactor Building asmpl d.ine to monitor R-15044 - Inspection ' . ^- Report No. 50-312/83-16, Sections II.A and B identified
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f questions related to the quality of iodine and particulate . samples obtained by WRGM, R-15044. Particulate and iodine line loses had, pot. bees evaluated (83-16-07, Open) (Unresolved)". . ,,
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. Licensee Response ' - , f' "The District re,sgived this concern during the exit interview - .g.onducted by Messrs. H. North and H. Cillis on May 25, 1984. ,. , ., , N Ac was pointed out that the sample line used to sample j containment atmosphere through the Post.-Accident Sampling ' . + system ja enot uses to measure, f odina or particulate per our ' Core Da%ge Assessment methodology (NEG.100). Therefore, the ' . question of iodine and particulate plate out in the sample line does not' apply.- Please referstb,, item II.h(83-16-06) of your letter 6f July 30, 198,4, where the Conunission acknowledges the resolut' ion of this item. Items 83-16 07 and 83-16-06 discuss the'same finding."7 , , - .' - ' , , . . , . Current Status ~
., . This mitterlis' closed (83-17-07) Tresolved). - '%. -
c. _ NRC Concern,' ' , . , Engineering completed, , " Relocation of Water / Nitrogen manifold. construction had not started. In additf(n, the licensee , identified the conductivity adjustment ot'the ion ~ chromotography system as an item to,be relocated, action not -. complete (Unresolsed)". .. s l f ! , ,
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, u - 9 ?- Licensee Response N- P (1). '! Relocation of the Demineralized Water / Nitrogen manifold [ is necessitated to meet ALARA-only under an accident. !; condition resulting in high radiation levels in the area of the manifold. The present location of-the manifold l- under non-emergency samplin'g 'does not pose an ALARA, k concern. . However, the District. recognizes the need for.' ' (, _. engineering and is in the process of procuring the-needed relocation of the manifold and'has completed the detailed hardware before construction can start. As of now, the construction is scheduled to'be completed by October 19, t. _ . 1984." - . ,, , ,meP= i ' ~ ' (2) "The" relocation of the conductivity adjustment to.the same >v room as the PASS. control panel is being investigated on'a - very high priority basis. Several test runs.made have not . ' & 3 ,. J ; 'N been successful;due' to the long run of cable between the 1:_ x Wheatstone' bridge,and the adjustment control and the
' d resulting electromagnetic noise from the surrounding .r , ,,i i .Ifields,.; An'other, test is scheduled to be conducted in the < ,, .,next two weeks'by(substituting a bigger bridge. We ~ . earnestly wishsto. resolve this problem as soon as- i L '[ , \\ J jossibli, but"have not had a great deal of success. E j At ' < .. J',. A / 'I any rate,'the District,should be able to complete this , ' [4 " 'research andl development process and finish the l ' , ' ,; ' installation'of remo'te adjustment capability by ~ ' f * September 28, 1984;", - '< 4- . , _ 1, f Ub ,% j ' Current Status . 4,,j . u > Relocation of the' Water / Nitrogen manifold has been completed. Relocationlof the conductivity adjustment to the same room as- ' E the PASS control room was incomplete-at the time of this , inspection; however, ECN 5735 had been recently issued to relocate'the conductivity bridges to the PASS control panel. (Unres,olved) - ' - Licensee Comments Relocation of the conductivity bridge is expected to b'e accomplished in February of 1986-(See Part III, item III(c)). d. NRC Concern ' " Inspection Report No. 50-312/83-16, Section II.B.2, identified ' a pressure limitation with respect to operation of WRGM, j 1 R-15044 (Containment Atmosphere) (83-16-08, Open) (Unresolved)". Licensee Response "The wide range gas monitor (WRGM, R-15044) used for the Containment' Atmosphere is designed to sample up to a sample . . _ _ - ,.
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< n , v u se 7p- .p4 q f 7 4 % l' b ' < ,. '^ '" ,y h. . . . . ' a pressure of 15.0 pounds per square inch above the atmospheric. - pressure.- Under a Design Basis Accident'(DBA) condition, as - ' evaluated in the FSAR fod Rancho Seco, the time period during q + ' . " - . . which the containment pressure exceeds;the 15.00 psig limit of y 1 ',' the radiation' monitor, R-15044, is. limited-to no more-than ' ' L 17 minutes and the limiting. condition takes place.only during. ' the.very early. stages of a DBA. Although the pressure-inside s e, - the. Reactor Building does peak to 57 psig, the SFAS' starts the , Reactor Building Sprays at 30 psig and the pressure transient , , - S- falls-below the 15.00 psig within 17 mindtes. The Core ' Darnage ' ,; 7 . Assessment Procedure which uses the information from'this. -l f . o ' ~ , monitor would not be activated before the accident condition ' a , - had first been' stabilized or several hours after the initiation ' ~ + ' ~ of th'e DBA. -The internal pressure limitation of.the R-15044 to - 1 ' . 5 psig during normal or accident operating condition does not 1 . ,e .in any manner pose a restriction on its operability or intendedt ' function." i Current Status ' , , l ' . This item is closed (83r16-08) (resolvdd). - 1. .. .g e. -NRC Conceru -y. " Reactor blailding isolation valves supplying containment monitors and radiation atmosphere samples to PASS, the H2 ' . monitor.E-15044 cannot be opened during plant' operation, due-to ' a Technical Specification limitatiod>(Unresolved). A proposal ~ to change current sample penetration to the penetration -Y ' . supplying _.the existing containment atmosphere monitor'is under consideration". F Licensee Response g, j "The four reactor building isolation valves,ttwo for-each train, are remotely' operated through operator'~ action and can be opened during the plant operation without the violation.of any ~ , , _ Technical ^ Specifications. According to our Technical [ g Specifications under the section of Containment Integrity;f t is - % stated,'"all. automatic containment valves are operable or~ . closed by4 Safety Features-Actuation System"Q Since all four'of , - the valWs ' meet the'" operable" criteria, the system is .' s functional during" plant operation. District wishes to point ' % 4 out an'additionhl safe _ty feature of this sampling line; the ~ , , ' "+: ,f_ Topening oilany one of~the valves does not in fact degrade the , , . wis51ation dfetlie contdinment to the out' side 'since. the sample ' ' - A ' , ~ "? I [ g
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. , h;,3 . Current Status % - . . , ..This item remains unresolved. The inspection disclosed that , g . -many of the' licensee's staff were unaware of the above response ' until.it.was brought to their attention by the inspector. It 1 - 'is. currently being evaluated by the licensee for final resolution.~(Unresolved)
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LNRC Co'ncern "No procedure:for cere damage assessment. The licensee had' ~ prepared NuclearL Engineering Guideline -(NEG) 100 Estimating . q'4 g Core Damage, original, April 10, 1984. The guideline was approved by the Engineering and;QC Superintendent. The 2 , guideline.had been prep'ared without coordination with the . Chemistry and Radiation. Protection staff. The guideline .S' -
-specified that containment atmosphere and reactor coolant water < , - -samples.were to'be collected using the PASS and analyzed'for , radioisotopic concentration. The PASS was not designed to s . ur -permit concurrent' collection of gas and~1iquid samples. The - +R breakdown in communications between the Engineering and -
- Chemistry and Radiation Protection organizations resulted in
< . the' generation of an-apparently unworkable procedure f L(Unresolved)". s - A ' Licensee Response ' ' p " - " Currently, the District doe's not have a Core Dauge Assessment , > Procedure (CDAP), but-has prepared a. Nuclear Engineering , Guideline NEG 100 which will-be.the basis for writing a ..* 'A ~ detailed CDAP. ~ District has scheduled the, completion of a ' 3N' -workable CDAP by September.12,- 1984. ~ ii -Neither the PASS nor.the CDAP or the present NEG.100 was , .intendedito require concurrent-sampling and/or analysis of <%>' ' liquid and gas' samples. Current. communications with the ' - ,' - LChemistry?and Radiation Protection.and the plant operations engineering groups have shown that the liquid and gas sampling ' ' ~ .'% x 'is. understood'by al1<t6 be'a sequential rather than a parallel- . ^ ', Q .' ' operation". g' j y Q?L .
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q . . This"iteswascompletId. Core.-Damage Assessment' Procedure I' i N AP.567 Re C 1, dated.03-01-85'has been implemented (resolved). ,, . y' ' <n r . , "?l c , ' ~ gj$NRC Toricern ^ , J .. -
~ w, , , m, o -- ,_ 7. ir . - .g" Boron?and Chloride anal' sis should be keyed to restrictions e j. ~ y ,- 4 # related tiCore Damage' Assessment -(Unresolved)". . b ' " f - ~ . ' ,." .t ' _3 ,; y , * ~ t: ; ~. ~ '
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- , . . '., 9 ' . Licensee Response ' This matter will be resolved during the development of the " 4 CDAP and will' meet the schedule commitment of October 12, 1984,. as discussed for item.(d) above." i Current-Status This item was, completed (resolved). ' h. NRC Concern r " Demonstration of representative sampling accuracy and range of analysis capability was not complete (Unresolved)."
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Licensee Response - " Work is continuing to complete and close out this item before September 12, 1984."
. Current Status This item'was incomplete as of the time of this inspection. It should be noted that-the PASS is designed to obtain a -
- containment atmosphere sample and reactor coolant samples from
the pressurizer, "B" OTSG bottom drain line, and the reactor building sump via the decay heat system. There is insufficient ' data to state with any degree of accuracy how well the system works. Representative sampling of containment atmosphere, "B" 0TSG bottom drain line,-and the' pressurizer had not been demonstrated as of~Septmeber 27, 1985. Representative sampling from the decay heat system is based on the comparison of'only two samples that were just recently obtained (e.g. August 28, 1985). To date, no attempt'has been made to sample from the , "B" OTSG drain line. Policies regarding startup and system i . testing,, frequency _for-use of the PASS system under normal - - plant _ operations, training, demonstration of representative , sampling, range of analysis, and accuracy have not been established. This' item remains unresolved.
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' Licensee Comments. [ j'* , [] [ The" licensee's, staff indicated that they are hesitant to obtain ~
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, 3.L samples from'the "B" OTSG drain line because it is a' potential ^ c crud trap whibh could~ greatly; increase the radiation levels ' 1 along'its lengthy' sample' lines if it were used. The staff ', ; iistated'theylhave not+been'able to demonstrate representative . "- ~j sampling of:the? containment atmosphere because of the problem '
, ~ discussed in 1 tem'II.(e),above; 7 . -73., ,. j;s i . , , 'N i. NRC Concern (NUREG-0737, II.F.1.2) rpx + ~' ~" Procedure. development for recovery of shielded and unshielded ~ iodine and. particulate samples from G.A. monitors. Procedures ' , y- m
F ~ - r . . .,e } -. . s , , 'AP.305-24, Reactor Building Air and-Stack Samples, Rev. 2, April 11,1984,. AP.305-26, Auxiliary Bailding Air and Stack ' ' Samples, Rev.-2, December 14, 1983 and AP.305'29, Radwaste - Service Area Vent Samples, original, July 11, 1983, address recovery of particulate and iodine sample media from the ' General Atomic (GA). Wide Range' Gas Monitor (WRGM) skid. = - TProcedares AP.305-24 and AP.305-26 provide. instructions for- collection of low activity,' non emergency samplesi Procedure , 3~ ' AP.305-29 provides similar instructions but does not- specifically limit sample recovery to low' activity,cnon: emergency conditions. None of the procedures address' recovery 'of high activity post accident samples (Unresolved) (83-16-09), , , -(Open)." I~~ Licensee Response- , -A All three of the above procedures will be reworked to address , , ' the recovery of the particulate and iodine media for transport x. y to the analysis station under normal and accident conditions of low and high activity, respectively. The District proposes the. proper completion of the three procedures by Octobe r 12, 1984."
Current Status This item remains open (83-16-09) (Unresolved). . Procedures: + were not developed to address recovery of high activity post ( accident samples. The licensee's staff could not determine why ' , p _this item was not' completed. ' ' e . 7 ,%, . ,- , III. Additional Observations n , ' _' - ' - . . - . . ,~ a. san NRC letter to SMUD, dated July 12, 1982 requested the 7 b .licensse'to, submit information related to the following - ' f (criterion:" '^1 n ~ f , ,
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,. . ., . . ',t.r'.' . . _ ." + y. - i> _, , , , < > % If,.in-line, monitoring is used for any' sampling and analytical " , ' " - - ,, capability,specified herein, the licensee shall provide backup. r . sampling throughJgrab samples, and shall demonstrate the l v' ' w -capability df' analyzftng the samples. Established planning for ~ . analysis at offsite' facilities is acceptable. Equipment , , _ _ ' . provided 'for' backup _ sampling shall be capable of providing 'at" ' (, ' least one sample per day for 7 days following onset of the. accident, and at least-one-sample per week until the accident - N condition..no longer exists. 4 < ,, u ' Clarification . , A capability to obtain both diluted and undiluted backup = p. . samples is required. Provisions to flush inline monitors to E facilitate. access for repair is desirable. If an offsite l laboratory is to be relied on for the backup' analysis, an li, ' ; - explanation.of theicapability to ship and obtain analysis for . I f l' . 4 ' s + c
~ . - - .-_ < .- , ' wh _ ," _31 l g , one sample per week thereafter until accident condition no - , [[ . longer exists should be provided." The licensee's respon'se datedT0ctober 13, 1982 to this request - reads as follows: Response ~ ' " Grab sample collection flasks are provided to' allow the , Jacquisition'of'any type of sample conditions. required to' perform the' desired analysis. 'As stated previously, methods , are still under development for-the handling, transport and
analysi,siof the grab samples." , Current = Status y ..m I ['SERs dated February 15, 1983 an'd September 2, 1983, recognize l 'that the licensee's, PASS-is capable of obtaining both diluted - - ~ - i \\ ,andfundiluted samples'as'hoted in the above response. The !""l ' ,lleensee's . system is cuirently _ capable of obtaining a three ' ~ ~2 <' milliliter 1(al) undiluted or diluted grab sample. The licensee ' is" currently inithe' process of ordering a complete sampling ~ s' Jp'ack'aiet(grab sample flask and shield) from a vendor. The grab - + 7- f sample-size is e d to increase up to.50 ml.if the vendor. g C [ p package is appro,xpecte (e ved. 2_ Q, 4 p yyg ' ,- '- < 7/At.the;present time,$prodedures for handling and shipping the' , . . 5o 1. expected highlysconcentrated undiluted' liquid samples (e.g.'10 / ) ' developed. Sample: shields _for 43'#1, Curies ml fhave notsbeentransportihithesampleswerenotavailableatthetime J w k - inspecti6n'(see it,em .II.'(c) .in ; paragraph c, _ above) . -~ , < w r, , 2 + . . , Licensee's-Comments 4The staff stated that they only plan to-take diluted samples ' until> such time that the vendor package and procedures become - ' available.s No firm completion date has been established for' completing this item. .The staff expects that there would be'a long lead time (e.g., early 1987) before thecshields will become available. ' - b. Updating of SMUDs Technical Specifications pursuant to Generic Letter 83-37,'"NUREG-0737 Technical ~ Specifications" to include , NUREG-0737,-Items II.B.3 and II.F.1 as license-conditions has not been completed. The' licensee proposed submittal (Amendment 83, Supplement 2 of January 23, 1984, and Amendment 100 of. January 23, 1985) are currently being negotiated between the ' ' ' ' licensee and NRR. , % c. The. licensee staff has submitted Modification Request No. 126,- - dated June 24,'1985,_" Post-Accident Sampling System Improvements" to management for the following improvements: tc, .s s ? , .E+ 3-
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-~ . w % w s _ _ I* . Add control.. valve in the pH/ conductivity loop to load ion ~ ' . chromatograph. r s I., Relocate Ion Chromatograph (IC)' support equipment, revise + . ' '
, IC configuration and replace Dionex Program Controller - 4
with a-manual: control panel. , .4 . - * Relocate isotope analyzer, power supply and cryogenic flask near' PASS panel. . n ,- - , - ' -* Move grab sample taps from east end to the west end of'the ' Sample' Collection and Analysis' Station (SCAS). ~ Replace SCAS' drain pumps P-710A&B. . -* i . Add' gross sample radiation monitor.
'
Replace Decay Heat ' Removal Containment Sump sa:sple line 11eaking valves. , " ' ' -
Add pressure, temperature and level instruments on ' ' -different tanks in the SCAS. ,
- . Simplify and create new graphics on PASS panel.
Eliminate unnecessary tube fittings from SCAS sample lines. , , '* Replace existing gas and liquid separatio'n tank V-715 and v - valve HV-70007. - - , The purpose for the modifications are: , -H - ~
- -
To improve the reliability and performance of PASS. To minimize the sampling.and analysis time for liquid and.
gaseous samples. To reduce radiation exposure for operating personnel.
, - ITo. reduce operator-training time. ' *- + p. .w A. Construction, startup testing, and turnover to Nuclear Operations of the above improvement items are not expected to - " be completed until March' 1987. 7-w ., , . - , m, _' % - ?. ../ . . W. . g? ,
- ' l'd..
.The/following observations related to operation of the PASS on r._
- ', ' l'lAdgtsst'27,and28',,1985, were reported by the licensee's Quality
Assurance staff in QA' surveillance reports.447 and 448: l
~; e . . j . - , ! a ? s.s c ' .t . <~ f * - ;QA'surveillancelreport 447 made the following observation: ~ , ' % ~" Chem-Rad personnel' struggled with a complex and. (i4)ijudreli'ble:systemtoprepareitforoperationduringthe t, ,/ & 7 .~c L - ' a . s Q~> o( l* iemergency drill.jThe Chem-Rad people demonstrated. o .. j z,.> 3 n 3 ,j , . . j> - a 1 . c
. .- .. ; R ~;f
- p,W \\f g ~l, , , 7, ; j - . - t' ' ' E r., ' yl'
- ,
., p y. i , %) y ~ ~
, , 13 - t1 , -i ; knowledge of the system and principles of'its' operation, but-were unable to make the PASS perform all.its design functions."' The-report.added: "The Chem-Rad personnel expressed frustration:that the problems they had ~ identified in the past were not resolved in a timely ~ . manner and that they were" under the gun "to make the ' system' operational in a limited amount of time." QA surveillance report 448 provided the following ' information: " Personnel attempted.to use the PASS operating procedure, but found it nearly impossible to ' -follow. .The area is too confined to use SCBA equipment and perform the assigned task,' even under the ideal conditions which existed during the drill. The ion chromatograph (IC) did not operate smoothly, and the remote controller unit for-the IC:did not change detector
ranges properly....The system would prove difficult, if not impossible to operate in its present configuration during a real accident. " Once it was determined that the procedure was unworkable, >- the Technicians manipulated the' PASS based on their system knowledge. The problem with the IC detector range was noted and corrected, and an accurate value for boron was obtained. A sample was drawn for the Ge(Li) detector and analyzed which produced an accurate radiochemistry: analysis (values were compared to Chem Lab results for Decay Heat samples analyzed earlier). A-qualitative indication of chlorides was obtained from the IC on a second sample. Following sample' analysis, a pressure spike in the demin water supply. caused the flow element-to jam and block the demin flush water supply to the PASS. , One potential Health Physics' problem with the system tdesign was noted by the participacts. Presently, a- minimum inventory of 8 liters of water must be maintained - in the PASS waste tank due to instrumentation design. During.an-actual ~ failed. fuel accident, 8 liters of reactor coolant (at'10 Ci/ml)~would contain-80,000 Ci. This - inventory would present a significant radiation hazard to , :anyone required..to operate the PASS under these conditions 'and.wo'uld . render the Ge(Li) detector useless." l > . ' ' [DiscussionswiththePASSTaskForceChairmanrevealedhehad _ not seen, -received, or been made aware of the above ~' e A: , ;,r
- shrveillance reports'.
, } L -> - -. .<. ~ e. A review of the PASS procedure AP.305-35, Rev. 5, dated ,i' ~ August 21, 1985, . was accomplished during the inspection. The , following, observations,were made: , , , - . . M . 1The procedure ~is 145 pages in langth, it has no index, and. '
appears to be-very difficult if not impossible to follow - , , - r -t . h'
., . - - - . .; - - - - - - - - = - - - - - + ,- - . + . < . . -- 14. ' , r . . . k 'by individuals'not having knowledge-or training in use of .the system. [ T< The: licensee is. aware ~of'these problems and.has taken steps to simplify the procedure. However, additional testing and the. improvements discussed under item III.c above need to be accomplished in order to simplify the ' procedure. In a letter to the NRC, RJR'83-512-of June 17, 1983, the f.
licensee stated: "The District will commit to refresher e training involving use-of PASS equipment for a sufficient nuaber of designated equipment users to insure the availability J of trained personnel to support post-accident sampling " requirements. The frequency of such testing / training will be every six months i25%." , - Th'e iriformation provided in the June ,17,' 1983, was used by-the NRC as'a basis for issuance of the. September 2, 1983 SER._ The SER concluded-that the licensee met all eleven of the criteria outlined in NUREG-0737 for PASS based on the information ' - provided in the June 17 letter. Current Status = Discussions'with~the licensee's staff and a review-of training records disclosed: The licensee's Training Superintendent, Task' Force
Chairman, and Chem-Rad group users were not= aware of the- June 17,.1983 commitments until it was brought to their attention by the NRC inspector. 1 . Designated equipment users have not been identified. ,At-
the time ~of this inspection one licensee' Senior Chem-Rad Assistant, one' licensee Chem-Rad Assistant, and Senior t; Chemistry and Radiation Protection Technician under ' ' jcontract to ARC, were the only PASS part time users . ? assigned to become' skilled in operational aspects and to ' - resolveiits: operational problems. , , - g _ The last clas's room. training conducted was in April.1984. , ~ - * [3 s7 ' - The licensee's staff stated .-that no additional classroom , , 'e - - , , or . hands-on' tiraining was provided-~since April 1984 except n for the' individuals discussed above who were primarily ~ ' ' - r assigned to'sssure the system worked properly for the ' > 4 ' ' w , " ~Jemergency)drillheldonAugust 28, 1985. , . < i q L t,. ' " v ...,'g '*_ ,Several!of thefpreviously trained individuals have either i ~ movedton to other positions or are no longer employed at ' ." ' ! :SMUD. Y v - , U~ - , ' ' ~ '. . 4 3 n -- -
- '
! Discussions were held with the individuals that were != " .previously trained in 1983 and 1984. Seventy-five percent , p a , . ,,- ),- - $' f '*l u- 7 y e ey -i,99 g- s.. ,..g->,,y-pggm- ..y-+p.,----- .-= , .- ,.. yyw y 5me u-e --9 -- .n.A- 'v
, - . . . , - - li - 115 , < . . < - . .
' of~those questioned stated th'ey currenily would not be "" ~ able to' operate the system unless.they received. additional ~ training (e.g. ,' class room a'nd on-the-job) . The remaining" twenty-five percent stated they felt they could operate .
- the PASS by-following the procedure. All individuals'
"
- i _
s questioned stated that they had not. received any ' ' additional training or conducted hands on training since - < J receiving the initial training. , .
- g.
The inspector asked-the licensee's staff if they:would be able . to demonstrate tbeir capability to sample the containment- ' atmosphere and reactor coolant with the reactor st 100% power , utilizing. individuals selected by the inspector. The inspector - uazuVR stated the selection would be made from those individuals - ' " _ previously trained in 1983 and 1984; however, individuals involved in the August 28, 1985. drill, were to be excluded from 9'1 the selection. '
- . The-licensee's. staff stated they would be willing conduct"the. ,-, b . However, they felt the staff lacked: .(1) an demonstration. awareness of the changes that have occurred since they were- ' previously trained,_(2) hands-on training, and (3) the current _ operating procedure was extremely difficult to follow. Therefore,:the staff felt it would be useless to conduct the- - demonstration. The inspector agreed. ' IV. Summary of Matters Remain'ing Unresolved , m, - - _ PA,II.(a): ' Availability,of PASS sample shields. > ' - 4: ts M - .. . , . ~ . -
- ~.?'
The licens~ee was infbrmed that this item is an apparent' ~~ _ ,-]ldeviafionifromtheirAugust 30, 1984 commitment - -
,- - *l/ -(85-28-01).;. ~ , , .u 3 : ,, , x. n. u .s s ,
- II-(c)
- *Relocationiof Water / Nitrogen manifold and ion
- 4x
/ - g a[ I 1 [ chromo,tograph contiols'. - s , m , 'e>Ti* ,s; : .v 3 + , i %J,_ }}. 'V IThe licen'see"kas id' formed that failure to finish' the =r , .- . installation $of remote adjustment capability by
"p ~ . " ,
5" ' September,28, 1984,'their August ,was an apparent deviation of their L, commitme'nt'made in 30, 1984 letter- . , , 1(85-28-02). . ., . " % ~> ,' , ,II (e): . Inability to obtain reactor building atmosphere sample , during operation resulting'from Technical Specifications- imposed restrictions on isolation valves during << opersti6ns'. . (Unresolved) ~
- -
. ' The inspector reminded the licensee that this problem was . , ' identified in September 1983 (see Inspection Report- 4 - 50-312/83-24, paragraph 9) and of their August 30, 1984 "- response which stated that the system is functional during plant. operations. The inspector informed the licensee that a final resolution to this item must be determined in ' s - , $ s 4 Y >&
. _ - ' ~ - > . . . .. 4 . l x -16 ' - - _ , A n > . a timely' manner even it requires the installation of JC, " < "' ' Engineered' Safety Feature type valves. (; 6
1/~ .II (h): , Representative sampling, accuracy, and range oft. capability. ' not demonstrated and documented. (Unresolved) r ~ ' , It is not clear' whether the . licensee has . fully met the. ' intent of Criterion 10.; expressed in NUREG-0737, 1.. Section II.B.3 and as provided in their response to,this , item which is identified in a licensee letter to the NRC -dated, May 2, 1983. The May 2nd letter states, "These items will be verified during the startup and system 1 , testing". As previouslyl discussed, the licensee has not
- ~-
d" , demonstrated that representative reactor coolant samples from the pressurizer, "B".0TSG bottom drain line, or cdntEinment atmosphere can be obtained. . Currently.the. ~ / licensee's capability related toLthis topic is: based , ' solely on two' reactor coolant samples taken1from the decay - - .,_ i, s i. heatisystem. _The examination disclosed that the licensee , , ' N H'" fl e ?'. '" , has not defined or. implemented a PASS startup and system 7:testingrprogram, nori did it appear like the licensee had - , < , p ,. ._s 'y ' - \\'r/ sufficient, data:available that clearly indicated the PASS ' , , sis Efunctionedias it was designed. - y s {^ < ,- e . . > , [I'I'(if:s[hf66Edur'Es(fo[tlIe. recovery of high activit ' - 's d '( {* ppost-accidentIsamples hsve not'been developed (NUREG-0737. ~ frN q ' < II F.1.2).' t > ? ' . * * M. ..J
M $44; /44xs ,;~ i ~ ' %[ } # Thelic5nseewas[infirbedthatthisitemisanapparent' - e _. t.lyAr '$ dfviat' ion' fr'om the', commitment provided in their letter of - . , ' t' ~ -August /30,' 1984, which' stated the procedures'were to be-
' " completedby' October 12,' 1984. (85-28-03) ~ ' s t. ' ,Y , 'i ' . ( , III (a): La'ck of-procedures.for obtaining undiluted backupJsamples. -(85-28-04,' Unresolved). , I C This is a'new observation. '~
. . . L III (d)~: Development of simplified PASS operation procedures which- 'can be quickly. consulted under emergency conditions. ' '(85-28-05, Unresolved)- ' This is a new observation. ' ~ -III (e): . Training of PASS equipment users. f _ ^ -The licensee was informed that this item was an. apparent - deviation'from the commitment made in their June 17, 1983 c , ,. ' letter-to the NRC. (85-28-06, Unresolved) , . .., ^ .. .The 'above observations and.other findings . discussed in this section Lu were brought to the~ licensee's attention.at the exit interview. The ' b . licensee was further informed that it was not fully clear whether ' " '
- -they: met the; intent of NUREG-0737.or the Commission Order of
, h . I s > y > p s, <_
,_ , _ s.: '. J - fy, , 17 " '. . , < . f - i . r ., iq March 14, 1983. The inspector expressed concern about the informal - - Japproach taken with respect to training, defining how the system J, will be utilized under normal plant operations, the startup. testing '* ' program, and what appeared to be a lack of direct management. ' i involvement. This item remains unresolved.-- (83-24-01) ' Radioactive Effluent Releases - Gaseous ' Licensee records of gaseous waste releases for the period of October 1984' through' September.1985 were_ examined for the purpose of verifying ' . ' > compliance with Technical-Specifications, Table 4.22, " Gaseous - Effluents." Selected records ~ and portions of the following documents were reviewed: -
. . Procedure AP.305-14, " Environmental Releases of Airborne '
-~ Radioactivity" .
Procedure AP.305-22, " Air Sampling Gland Steam Exhaust" . Procedure AP.305-23,. " Air Sampling Condenser Air Ejector" '* ta Procedure AP.305-24, " Reactor Building Air and Stack Samples"
~ Procedure APz305-25, " Waste Gas Decay Tank' Sampling"
. . Procedure'AP.305-26, " Auxiliary Building Air and Stack Samples"
Procedure AP.305-29, "Radwaste Service Area' Vent Samples"
~ Discharge and release-permits for the period of October 1984 through
, _ September 1985. Semiannual Effluent Release Report of September 26, 1985. >
- -
Annual' Radiological Report of March 29, 1985.
QA Audit Reports-#0-678 of December 14,-1984 and #0-691 of May 3, 1985. FSAR,'Section 11.1, " Radioactive Waste Handling"
!^ 'It should be noted that paragraph two of .the " Bases" in Section 4.20 of -the TS-states the following':~ - sw . r _ ' The flow rates ,in' the Rea' tor' Building Purge Vent, ' Auxiliary - ~
- ) Q
- c ' . , Building 1 Stack and Radwast'e'. Service Area Vent are constant as they , use single < speed-fans.' The' Reactor' Building Purge Vent has two; ~ ',w differentiflow rates,4 winter and summer, however, administrative controls.assureiu' sing-the' correct flow rate where applicable. 'The " i. actual-flow rate of'the v'entilation systems are periodically
- 3
Q eternihed'b'y' surveillance procedures. The' flow rate measurement ' devices are used 'only 'as flow iddicating devices and not for actual c ( Jmeasu' rem'edt[ oft flo'w' rate. - Also,' as these flow rate devices must be ' - .e -
- _
1 _ ,1 , '* ~-
.
- j
( m.. . e
- - ~ , &~ ~ ' , , j ij b ,, Ij i - J, , N ~ , - V. fj'i K. ,!
, . _ - . 13 . removed from the ventilation system for the channel test, and in addition transported to the manufacturer for calibration, the frequencies have been set as shown in Table 4.20-1." Additionally,-TS, Table 3.16-1l states: "With the flow rate device inoperable, effluent releases may continue provided the flow rate used is the maximum design flow rate." The examination disclosed the following: (a) .The licensee's staff was unaware of the conflicting statements in the TS concerning that flow rate measurement devices are used only as indicating devices and not for actual flow measurements. Therefore, procedure'AP.305-14 allows for use of the measured flow rate for calculating releases from the Radwaste Service Area, Reactor Building Purge, and for the Auxiliary Building Stack. The inspector brought this observation to the licensee's attention. This item will be brought to the attention of NRR for clarification. This item will be examined during a subsequent inspection. (85-28-07) (b) The SCRA responsible for reviewing discharge / release permits was not aware of the Table 3.16-1, TS requirements related to use of the maximum design flow rates. (c) Maximum flow rates used for calculation of Reactor Building Purge releases were inconsistent. Flow rate values of 74,000 CFM and/or 77,000 CFM are being used on an interchangeable basis. The maximum value designated in AP.305-14 is given as 77,000 CFM, whereas, Section 9.7 of the FSAR and some discharge permits provides a value of 74,000 CFM. This observation was also brought to the licensee's attention. (d) The Reactor Building Purge flow rate measurement device was reported as broken sometime prior to April 7, 1984. A Nonconformance Report (NCR) to replace the device was issued on July 11, 1984. The device did not get replaced. It was still inoperative at the time of this inspection. The inspector was informed that the flow rate measurement device may not be installed in a location (e.g. stack) which is representative of the parameters that the device was designed to measure. The staff stated that the device was installed upstream of the exhaust blower and filters. A review of P&ID revealed that the device was installed in the location identified by ~ the licensee's staff. 'It appears that any leaks between the measurement device.and stack may not be measured. This observation was. brought to the licensee's attention. This item will be examined during a subsequent inspection. (85-28-08) -(e) The inspector noted that-several (4 of 12) discharge / release permits contained math errors. None of the errors had any significant affect.on the outcome of the releases. All of the discharge / release permits had-received an internal review by a SCRA. The , ineffectiveness of the licensee's1 review process with respect to this item was discussed at the exit interview.
ae v' y e < .- y( - 19 . B'ased on'the examination, it appears that gaseous effluents were within ppt 10 CFR Part'50, Appendix I design objectives.
- No violations or deviations were identified.
- , .
- 5.
Follow-up on Previous Inspection-Findings " .I. ' Enforcement' Items ai '(Closed)' -Inspection Report 50-312/84-17 identified the ' licensee's failure to audit the performance, training, and qualifications of the entire facility staff as~ required by i ' Technical Specifications, Section 6.5.2.8.(b), " Audits". The , ilicensee's written response dated November 21, 1984, identified ' that appropriate corrective actions would be implemented by- March 1, 1985. A discussion related to this item was held by ' the licensee's' staff involved in implementing the corrective ' actions identified in the. licensee's letter of November 21, , , 1984. A copy of licensee Audit Report No. 0-727 dated July 31, 1985, and the applicable checklists (MSRC #4&32) used to perform the audit were reviewed. - - Minor discrepancies with the audit report were noted by the inspector even though the audit appeared.to'be consistent with- TS,~ Section 6.5.2.8(b)' requirements. The inspector noted that~ the audit indicated that all of the. Chem-Rad Assistants (CRAs) met ANSI N18.1-1978~ qualifications even though the licensee's ' ' Chemistry and Radiation Protection staff had informed the . ~ inspector that two CRA's still did not meet' ANSI N18.1-1978 qualification. The inspector also noted that the audit failed to determine whether the current training program for the Chemistry and Radiation Protection group is in compliance ~with Technical Specifications, Section 6.4, " Training". The inspectors observations were discussed with the licensee's staff responsible for performing the audit'and was also-brought to the licensee's attention at.the exit interview. The licensee's staff informed the inspector that an audit of the ' licensee's current training program would be accomplished for:
- the purpose of verifying compliance with TS, Section 6.4.
-The f inspector emphasized the need for improving the effectiveness of-future audits. ~This matter is considered closed. .
'" ' '(84-17-13). - , _ , IIj[ Follow-upItems, , I , -fa. 4 (C1'osed)f(50-312/85-12) Concerns related to the establishment
, 11 of procedures for: (1) determining exposures resulting from i personnel skin' contamination occurrences, and (2)'for providing instructions >to) radiation protection technicians in prescribing -m - -the"placeme'nt of personnel dosimetry are discussed.in J paiagraphs'3.d.3'and:5 of Inspection Report 50-312/85-12. The
~1icensee'stactions.related to_these concerns were examined and , l' were foundLto be satisfactory. This matter is closed (85-12-01 . .and;85-12-02). . "A ' - ,e , 1 e _
m _ .. - ' .> " t a 20 - - . % -
> w , . , . , i
' p* . ~ f , " b 3:l b. (0 pen) Follow-up (50-312/83-16) Paragraph 10 of Inspection ', Report 50-312/83-16 identified that a modification of Radwaste ' ,' - Service ~ Area Ventilation system was in progress. ~ Based -on discussion held with'the licensee staff on October: 28,
, '1985, the purpose for the~ modification was to enhance the exhaust ventilation system servicing'the grade level of the 4 auxiliary building. The licensee staff indicated thst the unit will service the hot machine shop, decontamination room, waste D compaction room, and the mezzanine area. -The modifications ' have been completed. The staff stated that.the system would be. , turned:over to operations upon completion of the preoperational test program. This is currently being heldup because of a y s - manpower shortage. - The inspector observed that the personnel and equipment hatch on the grade level of the auxiliary building is normally -maintained open to the outside environment. Section 9.7.1.2 of a the FSAR states: "The path of ventilating air in the potentially radioactive contaminated areas is.from the areas of , low activity towards the areas of progressively high activity." ' Discussions'with the licensee's staff indicated that no checks are made to assure an inward flow is maintained adjacent to the personnel and equipment hatch opening. :The licensee's staff assumes that a negative pressure-is maintained because of' system design. Tests to verify that air-flow patterns have not - " changed since the system was last balanced are.normally not ' e: . . performed by the licensee since they are not required by the ' Technical Specifications. 'The inspector presented the open hatch as a potential unmonitored release pathway to the licensee representative. ' - The licensee representative indicated that they would look into ' this matter. The' inspectors observations were brought to the licensee's- attention. The need to complete the testing of this system in a timely manner was emphasized. (83-16-02, Open) c. Testing of Air Cleaning Systems ~ (Closed)' Follow-up item (50-312/84-27) ' Inspection Report ' 50-312/84-27, paragraph 5 identified that twenty-four open . items'were found.bydn%11censee's in-depth audit of filter - - ' s . systems required by Secti'on(s) 4.10, " Emergency Control Room
3 t. Filtering System," 4.11, l' Reactor Building Purge Exhaust s ' , y" ; Filter Systems'." 'The? licensee audit report, 0-661, stated that Filtering'Systein" and 4.12f " Auxiliary and Spent Fuel Building 3 . "_ .. complete compliance with the TS requirements was questionable. q. , , , - l Ailicens'ee lvEAt-report-84-23 of January 29, 1985, described the~ findings.,ofithe audit. ,The LER provided the root causes of ,. . w , t - 4 s e , ,
N'# . ?, s , ,
- f(
7 4 ? 5 + , . .4 4
y . . - . - - , I ' j '9 f.
- - , j 3- f, - - - 3 , , 21 g; , e g, 7' the items identified and the' corrective actions taken to bring .y the. program into compliance with the TS. ' , g. ' An examination was conducted for the purpose-of verifying that ' < the licensee's. corrective actions were accomplished and that . the licensee's current program was consistent with the TS. - . Selective records related to this topic were examined. ' . . . ,. The examination disclosed that the-licensee has completed the corrective actions identified in the LER, personnel responsible for the program were trained,'and procedures were revised and _ implemented to bring the program into compliance with the , ' regulatory requirements. , , A review of the procedure changes and of selected surveillance , checks of 'the. filter cleanup systems .that were performed during the 1985 refueling outage' indicated that the licensee's program ,, appears to be'consiiitent with the regulatory requirements. ' , iThis matter is closed. ,(84-27-02) . ' % ,
, _ ,. _, ,, _ _ . %No violations or deviations;were identified. . ~ _ .- , <,/ , ,y ,L
, , 6. - Testinarof Re' actor Coolant' Water Quality 1 4 . , LCO'sIan'd! testing'of the reactorTcoolant system activity is specified in ' TS, Section.3.1.4, " Reactor Coolant System Activity", and Table 4.1-3, . "Minimus Sampling Frequency". ' , _ , '; ( ' ' . .. . Records including reports of radiochemical analysis, gross activity, i chloride ..oxygeni and fluoride concentrations for the period October 1984 through September 1985 were ~exaniined. Additionally,' samples and, analyses ofIthe, borated . water storage' tanli, core flood tank, spent fuel storage ' po'o'1, 'aind cooling tower . blowdown, were also reviewed. ' .. .r- ' All results were'within the TS both as to limits and'the test . frequencies. The licensee's tests were normally performed at a frequency - 4 that' exceeds the th,ose specified in the TS. s , , , . , i . No violations or deviations were identified.
7_ . -Liquid Holdup Tanks . , ~ 'The inspector verified, through discussions with the licensee's staff and e a review of appropriate records, that the quantity of liquids contained in' Regenerate Holdup Tanks and Outside Temporary Tanks contained less h p, than the-10 Curie limit prescribed in TS, Section 3.17.3. > 4 w No violations or deviations were identified. - 8. Radioactive Effluent Releases-Liquids
A The licensee's records of liquid waste releases for the period of October 1984 through September 1985 were examined for the purpose of determining compliance with Technical Specifications, Section 4.21, " Liquid ' a o T
- "?
, n at '[' i + . . . .
n-
ys f. ', "" , , Qf , , 22 '
- J
Q
, , if , .. ' 4 3 Effluents". Release permits and analytical records for the period ' , between Occob'er 1984 and September'1985 were reviewed. o , Concentrations of radioactive materials in liquid wastes were les: than the Lower Level of Detection (LLD) values (excluding, Tritium) in - Technical Specifications, Table 4.21-1. _, ~ > A11111guid' radioactive releases from the plant.are made from the Regenerate. Holdup Tanks-(RHUT) to.the retention basins. Releases beyond. ' the site boundary.are made from the retention basins. All RHUT releases are sampled and analyzed pursuant to TS, Table 4.21-1 and monitored with a Process Effluent Radiation Monitor (PERM) (R15020) as required by TS, Section 4.19,'" Radioactive Liquid Effluent Instrumentation". There are - no specific TS requirements governing the monitoring of retention basin ~ , releases with a PERM and for obtaining and analyzing of grab samples. - However, the licensee has always obtained grab samples of retention basin releases and until February 1984 monitored basin releases with ' PERM R15017. PERN R15017 was used as a' backup to PERM R15020; however, it is no longer in service. The licensee is in the process'of replacing it with a more sensitive dual channel system (R15017A and R15017B). The licensee's staff indicated , ' - that_the replacement system installation would be completed by March
-1986., The replacement system is designed to provide an isolation ' ' function. This item will be examined during a subsequent inspection. , (85-28-11) Licensee procedure AP.305-13, " Environmental Releases of Liquid - Radioactivity" which was established for ensuring compliance with the . regulatory requirements referenced above was reviewed. The licensee's , liquid effluent releases appeared to be consistent with procedure l AP.305-13 and what was reported in the licensee's 1985 Semiannual- . Effluent Release Report that was submitted to this office on p ~ f' September 26, 1985. The examination disclosed that there were no significant J unplanned / abnormal releases during the period of October.1984 through , September 1985. All releases were sampled and monitored in accordance with'the TS, Section 3.17.1. The alarm set point ~ determinations for the liquid effluent monitors were accomplished in accordance with the liceasee's Offsite Dose Calculation Manual (ODCM)'. The review of grab' sample analysis records disclosed that no releases ' containing detectable concentrations of fission or activation products " ! were made in the period of, January 'through September of 1985. , - No viblations or deviations.were [ Identified. s.: / - , ' l 9. Gas Storate1 Tanks. , - , / . ' p - < 7 The ' inspector, verified,,through discussions and a review of approprir te . records, that;the quantity of4 radioactive material contained in each _ storage, tank were determined pursuant to TS, Section 4.24 and maintained below.the l'imit prescribed in TS,,Section 3.20. The review disclosed. i '
' ~, . , , , f ,,
- g
.. 7t, ' 4 ,
h'f ',, sh 7
- }s
p, j
..% ' _s
% [ f 5 2
- ."
- -
. V, 23: , i that quantities contained in.the licensee's storage. tanks.at any one time never exceeded a small fraction of the 135,000 Curies allowed by the TS. No violations'or deviations were identified.' . t ' 10.' Liquid and Gases Effluent Instrumentation ~ Selected records and procedures associated with-the surveillance testing of radioactive. liquid and gaseous effluent instrumentation were examined. , _ A; random sample of liquid and gaseous waste release permits were also examined to verify that the set points had been determined in accordance
- with the licensee's Offsite Dose Calculation, Manual (ODCM). During a
tour'ofLthe licensee's-facilities, operation of effluent monitoring . instrumentation was confirmed. Technical-Specifications,Section(s) 3.15, 3.16 4.0, 4.19 and 4.20 , . provide. regulatory requirements for radioactive liquid and gaseous effluent-instrumentation. The require =ents and frequency for . demonstrating the operability of instrumentation by the performance of instrument channel checks, source checks, instrument channel calibrations, channel tests, and establishing of alarm / trip setpoints are provided in the applicable TS. Sections reference herein.
- The following procedures were reviewed
' I-602, " Area Radiation Monitor Calibration"
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I-603, " Liquid Radiation Monitor Calibration % I-604, " Gas Radiation Monitor Calibration" -
, I-605, " Radiation Monitor System Monthly Test"
I-651A, " Steam Line Radiation Monitor"
s , . . - . I-652, " Reactor Building WRGM"
I-653, " Auxiliary Bui1 ding Stack WRGM"
' , I-654,e"Radwaste Service Building Stack WRGM" - *~ SP200.2,f"DailyLInstrumenESurveillance"
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SP200.3, " Weekly Inshrument Surveillance" .. n~ j ' SP200.7;" Daily / Weekly [RadiationInstrument-Surveillances"
z m- , . , , I-011',," General Calibration Procedure" 1* ' , -
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, ' - ~AP.165,' " Radiation'Monitorin'g System" . .e ,
_,. Th'e. definition of an ." Instrument Channel Calibration" provided in Section 1.5.4 of the TS states the following: "An instrument channel calibration is a test, and adjustment (if necessary), to establish that ~ , I ' s _r- , , v . - - - - r-.- -gm .+ - - . . - - - - ,eg - s.- - - - , , - . - . . - ,-o,-,-. ,4-
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,e a , - . , - 24 ' uthe channel' output, responds with acceptable range and_ accuracy to known sb values of the parameter which the. channel measures or an accurate simulation.of-these-values. . Calibration shall encompass the entire channel,_ including equipment actuation,' alarm, or trip and shall be , deemed to include the channel test." TS,1 Table 4.20-1' requires that-the ~ sampler monitor flow rate measurement-devices for;the reactor building purge vent, auxiliary building stack, and radwaste service area PERMS be. . calibrated every two years. A discussion;with the. licensee's staff and a > ' _ review.of the method used for accomplishing the calibration of these- devices. disclosed that the calibrations performed by the licensee's-staff ' , 'on June'24,l1985 did not quantitatively compare the measured flow rate to a'known value. . The inspector was informed that the calibration technique ' employed.by the-licensee only verifies that the high and' low alarm setpoints provide an electronic signai at' selected points corresponding. , to scale values. The alarm points are set with an electronic _ signal. < _ ' The -actual value of the flow indicated a't the alarm setpoints were not verified. The licensee's staff; stated that they have.not established _a ' . method for comparing the ficw that ihe chennel measures to known values. 1 The_ inspector informed the licensee that failure to verify the values of the parameter (flow) which the channel measures was an apparent violation. (85-28-09)- fThe' examination also disclosed the following: Surveillance procedures for accomplishing the Instrument channel
- calibrations of ..the System and Monitor Flow Rate Measurement Devices for the instrumentation identified TS, Table 4.20-1 were not , ' developed at the time of this inspection. ' The high alarm set point value recorded'on the control room air and
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- ventilation intake radiation monitor monthly surveillance checklist
for February 1985 was listed as 100K' cpm. The high alarm set point value provided in procedure I-165 for this monitor is listed as - 10,000 cpm. The licensee's staff indicated it was an obvious error.
- The inspector noted that the error had gone undetected during a
< review of the checklist that was conducted on February 25, 1985. A. monthly surveillance check of the gland seal steam exhaust monitor
was not performed during the month of' June 1985 as required by; procedure I-65. The missed surveillance had not been detected by a- '. licensee review conducted on June 26, 1985. , y'. , _ w - - The above observations and theiviolation involving the failure to properly calibrate the PERMS flow rate devices were brought to the ' 3 , licensee's attention a.t th.e exit' interview. ~ < - y2 _ 11. ~Radloactive" Materials Sou'rces.. ,* , . '. Tec inical/ Specifications', Section 4.15, " Radioactive Materials Sources" ( _providesithe regulatory requirements for performing leakage tests of .[ radioactive;materialjsources.' ' 4 . ..
- An examination of{the
- licensee's" program for assuring compliance with TS,
Section,4.15 was. conducted. Accountability and leak test records related
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. m u, j . =w .. , 2 25 - pe g > 4 , w p ~ - 1 - - q ' + 7' .to'this topic were reviewed. The' inspector found that the licensee's , F p ' radioactive materials leak test program was implemented consistent with ' the regulatory requirements. s EN 'No violations.or deviations were-identified. S= 12. .Seco'ndary System Activity- '.gj [" " The inspector verified that the Iodine-131 activitiy in the secondary side - 2~ s ' 'oflthe steam generators was maintained-below the limits specified in-
Technical: Specifications, Section 3.10. Section 3.10 states that the , F, reactor shall notfremain critical if Iodine-131 activity exceeds 0.2 ' . ' _fuci/cc. , x j' /AreviewofapplicablerecordsdisclosedthatIodine-131levelsinthe . -secondary side were maintained below limits specified in the TS. l < T . . . 4Ho violations'or deviations were identified. r c,
113. - [acility Tour l. .. Tours of-the licensee's facilities were conducted on four different , occasions during the inspection. Licensee representatives were assigned u , .'to accompany the NRC inspectors during the tours. The following observations were made: i, , x- .. a. Radioactive 1yfcontaminated material wrapped in herculite was observed'to be hanging over the edge of the a cooling tower's water j , catch basin.' ,The spray from the cooling tower that sprayed over the i , contaminated material, driined.directly into the' water catch basin. ~~ l _7 + ~,,, _x y . l' - b. ~An accumblation of what appeared to be an over~ abundance of f Cradioactive ~wa'ste tis currentily"being stored adjacent .to both cooling towe'rs'.1 The , waste consisted *of a contaminated 5000 gallon water - ' " trailer,' sol'idified s' econ ~dary * resins, and main steam-line . reheater , partsjgeneratedffrom the-1983' refueling outage. ~ ~ 1 - , - . .? = ~ - - ~ , - . - , . . c. 7 Inconsistencies-in posting of high* radiation areas on the -20 foot ~ ' l4 -
- level'of ,the auxiliary, building;were observed. None-of the
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- inconsistencies were2in. noncompliance with Technical Specification,
Section' 6.'.13.7 I "High Radiation Areas" or 10 CFR 20.203(c),'"High 1 s 4 " " ,Radiition Afeas"; * y L[ _.
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-- -d. The information provided.on. radiation area postings installed at the . mezzanine level of the auxiliary building were'in disagreement with ..one another. Two_of'three signs installed indicated the radiation-
, E Llevels' ranged from 2 to 20 millirem per hour (arem/hr), while a ' third. sign stated the radiation levels ranged from 2 to 99-mres/hr. e. ' On:Septemberjk5','1985,;anauxiliaryoperatorwasobservedonthe resin transfer solidification' pad. The general ~ area radiation '* - Llevels .on the pad ranged from 2.5 to 50 mrem /hr while average contamination levels ranged from 200 to 2000 fisintergrations per minute per 100 square centimeters (dpm/100 cm ). Maximum - s h i $ v k
,, _ 3 , , y. E.: 26 . al ) v ,> 2 c E.. -4 . contamination levels of. greater than IE6 dpm/100 cm were denoted in . ~~ lthe area from licensee surveys. The individual was not_ equipped ~ with.a pocket ionization chamber as required by the RWP 85-782 and i licensee-procedures AP.305, Article 2, " Responsibilities of ~ Workers," AP.305-2, " Radiation Dosimetry: Internal and External" and. AP.305-3, Direct Reading Pocket Dosimeter Assignment and Use." The ' 'RWP under which the individual was signed in on.was not applicable to the resin solidification pad and therefore the the individual did- not have the correct anti-contamination clothing as specified on the - _ only applicable RWP, e.g. No._85-743. The individual wore a lab ' coat, rubber gloves, and rubber shoe covers. As a minimum RWP 185-743 required coveralls, cloth hood, cotton and rubber gloves, plastic and rubber shoe covers,.and a low range pocket dosimeter.-
f. 'On' September 26, 1985, a utility worker signed in on RWP 85-743 was - _ , observed in the'same area as the individual discussed in the above . paragraph. ;This_ individual was.not equipped with the proper. clothing (e.g. Llacking a cloth hood) spec ified on the RWP. The s assigned radiation protection technician did not have a copy of the i, ,RWP present at the work site'a,nd'he.was not fully aware of the' , m , ' radiation protection requirements specified on the RWP. The' , '7[ technician 1 stat,edhemayhaferinformedtheworkerthatahoodwas 1 , , _ not-re, quired becaus,e,he th.ought the RWP did not require one be' worn. . 3, s <f , s , g. I On det'ober 9 r 1985, a1 security guard was observed on the -20 foot ' 'levelfof:the auxiliary building.without the rubber shoe covers o' . q required:by the RWP 85-738 he had' signed in on. The guard Q - appaFently forgotTto' don, shoe, covers before entering the contaminated area. -Contaminstion levels were 'similar to the levels < ,
- identified in item (e) above.
< -1 - , . . .TheabIveobshivatio[swerebroughttodhelicen'see'sattention.puring the* ins'pection 'and ' at the exit . interview. The licensee's staff took' i - ' "immediate act' ion to r'epositionithe contaminated radioactive waste away- , 'from the water spray and to correct the information denoted on the . He _ . mezzanine po' sting. -The Plant' Manager expressed his conce'en about the RWP 4 violations. A copy of a recent licensee memo-(September.4, 1985) was _ reviewed. The topic discussed was'" Misuse of Radiation Work Permits".. ' ' The memo pointed;out'.each workers and supervisors responsibilities for becoming.. aware of and ensdring compliance with instructions.provided on RWPs. ' . The' inspector emphasized the importance of determining the disposition of _ the._large volume of radioactive waste that was observed during the-tour - and~for assuring consistency in the posting of radiation areas. The " ' ' - ' . inspector -informed the licensee the observations of September 25, 26 -and October 9, 1985, were an apparent violation of Technical Specification- 4 J6.11, " Radiation Protection Program" which states in part: " Procedures: ' .for personnel radiation protection shall be approved,- maintained, and ' adhered to.for all' operations involving radiation exposure" (85-28-10). , _ The inspector pointed out that the types of procedures referenced in paragraph ~(e) above'were established for assuring compliance with 10 CFR 0 > Part'20.
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,fa $Y"** ~' ,: c ., 14.,jUnresolved. Items. a , n; _ 2 C r:~ si a - B ;; , . < , > > ~ 'Unresolve,dlitems are' matteis fabo^ut' which more information is required in , %jorderto,ascer'tain;whethertheya're-acceptableitems,itemsof noncompliance.-(e.gi violations)i or' deviations. , Unresolved items -Ldisclosed-in previous inspections are discussed in paragraph 3. c' . , R lN ) ', > ., ' 15. Exit Interview - lp
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, , ' lThe inspectors' met.with the licensee representatives (denoted.in ~ paragraph 1)~at the conclusion of the inspection on September-27 and -October 11,'19.85. The scope and findings of the inspection were summarized. m . c._.
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- The violations and deviations discussed in paragraphs 10, 13, and 3 and
~ he status of unresolved items discussed in paragraph 3 were brought t 4 Ltv the, licensee's attention. , , The inspecto'r stated that.the findings. indicated that there was a breakdown of their communication and commitment tracking systems. -The inspector informed the licensee that several common weaknesses-were- observed in.each of the areas examined. The common weaknesses identified' 'were . as L follows : , a)' Failure to-track and implement commitments. - ' ~ b) ' Lack of closely supervised work. > c) Failure of management to verify goals, commitments and work- ' assignments are being met or implemented. . d). Inadequate review of documentation (e.g., NRC Inspection Reports, ~
- Instrument calibration data, gaseous effluent permits,
nonconformance reports, e) - Failure to complete work projects in a timely manner. (e.g., PASS, replacement of-the broken flow measurement device, installation of , PERM R15017A'and R15017B, Completion of Modifications to Rad Service Building). , - 9 t v 4 P l , - ' e ' ..~; -- - i % w %% % - }}