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Insp Repts 50-266/97-14 & 50-301/97-14 on 970707-11. Violations Noted.Major Areas Inspected:Review of Radiological Environ Monitoring Program,Water Chemistry Control Program & Health Physics Insp
	ML20151K427
Person / Time
Site:	Point Beach
Issue date:	07/29/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
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ML20151K382	List: ML20151K377; ML20151K408; ML20151K427;
References
	50-266-97-14, 50-301-97-14, NUDOCS 9708060081
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U.S. NUCLEAR REGULATORY COMMISSION

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REGION lli

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Docket Nos: 50-266; 50-301

Licenses No: DPR-24; DPR-27 4

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Report No: 50-266/97014(DRS); 50-301/97014(DRS) i

Licensee: Wisconsin Electric Power company

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Facility: Point Beach Nuclear Plant, Units 1 and 2 !

Location: 6610 Nuclear Road

Two Rivers, WI 54241

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Dates: July 7-11,1997

Inspectors: R. Paul, Senior Radiation Specialist

K. Lambert, Radiation Specialist

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Approved by: Gary L. Shear, Chief, Plant Support Branch 2 ;

Division of Reactor Safety I

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9708060081 970729

PDR ADOCK 05000266

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EXECUTIVE SUMMARY

Point Beach Nuclear Plant, Units 1 & 2

NRC inspection Report 50-266/97014(DRS); 50-301/97014(DRS)

l This routine inspection included a review of the Radiological Environmental Monitoring

Program, the water chemistry control program, and the liquid and gaseous effluent

monitoring program. The following specific observations were made

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* One violation was identified for failure to follow procedures involved with the

maintenance of environmental air samplers. The apparent cause is the lack of a

system to notify health physics staff when a procedure is revised (Section R1.1).

The Radiological Environmental Monitoring Program was effectively implemented

(Section R1.1).

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! * Plant water chemistry continued to be very good. A weakness was identified

l regarding the lack of documenting actions taken when chemistry parameters fall

outside their control limits (Section R1.2),

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Overall, area radiation monitors, and liquid and gaseous monitoring programs were

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effective. Radioactive releases and doce to the public from the releases were well

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below the regulatory permissible limits (Section R1.3).

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Required surveillance and tests on non-Technical Specification engineered-safety-

] featured air filtration equipment were performed appropriately with the test results

e indicating that acceptance criteria were met (Section R1.4).

The calibration and maintenance program for the alpha radiation monitors was well

i implemented, and the monitors had a good operability history (Section R2.1).

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The material condition of the post-accident sampling system was good and

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effective modifications were made to ensure the capability of containment air

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sampling during accident conditions (Section R2.2).

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e Overall, the chemistry quality assurance program was effectively implemented. A

weakness was identified in that instrumentation daily performance control charts

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were not evaluated for trends or biases, which could provide early indication of

instrumentation degradation (Section R7.1).

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A licensee audit of the primary water chemistry program identified several areas

with minor oeficiencies and corrective actions were being implemented

(Section 7.2).

A heat stress program is being developed in response to a heat stress incident

involving a worker in the lower cavity of containment (Section R8.1).

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Rooort Details

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R1 Radiological Protection and Chemistry (RP&C) Controls

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R 1.1 Radioloaical Environmental Monitorina Proaram (REMP) i

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a. Insoection Scoce (84750)

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The inspectors reviewed selected areas of the licensee's radiological environmental '

monitoring program (REMP) including the 1996 Annual Monitoring Report. The )

j inspectors also reviewed the program requirements described in the Off-site Dose

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Calculation Manual (ODCM), Updated Final Safety Analysis Report (UFSAR), and

Technical Specifications (TSs). In addition, the inspectors observed the collection

of environmental air samples.

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b. Observations and Findinas

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The 1996 Annual Monitoring Report appeared to comply with REMP requirements.

Environmental samples had been collected and analyzed; missing samples were

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documented; and the annual land use census had been conducted as required. The

environmental sample data indicated that there had been no discernable radiological

impact on the environment from the operation of the facility. Observed air sampling

equipment was within calibration and in good working order. Sampling locations

j, were in agreement with the procedures and the dose calculation manual,

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The inspectors accompanied a health physics technician during weekly rounds to

change air particulate filters and iodine cartridges. The technician was

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knowledgeable in the procedures and process to change the filters and cartridges.

During the rounds, the technician also performed monthly maintenance and

quarterly leak testing. The inspector observed that the technician was not

performing the monthly maintenance in accordance with the Maintenance and

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Calibration of Low Volume Air Samplers procedure. A temporary change to the

procedure was issued on June 3,1997, which, in part, changed steps 9.2.1(a) and

j 9.2.1(d) of the procedure from removing and reusing the bypass filter to removing

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and discarding all filters. The technician was observed removing the felt bypass

filters and reusing them on the pump exhaust, which was the process prior to the

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temporary change. The failure to follow the procedure is a violation of Technical

Specification 15.7.8.3, which required the ODCM to be established and maintained

in accordance with TS 15.6.8. TS 15.6.8, required, in part, that the plant be

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operated in accordance with major procedures, supported by minor procedures (VIO

50-266/97014-01(DRS); 50-301/97014-01(DRS)).

Discussions with the technician indicated that he nad not reviewed the Maintenance

J and Calibration of Low Volume Air Samplers procedure prior to performing the

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maintenance. The technician indicated that he had reviewed the procedures

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involving the collection of particulate filters and iodine cartridges along with other

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environmental collection procedures. The technician also indicated that he was not

informed of changes to the maintenance and calibration procedure. Further

discussions with a health physics supervisor and a health physics specialist

revealed that an E-mail message was sent out when procedures were being revised,

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but a mess. age communicating that a procedure revision had been implemented is

not sent. The specialist indicated that several weeks to several months may pass

between the procedural revision notice and the revised procedures implementation.

The specialist also indicated that when a temporary change is made a notice is not

generally sent to the technicians communicating the change. The licensee indicated

that there is not a process in place to notify health physics staff when procedures

are revised. However, Condition Report 97-1444 was initiated to address this

issue. Corrective actions for this condition report were being evaluated by the

health physics staff at the conclusion of this inspection.

c. Conclusions

Overall, the REMP program was effectively implemented. One violation was

identified for failure to follow procedures, with the apparent cause being the lack of

a system for notifying health physics staff when a procedure revision has been

implemented.

R1.2 Water Chemistry Control Proaram

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a. inspection Scope (84750) 1

The inspectors reviewed the licensee's water chemistry control program. This i

included discussions with cognizant individuals regarding chemical additions for

corrosion control. The inspectors also reviewed trend charts of numerous

chemistry parameters from January 1996 through March 1997.

b. Observations and Findinas

The water chemistry program was consistent with the Electric Power Research

Institute (EPRI) pressurized water reactor guidelines. A review of selected trend

records indicated that plant water quality was very good, and no significant

problems were observed. The secondary water chemistry parameters for sodium,

sulfate and chloride were maintained at less than ten percent of the EPRI guidelines.

The inspectors noted that when chemistry data parameters were outside the control

limit, timely action was taken to bring the parameter within limits. However, the

inspectors noted a weakness in that the corrective actions taken were not generally

documented. When questioned, staff could not always recall the problems

encountered and corrective actions taken. The lack of documentation could prohibit

the staff from identifying recurrent water chemistry problems and appropriate

corrective actions.

Radiochemistry trend charts for reactor coolant isotopic analysis indicated that

there were no problems with fuelintegrity. A review of selected reactor coolant

chemistry parameter trend charts indicated that coolant quality was very good.

Parameters were maintained below 10 peicent of the EPRI guidelines.

The recently replaced steam generators were in wet layup, with hydrazine added to

scavenge oxygen to reduce corrosion. The chemistry department was making boric

acid treatment preparations for passivating the steam generators during startup in

accordance with the manufacturer's recommendations. No problems were noted.

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l Plant water chemistry continued to be very good. A weakness was noted 'regarding :

- documenting actions taken when chsmistry parameters fall outside their control

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' R1.3 Liauid and Gaseous Radwaste i

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a. Insoection Scope (84750)

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The inspectors reviewed selected portions of the licensee's liquid and gaseous

i radwaste program. This review included observations of the operational condition

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of t'he monitors and effluent control instruments, reviews of monitor availability and

calibration records, radwaste discharge permit records and procedures, and effluent

j results. Dose quantification methodology and technical documents to determine :

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compliance with effluent requirements were reviewed. The inspectors also

, reviewed area radiation monitors (ARM), including the control room habitability

i- ARM, calibration procedures and results, and monitor alarm set points.

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l b. Observations and Findinas

, _To date there were no significant changes in the licensee's liquid and geseous

! effluent systems as described in the ODCM and the UFSAR. Quantification of

j gaseous and liquid discharges were completed in accordance with the appropriate

procedures, and the inspectors established that offsite doses and effluent release

monitor set points were calculated using ODCM methodology.

! Calibration of the TS effluent monitors was accomplished in 1992 using National

i Bureau of Standards primary (gas and liquid) sources to establish efficiencies and

! demonstrate linearity; subsequent calibrations used secondary sources. The review

l of the functional test and calibration data for the systems indicated they were j

performed in accordance with approved procedures and were technically sound. l

- However, a problem involving the liquid discharge monitor set points was identified '

j when, after several occasions, liquid discharges were secured after receiving an

alert alarm while the discharge was in progress. The securing of the discharges

j was caused because the operating procedure did not allow calculation and

j adjustment of the alert alarm set point until after the alert alarm was received, even !

! though it was reasonable to expect the alarm. This matter was discussed with the j

j licensee who indicated that the procedure would be modified to allow adjustment of ;

i the alert alarm set point prior to commencement of the discharge. Operability l

problems have only prevented meeting the licensee's goal of 95 percent alarm

! availability on two occasions this year.

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During plant walkdowns, the inspectors observed that the material condition of the

monitors and associated read out systems was good with few work request tags

j observed on the systems. The effluent monitor system radiation protection

engineer was knowledgeable of the system and its operating parameters.

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i The licensee maintained a fixed network of ARMS to monitor plant radiological

levels and provide early notification of possible adverse events. The ARMS

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constitute a fixed, in-place network with each specific monitor location and

expected background radiation levels described in the UFSAR. Oversight and l

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calibration of the ARMS (including the control room habitability monitor) was )

maintained by the health physics staff with the instrument maintenance group

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performing routine maintenance. During plant walkdowns, the inspectors observed

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ARMS in good operating condition and evidence of routine surveillance activities by l

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plant personnel. The inspectors reviewed selected calibration and maintenance !

records for the ARMS; no problems were identified.

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c. Conclusions

Overall, the liquid, gaseous, and ARM monitoring program was effectively

implemented. Radioactive releases and dose to the public from the releases were-

well below the regulatory permissible limits.

R1.4 Enaineered-Safetv-Feature Filtration Systems

a. Insoection Scope (84750)

The inspectors reviewed the latest test results of the Technical Specification

required engineered-safety-feature atmosphere cleanup filtration and absorption i

units.

b. Observations and Findinas

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The insectors reviewed the licensee's results for the most recently performed

containment purge and cleanup, drumming station, and control room emergency

ventilation systems tests. These tests included in-place charcoal adsorber leak

tests, charcoal canister iodine adsorption tests, and in-place high efficiency

particulate air filter tests. The test results were within the Technical Specification

limits and were performed using proper industry standards. During plant

walkdowns, the inspectors noted that the above systems were maintained in good

material condition. The isokinetic and main vent pathway exhaust systems flows

were periodically measured and compared, with no significant problems identified.

c. Conclusions

Required surveillance and tests were performed on engineered-safety-feature

filtration systems and the results of the tests indicated that Technical Specification

acceptance criteria were met.

R1.5 Radioactive Effluents (84750)

The inspectors reviewed the licensee's semiannual radioactive effluent reports from

January 1995 through December 1996, and some monthly effluent data from

January 1997. The inspectors noted that the personnel responsible for generating

the effwent reports were knowledgeable of the process and were effectively

tracking eilhmnt activity released. The total activity released in 1996 remained low

and was well below applicable regulatory requirements.

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R2 Status of RP&C Facilities and Equipment

R2.1 Facilities and Eauioment

The inspectors reviewed the operation and calibration methodology for the portable

alpha counting detectors. The inspection included observation of radioactive '

source condition, and review of procedures, detector operability history, and

calibration and test results.

Calibrations and instrument tests were performed as required. The inspectors

noted that a plutonium-239 alpha standard was the primary source used for

calibration and detector efficiency was about 28 percent on all alpha monitoring

equipment. The source did not appear degraded and its observed output was as

expected.

The overall calibration and maintenance program for the alpha monitors was well

implemented, and the monitors were noted to have good operability history.

R2.2 Post-Accident Samolina System (847501

The inspectors reviewed the licensee's post-accident sampling system (PASS)

capabilities. This included an inspection of the samp*ing stations, and discussions

with cognizant system engineering and chemistry personnel.

The inspectors noted that chemistry and system engineering had a thorough

understanding of the PASS system including the process with which a sample is

obtained, system connections, and the maintenance history. The containment air

sampling portion of PASS had been recently modified, due to the licensee

determining that the air sampling pumps were not capable of providing a

representative air sample at the calculated post-accident containment pressures.

This modification had been installed on both containment sampling systems.

Chemistry technicians have been provided training, and the functional test was <

scheduled for the near future. The inspectors determined that the material

condition of the PASS stations was good and that the licensee was capable of ;

obtaining required samples. '

The inspectors noted that the licensee had effectively maintained the material

condition of the PASS system and made modifications to ensure the capability of

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containment air sampling during accident conditions.

R4 Staff Knowledge and Performance in RP&C

R4.1 Staff Performance Durina Sample Acauisition (84750)

The inspectors observed chemistry technicians during the routine sample

acquisitions of primary samples from the residual heat removal system and the

mixed bed demineralizer inlet. In addition, a technician was observed collecting a

sample from a boric acid tank. The chemistry technicians appropriately contacted

the control room prior to obtaining each sample and at the end of each evolution.

The technicians used good sampling techniques including rinsing the bottles prior to

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obtaining each sample. The primary side sample procedure required continuous

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use, therefore one technician was reading the steps and the second technician was

manipulating the valves and collecting the sample. The technician collecting the

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primary side samples used good contamination control. The technician collecting a

boric acid tank sample reviewed the appropriate procedures prior to sample

collection and was very familiar with sampling requirements and sample locations,

R7 Quality Assurance in RP&C Activities

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R7.1 Laboratory and Instrument Control Proaram

f a. In_spection Scoce (84750)

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The inspectors reviewed the laboratory quality assurance program, including the

laboratory comparison program for radioanalytical instrumentation and quality '

l control of instrumentation.

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b. Observations and Findinos

l The inspectors reviewed the results from the interlaboratory radiological cross

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check program and noted generally good agreement, if agreement fell outside plus

, or minus ten percent, corrective actions were taken and documented. Control

charts were used to monitor the performance of counting equipment. A review of

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selected control charts indicated that corrective action was taken and documented

when instrument response falls outside the control limits. However, a weakness

i was identified in that the quality control program did not include evaluations for

i trends or changes in pattern on the control charts. Evaluating trends or pattern

chang % can provide early warning of instrumentation degradation and provide time

to correct a potential problem before instrument response falls outside the control

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Chemistry personnel indicated that a purchase order had been issued for procuring

a new laboratory program for data storage. This program will also include trend

charts for instrumentation response and have trending and bias identification

features built into the program. The chemistry manager indicated this should

correct the trending weakness. The manager also indicated that the program

, should be received later this year, and the expectation is to have the program

j running by the end of 1997,

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{ Overall, the quality assurance program was effectively implemented. A weakness

t was identified in that instrument trends or biases were not evaluated, which could

j provide early indication of degraded instrumentation.

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R7.2 Chemistry Department Audit (84750)

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The inspectors reviewed ':he results of a quality assurance audit of primary water

chemistry, and hazardous and special material control. This was a two week audit

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and included station personnel and an individual from another nuclear power plant.

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The audit indicated that while the monitoring and control of primary chemistry is

' effective, there were a number of areas in the program where improvements could

be made. The chemistry manager indicated that condition reports had been

initiated for the areas needing improvement. The inspectors reviewed several

condition reports, checked on their status and determined that progress was being

made. The inspectors noted that the audit appeared comprehensive and that

corrective actions in response to the condition reports were being implemented and

j should strengthen the chemistry program.

R8 Miscellaneous RP&C lasues

R8.1 Heat Stress incident (83750)

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The inspectors reviewed a condition report and circumstances surrounding a heat

stress incident involving an individual in the lower cavity of containment. During

the recent outage a worker had to leave the lower cavity because of heat stress;

the worker was not injured. The licensee's review of this event indicated that

although there was some discussion of the hot humid conditions in the lower cavity

of containment during the bre-job briefing, no specific cautions were discussed.

There was not a formal heat stress program at the station prior to the incident, to

inform workers of potential heat stress areas or cautions to be implemented during

work in creas of elevated temperature and humidity. The inspectors noted that as a

result of the condition report and review, an industrial hygiene contractor was

retained to develop a formal heat stress program.

) R8.2 (Closed) VIO 50-266/97008-02(DRS): 50-301/97008-02(DRS): Failure to provide

j hazardous material worker training to contract health physics technicians working in

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radwaste once every three years. The health physics staff implemented the

following corrective actions to the violation: suspended activities performed by

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contract workars unless under the direct supervision of properly trained individuals,

provided the required training to the workers, and incorporated the contract

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workers into the staff health physics continuing training program. The inspectors

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reviewed the corrective actions and concluded that the actions were appropriate.

j V. Manaaement Meetinas

i X1 Exit Meeting Summary

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The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on July 11,1997. The licensee acknowledged the findings

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

Rick Arnold, Chemistry Supervisor

Fred Cayia, Plant Manager

Elaine Epstein, Health Physics Specialist

Dave Gehrke, Chemistry Specialist

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Dan Gesch, Chemistry Supervisor i

Beth Hellman, Chemical Engineer

Kjell Johansen, Senior Nuclear Engineer

Ed Lange, Health Physics Supervisor ,

Rick LaRhette, Chemistry Manager !

Don LeClair, Health Physics Specialist !

Tim Smith, Health Physics Supervisor

Paul Tindall, Health Physics Manager

Clarice Zellmer, Chemical Engineer

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INSPECTION PROCEDURES USED

IP 83750: Occupational Radiation Exposure !

j IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring

LIST OF ITEMS OPENED AND CLOSED

Opened

50-266(301)/97014-01 VIO failure to follow a health physics procedure during the

maintenance of environmental air samplers

Closed

50-266(301)/97008-02 VIO failure to provide hazardous worker training to contract

health physics technicians worker in radwaste

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LIST OF ACRONYMS USED

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s ARM Area Radiation Monitors

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g DRS Division of Radiation Safety '

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EPRI Electric Power Research Institute

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ODCM Off-site Dose Calculation Manual !

NRC Nuclear Regulatory Commission !

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PASS Post-Accident Sampling System

PDR Public Document Room

PBNP Point Beach Nuclear Plant

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. REMP Radiological Environmental Monitoring Program l

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TS Technical Specification j

UFSAR Updated Final Safety Analysis Report '

j VIO Violation

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UST OF DOCUMENTS REVIEWED

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Chemistry Analytical Methods and Procedures, CAMP 106, Rev 5,6/4/93, "Interlaboratory

3 Radiological Cross Check Procedure"

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Chemistry Analytical Methods and Procedures, CAMP 600, Rev 24, Temp Change

! 10/29/96, " Primary Side Sampling Procedures: Primary Sample Panel Operations"

Chemistry Parameter Control Charts, January to July 1997

Condition Report, dated 6/25/97, not numbered, no heat stress program in place at PBNP

Emergency Plan implementing Procedures, EPIP 8.4.1, " Post-Accident Sampling, analysis

of Potentially High Activity Reactor Coolant"

Emergency Plan implementing Procedures, EPIP 8.4.2, " Post-Accident Sampling of

Containment Atmosphere"

! Environmental Manual, Rev 11, 6/21/95

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! Health Physics Calibration Procedure, HPCAL 1.33, Rev 4, Temp Change 6/3/97, !

" Maintenance and Calibration of Low Volume Air Samplers" l

Instrumentation Control Charts, November 1996 to July 1997

Interlaboratory Radiological Cross Check Data Sheets, February 1995 to June 1997

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1 Procedures Manual, NP 3.2.2, " Primary Water Chemistry Monitoring Program"

Procedures Manual, NP 3.2.3, Rev 4, Temp Change 6/3/97, " Secondary Water Chemistry

Monitoring Program"

Quality Assurance Audit Report, A-P-97-10, " Primary Water Chemistry, Hazardous and

Special Material Control" !

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ML20151K427

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