IR 05000293/1975002

Insp Rept 50-293/75-02 on 750116-17.Noncompliance Noted: Failure to Maintain Plant Release Rate of Iodines & Particulates w/half-lives Greater than 8 Days Below Level Set in Tech Spec 3.8.B.2

ML20206K465
Person / Time
Site:	Pilgrim, 05000000
Issue date:	02/21/1975
From:	Hyson R, Knapp P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204E974	List: 05000000/LER-1975-004, Forwards LER 75-004-00.Conclusions of Investigation Will Be Submitted in 10-day Rept BECO-82-194, Responds to Confirmatory Action Ltr 82-19 Re Identification of Spent Resin on Roof Tops & Pavement within Protected Area on 820611.Condensate Demineralizer Sys Identified as Resin Source & Secured.Related Documentation Encl IR 05000293/1975002 ML20204E969 ML20204J237 ML20206F330 ML20206K250 ML20206K259 ML20206K286 ML20206K305 ML20206K341 ML20206K353 ML20206K363 ML20206K365 ML20206K385 ML20206K423 ML20206K439 ML20206K444 ML20206K449 ML20206K480 ML20206K485 ML20206K494 ML20206K504 ML20206K510 ML20206K520 ML20206K526 ML20206K530 ML20206K548 ML20206K555 ML20206K564 ML20206K579 ML20206K598 ML20206K616 ML20206K635 ML20206K639 ML20206K659 ML20206K688 ML20206K693 ML20206K698 ML20206K704 ML20206K709 ML20206K731 ML20206K743 ML20206K748 ML20206K754
References
FOIA-86-58 50-293-75-02, 50-293-75-2, NUDOCS 8606300098
Download: ML20206K465 (8)

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SUM 1ARY OF FINDINGS s'

Enforcement Action F Items of Noncompliance Infractions i

i '; Iodine and Particulate Release to the Environs Failure to maintain the plant release rate of iodines and particulates (with half-lives greater than 8 days) to a level

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less than that specified in Technical Specification 3.8. This item was previously reported by the licensee as Abnormal Occurrence A0 50-293/75-04. (Details, Paragraph 2) _ Radiological Protection Procedures Failure to adhere to a Radiological Control Procedure as re-quired by Technical Specification 6.2.D. (Details, Paragraph 7) Deviations None

_0ther Significant Findings

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3 Current Findings

• Acceptable Areas

. . Data Interpretation

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A review of the licensee's evaluation of iodine and particu-

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late releases was conducte (Details, Paragraph 2) Personnel Exposures A review of personnel exposures to airborne iodine was con-ducted. (Details, Paragraph 4) Plant Operations A review of licensee plans for effecting reduction in iodine I

and particulate releases was conducte (Details, Paragraph 6)

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8606300098 PDR FOIA 860613 DURNSTEIB6-58 PDR

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. Unresolved Item *

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Licensee measurement capability of the main strek iodine car-tridge is considered an unresolved ite .

, Status of Previous Unresolved Items 0 '

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None

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Management Interview

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A management interview was held at the site on January 17, 197 Persons Present C. Baston, Division Head S. Martin, Process Engineer J. Seery, Chief Technical Engineer E. Comproni, Massachusetts Department of Public Health Items Discussed

. Purpose of the Inrioection

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c The inspector stated that this was a special inspection for the purpose of reviewing the specifics related to the iodine and par-ticulate release rate in excess of Technical Specification 3.8. for the period from January 7 through January 13, 1975. The areas jj.., of specific concern were delineated as follows: Verification of release rate calculations reported in

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A0 50-293/75-04. ,

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' Review history of primary coolant and condensate activities

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and their relation to the reported releas ' Review personnel exposures to iodine for affected perio . Obtain several iodine cartridge samples collected during this time for independent measurement . Review of licensee actions to minimize iodine and particulate releases during this tim { The inspector informed the licensee that a representative from the i

Department of Health of the Commonwealth of Massachusetts would be ,

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B. Review of Items of Noncompliance d

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The items discussed are as identified under Enforcement Action in the Summary of Findings in this repor ' '

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' C. Review of Licensee Plans Prior to Future Startuo N

f The licensee outlined his plans for determining the cause of the

{- excessive iodine and particulate releaes and for minimizing them

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in the futur (Details, Paragraphs 2 and 6)

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DETAILS

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l Individuals Contacted

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! G. Baston, Division Head

S. Martin, Process Engineer

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J. Seery, Chief Technical Engineer R. Smith, Chemical Engineer

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J. Lucero, Health Physics Engineer -

Nuclear Safety Associates (Consultant)

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W. Rogers, Senior Partner Main Stack and Plant Vent Releases The inspector revieved the licensee's iodine and particulate release records for the period from January 6 through January 15, 1975. The inspector verified that the plant iodine and particulate release rate had exceeded the rate specified in Technical Specification

' 3.8.B.2 by approximately 14% for the period from January 7, 1975 through January 14, 1975. This excessive release of iodines and particulates was the . subject of the licensee's Abnormal Occurrence Report No. 75-0 The inspector noted that the noble gas release a- a~ rate for the period f, rom January 6 to January 15, 1975 was within regulatory requirements. The licensee indicated that the excessive release rate for iodines and particulates was possibly related to

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the high iodine activity present in the reactor. coolant, especially

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during power transients which occurred during the affected perio , In order to help determine the exact cause or causes of the exces-

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sive releases of iodines and oarticulates, the licensee has con-

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tracted for the services of a consultant to study the proble .

The inspector observed during his inspection that a consultant was actively pursuing this stud . Consultant Study of Iodine and Particulate Releases The inspector discussed with the consultant his preliminary results

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and proposed plans for determining the cause of the excessive iodine and particulate releases. The consultant indicated th:t he was j actively conducting a sampling program designed to ascertain the

[ sources of the excessive releases. The sampling program, according I

to the consultant, included monitoring reactor coolant iodine activ-

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ity more frecuently, , determining the iodine activity of the various

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inputs to the plant ventilation system and relating plant operational aspects to observed increases in coolant iodine activity. The con-sultant tentatively recommended the following to the licensee:

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' Employ charcoal adsorption where only particulate filtration now

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exists in the plant vent syste ) 'b. Attempt greater utilization of the reactor cleanup system,

especially during startups and shutdowns, to minimize reactor

, coolant iodine " spiking."

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The consultant indicated that, as the study continues and more infor-untion~ emerges, more concrete recommendations will be made. The li-censee indicated that the in plant study will continue until the source of the excessive iodine and particulate releases are found and dealt wit . In-Plant Personnel Exposure The inspector reviewed with cognizant licensee representatives the extent to which personnel were exposed to iodine during the period of excessive iodine and particulate releases and high in-plant air- -

borne iodine activities. Based on this review,.the inspector deter-

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mined that apparently no personnel exposures to iodine in excess of

regulatory limits had occurre . Independent Measurenents * *

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The inspector obtained three iodine sample cartridges from the li-censee for analysis by Regional Office personnel to test the li-

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censee's analytical capability. The following comparison of results was obtained: ,

' Cartridge _ Iodine-131 Analysis Analyzed _ Licensee Value* NRC Value

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Plant Vent (1/11-12/75) 0.30 pCi 0.34 1 2.0% pCi Plant Vent (1/12-13/75) 0.36 pCi , 0.46 1 2.0% pCi Main Stack (1/12-13/75) ,

1.28 pCi 2.26 1 0.2% pCi The two plant vent sampic* analyses made by the licensee are considered in agreement; however, the main stack sample analysis made by the li-l censee was not in agreement with NRC's value. NRC representatives concluded that this discrepancy may be due to a required change in

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• The value submitted by the licensee was corrected for decay to the

.l,, count time for the NRC analysis.

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calibration factor with a change in the depth to which the iodine l penetrat'es the sanple cartridge. Upon being informed by the inspec-

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tor about the nonagreement, the cognizant licensee representative

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indicated that he will further evaluate his analytical techniqu . . This matter will be reviewed at the next inspectio . Licensee Action l- .

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. The inspector noted that the action taken by the licensee to .

minimize main stack and plant vent releases during the period of excessive iodine and particulate releases appeared to be as thorough as practicable.

. The licensee indicated that before returning to power operations the following mechanical and operational changes would be instituted:

(1) Slower and more deliberate startup.

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(2) Control of coolant iodine activity prior to startu (3) Implementation of Special Order No. 65 which includes:

i , - purging of drywell through the standby gas treatment system (SBGTS) whenever air in drywell requires face l masks

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4 g - maintaining a negative pressure on reactor whenever it

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is vented or opened to the drywell

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- maintaining a negative pressure on the condenser whenever

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reactor coolant is being dumped to it

- venting condensate domineralizers through the SBGTS when-ever venting is required .

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, - maintaining torus level as low as possible during normal j operation ,

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- noting the relation between significant changes on plant

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vent and stack activity charts and plant operations at time of change

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- utilization of reactor cleanup system at a reliable two

, pump capacity whenever possibl ,i

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7. Retention Building Tour

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.. During a tour of the Offgas Retention Building, the inspector noted

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that four contractor personnel involved in removing several solenoid

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valves and relocating them outside the charcoal vault were not ad-l ;. hering to the clothing requirements indicated on the Radiation Work

Permi Three of the individuals were not wearing cloth hoods and

the fourth individual was wearing neither a cloth hood nor coveralls

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which were required by the posted RWP. A licensee representative L

confirmed that the individuals were violating the RUP instructions;

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but, that the survey results stated on the RWP indicated only 100 dpm/ft2removable contamination, which rendered the clothing require-ments too stric .

The licensee representative agreed, however, that, despite the

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stringent requirements, the individuals should have followed the posted clothing requirements as required by Part 5.4.1 of the Radiological Protection Procedure entitled " Radiation Work' Permit Procedure." . .

The inspector noted that, upon discovery of the above procedural violation, the licensee representative initiated appropriate cor-rective actio . , .

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