Text

Insp Repts 50-424/87-34 & 50-425/87-24 on 870518-22. Violations Noted:Failure to Follow Procedures,Resulting in Inadvertent Release of Portion of Contents of Waste Gas Decay Tank
	ML20234E318
Person / Time
Site:	Vogtle
Issue date:	06/19/1987
From:	Kahle J, Stoddart P; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20234E279	List: ML20234E277; ML20234E298; ML20234E318;
References
	50-424-87-34, 50-425-87-24, NUDOCS 8707070530
	Download: ML20234E318 (18)
	v • d • e

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UNITc0 STATES

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NUCLEAR REGULATORY COMMISSION

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101 M ARIETTA STREET, N.W., SUITE 2000

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ATLANTA, GEORGIA 30323

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Report Nos.: 50-424/87-34, 50-425/87-24

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302

Docket Nos.: 50-424, 50-425

License Nos.:

NPF-68 and CPPR-109

Facility Name:

Vogtle

Inspection Con

e: Ja

8-22, 1987

Inspector:

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PMi. Stoddar+'

Date Signed

Accompanying Personfrei:

C.,Hughey

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Approved by:

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Odf(dA d3

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J./ .

'h1e, Chief ~

Date Signed'

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Divisi n of Radiation Safety and Safeguards

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SUMMARY

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Scope:

This routine unannounced inspection was conducted in the areas of

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liquid and gaseous effluent processing, analysis and monitoring, and

investigation of allegations.

Rr;sults:

One violation was identified - failure to follow procedures,

resulting in the inadvertent release of a portion of the contents of a waste

gas decay tank.

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8707070530 870629

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ADOCK 05000424

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REPORT DETAILS

1.

Persons Contacted

Licensee Employees

T. Greene, Plant Manager

R. M. Bellamy, Plant Support Manager

D. Smith, Superintendent, Nuclear Operations

C. C. Miller, Superintendent, Outages and Planning

R. M. Odom, Supervisor, NSAC

S. C. Ewald, Manager, Radiological Safety

W. F. Kitchens, Operations Manager

D. F. Hallman, Superintendent, Chemistry

P. H. Burwinkel, Engineering Supervisor, HVAC

A. E. Desrosiers, Health Physics Superintendent

C. E. Belflower, Quality Assurance Site Manager

W. C. Gabbard, Senior Regulatory Specialist

A. Stalker, Health Physicist, GPC

J. Daniel, Supervisor, Radwaste Processing

P. Jackson, Engineer, Chemistry Department

Other licensee employees included engineers, technicians, operators, and

office personnel.

Other Organization

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R. Cislo, Engineer, Bartlett Corporation

Nuclear Regulatory Commission

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J. Rogge, Senior Resident Inspector - Operations

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R. J. Schepens, Resic'ent Inspector - Operations

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H. Livermore, Senior Resident Inspector - Construction

C. Berger, Resident Inspector - Operations

Attended exit interview

2.

Exit Interview

The inspection scope and findings were summarized on May 22, 1987, with

those persons indicated in Paragraph I above. The inspector described the

areas inspected and discussed in detail the inspection findings listed

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below.

No dissenting comments were received from the licensee.

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One violation was identified when on May 18, 1987, apparently as a result

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of operator error in failing to follow procedures, approximately one-half

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of the radioactive gas inventory of a waste gas decay tank was

inadvertently released to the atmosphere concurrent with the release of

the contents of another tank.

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On May 18, 1987, the backflushing of a mechanical filter resulted in

contamination of the demineralized water system and of a steam generator.

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Extensive flushing of these systems was necessary to minimize

radioactivity levels and resulted in exceeding the capacity of available

waste retention tanks and sumps.

Automatic pump-over of an Auxiliary

Building Sump to a Turbine Building sump, coupled with isolation of the

Turbine Building sumps to prevent an uncontrolled release, resulted in

flooding of the lower level of the Turbine Building to a level estimated

at 18 inches by approximately 400,00 gallons of water.

The licensee did not identify as proprietary any of the material provided

to or reviewed by the inspector during this inspection.

3.

Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

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4.

Liquid Radwaste Process Systems (84521, 84723)

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The inspector reviewed the startup and initial operation of the alternate

liquid radwaste process system.

The system was supplied under contract

and consisted of eight demineralized vessels and a prefilter unit.

The

demineralized vessels were located within a shielded cubicle in the

Alternate Radwaste Building (ARB).

The vessels had hose connections on

the input and output and at the time of inspection were configured in two

trains of four series-connected vessels.

The prefilter was located

outside of the shield cubicle in a separate shielded container.

As of

May 19, 1987, the system had processed approximately 1.2 E+06 gallons of

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low specific activity liquid radwaste and had achieved decontamination

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factors (DFs) of between 50 and 100.

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Training records for radwaste personnel were dircussed with licensee

representatives.

All assigned personnel had been checked out on system

operation; however, not all personnel had been checked out on all related

activities.

For example, only four of nine assigned personnel had been

checked out on operation of the building crane. Licensee personnel stated

that getting all assigned personnel into a fully-qualified status had a

high priority.

One small liquid radwaste system spill, which was confined to a small

portion of the Alternate Radwaste Building, occurred when a system

pressure relief passed through a small opening apparently left by an

installer.

The pressure relief line had not been leak-tested under

pressure as the balance of the system had been. The pressure relief line

was subsequently hard-piped to a radwaste floor drain tank in the

Auxiliary Building to prevent a recurrence of the spill.

In discussions between the inspector and the radwaste supervisor, it was

noted that a problem had been encountered with a 5 micron backup filter,

which was positioned downstream of the 25 micron main pre-filters and

upstream of the input to the first demineralized bed. This backup filter

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had been added by the licensee as a means of providing additional

protection for the demineralized beds.

In use, it was found that the

backup filter had a low retention capacity and that as the capacity was

approached, the pressure drop (delta-p) across the filter rose rapidly.

Prior to the time this condition was recognized, Revision 1 to

Procedure 13290-C, April 1,1987, changed the maximum pressure drop from

25 psig to 40 psig, which was within the 50 psig rated capacity of the

filter.

After approximately one month of operating at pressure drops up

to 40 psig, it was recognized that the rapid load buildup characteristic

of the filter was such as to make the higher pressure drop of little

benefit.

Consequently the procedure was again revised, May 15, 1987

(Rev. 2), which changed the value for pressure drop back to 25 psig.

On May 19, 1987, contamination of the demineralized water system and the

need to flush contaminated water out of affected systems resulted in an

abnormally high volume flowrate of contaminated water into the radwaste

retention tanks and sumps (see Paragraph 7 of this report for additional

details).

When the first batch of this water was processed through the

radwaste demineralized system (Train B, with two cation beds and two mixed

beds, in series), the processed water came through at approximately input

radioactivity concentration, indicating resin depletion.

When the

processed water was recycled through Train B, the demineralizers again had

little or no effect on the radioactivity content of the water. As of the

end date of the onsite portion of this inspection, the contaminated water

cleanup problem had not been resol ved.

In subsequent telephone

discussions with licensee representatives on June 8-9, 1987, the inspector

was informed that changeout of depleted resin in two of the four beds had

allowed processing to be resumed with a satisfactory product being

obtained.

No violations or deviations were identified.

5.

Gaseous Radwaste Processing and Effluent Monitoring (84521, 84524, 84724)

The inspector reviewed selected aspects of the licensee's gaseous radwaste

processing system and of the gaseous effluent monitoring system.

On May 18, 1987, as a result of an apparent operator error, approximately

one-half of the contents of Waste Gas Decay Tank No. 2 (Unit 1) were

accidentally released during the time period in which the contents of

Waste Gas Decay Tank No. 4 were being released under a radioactive gaseous

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effluent release permit.

Tank No. 2 had been routinely isolated on

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May 16, 1987, and the contents had been sampled and analyzed for possible

release at a later date.

The release of Tank No, a was interrupted twice to accommodate system

problems, which requi *cd o,mting or closing valves, in accordance with

Procedure No. 11202-1, tir.t 0, June 6,1986, Gaseous Release Alignment,

No. 13202-1, Rev. 1, January 27, 1987, Gaseous Releases, and No. 36020-C,

Rev. 0, January 7,1987, Radioactive Gaseous Effluent Release Permit

Generation and Data Control .

The release of Tank 4 was initiated at

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12:47 pm on May 17

1987, and was interrupted at 1:02 pm the same date.

Release was resunc at 9:17 am on May 18, 1987,

and interrupted at

10:25 am.

Release resumed again at 12:47 pm and was completed at 7:53 pm

on May 18, 1987.

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Valve No. 1-1902-04-073, which controls discharge from Tank No. 2 was

found partially opened at about 6:00 pm on May 18, 1987 by an operator on

a routine rounds check. This occurred during the time period during which

the contents of Tank No. 4 were being discharged.

The valve was closed

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promptly, reported to a supervisor, and a Deficiency Card No. 1-87-1318

was prepared.

The resident inspector was notified of the uncontrolled

release on May 19, 1987.

A licensee representative reported that the

pressure in Tank No. 2 had dropped from 65 psig to 36 psig as a result of

the release.

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A licensee representative reported that the analysis of the sample taken

on May 16, 1987, from Tank No. 2, showed 5.3 E-4 uCi/cc of Xe-133,

8.7 E-6 uC1/cc of Xe-133m, and 1.7 E-6 uCi/cc of Xe-135.

The release was

made through a monitored release path and apparently did not significantly

affect the monitor readings which had been anticipated for the concurrent

release of the contents of Tank No. 4

No Technical Specification release rate limits or offsite dose commitments

were exceeded as a result of the inadvertent release.

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Although it could not be ascertained at which point in time the valve for

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Tank No. 2 was opened, or by whom it was opened, it was considered likely

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that the valve was inadvertently opened sometime between the interruption

of the second portion of the discharge of Tank No. 4, at about 10:25 am on

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May 18, and the resumption of discharge at 12:47 pm on the same date. Had

the valve been opened prior to 10:25 am, a drop in pressure in Tank No. 2

would have occurred during the release of gases from Tank 4 in the time

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frame 8:17 am - 10:25 am on May 18; if such a change occurred, it was

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neither observed nor reported,

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The inspector notified the licensee, both prior to and at the exit, that

this event was considered to be a probable violation of Technical Specification 6.7.1, failure to follow written procedures.

Nuclear

Operations Procedure No. 13202-1, Gaseous Releases, Step 4.1.4, requires

closure and tagging, with independent verification, of valves

1-1902-04-059, 1-1902-U4-073, 1-1902-U4-106, and 1-1902-U4-090.

Contrary

to the above, valve 1-1902-U4-073 was found open at approximately 6:00 pm

on May 18, 1987, resulting in an inadvertent release of radioactive gases

from Waste Gas Decay Tank 1-1902-V6-002, otherwise referred to as Waste

Gas Decay Tank No. 2.

(0pened) Violation 50-424/87-34-01, Failure to follow procedure for waste

gas releases.

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6.

Contamination of Demineralized Water System and Cross-Contamination of

Appurtenant Systems (84723)

The demineralized water system and the steam generator blowdown system

became radioactively contaminated on May 18, 1987, as a result of an

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operator initiated routine backflush of a mechanical filter.

Contaminated

water flowed into a number of appurtenant systems from the demineralized

water header before the full nature of the occurrence was recognized and

before the systems could be isolated.

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The mechanical filter involved was a stacked metal etched-disc type.

To

maintain flow and to reduce pressure drop across the filter media, the

filter was periodically isolated from the system it serviced and was

backflushed with nitrogen gas to dislodge accumulated " crud."

The " crud"

was then sluiced with water to a " crud" tank.

The " crud" tank would

normally be filled to about one-third of tank capacity. A spray nozzle at

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the top of the tank was periodically used to spray down the inner tank

wall with demineralized water to minimize crud buildup on the tank wall.

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It was postulated by licensee representatives that at the time of the

occurrence, the " crud" tank was either full or almost full of accumulated

crud and water and that the valve controlling the input of spray water

from the demineralized water system was either open for spraying or had

failed in the open position.

When nitrogen gas was used to clean the

mechanical filter, the gas pressure was apparently sufficient to

pressurize the " crud" tank and force part of its contents back into the

demineralized water header, into the demineralized water storage tank and

into the steam generator blowdown system.

A licensee representative

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estimated that approximately 300 gallons of contaminated water from the

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" crud" tank had been transferred to the demineralized water system and the

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steam generator blowdown system.

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The first indication that a problem existed came when two PERMSS (Process

and Effluent Radiological Monitoring and S;mpling System) radiation

monitors alarmed or indicated high levels of radioactivity when

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demineralized water was used to flush PERMSS Monitor #21 (servicing steam

generator blowdown liquid effluent), preparatory to initiating a release

via the normal radwaste release path.

Readings of approximately

30,000 cpm were observed on both PERMSS Monitor 21 and on PERMSS

Monitor 18 (which is the monitor for the liquid radwaste release path).

When indication of an abnormal release was seen, all plant liquid effluent

release pathways were promptly isolated, pending identification and

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resolution of the problem.

When further investigation revealed that the steam generator blowdown

system and the demineralized water header and demineralized water storage

tank were contaminated, action was undertaken to flush the systems.

The

large amount of water which was flushed-out rapidly filled the available

retention tankage and overflowed into sumps and leak control features of

the plant.

Some of the water flowed into a normally non-radioactive sump

and was automatically pumped to the turbine building sumps.

Normally, the

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turbine building sumps would have been automatically pump (ed to an-

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environmental release point through a radiation monitor

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capability of automatically terminating the discharge in the event a

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pre-established limit was exceeded) but previous operator actions

prevented any discharge.

The result was an accumulation of a volume of

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water in the turbine building such as to overflow the turbine building

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sumps and cover the floor of the lowest turbine building floor level to a

depth estimated at 18 inches,

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Prompt and efficient action on the part of plant personnel prevented an

uncontrolled release of radioactive material.

No violations or deviations were identified.

7.

Allegation Followup (99014)

The material presented in the following paragraphs was transmitted to

appropriate investigative organizations by copy of this inspection report.

a.

The inspector conducted a review of circumstances surrounding

Allegation RII-87-A-0071 on May 19-21,1987, during this inspection

and in telephone conversations with licensee representatives on

June 8-9, 1987.

An anonymous allegation received by a Resident Inspector on March 27,

1987, stated that radwaste operators in the Alternate Radwaste

Building (ARE) had been instructed by their supervisor to raise the

limit on pressure drop (delta-p) across the liquid radwaste system

particulate filter from 25 psig, as provided by Procedure

No. 13290-C, to a maximum of 40 psig. This action was alleged to be

in violation of plant procedures.

The

inspector

reviewed

Procedure

No. 13290-C,

" Portable

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Demineralization System," and in discussions with licensee personnel

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discussed changes incorporated in the procedure on April 1,1987, and

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on May 15, 1987.

The basic radwaste system parameters and operating ranges were

specified in Table 3 of Procedure 13290-C.

The pressure drop across

the radwaste system particulate filter, the topic of the allegation,

was specified in Table 3 (p. 31 of 34).

Revision 0, dated October 5,

1986, specified filter pressure drop as 0 to 25 psig for normal

operation and recommended changeout of filter cartridges in the event

that pressure drop exceeded 25 psig.

Revision 1, dated April 1,

1987, changed the value for pressure drop to 0 to 40 psig, with

changeout of cartridges if pressure drop exceeded 40 psig.

Revision 2, dated May 15, 1987, changed the numbers back to the

original values.

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Under Procedure 13290-C, Section 2, " Precautions and Limitations,"

Section 2.2.2 stated:

"When the pressure differential exceeds

(25)(40) 25* psig, the cartridge filters shall be replaced with new

ones."

Procedure 13290-C,

Section 4,

" Instructions,"

Section 4.2.1.5,

stated:

" Continue demineralized system operations as long as the

parameters in Table 3 are within the normal operating ranges as

listed on the table, or as directed by the Radwaste Foreman."

Procedure 13290-C, Section 4.2.5.a

" NOTES," read:

... When the

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pressure differential exceeds (25)(40) 25* psig, the dirty filter

cartridges shall be replaced."

A review of licensee records indicated that Revision I to

Procedure 13290-C was submitted for approval on March 27, 1987, and

was approved on April 1,1987.

Revision 2 was submitted on May 15,

1987, and approved on May 15, 1987.

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With reference to the allegation that the Radwaste Supervisor had

directed an increase in the value for pressure drop across the filter

in violation of procedures, a licensee representative stated that the

Radwaste Supervisor, acting under the provisions of Section 4.2.1.5

of Procedure No.13290-C (" CONTINUE demineralized system operations

as long as the parameters in Table 3 are within the normal operating

ranges, as listed on the table, or as directed by the Radwaste

Foreman") did in fact direct foremen to instruct operators to exceed

the 25 psig value specified in Procedure No.13290-C by directing

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continuance of operation until a pressure drop of 40 psig had been

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reached.

This action was considered by the licensee tc be

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permissible and in accordance with provisions incorporated in

Section 4.2.1.5 of the referenced procedure.

In support of the

safety aspects of the change to a g(reater pressure, it was stateddelta-p) across

that the rated design pressure drop

and outlet was 50 psig and that the system had been hydrostatically

tested to over 200 psig.

The ARB Radwaste Operating Log for the period March 3-26, 1987, was

reviewed by the inspector.

The log indicated filter pressure drops

in excess of 25 psig in six separate entries between March 17, 1987,

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and March 26, 1987.

Two of those entries indicated that pressure

drops were in excess of 40 psig (log entries for March 22, 1987, and

March 25, 1987).

The values given are, left to right, Revision 0, I and 2.

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The ARB Radwaste Operating Log for March 17, 1987, indicated

operation at pressure drops in excess of 25 psig from 1930 hours0.0223 days 0.536 hours 0.00319 weeks 7.34365e-4 months to

2032 hours0.0235 days 0.564 hours 0.00336 weeks 7.73176e-4 months but there was no record or notation that this had been in

accordance with instructions from the Radwaste Supervisor or the

Radwaste Foreman.

A log entry for March 22, 1987, at 1653 hours0.0191 days 0.459 hours 0.00273 weeks 6.289665e-4 months ,

recorded a pressure drop of 70 psig but did not indicate how long the

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parameter was out-of-specification. At 0050 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months on March 25, 1987,

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a log entry stated "Gone to write MWO (Maintenance Work Order)* on

demin inlet filter" (presumed due to high but unquantified pressure

drop)*.

At 0350 hours0.00405 days 0.0972 hours 5.787037e-4 weeks 1.33175e-4 months on March 25, 1987:

... filter delta-p

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(pressure drop)* was 60 (psig)* ..." At 0642 hours0.00743 days 0.178 hours 0.00106 weeks 2.44281e-4 months on March 26, 1987,

filter pressure drop was 38 psig.

At 0651 hours0.00753 days 0.181 hours 0.00108 weeks 2.477055e-4 months on March 26, 1987,

filter pressure drop was 28 psig and at 1543 hours0.0179 days 0.429 hours 0.00255 weeks 5.871115e-4 months , filter pressure

drop was 27 psig.

In the ARB log at 1543 hours0.0179 days 0.429 hours 0.00255 weeks 5.871115e-4 months on March 26, 1987,

this note was entered:

"Please operate demins at 25 gpm with booster

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pump running.

If suction pressure is below 5, need to backflush

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(backflush operation pertains to mechanical filters upstream of the

radwaste system filter -- the radwaste system filter cannot be

backflushed).*

(If)* delts-p (is)* less than 40 (psig pressure drop

across the filter)*, drop (reduce)* flow in 5 gallon- (5 gallons per

minute)* increments until it (pressure drop)* drops below 40 delta-p

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(40 psig pressure drop)* per (Radwaste Supervisor)**."

The last

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entry above was the only record found of the alleged instruction by

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the Radwaste Supervisor to increase the value of the parameter

specified in the procedure.

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At 1731 hours0.02 days 0.481 hours 0.00286 weeks 6.586455e-4 months on March 26, 1987, the following notation appeared:

"MWO (maintenance work request)* has been generated on demin

prefilter.

Filter delta-p is above proceducers (sic)* limits." This

entry was typical of entries noting that a request had been submitted

for replacing the filter cartridges.

Revision 0 of Procedure 13290-C specified in three places that the

liquid radwaste filter cartridges were to be replaced when the

pressure drop exceeded 25 psig but did not specify an upper limit

which was not to be exceeded.

These appeared in Section 2.2.2,

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Section 4.2.1.5 (by reference to Table 3), and in Note

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Section 4.2.5.

Section 4.2.1.5 allowed the continuance of

demineralized system operations as long as the pressure drop across

the filter was either within the normal range of 0 to 25 psig (per

Table 3), or at any other limit or value directed by a Radwaste

Foreman.

The " exception" of Section 4.2.1.5 was cited by a licensee

representative as authority for the order of March 26, 1987, to raise

the limit for differential pressure across the fli;er to 0 to

40 psig.

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Parenthetical

added for clarity.

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A licensee representative stated that the changes in Revision 1,

submitted on March 27, 1987, and approved April 1, 1987, were made to

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formalize the instructions given the previous day to the system

operators to increase the allowable pressure drop across the filters

to 40 psig before filter cartridges were to be changed. This change

was made in an effort to prolong the effective life of the filters,

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However, licensee representatives stated that it was subsequently

found that the raising of the value to 40 psig did not result in

significantly extending system operation. This was attributed to the

characteristic performance of filters of this type, which once having

accumulated sufficient particulate matter to raise the differential

pressure drop above a value on the order to 20 to 25 psig,

continuation of operation resulted in rapid increases in pressure

drop with attendant decrease of flow rate.

After approximately one

month of operation in this mode, it was determined that there was no

significant benefit to be gained _by operating at the higher pressure

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drop and the procedure was again revised to incorporate the original

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values.

It was the conclusion of the inspector and of the inspector's

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supervisors that the alternative provision of Section 4.2.1.5 of the

procedure was meant to be applicable to all references in Procedure

No.13290-C to the changing of the filter cartridges in the event

that pressure drop exceeded 25 psig,

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As previously noted, the ARB log showed that the Radwaste

Supervisor's instruction to change the value of pressure drop was

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entered at 1543 hours0.0179 days 0.429 hours 0.00255 weeks 5.871115e-4 months on March 26, 1987.

There was no entry in the

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ARB log for March 26, 1987, to indicate that pressure drops had been

maintained in excess of 25 psig subsequent to the order.

On

March 27, 1987, a request for revision to the procedure was submitted

through plant administrative channels and contained a safety

evaluation of the revision.

The revision was approved on April 1,

1987, in accordance with plant procedures.

Based on the information described above, the inspector concluded

that there appeared to be no basis for citing the licensee for

violation of Procedure 13290-C and that while the circumstances of

the allegation were essentially correct, the Radwaste Supervisor's

actions were within the intent of the procedure and that no violation

had occurred.

On the basis of the above findings, the allegation was

not substantiated.

b.

A second part of Allegation RII-87-A-0071 stated that a Radwaste

Supervisor had instructed contractor personnel, specifically, Chicago

Bridge and Iron mechanics, to torque bolts to 20 foot-pounds more

than specified in Plant Procedure No. 13290-C.

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The allegation did not specify the time period in which the alleged

violation occurred and did not give the names of individuals concerned,

with the exception of naming the individual against whom the allegation

was made.

On March 27, 1987, a revision to Procedure No.13290-C was

submitted and was approved on April 1, 1987.

Revision 1 changed the value

for torquing the filter cover bolts from 45 to 60 foot-pounds. The change

represented an increase of 15 foot pounds, whereas the allegation

specified an increase of 20 foot pounds.

The inspector reviewed the ARB

Radwaste Operating Log for the period of March 3-26, 1987, the time period

immediately preceding the filing of the allegation at 0636 hours0.00736 days 0.177 hours 0.00105 weeks 2.41998e-4 months , on March

27, 1987.

No entries pertaining to torquing of bolts appeared in the ARB

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log for that period.

There was insufficient time available for the inspector to followup on the

part of the allegation concerning Chicago Bridge and Iron mechanics.

Therefore, the inspector's review of the portion of Allegation

RII-87-A-0071 was considered incomplete.

This matter was considered an

Inspector Followup Item and will be further reviewed during a future

inspection.

(0pened) Inspector Followup Item 50-424/87-34-02:

Review allegation

of procedural violation involving order for mechanics to torque

radwaste filter lid hold-down bolts to 20 foot pounds above specified

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value.

c.

The inspector conducted a limited-scope review of certain aspects of

Allegation RII-87-A-0069 during this inspection.

The review was

limited to the obtaining of information concerning the licensee's

academic and on-the-job training and experience requirements for

promotion, assignment, or hiring of persons to fill chemistry

positions at Plant Vogtle and Georgia Power Company.

The inspector

was instructed not to contact the person or persons making the

allegation.

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In the allegation and in supporting material, two significant points

were raised or stated concerning academic, training or experience

requirements.

These points were essentially as outlined below:

(1) Requirements for qualification and certification of Nuclear

Chemistry technicians are specified in the ANSI Standard and are

as follows:

Level I - 6 months to 1,000 hours0 days 0 hours 0 weeks 0 months ; Level II - 1,000 hours0 days 0 hours 0 weeks 0 months ;

Level III - 4,000 hours0 days 0 hours 0 weeks 0 months .

(2)

... that unqualified workers are testing drinking and reactor

"

cooling water ... " and "... unqualified technicians without

college degrees in chemistry are running tests on potable and

reactor cooling water at Vogtle."

.___-___________________ - _

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11-

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The details of the inspector's findings concerning the above -

allegations are discussed in the following paragraphs.

The current ANSI (American National Standards Institute, Inc.)

standard presumed to be referred to is ANSI /ANS-3.1-1981, "American

Standard for Selection, Qualification and Training of Personnel for

Nuclear Power Plants," issued December 17, 1981.

The standard was

reviewed by the inspector and pertinent information from and about

the standard is presented below.

Information concerning requirements of Plant Vogtle and/or of the

Georgia Power Company relative to chemistry, chemistry technicians,

and chemists was obtained in discussions between the inspector and

,

senior staff of Plant Vogtle and of the corporate offices of Georgia

1

Power Company.

i

Section 4.4.3, " Chemistry and Radiochemistry", of ANSI /ANS-3.1-1981,

relative to the individual

responsible for supervision of

radiochemistry groups, requires that a supervisor shall have a

Bachelor Degree in Chemistry or related science and shall have two

years experience in chemistry, of which one. year shall be nuclear

power plant experience in radiochemistry.

Section 4.5.2 of ANSI / ANSI-3.1-1981, relative - to technicians,

requires a high school diploma and three years working experience "in

their specialty."

It is further required that technicians shall have

demonstrated their ability to perform assigned tasks and their

knowledge of the significance of these tasks on plant operation.

Chemists at Georgia Power's Plant Vogtle fall under two broad

categories -

" Management Staff" and " Chemistry Technicians."

A

chemistry " Technician I" is an entry level technician position.

A

" Technician II" is rated above " Technician I" and is the minimum

!

considered by Georgia Power to be an " ANSI Qualified" position.

A

" Senior Technician" is rated above " Technician II" and is the highest

non-management technician category.

" Senior Technician" was presumed

to be the " Level III" referred to in the allegation. A " Foreman" is

a management staff representative, ranking higher than " Senior

4

Technician" and is the lowest level of management supervision.

Over

the " Foreman" is the Chemistry Supervisor, also a management staff

<

representative.

Georgia Power's " Technician I" or entry level trainee position

requires either a college degree (not necessarily in chemistry) or :

the passing of a written and verbal college " equivalence" test

administered by a (senior) corporate staff member. There is no ANSI

or Georgia Power requirement for prior experience at either a nuclear

or non-nuclear facility for entry level positions.

i

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_ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _

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12.

.

Progression to the " Technician II" level requires satisfactory

{

completion of 2,000 hours0 days 0 hours 0 weeks 0 months of laboratory work or technical training in

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plant chemistry.

The licensee considers " Technician II" chemistry

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personnel to fully meet the criteria of ANSI /ANS-3.1-1981 for

)

radiochemistry technicians.

The position of " Senior Technician" requires at least 4,000 hours0 days 0 hours 0 weeks 0 months

'

experience as a " Technician II," or equivalent prior nuclear

experience.

Licensee representatives pointed out that promotion to

)

" Senior Technician" involves substantially more than just the

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accumulation of 4,000 hours0 days 0 hours 0 weeks 0 months of experience and includes such items as

!

completion of specific training modules or skill tests, consistency

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and accuracy of analyses, and job performance ratings.

1

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ANSI /ANS-3.1-1981 does not categorize technicians as I, II, III, or

" Senior."

A foreman ranks higher than a Senior Technician and represents the

i

lowest level of staff or management supervision.

There are no

I

specific ANSI /ANS-3.1-1981 requirements for this positten.

However,

)

Georgia Power Company equates the foreman position to that of

supervisor of radiochemistry in ANSI /ANS-3.1-1981, which requires a

bachelor degree (field not specified) and a minimum of 2 years

experience in chemistry, of which 1 year must be in radiochemistry.

Summaries of personnel records of 20 unidentified chemistry

i

technicians were reviewed.

Fourteen had bachelor degrees, four had

Associate Degrees (2 yr college), one had a 4-year technical school

diploma as a Chemistry Technician, and one had a high school diploma

i

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with no college but had successfully passed the licensee's

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" equivalence" test.

Records showed four persons (as of the date of this inspection) in

the " Technician I" category.

One person, a new hire, had no

experience on the training record as of the date of the inspection.

Two persons had ten months of experience, and a fourth had 16 months

of experience. All had college degrees.

l

Records of six " Technician II's" showed two persons with 14 months

experience, one person with ten months on the present assignment and

one year prior Georgia Power experience, one person with 10 months

i

experience, one person with eight months experience, and one person

j

with four months experience in the present assignment, but with ten

l

years prior nuclear experience and a diploma in Chemical Technology.

'l

With the exception of the last person listed, all of the above had

college degrees.

Qualifications of seven " Senior Technicians" were as follows:

6 years in present assignment, Bachelor of Science Degree in

-

Biology, 6 years with Georgia Power

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5 years in present assignment, Bachelor of Science Degree in

-

Biology, 5 years with Georgia Power

4 years 'n present assignment, Bachelor of Science Degree in

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Chemistry, 4 years with Georgia Power

1 year in present assignment, Bachelor of Science Degree in

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Physics, 4 years with Georgia Power

1 year in present position, Bachelor of Science Degree in

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Biology, 2 years and 8 months with Georgia Power

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3 years in present assignment, Associate in Science (2-year)

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Degree in Nuclear Engineering, 3 years with Georgia Power

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3 years in present assignment, Bachelor of Science Degree in

-

Chemistry, 3 years with Georgia Power,

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Records of six Chemistry foremen were reviewed with the following

l

results:

I

4 years experience in current position, Associate (2-year

-

college) Degree, 10 years total nuclear plant experience,

l

Georgia Power Employee since 1983

-

3 years in current position, Associate Degree, 3 years total

nuclear plant experience, and Georgia Power employee since 1984

Recent promotion from Tech II, Bachelor of Science Degree in

-

Chemistry, 2 years nuclear plant experience

3 years in present position, 5 years prior nuclear experience

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(Navy), 4 years of college electronics - no degree (passed GPC

college-equivalence test)

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3 years in present position, Bachelor of Arts Degree in History,

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3 years nuclear experience (Georgia Power)

-

3 years in present position, Bachelor of Science Degree in

'

Biology, 3 years nuclear experience

The above information was compiled in accordance with instructions,

I

as previously noted. The inspector did not assess the qualifications

!

of the individuals concerned and did not evaluate the validity of the

portion of the allegation concerning qualifications of chemistry

technicians and foremen as to nuclear plant experience and the need

for a college degree in chemistry.

The second allegation point concerned unqualified workers testing

drinking and reactor cooling water and unqualified technicians

I

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.

.

14

without college degrees in chemistry running tests on potable and

reactor cooling water at Plant Vogtle.

Relative to unqualified workers testing reactor cooling water, the

inspector considered this metter to be fully discussed in the

foregoing paragraphs on ANSI /ANS-3.1-1981 qualifications for

chemistry personnel.

'

ANSI /ANS-3.1-1981 does not address testing of drinking water.

i

Relative to unqualified workers testing drinking / potable water, the

l

inspector contacted the Water Protection Branch, Natural Resources

Department of the State of Georgia.

There are various State of

Georgia certifications required for persons performing laboratory

tests. Without going into detail as to the specific requirements for

each type of State certification, the oni/ academic requirement for

l

any of the State certifications for laboratory testing of

drinking / potable water is that a person to be certified shall be a

'

high school graduate or possess a hi gh school equivalence

I

certification (G.E.D.).

In other words, a college degree in

l

chemistry is not required for State certification as a

drinking / potable water analyst.

As previously noted, the above information was compiled in accordance

with instructions.

The inspector did not assess the qualifications

of the individuals concerned and did not evaluate the validity of the

portion of the allegation concerning qualifications of chemistry

technicians responsible for analyzing drinking / potable water.

8.

Licensee Action on Previously Identified Inspector Followup Items Unit 1

(84521,84523,84524)

(Closed) 50-424/86-34-01, Install shielded prefilter in TSC ventilation

(Vogtle Readiness Review finding).

The design and construction of this

item were previously reviewed in 50-424/87-09, Paragraph 6.

During this

inspection, the inspector verified the installation of the system, which

was located in an alcove next to the HVAC system for the TSC. The system

appeared to be adequately shielded.

The prefilter had not been tested at

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the time of the inspection due to excessive vibration of the system

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blower; however, IFI 50-424/87-09-02 was previously opened for review of

DOP and freon leak tests of all TSC HEPA filters and charcoal adsorbers,

which included the prefilter.

On the basis of the above discussion, IFI

50-424/86-34-01 is considered closed.

(Closed)

86-37-02:

Review licensee and plant procedures to delete

reference to inplant " efficiency" testing of HEPA filters or equipment,

and 85-37-03:

Review revised implementing procedures to specify correct

leakage values for HEPA filter banks.

Both of the above items represented a common error or misconception on the

part of licensees, i.e., that an inplace test for bypass leakage in a HEPA

filter system may be interpreted in terms of percent efficiency of the

1

. _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

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HEPA filter media.

ANSI N510-1980, Section 10.1," Purpose", states "The

in-place test is a leak test of the installed system and should not be

i

confused with the efficiency test of individual filters." Similarly, the

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hal%enated hydrocarbon leak test of carbon adsorber beds is not a measure

i

of the efficiency of the system for retention of radiciodine.

l

Both in the FSAR and in plant procedures, reference was made to

"ef ficiency" in referring to leak testing.

While this practice was

technically incorrect, it is a relatively common practice in the industry

and it was not considered to be a significant safety concern.

On this

basis, both of the IFIs listed above were considered closed.

(0 pen) 86-137-06: Review applicant (licensee) evaluation of mechanisms of

sample line transport for iodine in long sampling lines.

Licensee

representatives stated that the evaluation had not yet been completed.

This item remains open.

,

(0 pen) 87-09-01:

Evaluate PASS operation after plant has operated at

l

least 30 days at full power and correlate analytical measurements against

'

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normal sample results.

The plant had not been operated fcr 30 days at

l

full power at the time of this inspection. This item remains open.

(0 pen) 87-09-02:

Review results of D0P and freon leak tests of TSC

filters and charcoal adsorbers.

This system was inoperative at the time

of the inspection.

A licensee representative stated that the

preoperational test had not been completed due to excessive vibration of

the system blower or drive motor.

The D0P and freon tests could not be

run until the vibration problem had been corrected.

This item remains

open.

(Closed) 86-37-01:

Review licensee FSAR update to reflect ASTM D3803

criteria for carbon testing.

The FSAR, as amended up to the date of this

inspection, continued to reference Regulatory Guide 1.52, Rev. 2 (March

l

1978) for criteria for carbon testing. This reference did not accurately

reflect currently acceptable criteria for carbon testing, except through

'

an intricate reference path.

Regulatory Guide 1.52, Rev. 2, referenced

i

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ANSI N510-1975; ANSI N510-1975, in turn, referenced an obsolete DOE

standard, RDT M16-IT (October 1973) which formerly contained specific test

methods and criteria.

The current version of RDT M16-1T deleted the test

methods and criteria of RDT 16-1T (October 1973) in favor of referencing

ASTM D3803 test methods and criteria.

The current ANSI N510-1980 also

similarly referenced ASTM D3803.

This IFI suggested a shortcut of the

reference path to ASTM D3803 which the licensee did not elect to adopt.

Since all U.S. testing laboratories known to the NRC had converted their

I

test procedures to comply with ASTM D3803 and no longer follow the older

l

RDT procedure, the point is considered moot and of no significant safety

I

consequence.

On this basis, this item is considered closed.

- - - - - - - - - - - - - - - - -

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16

10. Licensee Action on Prev'ously identified Inspector Followup Items Unit 2

(84521,84523,84524)

(Closed) 50-425/86-18-33, Complete all procedures required for post

accident liquid effluent sampling.

The NRC does not require that the

applicant establish procedures specifically for liquid effluent sampling

under post accident conditions.

Since there is no requirement for a

procedure such as was indicated in the appraisal, this item is withdrawn

and is considered closed.

(0 pen) 86-18-82

Completion of procedures for PASS calibrations and

verification and troubleshooting.

The Unit 2 PASS was not ready for

inspection as of the date of this inspection and will be inspected during

the preoperational inspection program at a later date to be determined.

This item remains open.

(0 pen) 86-18-83, Completion of PASS training once the system becomes

operational and updating tracking system to reflect this.

The Unit 2 PASS

i

l

was not expected to become operational until at least 1989.

This item

will be reviewed during preoperational inspections at the appropriate

time. This item remains open.

3

(Closed) 50-425/86-18-84, Complete " flagging" process on training tracking

system for PASS personnel requiring semi-annual retraining. The inspector

l

reviewed the PASS training program, examined individual training file

jackets, examined course material, examined course training records, and

observed operation of the computerized training records and tracking

system.

The tracking system was judged to be adequate; on this basis,

this item was considered adequate and is considered closed.

(Closed) 86-18-85:

Final placement of designated equipment at local

panel, TSC (Technical Support Center) storage cabinet, and radiochemistry

cabinet.

During a walkdown of the PASS, the inspectors determined that

i

equipment, supplies, and procedures were in-place at the local PASS

cont"

3anel, in the PASS TSC storage cabinet and in the radiochemistry

lab c- inet.

Based on the foregoing inspection and discussions of Unit 1

PASS operation with applicant personnel, this item is considered closed.

(0 pen) 86-18-86, Completion of final PASS operational testing.

Final

Unit 2 PASS preoperational testing, necessary prior to fuel load of

Unit 2, had not been scheduled as of the date of this inspection.

This

item remains open.

(Closed) 86-18-87:

Revise procedure 33016-C to include missing

instructions on valve numbers, activity curves, and data sheets.

The

inspectors reviewed Procedure 33016-C, Rev. 2, November 14, 1986.

Valve

numbers had been entered on appropriate drawings.

Appropriate tabular

data were provided for (1) gaseous noble gas activity versus zero iodine

activity and (2) expected iodine activity versus flow rate versus sample

time.

Figures were also developed for grab sampling equipment items and

building locations.

The procedure calls for results to be logged in the

_______-__-___________a

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Lab notebook as directed by Procedure 31045-C, " Chemistry Logkeeping,

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Filing and Record Storage;" for this reason, no data sheets were provided

or deemed necessary.

The inspector found the revised procedure to be

.

adequate and on the basis of that determination, this item was considered

3

'

closed.

1

(0 pen) 86-18-88:

Assure volume of vent air representative of actual

)

effluent activity; or that correction factors developed compensate for

j

sample scavenging mechanisms.

The inspectors reviewed applicant

i

Procedure 33610-C, Rev. 2, November 14, 1986.

The procedure appeared to

be adequate as to the volume of vent air being representative of actual

effluents for sampling of noble gases.

However, the procedure did not

adequately address several areas of concern in the collection of

representative samples of radioiodines and particulate.

Specifically,

j

the procedure did not address (or provide a satisfactory reference for)

the representative sampling or extraction of iodines and particulate from

the exhaust stream and did not address losses, or correction factors for

losses, of iodines and particulate

in the sample transport of the sample

through long lines from the point of withdrawal from the exhaust steam to

the point of collection on the filter medium or absorber medium. Guidance

on this matter acceptable to the staff appears in ANSI N13.1-1969 and in

the proceedings of the bi-annual nuclear air cleaning conferences

sponsored by the Department of Energy. This item remains open.

(Closed) 86-18-89:

Complete Implementing Procedure 3306E-C.

The

inspectors reviewed 33065-C, " Gamma Spectroscopy Analysis under Accident

Conditions," and discussed the procedure with applicant representatives.

Actual verification of sampling and analysis under radioactivity

conditions will be accomplished at a later date during the NRC evaluation,

which will be performed at such time as the reactor attains a minimum of

30 continuous full-power days of operation immediately prior to the date

of the evaluation.

Since the evaluation is listed under IFI 86-18-86 as

requiring inspector followup, this item is considered closed.

(Closed) 86-18-90:

Develop and implement a procedure for safely and

,

l

accurately analyzing liquid effluent samples.

There are no formal NRC

l

requirements that the applicant must have established procedures for the

i

safe and accurate sampling of liquid effluents.

This item is withdrawn

and is considered closed.

l

(Closed) 86-18-91: Develop procedures for safely and accurately analyzing

l

liquid effluent samples. There are no NRC requirements that the applicant

must have established procedures for safely and accurately sampling and/or

analyzing liquid effluents.

This item is withdrawn and is considered

closed.

1

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ML20234E318

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