ML20239A107
| ML20239A107 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/31/1987 |
| From: | Croley B, Esperanza E, Humenansky D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | |
| Shared Package | |
| ML20238F564 | List: |
| References | |
| NUDOCS 8709170081 | |
| Download: ML20239A107 (33) | |
Text
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EXPANDED AUGHENTED SYSTEM REVIEW AND TEST PROGRAM (EXPANDED ASRTP)
EVALUATION OF THE RADIATION HONITORING SYSTEM l
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SUBMITTED BY M
/kdb M DATE:
/ EFREN'R. ESPERANZA C TEAM LEADER rW t d 2
DATE:
$ '3 l N CONCURRENCE:
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EXANDEDASRTPPROGRA[ MANAGER DAVID HUMENANSKY M
CONCURRENCE:
DATE:
J) Y
/
~B0B CROLEY
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DIRECTOR, NUCLEAR TE NICAL SERVICES l
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TABLE OF CONTENTS Paae Number
1.0 INTRODUCTION
3 2.0 PURPOSE 4
3.0 SCOPE 5
4.0 OVERALL RESULTS AND CONCLUSIONS 6
5.0 SPECIFIC CONCERNS 8
5.1 Acknowledged (Valid) Concerns 8
5.2 Open (Potential) Concerns 9
6.0 ATTACHMENTS 10 6.1 List of Documents Reviewed 11 6.2 Status of RIs 13 l
6.3 Detailed Observations - Requests for Information 14 l
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EXPANDED AUGMENTED SYSTEM REVIEH AND TEST PROGRAM EVALUATION OF THE RADIATION HONITORING SYSTEM
1.0 INTRODUCTION
The Rancho Seco Expanded Augmented System Review and Test Program
[ASRTP] evaluation effort involves an assessment of the effectiveness of the System Review and Test Program [SRTP) and an analysis of the adequacy of ongoing programs to ensure that systems will continue to function properly after restart.
The Expanded ASRTP is a detailed system by system review of the SRTP as implemented n.1 33 selected systems and an in-depth review of the engineering, modification, maintenance, operations, surveillance, inservice testing, and quality programs.
It also conducts a review, on a sampling basis, of many of the numerous ongoing verification and review programs at Rancho Seco.
Six multi-disciplined teams composed of knowledgeable and experienced personnel are tasked with performing the Expanded ASRTP.
Each multi-disciplined team consists of dedicated personnel with appropriate backgrounds to evaluate the operations, maintenance, engineering, and design functional areas.
Independence, perspective, and industry standards provided by team members with consultants, architect engineer and vendor backgrounds are joined with the specific plant knowledge of SHUD team members.
Each team performs an evaluation on a selected system using the same fundamental evaluation techniques employed by the NRC in the ASRTP inspection.
System Status Reports are used as the primary source of leads for the teams.
They are augmented with references to available source and design bases documents as needed.
Team synergism and communication is emphasized during the process in order to enhance the evaluation.
Each team prepares a report for each completed selected system evaluated.
This report is for the Radiation Monitoring system. 1
2.0 PURPOSE The objectives of the Expanded ASRTP evaluation are to (1) assess the adequacy of activities and systems in support of restart and (2) evaluate the effectiveness of established programs for ensuring safety during plant operation after restart. l
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3.0 SCOPE To accomplish the first objective, the HVAC team evaluated the Radiation Monitoring system to determine whether:
1.
The system was capable of performing the safety functions required by its design bases.
2.
Testing was adequate to demonstrate that the system would perform all of the safety functions required.
3.
System maintenance (with emphasis on pumps and valves) was adequate to ensure system operability under postulated accident conditions.
4.
Operator and maintenance technician training was adequate to ensure proper operations and maintenance of the system.
j 5.
Human factors relative to the system and the system's supporting procedures were adequate to ensure proper system operations under normal and accident conditions.
To accomplish the second objective, the team reviewed the programs as implemented for the system in the following functional areas:
1.
Systems Design and Change Control 2.
Maintenance 3.
Operations and Training 4.
Surveillance and Inservice Testing 5.
Quality Assurance i
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Engineering Programs The team reviewed a number of documents in preparation for and during the Expanded ASRTP evaluation.
This list of documents is found in Attachment 6.1.
The primary source of leads for the team were the problems identified in the Radiation Monitoring System Status Report.
Various source documents such as the USAR and Technical Specifications and available design bases documents were reviewed as needed to augment the information needed by the team.
The evaluation of the Radiation Monitoring system included a review of pertinent portions of support systems that must be functional in order for the Radiation Monitoring system to meet its design objectives.
R Q.ERALL RESULTS AND CONCLUSIONS 4.0 V
The more significant issues identified pertaining to the adequacy of the SRTP and the effectiveness of programs to ensure continued safe operations after restart are summarized below.
The summary focuses on the weaknesses identified during the evaluation. Attachment 6.3 provides detailed findings by providing the Request for Information (RI) forms that are used by the Expanded'ASRTP teams to identify potential concerns during the evaluation.
Section 5.0 lists the specific concerns identified by the teams.
The numbers in brackets after each individual summary or concern refer to the corresponding RIs in Attachment 6.3.
l 4.1 RADIATION MONITORING SYSTEM 4.1.1 Some Radiation Monitoring System Status Report (SSR) problem resolutions may not fully address the identified problem, l
[RI #101] [RI #125]
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ECNs A-2332 and R-1227 addressing SSR Problem 6 changed the HVAC System in the grade level of the Auxiliary Building (Controlled side) by installing a new exhaust fan, radiation monitor, and filters for the exhaust flowpath.
The ECN is still open, however, if it is implemented as written, the design will allow an unmonitored flowpath of contaminated air to the atmosphere to exist until operators can trip supply fans and open/close certain Auxiliary Building doors.
A draft RM-Il annunciator procedure was written which includes some of the discussion in the Design Bases Report (DBR) for R-1227 for a high radiation alarm on R-15546A, but it is incomplete.
The procedural guidance and operator action does not appear to be a long term solution.
The use of procedural guidance in the situation where the exhaust fan is shut down/ trips is inconsistent with the design of HVAC systems in other plant areas where contamination is a potential problem during i
accident / normal conditions.
The resolution to the SSR Problem #1 as recommended in ECN R-0457 limits access for Control Room Operator to Radiation Monitoring Trend Information during power operation.
ECN R-0457 recommended to transfer radiation monitors trending from recorder RJR-013 at the Radiation Monitoring Panel (inside the Control Room Area) to panel H3THI (outside the Control Room Area).
It was relocated to provide the Health Physics staff with readable plant gaseous radiation activity trends to analyze trend data at H3THI following an alarm e.g., on the Air Ejector Radiation Monitor. j i
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OVERALL RESULTS AND CONCLUSIONS (Continued) 4.1.2 A Casualty Procedure to provide guidance in the event of RM-ll failure does not exist.
Failure of the single RM-ll computer terminal and/or display will cause at least those RM-80 radiation monitors to be declared inoperable.
RM-ll failure will also cause a loss of Control Room indication of RM-80 radiation monitor status and RM-80 detected radiation levels.
A draft revision (Rev. 3) of RM-ll Annunciator Resconse Procedure provides guidance for temporary measures (installation of an RM-23P if an RM-23L is not permanently installed) in the event of RM-ll failure.
However, the problem of providing the Control Room with information obtained from the RM-23P and RM-23L installed locally at the monitor in the field is not addressed in the draf t procedure.
The delay in getting information during an accident situation that would aid in determining the safety status of the plant and the extent of the radiological hazards will greatly increase the time required to make necessary decisions that are necessary to determine and maintain the i
plant safety conditions. [RI #162]
4.1.3 A review of the system test matrix indicated that one of the system's main functions, emergency grab scmpling, is not tested on a periodic basis.
The emergency grab sampling functions of the Containment Atmosphere and Reactor Building Stack Monitor, the Auxiliary
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Building Stack Monitor, and the Auxiliary Building Radwaste Service Area Stack Monitor may not perform as intended in i
the event of an emergency.
[RI #131]
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5.0 SPECIFIC CONCERNS A list of the specific concerns the Expanded ASRTP team believes are new concerns not previously identified for resolution follows:
5.1 Acknowledged (Valid) Concerns 5.1.1 The relocation of Radiation Monitor trending from recorder RJR-013, which was accomplished per ECN R-0457, at the Radiation Monitoring Panel (inside the Control Room Area) to panel H3THI (outside the Control Room Area) imposes restriction for the operator in the Control Room to Radiation Honitoring Trend Information during power j
operation.
[RI #101]
j 5.1.2 The system design per ECNs A-2332 and R-1227 allows an unmonitored flowpath of contaminated air to the atmosphere to exist until operators can trip supply fans SF-A-1 and SF-A-2 and Open/Close certain Auxiliary Building doors.
[RI #125]
5.1.3 Surveillance Procedure SP.451 does not consider an industry recommended multiplication factor in the flow rate calculation which may unnecessarily declare Radiation Monitors R-15044 and R-15045 inoperable.
[RI #103]
5.1.4 Labeling discrepancies were identified for Radiation Monitor skids R-15044, R-15045 and R-15046A and their associated P& ids.
[RI #115]
5.1.5 There are not any Preventive Maintenance Procedures for Radiation Honitors and associated equipment.
[RI #117]
5.1.6 The emergency grab sampling functions of Radiation Honitors R-15044, R-15045 and R-15046A are not periodically tested.
[RI #131]
5.1.7 Operators are not providing guidance on operability of radiation monitors.
[RI #156]
5.1.8 Radiation Honitoring devices may be calibrated to incorrect setpoints due to inadequacy of documentation and procedures.
[RI #158]
5.1.9 Training for Radiation Protection Technicians is inadequate for familiarity with the operation of Radiation Monitors and RH-ll computer.
[RI #159]
5.1.10 There is not a Casualty Procedure for failure of single RH-11 computer or its terminal.
[RI #162]
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A knowledaed (Valid) Concerns (Continued) 3 5.1.11 Operating Procedures to control the use of backup radiation monitoring equipment when primary accident monitoring equipment becomes inoperable in an emergency situation may be inadequate.
[RI #155]
5.2 Ooen (Potential) Concerns None 4
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6.0 ATTACHMENTS l
6.1 List of Documents Reviewed 6.2 Status of RIs 6.3 Detailed Observations - Requests for Information i
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e LIST OF DOCUMENTS REVIEHED AP.305-24 Reactor Building Air and Stack Samples AP.305-26 Auxiliary Building Air and Stack Samples AP.305-33 Radiation Monitoring System AP.313-2 Emergency Grab Air Sampling for R-15044, R-15045 and R-15046A AF.23.15 Equipment labeling, 03-07-87 10CFR50.54 Code of Federal Regulations, Title 10, January 1, 1987 SO 87-19 Disabled Annunciator Log Book (Control Room)
Radiation Honitoring System Design Bases Report H2PSA Annunciator Response Procedure I.602 Area Radiation Monitor Calibration I.605 Radiation Monitor System Monthly Test l
I.606 Reactor Building Purge / Radiation Honitor Interlock Test General Atomic Maintenance Manual N16.13-IH22 and N16.13-IH23 Victoreen Maintenance Manual, N16.01-31 Generic Letter 87-02 i
Operating Procedure A.65, Rev. 13, Radiation Detection System - Gaseous, j
Particulate and Iodine Operating Procedure A.66, Rev. 6, Radiation Detector Liquid System i
l Occurrence Description Report,87-564 l
Occurrence Description Report, 87.610 i
00-21-I-6100 Licensed Operator Training Program - Radiation Monitoring System Offsite Dose Calculation Manual, Rev. 3 Proposed Technical Specification Amendment 153 NRC Temporary Instruction 2515/87 NUREG-0737, II.E.4.2, Appendix B; Design and Qualification Criteria for Accident Monitoring Instruction Reg Guide 1.97, Rev.
RP.313-06 Radiation Monitor Alarm Response RM-ll Annunciator Response Procedure, Rev. 3 l
Radiation Monitoring System Status Report Radiation Honitoring System Test Matrix SP.446 Honthly Test of the Containment Area Hi Range Monitors SP.447 Honthly Test of the Hi Range Noble Gas Effluent Henitors SP.448 Honthly Test of the Main Steam Line Radiation Mont tors SP.450 Biannual Calibration of Radiation Monitor Sampler Flow Rate Measurement Devices FISHL-15001A&B and FISHL-15002A&B l
SP.451 Semi Annual Channel Test of Reactor Building Purge Vent and Auxiliary Building Stack Effluent Flow Rate Devices SP.452 Refueling Interval Channel Calibration of Reactor Building Purge Vent and Auxiliary Building Stack Effluent Flow Rate Devices 4
SP.200.07 Radiation Instrumentation Technical Specifications:
Sections 1.0, 1.3, 3.1.6.5, 3.1.6.7, 3.5.5, 3.15, 3.16, 6.0 ATTACHMENT 6.1 i l
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LIST OF DOCUMENTS REVIEHED (Continued)
USAR Section 1.4.17, July 1982, Criterion 17 Honitoring Radioactivity Releases (Class B)
USAR Section 11.3.2.3, Post Accident Radiation Monitors USAR Section 11.3.1.1, On-Site Monitoring ECN R-0913 Replacement of R-15001 and R-15002 ECN A-3683 New Post Accident Rad Monitor System Dwgs. H-510 H-511, M-512 and H-513, E-318-1, Rev. 21 l
Hork Request #114174 Haster Equipment List i
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ATTACHHENT 6.1 L- ------
STATUS OF RIs.2 provides RI status as of this report date. An RI is considered closed if the Team Leader was convinced a potential concern was not valid or not significant enough to be an RI. An RI would also be closed if requested information was provided.
All other RIs are open.
Acknowledged RIs are open RIs that have been accepted as valid by the responsible organization and have been stated as concerns in Section 5.0.
RI NUMBER STATUS 101 ACKN0HLEDGED 102 CLOSED 103 ACKN0HLEDGED 115 ACKNOWLEDGED 117 ACKNOWLEDGED 122 CLOSED 123 CLOSED 125 ACKN0HLEDGED 131 ACKNOWLEDGED 148 CLOSED 155 ACKN0HLEDGED l
156 ACKN0HLEDGED 158 ACKN0HLEDGED 159 ACKNOWLEDGED 162 ACKN0HLEDGED 163 CLOSED l
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ATTACHMENT 6.2,
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DETAILED OBSERVATIONS - RE0 VEST FOR INFORMATIHt!
During an evaluation, all potential concerns are documented on Request for Information sheets (RIs) that are sent to the responsible organization to receive their input concerning the potential concern.
RIs are also used to request information that the EASRTP team is having difficulty obtaining.
These RIs are considered drafts throughout the entire evaluation until they become part of the report.
Responsible organizations can accept the l
potential concern as valid or they may disagree with the potential concern.
If they disagree, they can submit information that convinces the EASRTP team members that the potential concern is not valid, or they may redirect the EASRTP members to better focus the concern.
RIs developed during the system evaluation comprise this section of the report.
ATTACHMENT 6.3 l
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i REQUEST FOR INFORMATION (RI)
RI NO:
101 SYSTEM CODE:
RDM ISSUE DATE:
08-06-87 1
SUBJECT:
SYSTEM STATUS REPORT (SSR) PROBLEM #1 RESOLUTION:
ECN R-0457 DEPARTMENT:
SYSTEM ENGINEERING COORDINATOR:
JOHN ITTNER/4153 TEAM LEADER:
E. ESPERANZA/3951 l
POTENTIAL CONCERN /0VESTION:
The resolution to Radiation Monitoring System Status Report Problem #1, Recorder RJR-013 cannot be easily read" imposes a restriction for the operator in the control room to Radiation Monitoring Trend Information during power operation.
10CFR50.54 m(2)(iii) states that "When a power plant is in an operations mode other than cold shutdown or refueling" requires one senior licensed operator to be in the control room and another licensed operator to be at the controls. AP.23.05, Enclosure 8.1 defines the " Controls Area" and
" Control Room Area."
ECN R-0457 was dispositioned to transfer radiation monitors trending from recorder RJR-013 at the Radiation Monitoring Panel (inside the Control Room Area) to panel H3THI (outside the Control Room Area).
The design basis report for ECN R-0457 states, "The purpose of this change is to provide the Health Physics staff with readable plant gaseous radiation activity trends." This created a problem because someone other than the two licensed operators who are required to be inside the Control Room Area must be available to analyze trend data at H3THI following an alarm e.g., on the Air Ejector Radiation Monitor.
Annunciator response procedure for gas radiation monitors lists as a response item for the Air Ejector Radiation Monitor:
" Step 5.
Frequently check R-15004 trending on RJR-15000A, trace B, to evaluate activity increase / decrease."
The ECN may have accomplished its stated purpose, but imposed restricted access of this information to the Control Room operators during plant I
operation.
This could result in delayed operator response to an "off-normal" situation, i
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ATTACHMENT 6.3 l l
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1 REQUEST FOR INFORMATION (RI)
RI NO.
102 SYSTEM CODE:
RDM ISSUE DATE: _._q8-27-87
SUBJECT:
SYSTEM STATUS REPORT (SSR) PROBLEM #6:
"A-546. R-15546 AND
. R-15546A NOT IN SERVICE" DEPARTMENT:
OPERATIONS COORDINATOR / EXT:
R. MACIAS/4589 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0 VEST 10N:
A review of the procedural changes required by the resolution of System Status Report #6 brought out the following concern.
Some important information included in the Design Basis Report (DBR) for ECNs R-1227 and A-2332 has not been included or identified for inclusion in the applicable procedures.
The absence of this information could result in an extended unmonitored release from the site.
The procedures reviewed were in draft form.
ECNs R-1227 and A-2332 are no_t closed.
The concern addressed here may also be identified as part of the normal review process, but are offered to ensure the concerns are addressed and, if found valid, are properly tracked prior to the procedures being used operationally.
BACKGROUND i
ECN A-2332 and R-1227 changed the HVAC system in the grade level of the Auxiliary Building (controlled side) by installing a New Exhaust Fan (A-546), Radiation Monitor (R-15546A), and the filters for the exhaust flow path. The DBR for ECN A-2332 specified certain actions to remove A-546 from service for maintenance.
" Secure supply fans SF-A-1, SF-A-2 as soon as possible.
Do not begin any maintenar.ce activity on the makeup i
tank / filters / valving area until A-546 is declared operational.
Personnel
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occupancy to be limited. Securo all Auxiliary Building Doors open to l
atmosphere.
Procedurally open no mally closed door to the -20 ft elevation to exhaust the grade level area via A-542A or A-5428."
Similar actions are required as "Special Oper ding Requirements" following a trip 1
or other loss of A-546.
Operating Procedure A.148, original, Auxiliary Building HVAC Systems, I
draft dated 06-03-87 did not include the DBR conditions in Section 7.7, Directions for Shutdown of A-546 for Filter Maintenance, or in.Section 6.7, Normal Shutdown.
If the procedure is executed as written, without shutdown of the supply fans described in the DBR, air Will flow out doors and other openings to create an unmonitored flow path off site.
ATTACHMENT 6.3 _.
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Casualty Procedure, C.148, Loss of MCC, Rev. 4, dated 4-3-85 does not i
contain any direction for trip of the power supply breaker for A-546 (Breaker 2D415).
The same requirements specified by the DBR would apply.
No actir a item to incorporate this concern could be identified.
The RM-11 (Radiation Monitors) annunciator procedure (draft, dated 7-27-87, Rev. 3 includes some of the discussion included in the DBR q
(R-1227) for a high radiation alarm on R-15546A, but is incomplete.
Response, step four states:
4.
Consult with Rad Protection to:
- Coordinate isolation and decontamination activities.
Evaluate termination of the release by stopping Auxiliary Building Grade Level Exhaust Fan A-546.
The DBR for ECN R1227 specifies:
l The release should continue even after a high alarm.
Should health physics determine it necessary to trip A-546, supply fans SF-A-1 and SF-A-2 shall also be tripped manually.
All doors at grade level leading to the atmosphere be secured.
i Door to -20 ft level be kept open to allow some suction of the A-542 A and B pathway to preclude out leakage from grade level.
The RM-11 annunciator response for a high radiation alarm on R-15546A provides other valuable guidance for operator but is lacking in guidance to prevent an unmonitored flow path off site.
As previously noted, these comments are made on ECNs nal closed, and procedure drafts.
They were considered significant enough to be documented here to ensure they were considered in the procedure review process.
This RI is CLOSED.
This has been combined with RI #125.
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REQUEST FOR INFORMATION (RI)
RI NO:
103 SYSTEM CODE:
RDH ISSUE DATE:
08-05-87
SUBJECT:
SP.451 FLOW VERIFICATION ACCURACY DEPARTHENT:
SYSTEM ENGINEERS COORDINATOR:
JOHN ITTNER/4153 TEAM LEADER:
E. ESPERANZA/3951 POTENTIAL CONCERN /00ESTION:
Due to an inconsistency in a flow rate calculation in Surveillance Procedure SP.451, Radiation Monitor R-15044 and R-15045 may be declared inoperable unnecessarily.
I Surveillance Procedure SP.451, Semi-Annual Channel Test of Reactor Building Purge Vent and Auxiliary Building Stack Efficiency Flow Rate Devices, is performed to verify Reactor Building and Auxiliary Building exhaust air flow rates are accurately indicated at radiation monitors R-15044 and R-15045. Air velocities at the centerlines of appropriate ducts are measured to facilitate calculation of air flow rates.
The American Conference of Government Industrial Hygienists Handbook, Industrial Ventilation, states:
The use of a single centerline reading for obtaining average velocity is, at best, a very coarse approximation. When a centerline reading is taken, the location must be 10 diameters of straight duct downstream from the nearest disturbance.
The underline velorfty pressure thus obtained should be multiplied by 0.81 or the velocity by 0.9 to obtain an approximation of the average velocity.
I The recommended factor is not included in the surveillance calculation.
l Therefore, the surveillance calculated flow rate is greater than the actual flow rate and may not agree with the flow rate, indicated by the radiation monitor.
This may cause the radiation monitors to be declared inoperable unnecessarily.
An ODR was written to document this problem as a procedural inadequacy.
ATTACHMENT 6.3 I
REQUEST FOR INFORMATION (RI)
RI NO:
115 SYSTEM CODE:
RDH ISSUE DATE:
08-07-87
SUBJECT:
LACK OF E0VIPMENT IDENTIFICATION DESIGNATIONS ON VALVES LOCATED ON RADIATION HONITOR SKIDS AND/OR P& ids DEPARTMENT:
NUCLEAR ENGINEERING COORDINATOR / EXT:
R. LAHRENCE/3849 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0VESTION:
The following labeling discrepancies were identified on R-15044 and R-15045 and their associated P& ids.
1.
Manual valves located on the radiation monitor skid for R-15044 are labeled; however, these valves are not identified on P&ID H-512.
No l
consistency seems to exist in this labeling since neither the manual valve for R-15045 or R-15546A are labeled.
2.
The detector outlet manual valve for R-15405 is labeled with the same valve number, HVS-799, as the detector outlet manual valve for R-15044.
These valves are not identified by number on drawing H-512.
3.
The flow indicators, RFI-15045 A/B, for R-15045 are not labeled.
4.
The motor operator outlet valve for detector R-15044 is labeled as HV-15044C.
Drawing M-551 identifies the valve as HV-150440.
5.
The cross tie sampic manual valve between R-15044 and R-15045 is i
labeled as HVS-771.
This valve is not identified on either drawings M-512 or M-551.
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i ATTACHMENT 6.3 REQUEST FOR INFORMATION (RI)
RI NO:
117 SYSTEM CODE:
RDM ISSUE DATE:
08-10-87
SUBJECT:
RAD-MONITORS MAINTENANCE PROCEDURES DEPARTMENT:
MAINTENANCE COORDINATOR / EXT:
JIH DARKE/4817 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /00EST1QS:
Maintenance Procedures are virtually non-existent for radiation monitors and associated equipment.
Victoreen Maintenance Manual N16.01-31 and G.A. Maintenance manual N16.13-IM22 and N16.13-IM23 recommends periodic maintenance of the Rad-Monitors and associated equipment.
At present there's no Preventive Maintenance (PM) Procedures on the Rad-Monitors and associated equipment other than changing filters.
There is no maintenance being performed on critical equipment.
Such as pumps, motors, belts, actuators, valves, etc.
1 ATTACHMENT 6.3 REQUEST FOR INFORMATION (RI)
REVISION 1 RI NO:
122 SYSTEM CODE:
RDH ISSUE DATE:
08-14-87
SUBJECT:
SURVEILLANCE PROCEDURE FOR RADIATION MONITORS DEPARTMENT:
SYSTEMS ENGINEERING COORDINATOR / EXT:
J. ITTNER/4153 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0VESTION:
The format of Surveillance Procedures SP.446, SP.447, SP.448, SP.451 and SP.452 may cause more than one rtdiation monitor to be declared out of service due to Surveillance Program technicalities; thereby, causing an unneces;ary limiting condition for operation to be initiated.
Each of the aforementioned surveillance procedures include instructions for testing two or more radiation monitors.
No provision has been made to allow testing of one monitor to be omitted should that monitor be out of service.
Nor has provision been made to allow the surveillance to be declared satisfactory if one of the monitors in a particular surveillance does not satisfy the acceptance criteria. All of the monitors in a given surveillance must satisfy the acceptance criteria for that particular surveillance to be acceptable.
This is an all or nothing situation which has caused serious difficulties during past plant operations.
The following is a list of the Surveillance Procedures and the radiation monitors tested by the procedure:
SP.446:
R15049, R15050 SP.447:
R15041. R15045, R15546 SP.448:
R15047, R15048 SP.451:
FE 15044A, FE 15044B, FE 15045 SP.452:
FE 15044A, FE 15044B, FE 15045 Unless separation provisions are made in the procedures listed or a separate procedure is implemented for each radiation monitor, the functionality of the various radiation monitors associated with a given procedure may be compromised.
l This RI is CLOSED.
l ATTACHMENT 6.3 i i
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REQUEST FOR INFORMATION (RI)
RI NO:
123 SYSTEM CODE:
RDH ISSUE DATE:
08-13-87
SUBJECT:
CONTROLLED DOCUMENT CORRELATING RADIATION MONITORS WITH RAD MONITOR FUNCTIONS DEPARTHENT:
NUCLEAR ENGINEERING COORDINATOR / EXT:
R. LAWRENCE /4365 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0VESTION:
The lack of a single controlled document which correlates individual radiation monitors with specific basic radiation monitor system functions may cause difficulties in establishing and maintaining programs for system training, testing, surveillance, maintenance and operation.
The Radiation Monitoring System Status Report lists four main system functions important for safe plant operation:
1.
Indication of radiation or activity level 2.
Detection of abnormal plant conditions 3.
Termination of (process) flow 4.
Sample collection (emergency)
An auxiliary function is also listed in the System Status Report:
Sample collection (routine).
Fifty-three radiation monitors are listed in the System Status Report.
Two rough draft: Radiation Monitoring System Design Bases reports and procedure AP.305-33, Radiation Monitorina System, were renewed in an attempt to establish a clea calculation. Also, both the System Design Engineer and the System Engineer were questioned to identify a document.
Although these sources provided a large amount of information, a single concise document correlating functions with radiation monitors could not be found.
This RI is CLOSED.
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i ATTACHMENT 6.3 l
REQUEST FOR INFORMATION (RI)
RI N0:
125 SYSTEH CODE:
RDM ISSUE DATE:
08-12-87 i
SUBJECT:
SYSTEM STATUS REPORT (SSR). RESOLUTION TO PROBLEM #6 ECNs l
A-2332 AND R-1227 DEPARTMENT:
NUCLEAR ENGINEERING COORDINATOR / EXT:
R. LAWRENCE /4365 TEAM LEADER / EXT:
E. ESPERANZA/3951 l
POTENTIAL CONCERN /0UESTION:
l The system design per ECNs A-2332 and R-1227 allows an unmonitored flow path to the atmosphere to exist until operators can trip supply fans and open/close certain Auxiliary Building doors.
BACKGROUND The resolution to Radiation Monitoring System Status Report Problem #6, I
"A-546, R-15546 and R-15546A not in service," changed the design of HVAC system per ECNs A-2332 and R-1227 in the grade level of the Auxiliary Building (controlled side) by installing a new exhaust fan (A-546),
Radiation Monitor (R-15546A), and filters for the exhaust flow path.
The DBR for ECN A-2332 specifies certain actions to remove A-546 from
' service for maintenance.
" Secure supply fans SF-A-1, SF-A-2 as soon as possible.
Do not begin any maintenance activity on the makeup tank / filters / valving area until A-546 is declared operational.
Personnel occupancy to be limited. Secure all Auxiliary Building doors open to atmosphere.
Procedurally open normally closed doors to the -20 ft.
i elevation to exhaust the grade level area via A-542A or A-5428."
Similar actions are required as "Special Operating Requirements" following a trip or other loss of A-546.
Operating procedure A.148, original, Auxiliary Building HVAC Systems, draft dated 6-03-87 did not include the DBR conditions in Section 7.7, Directions for Shutdown of A-516 for Filter Maintenance, or in Section 6.7, Normal Shutdown.
If the procedure is executed as written, without i
shutdown of the supply fans described in the DBR, air will flow out doors and other openings to create an unmonitored flow path off site.
Casualty Procedure, C.148, Loss of HCC, Rev. 4, dated 4-3-85 does not contain any direction for trip of the power supply breaker for A-546 (Breaker 20415).
The same requirements specified by the DBR would apply.
No action item to incorporate this concern could be identified.
ATTACHMENT 6.3 :
RI NO: 125 (Continued)
The RM-11 (Radiation Monitors) annunciator procedure, draft dated 7-27-87, Rev. 3, includes some of the discussion included in the DBR (R-1227) for a high radiation alarm on R-15546A but is incomplete.
Response, step four states:
"4.
Consult with Rad Protection to:
- coordinate ' isolation and decontamination activities
- evaluate termination of the release by stopping Aux. Bldg.
Grade Levei Exhaust Fan A-546.
The DBR for ECN R-1227 specifies:
The release should continue even after a high alarm.
Should health physics determine it necessary to trip A-546, l
supply fans SF-A-1 and SF-A-2 shall also be tripped manually.
All doors at grade level leading to the atmosphere be secured.
Door to -20 ft. level be kept open to allow some suction of A-542 A and 8 pathway to preclude out leakage from grade level.
CONCLUSION The procedural guidance and operator action does not appear to be a long-term solution.
The use of procedural guidance in the situation where A-546 is shutdown / trips is inconsistent with the design of HVAC systems in other plant areas where contamination is a potential problem during accident / normal conditions. As described in the USAR, Section 9.7.3.lC radwaste and fuel handling areas, the spent fuel pool area HVAC system and the radwaste area HVAC systems are interlocked to trip the supply fan if a negative pressure cannot be naintained within the HVAC area. As designed now, the unmonitored flow path will exist until an operator can trip the supply fans.
During an accident this may not be a high priority operator action.
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ATTACHMENT 6.3 l
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REQUEST FOR INFORMATION (RI)
RI NO:
131 SYSTEM CODE:
RDH ISSUE DATE:
08-24-87
SUBJECT:
PERIODIC DEMONSTRATION OF RADIATION HONITORING SYSTEM EMERGENCY GRAB SAMPLING FUNCTION I
DEPARTHENT:
SYSTEMS ENGINEERING COORDINATOR / EXT:
J. ITTNER/4153 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0UESTION:
The emergency grab sampling functions of the containment atmosphere and Reactor Building Stack Monitor (R15044), the Auxiliary Building Stack Honitor (R15045), and the Auxiliary Building Radwaste Service Area Stack Honitor (R15546A) may not perform as intended in the event of an emergency because the functions are not demonstrated on a periodic basis.
A review of the System Test Hatrix does not show that one of the system's i
main functions, emergency grab sampling, is not periodically tested.
It
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was also verified with the System Engineer and the Radiation Protection Supervisor, that no periodic testing of this function is performed.
Emergency grab sampling is accomplished by utilizing a flow path which differs from the normal sampling flow path; therefore, this function is not demonstrated during the normal course of operating the radiation monitors.
J Any deterioration in the equipment (flow path blockage, malfunctioning valves, etc.) utilized for emergency grab sampling may not be detected.
1 Any procedural inadequacies in the emergency grab sampling procedures may not be identified.
Proficiency of personnel in obtaining emergency grab samples may not be maintained.
ATTACHMENT 6.3 l
REQUEST FOR INFORMATION (RI)
RI NO:
148 SYSTEM CODE:
RDM ISSUE DATE:
08-25-87
SUBJECT:
ENVIRONMENTAL CONTROLS FOR WIDE RANGE GAS MONITOR (WRGM)
R-15546A SAMPLING / DETECTION STATION DEPARTMENT:
NUCLEAR ENGINEERING COORDINATOR / EXT:
R. LAWRENCE /3849 TEAM LEADER / EXT:
E. ESPERANZA/3951 l
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POTENTIAL CONCERN /0UESTION:
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The temperature in WRGM sampling / detection station may exceed the l
required environmental parameter limits suggested by HRGM manufacturer, this may affect the operability of Radiation Monitoring System.
1.
General Atomic (GA) Equipment Manual N16.13-IM01 for WRGM RDM Monitor (R-15546-A) station states following environmental parameters:
)
1 A.
Temp. Range:
35 degrees F to 122 degrees F
)
(2 degrees C to 50 degrees C)
B.
Humidity:
5% to 91%
2.
Sacramento Municipal Utility District (SMUD) USAR Manual Vol. VII.
Appendix 2B, Attachment 1 Meteorological Studies, Sec. IV Site Climatology, Table V for Temperature Climatology and Table VII for Relative Humidity states that:
Temperature Extremes (Table V Temp. Climatology)
A.
Unique Max. 115 degrees F (Sacramento) 8.
Unique Min. 19 degrees F (Stockton)
Humidity (AVG) in (percent) (Table VII Relativo Humidity)
A.
At 0400 Hrs.
91% (Sacramento and Stockton)
(Jan and December)
(Maximum)
B.
At 1600 Hrs.
25% (Stockton)
(July)
(Minimum)
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ATTACHMENT 6.3 4
RI NO:
143 (Continued) i SHUD USAR Vol. V, Section 11.3.2, states that R-15546A monitor is "...
designed to function during both accident and normal operating conditions and should be installed in Auxiliary Building Vent."
WRGH (R-15546A) sampling / detection station is located inside metal building with uncontrolled environment.
The system samples, detects, monitors and alarms Control Room Operator of Radio Activity in gaseous effluents in Radwaste Area Vent.
HRGH system consists of various l
electronic components, sampling lines, solenoid / motor operated valves, gas effluent sampling fan and other components are sensitive to the environments in which they function.
The operability of the monitor will be affected when the outdoor temperature drops below the equipment operating temperature of 35 degree F.
The malfunctions of any electronic components or sampling can could cause inability of RDH-15546A to monitor gas effluent.
i This RI is CLOSED.
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I ATTACHMENT 6.3
-?7-l 4
I REQUEST FOR INFORMATION (RI) l REVISION 1 l
l RI NO:
155 SYSTEM CODE:
ROH ISSUE DATE:
08-31-87
SUBJECT:
POST ACCIDENT RADIATION HONITOR OPERABILITY j
DEPARTHENT:
HEALTH PHYSICS /
COORDINATOR / EXT:
HARVEY STORY /4760 ENVIRONMENTAL PROTECTION TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0VESTION:
Operating Procedures to control the use of backup radiation monitoring equipment when primary accident monitoring equipment becomes inoperable in an emergency situation may be inadequate.
1 Technical Specification, Section 3.5.5, states "a failure of any one of the radiation monitors described in Items 1, 6 and 7 would require a return to operability within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or initiation of a pre-planned alternate method of monitoring using Operating Procedures."
J AP.305-28 is the procedure which covers the pre-planned alternate method I
of monitoring required by Technical Specifications.
AP.305-28 refers to AP.305-14 for non-emergency monitoring and to the Emergency Plan (AP.500) j for emergency monitoring.
Two specific concerns with the monitoring of radiation as required by the Technical Specifications are identified i
below.
i 1.
No monitoring of the Radwaste Vent and Main Steam Line required by the Technical Specification is covered in the procedure.
2.
The method of monitoring radiation in the Reactor Building and Auxiliary Building stacks may be insufficient during accident conditions because of the possible high radioactivity concentration which would not allow personnel to handle the gas chambers.
EPIP-5345 (draft) has been written to replace AP.507.
This draft procedure does not reference any specific radiation monitoring per Technical Specification Section 3.5.5.
The procedure writer identified that the Radiation Control procedures would address this.
- However, AP.305-24, 26 and 29 do not address emergency conditions.
EPIP-5200 directs the collecting of grab samples per AP.313-2 for l
R-15044, R-15045 and R-15546A.
However, these radiation monitors will be l
l inoperable, making grab sampling impossible.
EPIP-5390 is a procedure to be written for emergency stack sampling because AP.305-24 and 26 for Reactor Building and Auxiliary Building stack sampling, respectively, require excessive sample sizes for the level of radioactivity present under accident conditions.
However, this procedure has yet to be initiated.
ATTACHMENT 6.3 l
REQUEST FOR INFORMATION (RI)
RI NO:
156 SYSTEH CODE:
RDM ISSUE DATE:
08-21-87
SUBJECT:
OPERATOR KNOWLEDGE OF OPERABILITY OF RADIATION HONITORS DEPARTHENT:
OPERATIONS COORDINATOR / EXT:
R. MACIAS/4589 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0VESTION:
Operators are not always cognizant of which radiation monitors are operable.
This may lead to not being in compliance with Technical Specifications 3.1.6.7, 3.5.5, 3.8.1, 3.15, and 3.16 without operator knowledge or delaying operable status of radiation monitors.
This will l
unnecessarily delay exit from an L.C.0. condition.
l No system is in place which allows licensed operators to l
1 determine the operable status of radiation monitors.
l The operators have no procedure defining operable or inoperable for radiation monitors on RH-il.
Operator shift turnover sheets do not agree at all times on which detectors are operable or inoperable and, if inoperable, I
why they are inoperable.
The Control Room Log and the Hanagement Log do not agree at all times on which detectors are operable and, if not, the reason that they are inoperable.
l ATTACHHENT 6.3 s
REQUEST FOR INFORMATION (RI)
RI NO:
158 SYSTEM CODE:
RDH ISSUE DATE:
08-24-87
SUBJECT:
INADEOUATE SETPOINT DOCUMENT DEPARTHENT:
NUCLEAR ENGINEERING COORDINATOR / EXT:
T. TELFORD/3849 TEAM LEADER / EXT:
E. ESPERANZA/3961 POTENTIAL CONCERN /0UESTION:
Radiation Monitoring (RDH) devices may be calibrated to incorrect setpoints.
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Some of the entries for AP.165 reference to ODCH AP.305 for j
calculations of setpoints.
Methods of maintaining files on the J
current calculations are weak and incorrect calibrations have l
been and could be performed using earlier calculations.
j Process Standards is a partial setpoint document of selected instruments.
It does not reference support documents and does not provide signal to engineering unit conversions.
Plant j
could provide no criteria for instrument inclusion or exclusion in process standards.
l Plant could not produce error analysis on RDH instrument accuracy.
Process Standards provide adjustment tolerance only and not absolute accuracy or As Found tolerances.
Without a controlled accessible document listing indication and loop accuracies, operations procedures may be requiring improper settings by not accounting for instrument errors.
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l ATTACHMENT 6.3 l l l
J
REQUEST FOR INFORMATION (RI)
RI NO:
159 SYSTEM CODE:
RDM ISSUE DATE:
08-24-87
SUBJECT:
GENERAL ATOMICS RADIATION MONITORS AND RM-ll COMPUTER TRAINING DOR RADIATION PROTECTION TECHNICIANS DEPARTMENT:
TRAINING COORDINATOR / EXT:
P. TURNER /4647 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0UESTION:
There is inadequate training for Radiation Protection Technicians about the General Atomics Radiation Monitors and the RM-11 Computer. A familiarity with the operation of this equipment is essential for Emergency Response Sampling and verifying Technical Specification limits are not exceeded.
There is a need to develop a Training course for RP Technicians about the General Atomic Radiation Monitors and the RM-11 computer system, to ensure they are capable of performing the required action during normal and alarm conditions.
After interviewing several RP Techs, it was commonly expressed that they need formal training on the RM-11.
There is not a course lesson plan for training the RP Technicians on the use and operation of the RM-ll computer.
The RP Technicians use the RM-11 every day for updating the RP daily shift status.
They also retrieve flow information from the RM-23 modules.
RP-313.06 Procedure (Radiation Monitor Alarm Response by RP Technicians) is currently in Draft form but will require the RPs to perform specific verifications to ensure the parameters are within requirements set forth by Technical Specifications (3.1.6, 3.17.1 and 3.18.1).
ATTACHMENT 6.3 -
U
REQUEST FOR INFORMATION (RI)
RI NO:
162 SYSTEM CODE:
RDM ISSUE DATE:
08-26-87
SUBJECT:
EFFECT OF RM-11 FAILURE ON THE RADIATION MONITORING SYSTEM DEPARTHENT:
OPERATIONS COORDINATOR / EXT:
R. MACIAS/4350 1
TEAM LEADER / EXT: _L.
ESPERANZA/3951 POTENTIAL CONCERN /00ESTION:
A Casualty Procedure to provide guidance in the event of RM-11 failure does not exist.
Failure of the single RM-ll computer terminal and/or display will cause at least those RM-80 radiation monitors to be declared-inoperable.
RM-ll failure will also cause a loss of Control Room l
indication of RM-80 radiation monitor status and RM-80 detected radiation l
levels.
USAR Section 1.4.17 states, "the radiation monitoring system is designed to indicate and warn of high radiation levels throughout the plant.
Visual presentation of readings, recorded presentation, and an audible / visible alarm at both the detector location and the Control Room are provided." USAR Section 11.3.2.3 further explains that the noble gas effluent monitors provide indication in the Control Room of radiation j
levels over normal and accident ranges when combined with existing process radiation monitoring equipment.
This is intended to provide early warning of potential equipment malfunctions and biological hazards.
A draft revision (Rev. 3) of RM-11 Annunciator Resoonse Procedure provides guidance for temporary measures (installation of an RM-23P if an j
RM-23L is not permanently installed) in the event of RM-11 failure.
However, the problem of providing the Control Room with information obtained from the RM-23P and RM-23L installed locally at the monitor in the field is not addressed in the draft procedure.
As a result, the most current radiation monitor information may not be available in the Control Room, in the event of a RM-ll failure.
There is also the possibility that errors will be inadvertently introduced when transferring
{
information from indicators installed in the field to the Control Room.
In summary, the delay in getting information during an accident situation that would aid in determining the safety status of the plant and the
)
extent of the radiological hazards will greatly increase the time required to make necessary decisions that are necessary to determine and maintain the plant safety conditions.
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ATTACHMENT 6.3 4
I 1 I
REQUEST FOR INFORMATION (RI)
RI NO:
163 SYSTEM CODE:
RDH ISSUE DATE:
08-27-87
SUBJECT:
POWER DISTRIBUTION RADIATION HONITORING CABINETS DEPARTMENT:
NUCLEAR ENGINEERING COORDINATOR / EXT:
T. TELFOR0/3849 TEAM LEADER / EXT:
E. ESPERANZA/3951 POTENTIAL CONCERN /0VESTION:
Loss of one fuse makes all of Victoreen Radiation Monitors inoperable limiting the ability of operators to determine personnel safety and environmental radiation levels.
1 Occurrence Description Report 87-610 described where loss of one l
fuse disabled Radiation Monitoring Panels H4HRG (R-15001, R-15003, R-;5004, R-15005, R-15006 & R-15007), H4HRL (R-15001, R-15008, l
l R-15009, R-15010, R-15015, R-15018, R-15016, R-15019A/B & R-15021) and H4HRA (R-15026, R-15027, R-15028, R-15029, R-15030, R-15031, R-15032, R-15033, R-15034, R-15035, R-15036, R-15037, R-15038, R-15039, R-15040, R-15041, R-15042 & R-15043).
l This caused Technical Specification and USAR Radiation Monitors to i
be deenergized.
NUREG Reg. 0737, Append'x B, Page B-2 prohibits a single failure that disables monitors and affects the function of the Radiation Monitoring System and the load on operators.
This RI is CLOSED.
ATTACHMENT 6.3 )