ML20196B690

Rev 0 to Radiological Effluents Action Plan

ML20196B690
Person / Time
Site:	Rancho Seco
Issue date:	01/31/1988
From:	Coward G, Croley R, Martin D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:
Shared Package
ML20196B679	List: ML20196B675 ML20196B690
References
EP-88-001, EP-88-1, TAC-56033, NUDOCS 8802120083
Download: ML20196B690 (16)

Text

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RADIOLOGICAL EFFLUENTS ACTION PLAN for Rancho Seco Nuclear Generating Station Sacramento Municipal Utility District Report No. EP 88-001 Revision 0 January 1988

$1 M D.W. Martin J Manager-Environmental Protection Department

/R. Croley /

Director-Nuclear Tefnical Services h -

G.A. C'oward Assistant General Manager-Nuclear Technical and Administrative Services D D b b 1GG J. Firlit Assistant General Manager-Nuclear Power Production i

Distribution: C. Andognini J. Firlit J. Vinquist G. Coward J. McColligan M. Weaver B. Croley J. Shetler D. Fischer G. Cranston D. Keuter J. Flynn i R. Huebner F. Kellie F. Fedor T. Redican E. Yochheim F. Lopez l K. Meyer P. Turner T. Tomchuk l D. Martin B. Kemper B. Stahl

! H. Story L. Fossum J. Strange l P. Bender M. Anderson Files l W. Harris D. Brock DO K 2 h!O P

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t TABLE OF CONTENTS Section Title Page Executive Summary ii 1.0 Introduction 1 2.0 Radiological Effluent Action Plan 2 2.1 Modify Plant Systems and 2 Procedures to Reduce Source Term

- Phase I.

2.2 Modify Plant Systems and 3 Procedures to Reduce Source Term

- Phase II.

2.3 Modify Plant Systems and 4 Procedures to Reduce Source Term

- Phase III.

2.4 Modify Technical Specifications 6 and Related Documents - Phase I. '

2.5 Modify Technical Specifications 6 and Related Documents - Phase II.

2.6 Modify Technical Specifications 7 and Related Documents - Phase III.

2.7 Modify Laboratory / Computer (and 8 Plant) Equipment - Phase I.

2.8 Modify Laboratory / Computer (and 8 Plant) Equipment - Phase II.

2.9 Modify Laboratory / Computer (and 9 Plant) Equipment - Phase III.

l 2.10 Evaluate and Reassign Interfaces 10 and Accountabilities - Phase I.

2.11 Evaluate and Reassign Interfaces 10 and Accountabilities - Phase II.

3.0 Schedule 11 4.0 Resources 11 I

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1 EXECUTIVE

SUMMARY

This plan describes actions completed or in progress to bring the Radiological Effluents Program and the effluent release process at the Rancho Seco Nuclear Generating Station within the guidelines established by 10CFR50, Appendix I (this includes reducing the potential for unplanned releases). The plan addresses the following items: I

1. Modifications to improve Liquid Radioactive Waste Processing Systems.

2. Technical Specification (PA-155), OffSite Dose Calculation Manual (0DCM) and Radiological Environmental Monitoring Program (REMP) Manual revisions, which includes third party review and validation.

3. Assignment of single point accountability for radiological effluents.

4. Effluent release program and procedure improvement, relating to future releases.

5. Hardware improvements, relating to measuring radioactivity in effluents.

6. Software improvements, relating to programs used in performing effluent related calculations and retaining effluent related information.

7. Cost-benefit analysis, relating to additional upgrades in hardware and programs (this includes modifications relating to site drainage systems where the potential for unplanned effluent releases exist).

The effectiveness of the Radiological Effluents Program and the prevention of recurring effluents problems, with associated off- site dose problems, are directly dependent upon the proper combination of equipment, programs and training of personnel. These areas are addressed in a three phase approach, which is detailed in the action plan.

This three phase approach is designed to ensure that:

1. The Effluent Control Program is ready for RESTART (Phase I).

2. Near term actions will improve the program after RESTART (Phase II).

3. Long term actions will continue to evaluate plant systems and programs and make necessary modifications to ensure the District maintains the ability to operate the Rancho Seco Nuclear Generating Station within 10CFR50, Appendix ! Design Objective Guidelines (Phase III).

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Note: This plan is a parallel document to the Short Term Effluent Control Program. Portions of the short term program address specific issues related to radiological effluents as well as the overall Radiological Effluents Action Plan.

The Action Plan places emphasis on proactively managing and controlling radiological effluents, to keep the volume and concentration of releases to a level that will permit compliance with 10CFR50, Appendix I guidelines.

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1.0 INTRODUCTION

The Mission Statement of the Radiological Effluents Action Plan is to "Accomplish the necessary actions required to bring the Rancho Seco Nuclear Generating Stations Radiological Effluents Program into compliance with 10CFR50, Appendix I guidelines" (this includes reducing the potential for unplanned releases).

In the past, the Rancho Seco Nuclear Generating. Station has experienced radiological effluent releases in excess of guidelines contained in 10CFR50, Appendix I as well as unplanned releases of effluents. The reasons for such releases include poor equipment performance, fragmented departmental groups attempting to monitor and account for radiological releases, poor system design, inadequate procedures, inadequate training and improper management.

This Action Plan has been formulated to implement a number of improvements in the Radiological Effluents Program and ta bring radiological releases within 10CFR50, Appendix 1 guidelines. Action items address a full scope of accountabilities including organizations, equipment, procedures and trair.ing.

Proactive management of plant operations are directed towards keeping the volume and concentration of radiological releases as low as is reasonably achievable.

Single point accountability for ensuring the implementation of the Action Plan currently resides with the Manager, Environmental Protection. Responsibility for specific items within the Action Plan resides with the Supervisor, Health Physics / Chemistry Services.

The Action Plan contains four (4) major goals, as outlined below:

1. Modify plant systems and operating procedures to reduce the radioactive liquid effluent source term.

2. Modify Technical Specifications and related documents (i.e., ODCH, REMP Manual, and USAR) and procedures to address Standard Technical Specifications and Good Operating Practices, as they apply to the Rancho Seco Nuclear Generating Station.

3. Modify plant laboratory and computer equipment (including software); used to measure and calculate concentrations and doses in support of radiological effluent releases.

4. Assign specific accountabilities related to radiological effluent control and releases.

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i These major goals will be accomplished by developing detailed objectives, based upon three phases of implementation. Short term items are to be completed by RESTART. Near term items are to be completed by full power operation, which is currently scheduled for July 1988. Long term items, which are comprised primarily of evaluations for future modifications, have only a completion date assigned for the evaluation. Completion dates for the work itself will be assigned after reviews of the evaluations are performed.

2.0 RADIOLOGICAL EFFLUENTS ACTION PLAN 2.1 G0AL: MODIFY PLANT SYSTEMS AND PROCEDURES TO REDUCE SOURCE TERM -

PHASE 1.

Ob.iective 1:

Implement operation of the Liquid Waste Processing System Modification (Strainer and Sluicable Demin).

Action Reauired:

1. Ensure an adequate supply of correct resin and necessary spare parts by restart.

2. Ensure an adequate "System Descriptior.' .:nd technical documents are in place by restart.

3. Test the equipment for functional capability. Determine optimum operating configuration before restart.

4. Develop operating procedure, consistent with the functional testing results, by restart.

5. Ensure that Operations and Chemistry personnel are trained to support the system, in accordance with Technical Specification and procedural requirements, by restart. ,

6. Develop operating limits for failed fuel and primary - secondary leakage by restart.

7. Perform preliminary engineering study to evaluate the planned operating configuration by restart.

Ob.iective 2:

Develop a program for systematic management of Water Inventory in the Secondary Plant. This program should include an implementation schedule.

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1. Complete program description and schedule by restart.

Obiective 3:

Perform an engineering analysis that evaluates the effects of increasin Makeup / Letdown flow on primary side to reduce contamination in the secondary.g '

Action Reauired:

1. Complete the analysis by restart.

Ob.iective 4:

Dedicate an individual from Operations to coordinate radioactive waste activities relating to the minimization of all waste generations.

Action Reauired:

1. Have individual assigned and ensure that he/she is trained in the duties of such a coordinator by April 1, 1988, 2.2 GOAL: MODIFY PLANT SYSTEMS AND PROCEDURES TO REDUCE SOURCE TERM

- PHASE II.

Obiective 1:

Modify tank f**m area drains to prevent unplanned releases.

Note: All drains, which include tank farm, storm and other effluent paths, are designated for modification with this plan or the Short Term Effluent Control Program.

Action Reautred:

1. Complete modification by May 1,1988.

Ob.iective 2:

Develop on-line evaluation / trending program for deminerlizers effectiveness.

Action Reauired:

1. Complete program by February 1, 1988 (Program development will be dependent upon the final selection criteria established for resin inside these deminerlizers).

Ob.iective 3:

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Use engineering analysis and operational data to evaluate optimization of source term reduction.

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Action Reauired:

1. Complete evaluation for optimizing source term reduction by March 1, 1988.

Ob.iective 4:

Modify various secondary water pathways (via ECN 1087A) to -reduce the volume of water required to be released.

Action Reauired:

1. Complete ECN 1087A by June 1,1988. Expedite Tank Farm Modifications in accordance with LRSL priorities. ,

Ob.iective 5:

Evaluate current practices used during Polisher Resin transfer to de-watering lines.

Action Reauired:

1. Complete evaluation by April 1, 1988(this evaluation should contain resolution to the final disposition of de-watering liquid). Submit the evaluation, with modification recommendations, to the LRSL for review by June 1, 1988.

2.3 G0AL: MODIFY PLANT SYSTEMS AND PROCEDURES TO REDUCE SOURCE TERM -

PHASE III.

Ob.iective 1:

Evaluate adding additional deminerlizers and/or Holdup Tanks.

Action Reauired:

1. Complete an evaluation which includes engineering, cost benefit and effluent release studies and submit this evaluation, with modification recommendations, to the LRSL for review by July 1, 1988.

Ob.iective 2:

Evaluate increasing deminerlization capabilities (specifically in relation to Cesium) on the primary water side.

Actions Reauired:

1. Complete an evaluation which includes engineering, cost benefit and effluent release studies and submit this evaluation, with modification recommendations, to the LRSL for review by March 1, 1988.

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Obiective 3:

Initiate a Water Inventory Control Program for the primary water side (this program should take into consideration a review of the current Operations program for inventory control and if applicable, modification for continued usage).

Actions Reauired:

1. Have the program operational by July 1, 1988.

Obiective 4:

Evaluate cperability and use of Miscellaneous (Tritium) Waste Evaporator.

Actions Reauired:

1. Complete an evaluation which includes engineering, cost benefit and effluent release studies and submit this evaluation, with modification recomendations, to the LRSL for review by July 1,1988.

Obiective 5:

Evaluate 1984 Bechtel Options Study, and other information which includes public commitments made concerning evaporation ponds, on modified use of Evaporation Ponds.

Actions Reauired:

1. Complete an evaluation which includes engineering, cost benefit and effluent release studies and submit this evaluation, with modi fication recomendations, to the LRSL for review by July 1,1988.

Ob.iective 6:

Evaluate the need for increasing gas stack height to ensure compliance with 10CFR50, Appendix I guidelines.

Actions Reauired:

1. Complete an evaluation which includes engineering, cost benefit and effluent release studies and submit this evaluation, with modification recomendations, to the LRSL for review by September 1, 1988. If recomendations are for such increases perform the modifications and associated procedure / manual changes by January 1, 1989.

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2.4 G0AL: MODIFY TECHNICAL SPECIFICATIONS AND RELATED DOCUMENTS - PHASE I.

Obiective 1:

Develop an Effluent Control Manual (ECM) to address the policies and interfaces of the Radiological Effluent Program.

Actions Reauired: '

l. Complete the manual by restart.

Ob.iective 2:

Revise Technical Specifications to ccmply with Standard Radiological Effluent Technical Spacifications (RETS), as modified to address specific characteristics of the Rancho Seco Nuclear Generating Station (PA 155).

Actions Reauired:

1. Complete revision by restart.

Ob.iective 3:

Revise ODCM and REMP Manual to reflect revised Technical Specifications.

Revise implementin effluent releases. g and administrative procedures for liquid and gaseous Actions Reauired:

1. Complete revisions by restart.

2.5 G0AL: MODIFY TECHNICAL SPECIFICATIONS AND RELATED DOCUMENTS - PHASE II.

Ob.iective 1:

Review USAR, Technical Specifications, ODCM, REMP Manual and procedures to ensure that the overall effluent control program is congruent.

Actions Reauired:

1. Complete this review by March 1, 1988.

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2.6 GOAL: MODIFY TECHNICAL SPECIFICATIONS AND RELATED DOCUMENTS - PHASE III.

Ob.iective 1:

Develop procedures that will require repeating this review on an annual basis and will include a periodic evaluation of values used for LLDs.

Actions Reauired:

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1. Complete procedure development by April 1,1988.

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.- l 2.7 GOAL: MODIFY LABORATORY / COMPUTER (AND PLANT) EQUIPMENT -

PHASE I.

. Ob.iective 1:

Purchase new detector and implement operation to provide capability of measuring at required Lower Level of Detection.

Actions Reauired:

1. Purchase and make detector functionally operational by restart.

2.8 G0AL: MODIFY LABORATORY / COMPUTER (AND PLANT) EQUIPMENT -

PHASE II.

Obiective 1:

Debug, test 'and V&V Nuclear Data Software (REIMS = a complete effluent accountability computer system).

Actions Reauired:

1. Complete debug, testing and V&Y by May 1, 1988.

Obiective 2-Revise associated procedures and implement REIMS.

Actions Reauired:

1. Complete revisions to procedures and program implementation by June 1, 1988.

Obiective 3:

Design and install additional flowrate monitoring instrumentation in liquid and gaseous effluent streams.

Actions Reauired:

1. Complete installation by July 1, 1988.

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Ob.iective 4:

Install additional environmental sampling points; which consist of additional wells on District owned Rancho Seco Nuclear Generating Station property.

Actions Reouired:

1. Complete well installation and installation of additional sampling points by April 1, 1988.

2.9 GOAL: MODIFY LABORATORY /COMPllTER (AND PLANT) EQUIPMENT -

PHASE III.

Obiective 1:

Evaluate additional modifications of counting laboratory and/or counting equipment / techniques required to achieve LLDs at 10% equivalent 10CFR50, Appendix I values.

Actions Recuired:

1. Complete an evaluation which includes engineering, cost benefit and effluent release studies and~ submit this evaluation, with modification recommendations, to the LRSL for review by July 1, 1988.

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-2.10 G0AL: EVALUATE AND REASSIGN INTERFACES AND ACCOUNTABILITIES - PHASE 1.

Ob.iective 1:

Assign single point accountability for Radiological Effluents at the Rancho Seco Nuclear Generating Station.

Actions Reauired:

1. The Environmental Protection Department has been assigned such accountability as per CEO letter GCA 87- 747, dated 11/12/87.

Ob.iective 2:

The department with single point accountability for the Radiological Effluent Control Program will be responsible and accountable for the completion of this Action Plan.

Actions Reauired:

1. Modify the Action Plan as required to identify proper accountability by restart.

2.11 G0AL: EVALUATE AND REASSIGN INTERFACES AND RESPONSIBILITIES - PHASE II.

Ob.iective 1:

Transfer responsibility for implementing effluent releases from the Radiation Protection Department to the Chemistry Department.

Actions Reauired:

1. Complete this transfer by June 1, 1988.

Obiective 2:

Transfer designated portions of the "multiple level review" responsibility for effluent releases from Radiation Protection and Operations to Chemistry and Health Physics / Chemistry Services (HPCS).

Actions Reauired:

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1. Complete this transfer by June 1, 1988.

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3.0 SCHEDULE The schedule for completing items within the Action Plan are contained within Section 2.0.

4.0 RESOURCES 4.1 The Environmental Protection Department has available resources for applicable items in Section 2.0 of this Action Plan. However, these resources currently consist primarily of contractor personnel and these personnel must be maintained through June 1988 unless replaced by permanent SMUD personnel.

The Health Physics / Chemistry Services division of the EP Department has responsibility for coordination and development of existing and new activities within the Effluent Control Program. Implementation of the programs requirements will be the responsibility of Chemistry, Operations, Training, Maintenance and Radiation Protection; as detailed in Section 4.2 of this Action Plan.

4.2 Resources Required from Other Departments Maintenance Deoartment:

Goal 2.1, Objective 1, Action Item 1 and 2 Goal 2.2, Objective 1, Action Item 1 Goal 2.2, Objective 4, Action Item 1 Goal 2.8, Objective 3, Action Item 1 Ooerations Deoartment:

Goal 2.1, Objective 1, Action Item 3 and 4 Goal 2.1, Objective 4, Action Item 1 Goal 2.11, Objective 2, Action Item 1 Nuclear Enoineerino Department:

Goal 2.1, Objective 1, Action Item 2 and 7 Goal 2.2, Objective 1, Action Item 1 Goal 2.2, Objective 3, Action Item 1 i Goal 2.2, Objective 4, Action Item 1

Goal 2.8, Objective 3, Action Item 1 Nuclear Trainino

l Goal 2.1, Objective 1, Action Item 5 11 l

-Material Control:

Goal 2.1, Objective 1, Action Item 1 Goal 2.7, Objective 1, Action Item 1 Information Manaaement Systems:

Goal 2.8, Objective 1, Action Item 1 Chemistry:

Goal 2.1, Objective 1, Action Item 1 Goal 2.7, Objective 1, Action Item 1 Goal 2.11, Objective 1, Action Item 1 Goal 2.11, Objective 2, Action Item 1 Radiation Protection:

Goal 2.11, Objective 1, Action Item 1 Goal 2.11, Objective 2, Action Item 1 Test Groun '

Goal 2.1, Objective 1, Action Item 3 a

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