ML20206R999

Insp Rept 50-213/86-15 on 860519-22.Violations Noted:Failure to Write Radiochemical Procedure to Prescribe Frequency of Certain Sampling & Analyses & to Perform Required Sampling & Analyses

ML20206R999
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/30/1986
From:	Mark Miller, Pasciak W, Rabatin K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206R963	List: ML20206R957 ML20206R974 ML20206R999
References
RTR-REGGD-01.033, RTR-REGGD-1.033 50-213-86-15, IEB-79-19, NUDOCS 8607070274
Download: ML20206R999 (7)

See also: IR 05000213/1986015

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/86-15

Docket No. 50-213

License No. DPR-61 Category C

Licensee: Connecticut Yankee Atomic Power Company

Hartford, Connecticut 06101

Facility Name: Haddam Neck Power Plant

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Inspection At: Haddam Neck, Connecticut

Inspection Conducted: May 19-22, 1986

Inspectors: AM9/[/lota 6 'MS/A:-

M. mller, Rattiation Specialist dhte

A %l/AcL }&L. 6bSlh

K. RabatfM, iptionSpecialist '

date

Approved by:

W. J

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m [JaMC

asciak, Chief, Effluent Radiation ' d(te

Pr ection Section

Inspection Summary: Inspection on May 19-22, 1986(Inspection Report

No.50-213/86-15)

Areas Inspected: Routine announced inspection of the licensee's liquid and

gaseous radioactive effluent control programs. Areas reviewed included:

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effluent release records and reports, effluent sampling and analysis program,

j Offsite Dose Calculation Manual (ODCM) implementation and radioactive waste

system operations.

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Results: Of the areas inspected, two violations were icentified: failure to

write a radiochemical procedure to prescribe the frequency of certain sampling

and analyses; and failure to perform required sampling and analyses. One-un-

resolved item was identified for a missing record of a liquid radioactive waste

release to the environment. Other concerns of record management were also

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identified.

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DETAILS

1.0 Licensee Personnel Contacted

• R. Graves, Station Superintendent

• J. Beauchamp, Quality Assurance Supervisor

• M. Quinn, Chemistry Supervisor

G. Goncarvas, Chemist

T. Lantry, Assistant Chemistry Supervisor

S. Matthews, Chemist

L. Blaede, Auxiliary Operator

T. Donzella, I&C Planner

• Denotes those present at exit meeting on May 22, 1986.

2.0 Purpose

The purpose of this routine inspection was to review the licensee's

radioactive waste and effluent controls program with respect to the

following elements:

Effluent Release Records and Reports

Effluent Sampling and Analysis Program

Offsite Oose Calculation Manual Implementation

Radioactive Waste System Operations.

3.0 Effluent Release Records and Reports

3.1 Radioactive Waste Discharges

The inspector reviewed selected radioactive liquid, gaseous and part-

iculate release discharge permits, as well as associated procedures,

analysis printouts and calculations for 1985 through March 31, 1986.

The inspector also reviewed the licensee's Semi-Annual Effluent

Report for (July - December,1985) issued February 28, 1986.

The inspector determined that no Technical Specification limits for

planned or unplanned radioactive effluents had been exceeded for 1985

and 1986 to date. The inspector also verified that the radioactive

waste treatment systems were used for all releases during that same

time period, if applicable. The inspector also determined that

twelve gaseous releases listed in the Semi-Annual Effluent Report, as

abnormal, and an unplanned gaseous release from a pressurizer capil-

lary bleed that occurred on January 3,1986 did not exceed Technical

Specification 7/8.1 limits or the licensee stated criteria for ab-

normal releases, i.e. , >1500 u Ci/sec release rate. However, the

following concerns were identified:

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a. A gamma analysis rec rd for a liquid radioactive release

from steam generator No.3 on January 13, 1986, permit L-26

was not available at the time of the inspection. In add-

ition, the sample datt listed on permit L-26 was after the

discharge date/ time. A tritium analysis was available.

This item is considered unresolved and will be reviewed

during a subsequent inspection (50-213/86-15-01).

b. The inspector noted in the 1985 Semi-Annual Effluent Report

(2nd half) that the licensee used inconsistent terminology

and did not perform a complete review. For example:

The licensee had not documented criteria for defining

an abnormal gaseous release, and an undetermined criteria

was used to identify abnormal gaseous releases in the

subject report. In addition the licensee used the term-

inology, unplanned, to characterize planned and unplanned

miscellaneous releases and abnormal batch and continuous

releases. The inspector stated this common identifier was

misleading and should be clarified. In addition, the in-

spector noted that some of the radioisotope concentrations

listed as abnormal releases in the subject report contained

transposition and mathematical errors. The licensee stated

these concerns would be corrected. This item will be re-

, viewed during a subsequent inspection (50-213/86-15-02).

3.2 Radiological Environmental Monitoring Program

The inspector reviewed the licensee's Radiological Environmental

Monitoring Program annual report for 1985. This report summarizes

the results of the sampling and analyses of environmental media to

determine the radiological impact of station operations. These

environmental media include air, water, vegetation, and aquatic

plants and animals. In addition, direct radiation is monitored by

placement of thermoluminescent dosimeters at various locations around

the station.

As a result of this review, the inspector determined that the 11-

censee has generally complied with its Technical Specification re-

quirements for sampling frequencies, types of measurements,'analy-

tical sensitivities, and reporting schedules. Exceptions to the

sampling and analysis program were-adequately explained, e.o.c low

. air sample volume due to power failure. The report included sum-

maries of the laboratory quality assurance program and of the land

use survey.

The analyses of environmental samples indicated that doses to humans

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from radionuclides of station origin were negligible.

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4.0 Effluent Sampling and Analysis Program

The inspector reviewed licensee documentation and verified sampling lo-

cations to determine if liquid and gaseous effluent sampling and analysis

was being conducted as required by Technical Specification Section 7/8.1

as specified in Section I of the REM 0DCM (Radiological Environmental

Monitoring Offsite Dose Calculation Manual). Selected surveillance pro-

cedures were also reviewed including the following:

SUR 5.4-4, Rev.16, " Reactor Coolant, RWST, BAMT, and RHR Chemistry

Surveillance" 1/17/86

• SUR 5.4-11, Rev. 5, " Air Ejector Surveillance" 7/10/85

SUR 5.4-13, Rev. 5, " Liquid Radwaste Release Sury." 1/1/86

• SUR 5.4-14, Rev. 8, " Gaseous Radwaste Release Sury." 1/1/86

SUR 5.4-18, Rev. 7, " Surveillance of Unmonitored Potential. Radio-

active Release Paths" 1/9/86

SUR 5.4-19, Rev. 6, "Radiat on Monitoring System Air Ejector Gas

Monitor (RMS-15)" 1/1/86

SUR 5.4-21, P~. 6, " Sampling and Analysis of Cont. Purges" 1/1/86

SUR 5.4-22, Rev. 7 " Steam Gen. Weekly Compositing and Analysis"

1/1/86

SUR 5.4-23, Rev. 7 " Waste Gas Decay Tank Sampling and Analysis"

1/1/86

SUR 5.4-24, Rev. 10 " Main Stack Sampling and Compositing" 1/1/86

SUR 5.4-27, Rev. 7, " Test Tank Sampling and Analysis" 1/1/86

Within the scope of this review the following violations were identified:

Technical Specification 6.8 requires, in part, that written procedures

she.11 be established, implemented and maintained that meet the recommen-

dations of Regulatory Guide 1.33, Appendix A. R.G.1.33 states that

chemical and radiochemical control procedures be written to prescribe the

nature and frequency of sampling and analyses.

Contrary to the above, since Janaury 1,1986 radiochemical licensee proce-

dures did not prescribe all the sampling and analysis frequencies for

continuous liquid releases to the environs.

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Technical Specification Section 8.1.1.1.1 requires that radioactive liquid

waste shall be sampled and analyzed in accordance with Section I of the

REMODCM.Section I of the REMODCM, Table C-1 requires daily grab sampling

and weekly analysis of composite samples for continuous releases from

steam generator blowdown and service water effluent.

Contrary to the above, daily grab samples and weekly analysis were not

conducted for continuous releases from steam generator blowdown on

January 1 through 3, 1986, and from service water effluent on January 1

through May 22, 1986.

The inspector noted that sampling of the service water effluent on a

monthly frequency was added to procedure SUR 5.4-18 on April 8, 1986, and

daily grab sampling of the steam generator blowdown was added to procedure

SUR 5.4-22 on May 22, 1986. However daily grab sampling of the service

water effluent was not addressed because the licensee had not intended to

meet this frequency as they had misinterpreted Table C-1 of the REM 00CM,

Section I. The licensee stated they would ensure their surveillance

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procedures addressed the required surveillance, and would submit revised

effluent sampling requirements for NRC approval to clarify their intended

sample and analysis program.

The inspector also noted that a corporate audit of the chemistry depart-

ment's implementation of the REMODCM (generally known as RETS) had been

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scheduled for the following week. In addition, onsite quality assurance

tracking of Technical Specification surveillances, as defined in ACP

[ 1.2.11.1, Revision 12 was to be performed by next month.

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Failure to prescribe the frequency of certain sampling and analysis and

failure to perform required sampling and analysis is a violation of

Technical Specifications 6.8 and 8.1.1.1 (50-213/86-15-03).

5.0 Radiological Environmental Monitoring Offsite Dose Calculation Manual

Implementation

The inspectors reviewed the licensee implementation of the Radiological

Environmental Monitoring Offsite Dose Calculation Manual (REM 00CM) as

specified in Technical Specifications 7/8.1 " Radioactive Effluents". The

inspectors also reviewed results of surveillance tests to demonstrate

compliance with the Technical Specification requirements for calculations

of dose contributions from plant radioactive effluents to unrestricted

areas using the methodology specified in the REMODCM.

The inspector determined the main stack and river effluents monitors were

calibrated in accordance with surveillance procedures, SUR 5.4-17 and

5.4-15, respectively. A noted strength of the licensee's calibration

program was the use of duplicated geometries, and statistical treatment of

calibration data, including curve fit test, y-intercept, defined variance

and slope consistency.

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With regard to ODCM' implementation, the licensee used computer software

programs for dose calculations and determining effluent monitor setpoints.

The inspector noted these programs had not been documented or verified.

The inspectors stated that these software programs should be documented

and then verified with predetermined data sets as referenced in Regulatory

Guide 4.15. The inspectors also noted that the calculations for cumu-

lative dose contributions as required by Technical Specification 8.1.3

were not dated, demonstrating that the thirty-one day requirement had

been met. These calculations also were not signed off by the designated

reviewers. The licensee stated that the cumulative dose calculations

were being performed once per thirty-one days and the calculations would

be dated and reviewed in a timely manner. The licensee also stated that

dose calculations would be included on the liquid release permits.

The inspectors reviewed Chemistry and Surveillance procedures

implementing the REMODCM and discussed some procedure improvements with

the licensee. These included:

• Chemistry Procedure CH0P 4.29 " Calculation of Liquid Permits by

Hand" did not address dose calculations for liquid effluent

releases. This procedure also included tables from 10 CFR 20

l Appendix B which were not legible.

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Surveillance Procedure SUR 5.4-15! " Radiation Monitoring System

Liquid Monitor Calibration" indicates in the alarm set point

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equation that a maximum of 5000 gallons-dilution flow is available

for each service water pump in use, yet the equation in the REM 0DCM

references 4200 gallons maximum possible flow per pump. This

procedure was also missing a summation bracket which ensures that

the total isotopic activity is used for calibration.

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Surveillance Procedure SUR 5.4-17 "RMS Main Stack Gas Monitor" in-

, dicates that units for Ki (weighted average total-bocy dose factor

i due to gamma emissions) are Curies, yet the ' calculations are per-

formed with Ki in micro-Curies.

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The licensee had not provided a procedure for calculation of Part-

iculate Release Permits by hand.

The licensee agreed to correct the above procedures. These items will be

reviewed during a subsequent inspection (50-213/86-15-04).

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6.0 Radioactive Waste System Operations

The inspector toured the licensee's radioactive waste processing facil-

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ities and radioactive wasta control panel located in the primary auxiliary

! building and discussed system operation with cognizant licensee personnel.

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The inspector discussed the procedures for_ operation, valve line-up and

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functional checks for radwaste equipment and instrumentation. This review

included a review of the control room operator surveillances performed in

accordance with SUR 5.1-11, and auxiliary operator logs associated with

radwaste processing system.

The inspector observed that the waste processing system was well main-

tained and maintenance requests for instrumentation that was

out-of-service (0.0.S.) were typically less than two months. However, the

inspector noted identification of equipment 0.0.S. or having functional

problems was not formalized until work to return the equipment to service

was initiated. For interim measures, uncontrolled notes, which served as

reminders to the operators, were the only identification for equipment

such as waste discharge pumps, that were unavailable.

The inspectcr suggested the use of a tagging system similar to the

Millstone tagging procedures. The licensee stated their tagging policy

would be examined for equipment not available. This item will be reviewed

during a subsequent inspection (50-213/86-15-05).

The inspector also verified that waste processing operators received

training and retraining in accordance with the IE Bulletin 79-19. Per-

sonnel demonstrated good understanding of system capabilities, and alarm

response procedures were available. However, there were no system draw-

ings availnble at the auxiliary operator work stations. The licensee

stated drawings were being prepared for this location to supplement access

to controlled drawings.

7.0 Exit Interview

The inspector met with the licensee representatives (denoted in Section

1) at the conclusion of the inspection on May 22, 1986. The inspector

summarized the purpose, scope and findings of the inspection. At no time

during this inspection was written material provided to the licensee by

the inspe'ctor.

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