ML20129A494

Insp Rept 50-213/85-08 on 850325-29.Violation Noted:Failure of Annual Audits to Include Entire Scope Required by ETS

ML20129A494
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/10/1985
From:	Shanbaky M, Struckmeyer R, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129A484	List: ML20129A480 ML20129A486 ML20129A494
References
50-213-85-08, 50-213-85-8, NUDOCS 8506040628
Download: ML20129A494 (11)

See also: IR 05000213/1985008

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/85-08

' Docket No. 50-213

License No. OPR-61 Priority --

Category C

Licensee: Connecticut Yankee Atomic-Power Company

P. O. Box 270

Hartford, Connecticut 06101

Facility Name: Haddam Neck Plant

Inspection At: Haddam Neck Site and Northeast Utilities Service' Company (NUSCO)

Inspection Conducted: March 25 - 29, 1985

Inspectors: - A / '

A. A. Weadock, Radittion Specialist date

Y n

R. K. Struckmeyer, Rfr61ation Specialist

YkE date

Approved by: M. A f//O/(f

M. M.~ Sh'IT16a ky , Chi ef' ' da t'e

PWR Radiation Safety Section,

Emergency Preparedness and

Radiological Protection Branch

Inspection Summary: Inspection on March 25-29, 1985 (Report No. 50-213/85-08)

Areas Inspected: Routine, unannounced inspection of the operational radiolo-

gical environmental monitoring program, including management organization,

environmental sample collection, control of contractor activities, meteorole-

gical monitoring, audits, and reports. The inspection involved 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> of

inspector effort by two. region-based inspectors.

Results: One violation was identified: failure of annual audits to include

the entire scope required by the Environmental Technical Specifications.

Details in Section 7.0.

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DETAILS

1.0 ~ Individuals Contacted

N. Corsi, Environmental Technician A, POSL

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• R. Crandall, Supervisor, Radiological Engineering Section

• J. Doroski, Sr. Engineer, Radiological Engineering Section

• W. Eakin, Assoc. Engineer, Radiological Engineering Section

P. Jacobson, Chairman, Connecticut Yankee Environmental Review Board;

Manager, Northeast Utilities Environmental Laboratory

• D. Lenth, Supervisor, Production Operation Services Laboratory (POSL)

• F. Libby, Supervisor, Design and Operations QA

• G. Martel, Senior Engineer, POSL

R. Nejfelt, Environmental. Technician A, POSL

• R. Parker, Environmental Specialist, POSL

• 0. Powell, Manager, Earth Sciences

L. Rayburn, Assoc. Scientist, Radiological Engineering Section

• R. Rodgers, Manager, Radiological Assessment Branch

• J. Santovasi, Scientist, Environmental Programs

H. Siegrist,. Supervisor, Radiological Protection Section

M. Quinn, Chemistry Supervisor, Haddam Neck Plant

• Attended the exit interview on March 29, 1985.

Other licensee employees were also contacted or interviewed during this

inspection.

2.0 Purpose

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

mentation of its Meteorological and Radiological Environmental Monitoring

Programs with respect to the-following elements:

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management organization

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environmental sample collection

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control of contractor activities

-- ~ meteorological monitoring system operation and calibration

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audits-and appraisals

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reports

3.0 Management Organization

The inspector reviewed the licensee's organization for the. management of

.the Radiological Environmental Monitoring Program (REMP). Sample collec-

tions are performed by environmental technicians within the Production

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.0peration Services Laboratory (POSL). The supervisor of POSL reports

through:the Manager, Production Operation Services to the Vice President,

LFossil and Hydro Production. .

Sample analyses, except TLDs, are performed by contractor laboratories.

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Routine TLD analyses are performed by POSL. Laboratory oversight, review

and. analysis of data, and preparation of the. annual radiological environ-

mental monitoring program report are the responsibility.of engineers in the

Radiological Assessment Branch (RAB). The Manager, RAB, reports through

the Director of.the Nuclear Engineering Department to the Vice President,

. Nuclear and Environmental Engineering.

4.0 Enviro'nmental Sample Colle~ction-

The inspector reviewed the licensee's program for the collection of environ-

. mental, samples by the following methods:

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-direct observation of sample collection techniques and environmental

-monitoring station operability;

-- . review of various sample collection procedures;

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review of training records for environmental. technicians;

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discussion with supervisory personnel.

Within'the scope ~of the above review,'no violations were identified.

Technicians responsible for environmental sampling had received training

and were signed off on'the relevant sampling procedures. All observed

-environmental monitoring stations were found to be operable,' within cali-

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bration, and:at the correct location as identified'in the Environmental

. Technical Specifications.

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The' licensee has recently developed a chart which is posted in the Pro-

duction: Operations Services Laboratory (POSL) and which identifies re- .

quired environmental samples and sampling frequencies for the entire year.

This chart is under the direct control of POSL supervisory personnel, and

is reviewed frequently to insure all required samples are being collected '

and to make weekly sampling assignments. Although not charged with the

responsibility for environmental sample collection, the Radiological As-

sesment-Branch of the Northeast Utilities Service Company (NUSCO) main-

tains and keeps. current _a duplicate of the sample collection chart. The

inspector concluded the licensee is providing sufficient management over-

sight in the environmental sampling program.

5.0 Control of Contractor Activities

-The licensee contracts with Chemical Waste Management of Massachusetts,

E Inc. and-Teledyne Isotopes, Inc., to perform analyses of environmental

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samples.

The Yankee Atomic Environmental Laboratory is used as the licensee's QA

laboratory. The licensee maintains control over contractor activities and

verifies the adequacy of environmental sample analyses by.three methods:

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. 1) implementation of a quality control program for analytical measure-

ments;

2) review of analysis results with follow-up for anomalous values;

3) audit of contractor facilities.

5.1 Quality Control Program

The inspector reviewed the implementation of the licensee's pro-

gram for the quality control of environmental sample analysis by the

following methods:

review of procedure RAB 3-2, " Quality Control of Radiological

Environmental Monitoring Program;"

review of the " Connecticut Yankee Quality Control Spiking

Data Book;"

• discussion'with licensee personnel.

Within the scope of the above review, the following concerns were

identified:

The licensee currently receives radioactive standards from the

EPA Environmental-Monitoring Systems Laboratory in Las Vegas,

Nevada. These standards are used by the licensee to spike

samples which are sent to its vendor laboratories for analysis.

The licensee indicated that all standards received from the EPA-

laboratory were exempt quantities, and that an NRC materials

license was not required for possession. Currently, POSL is

licensed only to possess a sealed source used to irradiate

TLD's.

The inspector reviewed various calibration certificates that were

provided with several shipments of I-131 from the EPA laboratory

and concluded, based on activity levels, that a strong possibi-

lity exists that the licensee received quantities of I-131 greater

than the exempt activity identified in 10 CFR 30.71, Schedule B.

Verification was not possible at this time since the licensee,

under the assumption that all received standards were of exempt

quantity, did.not keep adequate records of when specific stand-

ards were received. This item is considered unresolved pending

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subsequent investigation (213/85-08-01).

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~The inspector discussed spike sample preparation with the 11-

censee, and viewed the radioactive standards storage locker and

the sample preparation area. Two immediate concerns were identi-

fled:

1) -the licensee is using radioactive standards in an area

-used by-POSL employees to prepare coffee and as a lunch-

room;

2) smear surveys of the sample work areas are not being

performed.

-The licensee indicated they have 'previously identified the pro-

blem of the close proximity between the lunchroom and the sample

preparation area and plan to move all sampling laboratory ac-

tivities to a separate room. .The licensee showed the inspector

the:1985 POSL budget, which-included funds for the purchase of a

laboratory sink and exhaust hood to be placed in the new labora-

to ry. The licensee indicated that the new sample preparation

area should be complete by September 30, 1985; and committed to

performing smear surveys of.the sample preparation area on a

routine basis until that time. This area will-be reviewed in a

subsequent inspection (213/85-08-02).

The. inspector reviewed procedure RAB 3-2, " Quality Control of

Radiological Environmental Monitoring Program," and noted this

procedure does not address the preparation of quality control

samples (splits, spikes, etc.). .The inspector indicated to the

licensee that detailed, written procedures should be developed

to insure control over the preparation of these~ samples. The licensee

. stated they would develop procedures for-the preparation of

.these samples and have~them in place by July 31, 1985. The

adequacy of the licensee's control of quality control sample

preparation will remain unresolved pending review of these pro-

cedures.(213/85-08-03).

5.2 Review of-Data Analysis Results

The inspector. reviewed the adequacy of the licensee's program for

the data review of analyses performed on environmental samples by

the following methods:

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review of procedure RAB 3-3, " Radiological Analysis Data

Checks"

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review of licensee's " Exemption Reports" Book

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discussion with involved licensee personnel

Results of sample analyses incoming to the Radiological Assessment

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Branch receive a three party review. The inspector reviewed the

licensee's. data review worksheets and verified that.the licensee is

identifying inconsistencies and problems _with the data and adequately

complying with procedure RAB 3-3.

The licensee maintains.an " Exemption Reports" book to identify and

track anomalous values and instances where the vendor laboratory

fails to meet Minimum Detectable. Levels (MDL) or-required analysis

timetables. In such instances, the licensee sends a report to the

laboratory which requires a response and resolution to the problem.

The inspector noted that vendor responses to these reports were cur-

rent up to March 15, 1985. The licensee indicated the " Exemption

Reports" book is used to plan the frequency and scope of vendor

laboratory audits.

.5.3 ' Audit of Contractor Facilities

. Licensee procedure RAB 1-4, " Radiological Environmental Monitoring

Audit Program," requires'periedic audits of the groups involved in

the Connecticut Yankee Radiological Environmental Monitoring Program,

including contractor laboratories.

The inspector reviewed several 1983 and 1984 audits of contractor

facilities and determined that.they were being performed in accord-

ance with the above procedure and that findings were being tracked

and adequately resolved.

6.0 Meteoregical Monitoring System Operation and Calibration

6.1 Operation

The inspector examined the licensee's meteorological monitoring system,

including the on-site meteorological tower, the recorder charts in the

equipment house at the base of the tower, and the control room re-

corder charts. .It was noted that all instrumentation was operative,

and that the meteorological data readouts'from the equipment house and

.the control room appeared consistent.

6.2 Calibration

Responsibility for the maintenance and calibration of the meteoro-

logical. monitoring system is held by the Production Operations Ser-

vices Laboratory (POSL), Calibrations of the instrumentation are

performed quarterly. The inspector reviewed the following documents

to assess the adequacy of the licensee's calibration program:

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procedure.ES #201, " Wind Direction System Calibration,"

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procedure ES #205, " Wind Speed System Calibration,"

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procedure ES #206, " Analog Recorder Calibration,"

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procedure EPB-III-1-3, " Annual Meteorological Monitoring System

Maintenance Audit,"

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1983 and 1984 instrumentation calibration records,

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1984 Meteorological Monitoring System Maintenance Audit.

-Within the scope of the above review the inspector noted that, for

the instruments and calibration periods specified below, the licensee

failed to bring "beginning of period" or "as left" calibration mea-

surements to within the tolerances specified in the calibration pro-

cedure. Procedure #201 and #205 both require the individual perfor-

ming the calibration to "make any adjustments or component replace-

ments that are required to bring the measured values within the

tolerances as specified..." The instrumentation noted below was then

returned to operation without further adjustment.

Period Instrument System No. of Out of Tolerance Values

1st Qtr. 1983 196' Wind Direction 3

3rd Qtr. 1983 196' Wind Direction 6

2nd Qtr. 1984 196' Wind Speed 2

4th Qtr. 1984 196' Wind Speed 2

1st.Qtr. 1985 196' Wind Speed 2

Licensee failure to follow the calibration procedures as noted above

will not be considered a violation as it was noted that the toler--

ances required by the calibration procedures are more conservative

than instrument accuracies. required by Regulatory Guide 1.23, O_n

site Meteorological Programs. It was noted that the licensee's out-

of-tolerance calibration values exceeded the Regulatory Guide require-

ments in only one instance.

The inspector discussed with the licensee the recurring inability to

bring meteorological monitoring equipment within the tolerance ranges

specified in the calibration procedures. The licensee indicated that

an interference problem exists within the 9 pairs of underground

cable which carry the signal from the meteorological building to the

control room meteorological recorders. This results in a back feed

of between 0-2 volts on these signal cables which varies between

pairs and-dates when checked; the licensee indicated that the mois-

ture content of the ground contributes to the problem.

The inspector noted during a review of quarterly calibration data

sheets that notes and remarks on the sheets identified interference

problems on the control room cable lines as far back as the first

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quarterly-calibration in 1982. ~ The inspector ~ noted this appeared to

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be a long-standing. problem and discussed with POSL personnel what

steps had been taken to notify appropriate management and correct

this problem. The licensee produced the following correspondence:

Memo # RAD-83-107, dated August 15,.1983, ~from POSL to Connec-

ticut Yankee Management and the Environmental Programs Depart-

ment,~ NUSCO. Subject: Recommendation for weekly checks on

Nuclear Plant Control Room Meteorological Strip Chart Recorder.

Memo # MET-85-103, dated February 5,1985, from POSL to the Instrument

iand Control Section at Connecticut Yankee. Subject: Problems with

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meteorological Signal Cable from Met. Building to Control Room.

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The inspector reviewed the above correspondence and noted the August

15, 1983 memo describes inconsistencies with meteorological data

available on the control room recorders; however it attributes this

to a poorer accuracy in the recorders and a need for more frequent

equipment surveillances. At this time POSL began a weekly zero and

span check on the co'ntrol room meteorological ' recorders to supplement

the quarterly system calibrations.

Licensee memo MET-85-163. describes the problem with the transmission

cable and suggests options available to correct it. As of the date

of this inspection, none of the options _ suggested had'been imple-

mented. POSL personnel also ~ indicated that the Connecticut Yankee

Instrument and Control group had been informed of the cable problem

in 1984 and had performed a check on control room recorder accuracy;

however the POSL group had no documentation of this check.

The inspector reviewed a 1984 audit of the Meteorological Monitoring

System Maintenance Program carried out-by the NUSCO Environmental

Program Department and noted that no problems were identified.

The licensee stated during the exit interview that corrective actions

to resolve the identified signal transmission problem would include:

.1) an immediate fix of the transmission cable;

2) an evaluation of the use of alternate methods of data signal

transmission, in light of recurring problems with the under-

ground cable.

During a phone conversation subsequent to this inspection the licensee

indicated that a spare cable was made available for data signal trans-

mission from the meteorological tower to the Control Room on March 31,

1985. The licensee reported successful instrument calibration after

the cable switchover. Documentation of this calibration and further

actions by the licensee will be evaluated in a subsequent inspection

(213/85-08-04).

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7.0 Audits and Appraisals

.The. inspector reviewed the following procedure and audits to assess the

, licensee's performance in meeting the requirements of . Environmental

= Technical Specifications Section 5.3, Review and Audit:

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Procedure CYERB-1, " Periodic Environmental Audits,"

- Connecticut Yankee Semiannual Environmental Audit

1. A20021'- Summer, 1983;

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Connecticut Yankee Semiannual Environmental Audit

1. A20022 --Winter, 1983;.

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Connecticut Yankee Semiannual Environmental Audit

1. A60226 - Summer, 1984;

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Connecticut Yankee Semiannual Environmental Audit

1. A60429 - Winter, 1984;

'The inspector reviewed the final reports and checklists for the above

audits and found no evidence to indicate that the Summer 1983 audit

1. A20021 included a review of the Annual Environmental Operating Report,

Part.B or the Sen.fannual Radioactive Effluents Release Report. Ad-

ditionally,.the inspector found no evidence to indicate the Winter 1983

audit #A20022 included a review of the following:

1) -The Radiological Environmental Monitoring Program,

2) the Annua- Environmental Operating Report - Part B,

3) the Semiannual Effluent Release Report.

Environmental Technical Specifications Section 5.3, Review and Audit,

states in part "the Environmental Review Board shall make or cause to be

made at least semiannual reviews or audits of the following... surveillance

records, written procedures, and reports required for compliance with these

Environmental Technical Specifications."

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Procedure CYERB-1 has been implemented to insure the specific requirements

of E.T.S. Section 5.3 are met. Section 7.1.4 of this procedure identifies

the following specific areas to be included in the scope of the Environmental

Review Board (ERB) semiannual environmental audit:

1)' Radiological Environmental Monitoring,

2) Annual Environmental Operating Report - Part B,

3). Radioactive Effluents Release Report.

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The inspector indicated to the licensee that the failure of the _1983 semi-

annual audits to include the above areas constitutes an apparent violation

of E.T.S. section 5.3 (213/85-08-05). The licensee responded that since

the Annual Environmental Operating Report is produced annually, it should

not be necessary to review this' report semiannually. The inspector noted

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that both the 1983 semiannual audits failed to review the Annual Environ-

mental Operating Report.

.The inspector discussed the assignment of-specific responsibilities in

completing the ERB semiannual audit with the licensee. The corporate QA

section has overall responsibility for insuring the audit is conducted in

compliance with the implementing procedure and the Environmental Tech-

nical Specifications. Responsibility for performing the actual audit,

however, is assigned to a specific section supervisor or manager.

During 1983 and 1984, responsibility for auditing the. Radiological

Environmental Monitoring Program and related reports has been assigned

to the supervisor of the Radiological Engineering Section (RES).

The inspector noted that the delegation of authority described above

raises a potential conflict of interest concern with the conduct of the

audit, as.the RES is the section directly responsible for implementing _the

Radiological Environmental Monitoiing Program and producing all related

reports. The licensee stated'that the RES section audits its own activi-

ties because it is the only section with the necessary technical expertise

to do so; additionally, audit responsibilities are assigned such that RES

-personnel do not audit activities for which they have direct responsi-

bility.

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A review of the 1983 and 1984 ERB Audits indicated the scope was largely

limited to assessing compliance with the E.T.S. requirements regarding

sample frequency, sample volume, etc. The inspector concluded the li-

censee is in effect performing a peer review, and thereby meeting the

E.T.S. Section 5.3 requirement of a " semiannual review or audit..." The

above practice does not appear to insure the independence that is required

to meet the criteria. for an independent audit. The licensee stated that

methods for re- structuring the audit process would be evaluated. This

area will be reviewed in a subsequent inspection (213/85-08-06).

8.0 Reports-

The inspector reviewed the 1983 and 1984 Annual Environmental Operating

Reports (Part B-Radiological) and determined that these were complete and

comprehensive summaries of the sampling, analyses, and results of the

REMP, including the various aspects of quality control.

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- 9.0 Exit Interview-

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'The inspector. met with the. licensee . representatives l(identifled:in Para-

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graph 1) at.the conclusion of the. inspection on March 29,.1985. The in-

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- spector summarized the-purpose and_ scope of the inspection and the in--

_  : spection findings. At no time during thisLinspection was written material -

provided to the licensee by the in'spector.

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