IR 05000321/1993015

Insp Repts 50-321/93-15 & 50-366/93-15 on 930802-06.No Violations or Deviations Noted.Major Areas Inspected: Radioactive Effluents,Radiological Environ Monitoring,Water Chemistry,Training & Followup on Previous Insp Findings

ML20057A492
Person / Time
Site:	Hatch
Issue date:	08/29/1993
From:	Decker T, David Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20057A487	List: IR 05000321/1993015 ML20057A486
References
50-321-93-15, 50-366-93-15, NUDOCS 9309140296
Download: ML20057A492 (11)

Text

n o UNITED STATES

/e Ma %,& NUCLEAR REGULATORY COMMIS5lON  ;

y- f REGloN !! >

W( Q 101 MARIETTA STREET, N.W., SUITE 29

0 p, ', y ATLANTA, GEORGIA 30323-o199

% 8

.....*# SFJ 0 21993 ,

Report Nos.: 50-321/93-15 and 50-366/93-15 Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 i Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 ,

Facility Name: Hatch I and 2 Inspection Conducted: August 2-6, 1993  !

Inspector: /j h f/27/93 Date Signed D. V. pnEs ,

Approved by: (. 'nw N .8 d/ 4c T. R. Decker, Chief Adf/G Dats Signed Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards

!

I SUMMARY  ;

!

Scope: 1 This routine, announced inspection was conducted in the areas of radioactive ;

effluents, radiological environmental monitoring, water chemistry, training, i and followup on previously identified issue i l

Results: l In the areas inspected, no violations or deviations were identifie The licensee had implemented and maintained an effective program to monitor and control liquid and gaseous radioactive effluents. The projected offsite doses resulting from those effluents were well within the limits specified in the Technical Specifications and 40 CFR 190 (Paragraph 2). l

The licensee's radiological environmental monitoring program was effectively l implemented. The program requirements for sampling, analysis, and reporting were met. The program results for 1992 indicated that no measurable impact upon the environment or the public as a consequence of plant discharges to the atmosphere and to the river was established (Paragraph 3).

The results of the licensee's participation in the EPA's interlaboratory crosscheck program indicated that an effective quality assurance program had been maintained for analysis of environmental samples (Paragraph 4).

9309140296 930902 PDR ADOCK 05000321 G PDR a e'w * "-

O'

_ _- -

i  ?

!

i  ;

l

, The licensee's reactor coolant chemistry program was effectively implemente Parameters required to be monitored were maintained well within their ,

specified limits (Paragraph 6).  ;

<  ;

! The licensee's training and qualification program for Health Physics and j Chemistry personnel was effectively implemented (Paragraph 7).  ;

.

I One item (92-33-01), a violation for failure to dispose of licensed material (

in an authorized manner, was closed (Paragraph 8).  ;

.:  :

One unresolved item (93-03-01) concerning reactor building ventilation stack i j flowrate recorders will remain open pending review of the licensee's  !

'

j assessment of safety significance (Paragraph 8).

;

i s

'

i 1 ,

i t i ;

J  ;

,

,

j  !

S ,

j -

r

e t i

:

h

!

a l i-d ,

i

<

!

i i  !

!

r h

!

! *

l i

'

f

- - - . . . -.

- , . . , , - - - ,

-

. . _ . _ _ _ _ _ . .

REPORT DETAILS Persons Contacted Licensee Employees B. Arnold, Supervisor, Chemistry D. Bennett, Superintendent, Chemistry W. Duvall, Supervisor, Health Physics and Chemistry l

• 0. Fraser, Site Supervisor, SAER I

• W. Kirkley, Manager, Health Physics and Chemistry i

,

• L. Lawrence, Specialist, SAER j l

M. Marionneaux, Foreman, Health Physics  !

V. McGowan, Supervisor, Chemistry 1

• T. Moore, Assistant General Manager

• J. Payne, Senior Engineer, Nuclear Safety and Compliance J. Reddick, Supervisor, Health Physics j

• B. Roberts, Instructor, Plant Training i

• D. Smith, Superintendent, Health Physics i

• L. Sumner, General Manager l

• S. Tipps, Manager, Nuclear Safety and Complianc l l

Other licensee employees contacted included engineers, technicians, and  !

administrative personne l i

Nuclear Regulatory Commission ,

l E. Christnot, Resident Inspector

• B. Holbrook, Resident Inspector L. Wert, Senior Resident Inspector

• Attended exit interview- l Semiannual Radioactive Effluent Release Reports (84750)

Technical Specifications (TSs) 6.9.1.8 and 6.9.1.9 for both units )

described the reporting schedule and content requirements for the Semiannual Radioactive Effluent Release Reports. The reports were required to be submitted within 60 days after January 1 and July 1 of i each year covering.the operation of the facility during-the previous six 1 months. Summaries of the quantities of radioactive liquid and gaseous effluents released from the facility and an assessment of the radiation ,

doses due to those releases were required to be included in the report ;

,

The effluent data presented in Table 1 below were compiled from the licensee's effluent release reports for the years 1990, 1991, and 199 :

The inspector reviewed the reports for the year 1992-and discussed their content and the data presented in Table I with.the licensee. As shown'  !

in the table, there were increases in the amount of activity released during 1992 and in the radiation doses from the Unit 2 gaseous . .

'

effluents. The licensee attributed those increases to their recent problems with leaking fuel in Unit 2. The radiation doses from the '

l

!

,, -- . , - , - . , , . . , . . . . - - - - , _ . ,, - - = . .,

!

l l

!

l 2 i

j liquid and gaseous effluents were less than 11 and 3 percent of their i respective annual limits. The reports for 1992 also indicated that there were no unplanned releases or effluent monitors inoperable for more than 90 days during that yea i

'

Based on the above reviews, it was concluded that the licensee had implemented and maintained an effective program to monitor and control '

liquid and gaseous radioactive effluents. The projected offsite doses resulting from those effluents were well within the limits specified in the TSs and 40 CFR 19 Table 1 vg[,,,e Effluent Release Summary for Hatch Units 1, and 2 '

Activity Released (curies) ,

I Liouid Effluents Gaseous Effluents j Fission and Dissolved j

. Activation Noble Fission i Year Products Tritium Gases Gases Iodines Particulates Tritium l 1990 0.30 23 4.45E-2 1104 6.02E-3 2.56E-3 40

!

1991 0.72 29- 3.82E-2 279 4.71E-3 1.20E-3 34

l 1992 0.75 45 1.71E-1 1047 3.70E-2 5.29E-3 50 Annual Doses

)!

Liouid Effluents Maximum Total Body Dose Percent of Organ Dose Percent of Year (Limit: 3 mrem) Limit (Limit: 10 mrem) Limit 1990 Unit 1 0.30 1 .43 Unit 2 0.10 .14 Unit 1 0.27 .41 <

Unit 2 0.12 .18 Unit 1 0.18 .27 !

Unit 2 0.14 .20 2.0 l

l l

l l

l

. _ _ _

-

_ .

,

f :l

.

i

'

4 j Gaseous Effluents i Maximum Organ Dose

! Air Dose [From lodine, Tritium, i (Limits: Gamma 10 mrad, Percent of and Particulates] Percent of l

Year Betta 20 mrad) Limit (Limit: 15 mrem) Limit

!

! 1990 Unit 1 Gamma 0.09 .04 0.3 i Beta 0.15 0.7

! Unit 2 Gamma 0.06 .03 0.2 l Beta 0.15 Unit 1 Gamma 0.02 .02 0.1

Beta 0.04 0.2 j Unit 2 Gamma 0.02 .03 0.2 3 Beta 0.02 0.1 i )

1992 Unit 1 Gaama 0.03 .07 i

! Beta 0.04 l

Unit 2 Gamma 0.27 .09 0.6 i Beta 0.24 1.2

!  !

!

1 No violations or deviations were identified.

4 Radiological Environmental Monitoring (84750)  ;

'

i

TS 3/4.16.1 for Unit I described the operational and surveillance j i requirements for the radiological environmental monitoring program. The J

sampling locations, types of samples or measurements, sampling i

frequency, types and frequency of sample analysis, reporting levels, and i

}

analytical lower limits of detection (LLDs) were specified. TSs 6.9. and 6.9.1.7 for both units delineated the requirements for submitting, ,

i the submittal dates, and the content of the- Annual Radiological '

4 Environmental Surveillance Reports. The reports were required to be  :

l submitted prior to May 1 of each year and to provide an assessment of i j the observed impact on the environment resulting from plant operations I

during the previous calendar yea l

j The inspector reviewed the licensee's 1992 Annual Radiological

, Environmental Surveillance Report and discussed its content with the i licensee. The report was submitted on April 21, 1993, and included the following: a description of the program, a summary and discussion of the

'

results for each exposure pathway, analysis of trends and comparisons

'

with previous years and preoperational studies, and an assessment of the

<

impact on the environment resulting from plant opers.tions. The report also included the results of the Land Use Census required by Unit 1 TS

, 3/4.16.2 and the results of the Interlaboratory Comparison' Progra . required by Unit 1 TS.3/4.16.3. The following observations for the j various exposure pathways were produced by the licensee's evaluation of 1 the 1992 environmental monitoring program data and-documented in the report or were noted by:the inspector during the review of the report.

I

I

-. _ _ _ . _ _ _ , - . . . _ - . , . . - _ - ,, __ ..._ I

l

-

!

-

!

e

- Airborne - No man-made radionuclides were detected by gamma isotopic analysis of the of the quarterly composites of air l

particulate filters. 1-131 was not detected by gamma spectroscopy i in any of the charcoal canisters used for adsorbing iodine from l the atmosphere. Beta activity was detected on all particulate >

l samples collected from both indicator and control locations. The l observed gross beta activity levels were below or near the l required LLD.

l 1 * Direct radiation exposure - The quarterly expssures for 1992, as '

measured by thermo!uminescent dosimeters (TLDs), were consistent with the doses observed over the past 12 year ;

!

,

- Milk - Man-made radionuclides have not been detected in any of the

! milk samples collected during the last three year ,

l l

- Grass - Cs-137 was the only man-made radionuclide detected in the l samples collected during 1992 and the highest concentration l observed was only slightly over the required LL *

River Water - No man-made radionuclides were detected in the surface water samples collected from the Altamaha River during 1992, and no intakes for drinking water or. irrigation were found l

within 50 river miles downstream of the plant during the land use censu Fish - Cs-137 was the only man-made radionuclide detected in the fish samples collected during 1992 and the highest concentration l observed was less than the required LL * Sediment - Co-60, Zn-65, and Cs-137 were detected in the samples collected during 1992. Their concentrations were below or near their required LLDs and were typical of those found during previous year No measurable radiological impact upon the environment or public .

as a consequence of plant discharges to the atmosphere and to the river was establishe Based on the above reviews and discussions, it was concluded that the licensee had complied with the sampling, analytical and reporting program requirements and that the radiological environmental monitoring program was effectively implemented.

i No violations or deviations were identified.

l l Environmental Monitoring Quality Assurance Program (84750)

TS 3/4.16.3 for Unit I required the licensee to participate in an interlaboratory comparison program and to include a summary of the

,

program results in the Annual Radiological Environmental Surveillance Report. The licensee's report for 1992 provided a summary of the results l

l I

_ _ -

,

.

a

'

l 5 i

'

from the licensee's participation in the Environmental Protection Agency's (EPA's) Environmental Radioactivity Laboratory Intercomparison ,

Studies (Crosscheck) Program. The report also included descriptions of i

'

the various types of samples analyzed and the analyses performed, and an evaluation of the analytical results. A total of 35 samples were ,

analyzed in triplicate. Statistical evaluation of the program data indicated that no EPA control limits had been exceeded but warning limits were exceeded for two samples and one trend was detected. The licensee's investigation of these anomalies concluded that they were due to changes in background count rate. The report indicated that computer

'

software improvements had been developed to correct the problem and that !

those improvements would be implemented during 1993.

l Based on the licensee's overall performance in the EPA crosscheck l

program it was concluded that an effective quality assurance program had !

! been maintained for analysis of environmental sample ;

No violations or deviations were identifie l State Radiological Environmental Monitoring Program (84750) :

The Environmental Protection Division (EPD) of the Georgia Department of j Natural Resources, by contract with the NRC, independently monitors the .

concentrations of radioactivity in the environs of the licensee's :

facility and provides an annual report of their results. The inspector reviewed the report for 1992, and determined that the licensee's program l data were consistent with the EPD's result . Reactor Coolant Chemistry (84750)  ;

TSs 3/4.6.F.1, 3/4.6.F.2 and 3/4.15.2.7 for Unit 1 and 3/4.4.4, 3/4. l and 3/4.11.2.7 for Unit 2 described the operational and surveillance requirements for chloride concentration, conductivity, and specific .

activity in the reactor coolant and for noble gas radioactivity rate in the main condenser off-gas prior to treatment. Operational limits for those attributes and sampling frequencies were specified for various operational condition The inspector reviewed procedure 64CH-ADM-001-0S, Rev. 9, " Chemistry Program" and determined that it included provisions for collecting and analyzing reactor coolant and pretreatment off-cas samples at the frequencies required by the TSs. The procedure also identified specific sampling and analytical procedures which were to be used and the acceptance criteria for each attribute. The inspector reviewed plots of the above parameters for the period May 1992 through July 1993 and discussed those data with the licensee. During that period the chloride concentrations for both units were typically <3 ppb which was well below the TS limit of 200 ppb during power onerations. The coolant ;

conductivity for both units was typically <0.1 mho/cm and within the TS limit of 2 mho/cm during power operations. The coolant dose equivalent I-131 (DEI) was typically <2 E-4 Ci/cc for Unit I and

<5 E-3 pCi/cc for Unit 2. The higher DEI for Unit 2 was attributed to

.. -- . - -. -_ .

,

'

i

. : i

'

l l

6 $

i leaking fuel but was within the TS limit of 0.2 Ci/gm. The gross gamm !

radioactivity rate of the noble gases Xe-133, Xe-135, Xe-138,. Kr-85m, Kr-87, and Kr-88 in the pretreatment off-gas was referred to by the !

'

licensee as the " sum-of-six." The Unit 1 " sum-of-six" exhibited a decreasing trend over the period of June 1992 to March 1993. During that period the radioactivity rate decreased from >1000 pCi/sec to ,

<800 pCi/sec. After the March-April 1993 outage the rate was typically ;

<400 Ci/sec. The Unit 2 " sum-of-six" exhibited an 'ncreasing trend j over the period of May 1992 through April 1993 due to leaking fuel. The j radioactivity rate increased i.cm ~10,0000 C1/see to ~54,000 pCi/sec '{

during that period. The reactor power output was reduced to -85 percent '

of full power and the radioactivity rate decreased to ~15,000 Ci/sec ;

during June and July 1993. Those values were well within the TS -limit of j 240,000 Ci/sec. The licensee indicated that the Unit 2 " sum-of-six" l would be closely monitored until the end of the fuel cycl i i

Based on the above reviews and discussions, it was concluded that the !

licensee's chemistry control program was effectively implemente :

!

No violations or deviations were identifie !

l 7. Training (84750, 86750)

TSs 6.3 and 6.4 described the requirements for training and ,

qualification of licensee personnel. The licensee's programs for l'

training Health Physics and Chemistry personnel were implemented through System Master Plans which delineated pcsition descriptions, qualification requirements, and lists of required classes for specific ' l tasks. The programs included general employee training, basic academics ;

in health physics and chemistry, classes in specific job related topics, '

on-the-job training, and continuing trainin The inspector reviewed training records for two Health Physics technicians and one Chemistry technician. The assigned duties for one.of those Health Physics technicians involved preparation of radioactive material for shipment. The records indicated that those individuals selected had been trained in accordance with the System Master Plan Based on the above reviews, it was concluded'that the licensee had implemented an effective program for training and qualificatio No violations or deviations were identifie . Followup on Previously Identified Issues (92701) l (Closed) Violation,(92-33-01): Failure to dispose of licensed material '

in an authorized manne Prior to May 1992, the licensee had been disposing of sludge from the .

onsite sewage treatment plant by spreading the. sludge on licensee-owned i land outside of the protected area.' The sludge was released as non- !

licensed material based on measurements by procedures which had the l

l

I

'

,,

I

~

!

,

capability of achieving lower limits of detection (LLDs) required for radioactive effluent measurements rather than LLDs required for ;

'

radiological environmental measurements. The licensee's response to the Notice of Violation, letter dated February 2,1993, indicated that the licensee's procedure for operation of the sewage treatment plant had been revised to require samples from each batch of sludge be analyzed ,

with equipment capable of detecting radioactivity at the required LLDs ;

prior to release of the batch. The response also indicated that sludge found to contain activity above those limits would be prohibited from- -

- being disposed as non-radioactive waste except as allowed by 10 CFR 20

, or applicable regulatory guidance. During this inspection the licensee's procedure 64CH-0PS-001-0N was reviewed and found to have been revised to include instructions to notify Chemistry supervision if sludge sample results indicated the presence of radioactive contamination in excess of '

environmental LLDs. The inspector also reviewed shipping records which l documented two recent transfers of sludge to a licensed waste processo ;

The analytical results for that material indicated that it contained

'

Cs-137 at a concentration slightly higher than the environmental LL Based on the above reviews this item is close (0 pen) Unresolved Itea (93-03-01): Reactor Building ventilation stack flowrate deficiencie TSs 3/4.14.2 for Unit I and 3/4.3.6.10 for Unit 2 required at least one i

'

channel of the Reactor Building (RB) vent stack effluent flowrate measurement devices to be operable and demonstrated operable by performance of daily channel checks, quarterly channel functional tests, and 18 month channel calibrations. The resident inspectors identified several discrepancies associated with the Unit 2 RB stack flowrate chart ;

recorder and doc:mnted their findings in Inspection Report 50-321, 50-366/93-03. That u port documented inspe: tion activities for the period ;

February 7 through March 13, 1993. During routine tours of the control i room, the resident inspectors noted that the "A" channel of the chart j recorder indicated.that the RB stack flowrate was ~100,000 cubic feet per minute (cfm) and the "B" channel indicated ~200,000 cfm. In that the flowrate was used for calculating gaseous effluent radioactive releases and would be used for dose assessment calculations in the event of some types of accidents, the resident inspectors concluded that the difference between the two indicated flowrates was excessive. The resident in:;pectors also determined that the licensee had apparently failed to follow the chemistry surveillance procedure 62EV-SAM-003-0S

" Gaseous Waste Discharge Monitor Checks." That procedure stipulated that the RB vent flowrates indicated by the two channels were to be compared each day and if the difference exceeded 20 percent, corrective actions were to be initiated. That procedure also specified that-the higher of the two readings was to be recorded as the flowrate. Deficiencies in other related procedures were identified by the resident inspectors and documented in the above. referenced report. ine issue regarding the licensee's failure to identify inaccurate RB stack flowrate recorder indications was deemed unresolved pending review of additional information necessary to assess the safety significance of the issu .

,

r

'

.

.  :

During this inspection the licensee's actions with regard to the above i issue were discussed. Subsequent to the resident inspector's identification of this issue, the licensee initiated a corrective action plan and documented those plans on a corrective action tracking for Those actions included: determination of appropriate acceptance criteria for RB vent flowrate indications and revision of surveillance procedures to include those criteria, revision of emergency preparedness procedures to provide guidance regarding which channel indication to use for dose assessment, and determination of whether the flow unaitor probes were correctly positioned to provide accurate flow indications. The licensee indicated that a request for engineering assistance (REA) was made to their corporate services office regarding this issue and that a response had been received during the week prior to this inspection. The licensee further indicated that the information provided in that response was currently being evaluated for applicability as a basis for revision of their corrective action. plan. A copy of that response was provided to l the inspector for review. The response indicated that the erratiu behavior of the RB vent stack air flow sensors was caused by their i location in turbulent sections of the stack and suggested that the flow recorders be recalibrated to reflect the sum of the design air flows for the ventilation fans. The response also indicated that the total design '

maximum air flows for the Unit I and Unit 2 RB vent stacks were l

~

286,935 cfm and 198,840 cfm, respectively, and recommended that a conservative estimate of 300,000 cfm be used for both units in the emergency preparedness procedure for offsite dose assessments. The licensee also indicated that during 1990 an REA was made regarding the ,

stipulation in the chemistry surveillance procedure that the difference between the two channel indications for RB vent flowrate must be less than 20 percent. The response to that request indicated tLat turbulence in the ventilation system would cause different channel responses and recommended that the stipulation be deleted from tN procedure because -

it was not required by the TSs or the FSAR. Based on that recommendation and the current interest in this issue the licensee deleted those instructions from the procedure. The effective date of that change was i July 20, 1993. The licensee indicated that consideration was being given l to include in the procedure for daily surveillances performed by operations, a limit of 30 percent for the difference in the channel responses.

l After reviewing the above ir. formation, the inspector had further

! discussions with the licensea regarding their corrective action plan The inspector inquired as to why the RB vent stack air flow sensors should not be relocated to a section of the stack which was less turbulent and representative of the true flow. The licensee indicated that relocation of the sensors had been considered but not pursued due to the expense of a design change. The inspector observed that the calculation of gaseous effluents from the RB vent stack involved both air flow measurements and radioactivity concentration measurements, and that it would appear to be inconsistent to calibrate the air flow instrumentation to a design flow when the radiation monitor is calibrated with standards traceable to the national measurement system.

.

The licensee acknowledged the inspectors observation and indicated that

__ _ _ _ _ _ _ _

> . .

l

,

'

9

their planned actions regarding calibration of the flow indicators had J 1 not been finalized. The inspector inquired as to when the revisions to i the corrective action plan would be compete. The licensee indicated that >

a revised plan would be issued during the week following this inspection i but emphasized that the actions delineated in that plan were not to be

.

i

construed as commitments to the NRC.

,

Based on the above reviews and discussions, it was not clear that the l licensee had completed adequate corrective actions for this issue or performed an adequate assessment of the safety significance of the RB  ;

i vent stack flowrate discrepancies. This item will remain open pending i review of the licensee's assessment of the safety significanc '

i i

'

9. Exit Interview

-

The inspection scope and results were summarized on August 6, 1993, with .

! those persons indicated in Paragraph 1. The inspector described the

areas inspected and discussed in detail the inspection results listed  !

above. No dissenting comments were received from the license Proprietary information is not contained in this repor ?

I i

i I

i e'

E i

l

!

l

!

!

i