ML20128H837
| ML20128H837 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 09/27/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17264B184 | List: |
| References | |
| 50-348-96-10, 50-364-96-10, NUDOCS 9610100072 | |
| Download: ML20128H837 (16) | |
See also: IR 05000348/1996010
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION ll
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Docket Nos.: 50-348, 50-364
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Report No: 50-348/96-10, 364/96-10
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Licensee: Southern Nuclear Operating Company, Inc.
Facility: Farley Nuclear Plant, Units 1 & 2
Location: P. O. Box 470
Ashford, AL 35201
Dates: August 12-16, and 26-30,1996
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Inspector: George 'B. Kuzo, Senior Radiation Specialist
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Approved by: Albert F. Gibson, Director
Division of Reactor Safety
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Enclosure 2
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9610100072 960927
PDR ADOCK 05000348
G PDR ,
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EXECUTIVE SUMMARY
Farley Nuclear Plant, Units 1 & 2
l NRC Inspection Report No 50-348/96-10, 364/96-10
This specialinspection reviewed and evaluated Radiation Monitoring System (RMS), i
radioactive waste (radwaste) processing and storage, and operational radiation protection l
programs. Specifically, the adequacy and status of the RMS and radwaste facilities,
equipment and approved procedures, and the proficiency of staff were reviewed. In addition, i
radiation protection program controls and personnel monitoring associated with radioactive I
effluent processing and release, and with radwaste storage activities were reviewed.
Conclusions included the following:
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Review of RMS equipment, calibrations, and effluent release activities and solid I
radioactive waste and material controls identified five violations.
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One example of a violation of 10 CFR 50, Appendix B, Criterion V, for
failure to construct and maintain "as built" Unit 1 Post Accident >
Sampling System (PASS) containment airborne particulate detector !
(RE-67) sample line in accordance with approved configuration control l
procedures and drawings (Section R1.1).
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One example of a violation of 10 CFR 50.54(h) for failure to follow a
March 14,1983 Order to implement and maintain special calibrations of
the containment high range monitors in accordance with Three Mile I
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Island (TMI) Action item Table ll.F.1-3 (Section R1.2).
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One example of a violation of 10 CFR 20.1904(a) for failure to label
casks of contaminated resins (Section R1.4).
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Numerous examples of a violation of Technical Specification (TS) 6.11
for failure to follow procedures for use of personal dosimetry (Section
R1.4).
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One example of a violation of TS 6.8.1(i) for inadequate procedures to
assure adequate preservation of liquid effluent composite samples
(Section R7.1).
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Direct observations of an August 27,1996 liquid effluent release identified several
operational weaknesses including a System Operator's lack of understanding
regarding procedural compliance, and identification of minor procedural deficiencies
(Section R1.3).
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Housekeeping was acceptable within the resin dewatering facility and low-level
radwaste storage facilities and low volumes of radwaste were maintain on site.
However, numerous poor housekeeping practices were identified for RMS equipment
and within the Auxiliary Buildings (Sections R1.1, R1.4).
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Report Details
R1 Radiological Protection and Chemistry Controls
R1.1 Radiation Monitor System (RMS) Installation
a. Inspection Scope (84750)
The inspectors reviewed and evaluated general housekeeping and the adequacy of
installed process and effluent Radiation Monitoring System (RMS) detectors,
electronics, sampling lines and flow meters, as applicable, to meet Final Safety
Analysis Report (FSAR) commitments and to implement Offsite Dose Calculation
Manual (ODCM) and 10 CFR Part 20 requirements. The evaluation included, as
applicable, RMS equipment walk-downs with comparisons against configuration
control documents, production change notices (PCNs) and vendor design
specifications. Further, the installed sample line bend radii and piping specifications
were evaluated against recommendations specified in American National Standards
institute (ANSI) N13.1-1969, American National Standard Guide to Sampling Airbome
Radioactive Materials in Nuclear Facilities. General comparisons were made between
radiation monitor local and remote readouts, where possible.
The following RMS samplers or detectors, i.e. radiation elements (REs), and
associated equipment were included in the review: Unit 1 (U1) and Unit 2 (U2) Spent
Fuel Pool area (RE-5); U1 & U2 Containment Atmosphere particulate (RE-11) and gas
(RE-12); U1 Turbine Building ventilation exhaust normal (RE-15), mid (RE-15B) and
high (RE-15C) range; U1 & U2 Liquid Waste effluent discharge (RE-18); U1 & U2 '
Steam Generator Blowdown (SGBD) effluent discharge (RE-23A&B); Containment ,
Purge exhaust (RE-24A&B); Spent Fuel Pool ventilation exhaust (RE-25A&B); U1 & i
U2 Plant Vent gas (R-29B) and particulate (RE-29A); Main Control Room (MCR) air
supply (RE-35A&B); and U1 & U2 Post Accident Sampling System (PASS) airbome
particulate (RE-67).
b. Observations and Findinas
During the week of August 12,1996, the inspectors identified several examples of
poor housekeeping practices associated with the RMS equipment skids or sample
pump cabinets. The examples included several instances of tools, equipment and
supplies, e.g. wrenches, flashlights and leak detection fluid, found unsecured within
cabinets housing RMS sample pumps. In addition, excess filter papers and charcoal
cartridges were found within the RMS cabinets or adjacent to sample collectors. In
response to the identified poor housekeeping practices, the licensee initiated incident
Report (IR) 1-96-211 and completed corrective actions prior to the end of the
inspection. No similar concerns for the RMS equipment were identified during the
week of August 26,1996.
No concems were identified for comparisons of data supplied at local and remote
RMS readouts. Vendor documentation was reviewed which verified the accuracy of
the SGBD flow devices for monitoring effluent media at elevated temperatures. In
addition, the inspectors noted that the sample flow rate of 10 standard cubic feet per
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minute (SCFM) for selected tape drive monitors, e.g., RE-10, exceeded the original
vendor specification of 8.5 scfm. Vendor documents were provided which indicated
the issue was evaluted and allowed use of the higher flow rate.
However, the following issues regarding the currently installed RMS sample lines to
meet 10 CFR Part 50, Appendix B, Criterion V, and the intent of ANSI N13.1
recommendations were identified.
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The sample line supplying the U1 PASS containment atmosphere
particulate monitor (RE-67) was noted to have 90 degree elbows
installed. The inspectors noted that Production Change Notice (PCN)
< No. B-79-553, Note 4, specified that no elbows were to be used
l between sample inlet nozzle and filter cartridge and tubing was to have
- a minimum bend radius of five nominal pipe diameters. Review of the
Bill of Materials for the Work Order (WO) 10093 used to install the U1
RE-67 sample line indicated no elbows were included in the parts list.
The licensee was unable to determine when the cLrrent sample line
configuration was installed. Licensee stated that the installed
equipment would be changed to meet the documented design
requirements.
- Instrument Installation Drawing B-175976 Rev. 2, dated December 8,
1983, incorrectly labeled the inlet and exhaust lines associated with the
MCR air supply monitor (RE-358). A change to the subject drawing
was submitted prior to the end of the onsite inspection.
- The supply sample line for the U1 stack airbome particulate detector
(RE-29A) was noted to have 90 degree elbows installed. Review of
configuration control drawings Q-2-D11-RE-29E, B-85-2-3074 for the
process RMS did not provide specific details regarding use of elbows
on the sample line supplying the particulate sampler and only specified
that tubing bends be greater than five times the nominal pipe diameter.
The inspectors noted that similar 90 degree elbows were not used for
the RE-29A sample line installed on the U2 stack. Licensee
representatives stated that the installed piping would be changed to
meet the intent of ANSI N13.1,1969.
On August 29,1996, the inspectors verified that the appropriate changes to the '
installed inlet sample lines for the U1 RE-67 and the U1 RE-29A sample systems
were completed. ]
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c. Conclusions
Numerous examples of poor housekeeping practices were identified for RMS
equipment. The installed sample lines supplying the U1 RE-67 and U1 RE-29A
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airborne particulate monitors did not meet the intent of ANSI N13.1-1969. Further, the
inlet sample lines for the RE-67 monitor were not installed in accordance with the
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applicable PCN. This was identified as violation (VIO) 50-348,-364/96-10-01: Failure
to construct and maintain the "as built" U1 PASS containment airborne particulate
detector (RE-67) sample line in accordance with approved configuration control
procedures and drawings.
R1.2 Radiation Monitor System Calibrations
a. Inspection Scope (84750)
Approved guidance and resultant data for selected RMS detector calibrations were
reviewed and discussed. For each detector reviewed, source and electronic
calibration surveillance test procedure (STP) packages for the previous two
surveillances conducted prior to the onsite inspection were reviewed, evaluated and
discussed with licensee representatives. The following RMS detectors and associated
electronics were included in the review: U1 Containment High Range Monitors
(CHRMs) (RE-27A&B), U2 Fuel Storage Pool area (RE-5); U1 Containment
Atmosphere particulate (RE-11) and gas (RE-12); U2 Plant Vent gas (RE-298); and
U2 Turbine Building Ventilation exhaust (RE-15).
Calibration activities were evaluated against applicable sections of the FSAR, and
Technical Specification (TS) and ODCM requirements. In addition, calibration
activities to meet a March 14,1983 Order to implement and maintain licensing
commitments associated with Three Mile Island (TMI) Action item II.F.1 for the
CHRMs were reviewed.
b. Observations and Findinas
Excluding the CHRMS, no concerns or issues were identified for the RMS detector
calibrations reviewed. No significant data trends were observed and all calibrations
were conducted at the required frequencies.
From review of CHRMs loop calibration data completed in accordance with Farley
Nuclear Plant (FNP)-1-STP-227.18A, Revs. 4 and 5, the inspectors noted that in situ
calibrations were not conducted by electronic signal substitution for all range decades
above 10 Roentgens per hour (R/hr). Specifically, the applicable STP conducted the
in situ electronic signal calibration only for a value of approximately 10 E+3 R/hr at six
different switch positions of the CHRMs readout module and not for each range
decade from 10 R/hr through 10 E+7 R/hr. The inspectors noted that a
September 22,1980 licensee response to a September 10,1980 NRC request for
additional TMI-2 Action Plan information provided descriptions of the containment high
range monitors including special calibration. Regarding special monitor calibration,
the licensee's response documented, in part, that "in place calibration by electronic
signal substitution is provided for all range decades above 10 Roentgens per hour
(R/hr)." A subsequent January 14,1931 licensee response regarding the CHRMs
calibration documented that " calibration above 10 R/hr will be completed by utilizing
an electronic signal." Licensee representatives noted that susequent to establishment
of their calibration program, a 1983 vendor field procedure which used an electronic
signal substitution calibration for each decade from 10 through 10E+7 R/hr for the
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- CHRMs was developed. However, the procedure was not received from the vendor
- and thus, was not incorporated into the licensee's current procedure. The inspectors
, noted that the initial vendor guidance and supplemental source calibrations verified
l general monitor operability but that the in situ electronic calibration was necessary to
j demonstrate proper response at the maximum exposure rate values required to be
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monitored by TMI Action item II.F.1.
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c. Conclusions
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! In general, RMS detector calibrations were technically adequate and conducted at
j specified frequencies to meet established requirements. The failure to conduct in situ
CHRMs special calibrations by electronic signal for each range decade up to
. 10 E+7 R/hr as committed to the NRC was identified as violation (VIO) 50-348,-
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364/96-10-02: Failure to implement licensing commitments to meet TMI Action item
II.F.l-3 specifications in accordance with an Order issued March 14,1983.
! R1.3 Liquid Radwaste Analysis, Processing, and Release
4 a. Inspection Scope (84750)
i During the onsite inspection, radioactive waste (Radwaste) processing activities were
reviewed. Evaluated program areas included equipment operability, procedural
- adequacy and staff proficiency.
! On August 27,1996, the inspectors directly obsented and evaluated a U1, No. 2
l Waste Monitor Tank (WMT-2) liquid effluent processing activities. The review
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included pre-release sample collection and radiological analyses, determination of the
i U1 liquid effluent radiation monitor (RE-18) setpoints, and operations associated with
subsequent release to the environment.
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The following procedures were reviewed and evaluated during observation of the
. WMT processing and release:
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System Operating Procedure (SOP) FNP-1-SOP 50.1, Liquid Waste
j Processing System Liquid Waste Release from Waste Monitor Tank,
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Revision (Rev.) 37
l . Chemistry-Radiochemistry Control Procedure (CCP) FNP-0-CCP 208,
{ Chemistry Group Forms, Rev. 48
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- . FNP-CCP 212, Liquid Waste Release Program, Rev.15
- FNP-1-CCP-212 Detailed Guidance for Unit 1 Waste Monitor Tank
. Release, Rev. 3
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Personnel observed and interviewed regarding the liquid radwaste processing and
l release evolutions included MCR Operators, System Operators (sos) and chemistry
staff.
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b. Observations and Findinas
No significant issues were identified during review of U1 WMT-2 pre-release r.ampling
and radionuclide analyses. However, several minor procedural deficiencies and
operational weaknesses as discussed below were observed for monitor setpoint
determinations, procedural compliance, and equipment operability.
From observations of the U1 RE-18 liquid effluent monitor background count rate
immediately preceding the U1 WMT-2 release, the inspectors noted that the monitor
background count rate,2000 counts per minute (cpm), was less than the count rate,
4000 cpm, documented in the August 27,1996 release permit No. 960838.012.390.L.
From review of procedures and discussions with the Chemistry and Operations staff,
the inspectors determined that, in general, the documented background count rate
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was obtained subsequent to flushing the U1 RE-18 monitor sample line during the
l previous release. The inspectors determined that the current procedures would not
assure that the background count rate used was adequate to establish an accurate
i monitor setpoint prior to each release. Review of release permit data for effluent
l releases conducted between August 14-20,1996, indicated that the chemistry staff
j identified significant changes in RE-18 monitor background count rates and selected
the most appropriate values to establish the monitor setpoints. Licensee
representatives immediately addressed the noted concem and initiated Temporary
Change Notices (TCNs) to FNP-1-CCP-212 and FNP-2-CCP-212, which required use
of current U1 and U2 RE-18 monitor background count rates to establish release
setpoints.
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l A concem also was identified for a SO's understand:ng of procedural compliance.
l The SO initially involved with the U1 WMT-2 release, informed the inspectors that he
may not adhere strictly to FNP-1-SOP-50.1, 9 4.3.1 which required verification of
- discharge valve positions as locked, if he observed the valves in the correct position
l previously in the shift. The inspectors noted that the SO could vi ensure that the
valves remained locked, if for example, other valve operations , a maintesnce
i occurred between the time the valves were observed initially and when keys were
l secured by the SO. The inspectors noted that strict compliance with the procedure !
was expected. From review of records associated with U1 and U2 WMT releases j
conducted between August 11 through 21,1996, the inspectors did not identify any l
l specific examples of non-compliance by licensee staff. On August 29,1996, i
l Operations Management issued a night order reinforcing expectations for strict j
procedural compliance to all staff. l
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A concem regarding determination of the MCR RE-18 chart recorder operability was
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identified. From review of selected liquid release MCR RE-18 MCR chart recorder
data, the inspectors identified several instances, e.g. three U2 WMT releases
conducted on August 12,1996, where the recorder was declared and signed-off as "in j
operation" but visible chart recorder responses to performance of source checks per ,
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SOP 50.1, Appendix 2, g 2.5.5.1 were not observed. Although MCR operators stated
l that performance of source checks for the RE-18 chart recorder did not always result
l in a visible chart recorder trace, demonstration of the RE-18 source checks on 1
( August 29,1996, resulted in noticeable upscale deflections and noticeable marks on I
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i both U1 and U2 RE-18 chart recorder papers. From subsequent discussions with
l MCR operators and review of SOP 50.1, the inspectors identified inconsistencies
among MCR operators in defining when the chart recorder was "in operation."
Although not used for e' fluent release activities, the inspectors noted that the RE-18
chart recorders could be used to verify and/or re-evaluate liquid effluent data.
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Licensee representatives issued TCNs to FNP-1-SOP 50.1 and FNP-1-SOP 50.1 to
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verify that the RE-18 recorders were in operation by direct observation of an upscale
deflection by the RE-18 recorder chart when source checked.
c. Conclusions
Procedural and operation weaknesses for liquid effluent release activities were
identified. The weaknesses included lack of assurance to establish accurate
setpoints, a SO's misinterpretation of procedural compliance, and inconsistencies in
identifying out of service MCR RE-18 chart recorders by MCR operators.
R1.4 Radiological Controls .
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a. Inspection Scope (84760. 86750)
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Radiation protection program activities for routine U1 and U2 operations and radwaste I
and material storage activities were reviewed against TS and 10 CFR Part 20
requirements. In particular, the inspectors reviewed and evaluated the adequacy of
general housekeeping, personal dosimetry use, and radioactive material or radioactive i
waste labels, and verified implementation of physical controls for locked high radiation l
and very high radiation areas.
The inspectors made frequent tours of the licensee's protected areas, radiologically
controlled areas (RCAs), and reviewed and discussed procedural guidance and
selected survey results with selected Health Physics staff.
In addition, radiation control performance indicators regarding radioactive effluents,
solid radioactive waste storage and shipments were reviewed.
b. Observations and Findinas
Housekeeping practices within the resin dewatering facility and the Low-Level
Radioactive Waste (LLRW) storage warehouse were considered acceptable.
However, the inspectors noted several housekeeping weakness within the U1 and U2
Auxiliary Buildings. In particular, the inspectors noted trash and swipes strewn on the
floor of the radwaste drumming room. In addition, numerous gloves and paper were
observed on the floors of the Auxiliary building. Also, a pair of tattered disposable
plastic gloves were observed covering the U1 Containment Personnel Air Lock
penetrations. All identified housekeeping issues were addressed in a timely manner
by the licensee.
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The inspectors verified that physical controls for locked high radiation areas and for
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established locked very high radiation areas met TS and 10 CFR Part 20
requirements.
The licensee continued to maintain low inventories of radioactive waste onsite. In i
1994 approximately 62 radwaste or material shipments containing 500.1 curies were '
shipped to vendors for processing or to a burial facility. in 1995 approximatley 61
shipments containing 10.18 Cl of radioactive waste were snipped from the site. The
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licensee estimated the following waste quantities were on site:
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- Five 55 gallon drums containing Dry Active Waste (DAW) - 37.5 cubic
feet (ft )
- Metal Scrap - 91.6 ft' l
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Two SeaVan Containers of DAW - 2080 ft
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Four 60 gallon Overpacks of Spent Mechanical Filters 40.8 ft'
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Resins (currently in use or Ewaiting shipment) - 320 ft
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Resin Charcoal Mix 134 ft'
- Oil - 165 gallons ;
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In addition, the inspectors noted and discussed selected radwaste reduction efforts
implemented including improved communications to emphasize minimization of waste
produced, labeling of floor drains, operational activities to segregate waste streams
and enhance processing media efficiency, use of pressurized demineralizer systems l
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to reduce resin volumes and increased use of reusable items.
Concems were identified for labeling of stored Radwaste. The inspectors noted that
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10 CFR 20.1904(a) requires, in part, that each container of licensed material bear a
. durable, clearly visible label bearing the radiation symbol and the words " CAUTION,
RADIOACTIVE MATERIAL" or " DANGER, RADIOACTIVE MATERIAL." The label
i must provide sufficient information (such as nuclides present, estimates of quantities
j of radioactivities, radiation levels, kinds of materials) to permit individuals handling or
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using the containers, or working in the vicinity of the containers, to take precautions to
avoid or minimize exposure. On August 26,1996, the inspectors identified and
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discussed with licensee representatives the following concems regarding labeling of
radioactive material within the LLRW building, Dry Active Waste (DAW) storage area
! and for two SurPak casks containing contaminated resins. The casks were located
i outside of established RCAs.
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During tours of the LLRW storage facility, the inspectors noted that
- several containers with " Radioactive Material" labels affixed were used
to store materials identified as clean. For example, box 96-19 had a
Radioactive Materials label affixed but the contents were
identified as "new coveralls." Licensee representatives did not resolve
j the radiological status of the coveralls and box prior to the end of the
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onsite inspection.
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Several Low Specific Activity (LSA) containers storing contaminated
DAW located adjacent to the torting facilities initially appeared to not be
labeled. However, further review indicated that the containers were
labeled but as a result of restaging and restacking the LSA boxes, the
side of the boxes with the affixed label was moved out of the immediate
j line of sight. Licensee representatives corrected the identified issue
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l pnor to the end of the onsite inspection.
During tours of the facilities outside protected areas, the inspectors ,
noted approximately six SurPac casks staged along the east wall of
Auxiliary building. A durable, clearly visible label bearing the radiation ;
symbol and the words " CAUTION, RADIOACTIVE MATERIAL" was ;
affixed to each and each label was marked with a "NA" in the upper
left-hand corner. No information such as radiation levels nor kinds of
materials present were listed. Upon questioning, a licensee
representative stated that two of the casks contained contaminated ;
resins. During subsequent discussions with licensee management, the i
inspectors were informed that for the two casks containing radioactive l
materials, documentation of liner numbers and "No radiation levels l
above background" were indicated elsewhere on the sides of the casks !
and that the top of each was posted using radiation rope, and a trifoil i
posting identifying a " Radiological Restricted Area." The inspectors
subsequently toured the area and noted that the liner numbers and
radiation levels were not on the label, nor obvious. Also, the similarity
between labels on the empty and filled casks was identified as a poor
radiation protection practice. The inspectors noted that containers of
radioactive material exceeding the quantities listed in Appendices B and
C to gg 20.1001-20.2401, and which did not meet the exemptions
specified in 10 CFR 20.1905, were required to be labeled appropriately
to identify the hazards present.
The inspectors reviewed previous history regarding labeling issues at the licensee
facility. The review identified three previous NRC Inspection Reports (irs) 50-348,-
364/92-01, IR 50-348,-364/93-16 and 50-348,-364/94-11 which documented violations
associated with labeling of containers.
Concems also were identified for personal dosimetry use. Licensee procedure FNP- j
O-M-001, Health Physics Manual, Rev.12, effective July 14,1996, Section (@) 5.4 ;
requires dosimetry devices to be worn on the front of the body between the neck and ;
waist inclusive with the Thermoluminescent Dosimeter (TLD) and Digital Alarming )
Dosimeter (DAD) to be worn near each other. During the week of August 26,1996,
the following examples of improper personal dosimetry use were identified to licensee ,
Health Physics staff. ;
- Three maintenance workers within the LLRW storage area not wearing 3
their TLD and DAD on the front of the body. l
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A chemistry counting room technician was observed with the TLD and I
DAD on opposite sides of the body and below the waist. ;
An operator conducting liquid waste release tasks was observed with i
his personal dosimetry placed in the pants pocket. ;
A subsequent licensee survey of personal dosimetry identified 14 of 50 individuals,
i.e.,28 percent, wearing personal dosimetry improperly. The licensee issued incident !
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Report No. 1-96-235, and initiated immediate evaluation of training guidance and ;
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stationed HP staff at facility RCA entrances to assure proper use of personal 1
dosimetry. Licensee actions were continuing at the end of the onsite inspection.
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c. Conclusions
Low volumes of radwaste were maintained onsite. Weaknesses and violations were l
identified for licensee programs including inadequate labeling for containers of I
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radioactive material and improper personal dosimetry use. These issues were
identified as VIO 50-348,-364/96-10-03): Failure to label casks containing
contaminated resins in accordance with 10 CFR 201904(a) requirements; and VIO
50-348,-364/96-10-04: Failure to follow procedures in accordance with TS 6.11 for
use of personal dosimetry. In particular, the identification of current and three
previous NRC-identified violations associated with container labeling indicated a
continuing program weakness requiring heightened management attention.
R7 Quality Assurance in Radiation Protection and Chemistry Activities
R7.1 Radioloaical Measurement Quality Control
a. Inspection Scope (84750. 86750)
The inspectors reviewed implementation of the counting room quality control (QC)
activities to meet the intent of Regulatory Guide (RG) 4.15 as specified by TS 6.8.1(i).
Specifically, the adequacy of guidance for liquid waste effluent composite sample
preservation and for implementation of cross-check counting room radiological
analyses were reviewed and discussed in detail. In addition, results of program
implementation was reviewed.
The onsite review included the following procedural guidance:
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. FNP-0-CCP-47, Preparation of Composite Effluent Samples, Rev. 7
. FNP-0-CCP-220, Radiochemistry Cross Check Program, Rev. 6, l
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The following quantitative laboratory QC results were reviewed:
. July 1994 through August 1996 cross-check analysis results for tritium
(H-3), strontium (Sr)-89, Sr-90, and iron (Fe)-55
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January 1 through August 26,1996 Daily Gamma Spectroscopy System
Performance Data.
b. Observations and Findinas
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No significant concems nor negative trends were identified from review of the counting
room gamma spectroscopy QC performance data. However, the following issues
regarding liquid effluent composite sample preparation and completion of selected
l cross-check analyses were noted and discussed with cognizant licensee
representatives.
From review and discussion of FNP-0-CCP-47, the inspectors noted a concem
regarding the adequacy of liquid effluent composite sample preservation. The i
composite samples are collected for selected time periods, monthly or quarterly, and
are analyzed subsequently to quantify difficult-to-measure nuclides, i.e., Fe-55, Sr-89
and Sr-90, within the normal liquid effluent streams. However, the procedure did not
require use of standard chemical methods, e.g., acidification or carrier addition, to
maintain the chemical sample stability through time by preventing plate-out of the
radionuclides on the container sides. Further, the licensee had not conducted any
studies to establish the extent of radionuclide plate-out for the containers used to
store the composite samples. The inspectors noted that the current procedure was
inadequate to assure proper sample stability required to assure a representative and
accurate sample analysis for the difficult to measure radionuclides. During the onsite
inspections, licensee representatives issued a TCN to FNP-0-CCP-47 to acidify the i
composite samples to maintain sample chemical integrity by preventing plate-out of
radionuclides. Licensee representatives stated that additional studies to establish the
amount of radionuclide plate-out without using acid would be conducted. The
inspectors noted that these studies would determine the actual affect of the procedure
deficiency on the accuracy of effluent measurements.
From review of cross-check results and procedural guidance, the inspectors noted that
an intra-laboratory cross-check was being implemented using the laboratory's Fe-55 ;
standard but inter-laboratory Fe-55 comparisons had not been conducted since !
September 1992. The licensee stated that analysis of the inter-laboratory Fe-55 cross
check sample was based on receipt of NRC samples. The inspectors informed the
licensee that use of NRC samples to implement part of their cross-check program was
considered inappropriate and a program weakness. Further, the inspectors noted that
the NRC had discontinued supplying cross-check samples on a routine basis. The i
inspectors noted the identified issues as a significant program weakness. In j
response, the licensee initiated changes to their effluent monitoring program analyses, ;
in that the Sr-89, Sr-90 and Fe-55 analyses now would be conducted at a vendor
laboratory, in addition, TCN 6.B was initiated to FNP-0-CCP-220 to eliminate Sr-89,
Sr-90, and Fe-55 analysis from the cross-check program.
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c. Conclusions
Gamn a spectroscopy QC activities were implemented appropriately but a weakness
regarding implementation of the laboratory QC cross-check program for Fe-55
analyses was identified. The procedure for preserving liquid composite samples used
to estimate liquid effluent concentrations was determined to be inadequate. This was
identified as VIO 50-348, -364/96-10-05: Failure to have adequate procedures for
preserving liquid composite samples analyzed for quantification of effluent
radionuclide concentrations.
R7.2 Licensee Self-Assessment Activities (84750. 86750)
a. Inspection Scope (84750. 86750) ,
i
During the inspection period, the following audit reports regarding Health Physics
(HP), Chemistry, and Radwaste processing, packaging and transportation program
activities required by TS 6.5.2.1 were reviewed and discussed with licensee
representatives. ,
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Safety Audit and Engineering Review (SAER) Audit Report No: 95- l
ODCM/1-1, May 15-July 25,1995, dated July 26,1995
l
a SAER Composite Audit Report 93/21, of the On-site environmental
monitoring program and Off-site Dose Calculation Manual, conducted
October 18-27,1993 and dated November 5,1993.
. SAER Audit of the Farley Nuclear Plant (FNP) - Chemistry and
Chem'HP/ Environ /Radwaste STPs,96-CHM /6-1 and 96-STPc/34-1
- SAER Audit of Chemistry, Health Physics, and Environmental Groups
STPs, Report No. 95-STPc/34-1
a SAER Audit of Surveillance Testing - Health Physics and Radioactive
Waste Management, Report No. 95-STPc/34-1
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a SAER Spot Audit of the FNP Response to EPRI PWR Primary to i
Secondary Leak Guidelines, Report No. 95-SAER/21-8, dated October j
20,1995
a SAER Report of Radioactive Waste Management, Report No. 94- l
RWM/31, dated December 13,1994. ;
a SAER Report of Radioactive Waste Management, Report No. 95-
RWM/31-1, dated September 25,1995
In addition, the experience of the individuals conducting reviews in the specific audit
areas was discussed with management.
. . . - - _ _ _ _- _ ._ _ - -_- - - - -- -. . ..
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b. Observations and Findinas i
'
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The audits met TS required frequencies and addressed ODCM, Effluent, HP
Chemistry and Radwaste program areas. The majority of audit issues were
compliance-based although several performance-based findings and comments were
identified. For the eight audit reports reviewed, only three findings and nine
comments were documented. Findings included RCA access control issues, waste j
l processing vendor procedure review and inaccurate organizational structure l
'
documentation. No findings similar to the violations or weaknesses documented in i
this report were identified. i
- From discussions with licensee management, the inspectors determined that all the
4
auditors had previous and extensive experience within at least one of the FNP site
.
HP, Chemistry and Operations program areas. The audits did not involve individuals
from other facilities within the Southern Nuclear Operating Company.
c. Conclusions
2
The audit program met TS required frequencies, although the lack of outside auditors
was considered a program weakness. Based on the current NRC findings and limited !
issues identified by the licensee, the inspectors noted that methods to improve the
effectiveness of audits of HP and effluent program areas should be addressed by site j
management. '
Manaaement Meetinas and Other Areas
X.1 Exit Meeting Summary
The inspectors presented the inspection results to members of the licensee
- management at the conclusion of the inspection on August 30,1996. In addition, the
inspectors discussed the poor practices observed during evaluation of effluent release
activities. The licensee acknowledged the findings presented. Exceptions were taken
for the non-compliances identified for failure to meet CHRMs special calibration
commitments and for inadequate labeling of the casks containing contaminated resins.
,
X.2 Followup Teleconferences
i
On September 11,1996, a followup teleconference between Mr. R. Hill, Plant
Manager, FNP, and Mr. K. P. Barr, Chief Plant Support Branch, Division of Reactor
Safety, NRC Ril was conducted to discuss specific findings. The licensee restated
their position regarding their exceptions to the identified deviation and labeling
i violation.
The inspectors stated the licensee position would be reviewed and evaluated.
i Further, the inspectors noted that proprietary information was reviewed during the
inspection, but that specific proprietary details would not be included in the report.
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PARTIAL LIST OF PERSONS CONTACTED
W. Bayne, Chemistry Superintendent l
S. Fulmer, Technical Manager
M. Mitchell, Health Physics Superintendent
C. Nesbitt, Assistant General Manager, Support i
1. Stinson, Assistant General Manager, Operations l
M. Mitchell, Health Physics Superintendent
G. Waymire, Manager SAER
INSPECTION PROCEDURES
4
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IP 84750: Radioactive Waste Treatment, and Effluent and Environmental
'
Monitoring
IP 86750: Solid Radioactive Waste Management and Transportation of
Radioactive Materials
I
ITEMS OPENED, CLOSED, AND DISCUSSED I
Opened
50-348, 364/96-10-01 VIO Failure to contruct and maintain an "as
built" sample line in accordance with
configuration control procedures and I
drawings (Section R1.1). l
50-348, 364/96-10-02 VIO Failure to follow a March 14,1983 Order l
to implement and maintain commitments
for special calibration of CHRMs
(Section R1.2). J
I
50-348, 364/96-10-03 VIO Failure to label casks of contaminated
resins in accordance with 10 i
CFR 20.1904(a) requirements (Section
R1.4).
50-348, 364/96-10-04 VIO Failure to follow procedures for proper
personal dosimetry use (Section R1.4).
!
50-348, 364/96-10-05 VIO Failure to have adequate procedures for I
liquid effluent composite sample storage
(Section R7.1).
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LIST OF ACRONYMS USED
!
, ANSI American National Standards Institute
l CHRM Containment High Range Monitor
, cpm Counts per minute
! DAW Dry Active Waste !
, DEV Deviation
FNP Farley Nuclear Plant
FSAR Final Safety Analysis Report
A Cubic Feet l
LSA Low Specific Activity
MCR Main Control Room
NCV Non-cited Violation
ODCM Offsite Dose Calculation Manual
PASS Post Accident Sampling System
PCN Production Change Notice (PCN)
QC Quality Control
Radwaste Radioactive Waste
RCA Radiologically Controlled Area
RE Radiation Element
RG Regulatory Guide
R/hr Roentgens per hour
RMS Radiation Monitoring System
SAER Safety Audit and Engineering Review ;
scfm Standard Cubic Feet por Minute
SGBD Steam Generator Blowdown ,
SO System Operator !
'
STP Surveillance Test Procedure
TCN Temporary Change Notice
TMI Three Mile Island
TS Technical Specification
WO Work Order
VIO Violation
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