IR 05000341/1993015
| ML20046B988 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/30/1993 |
| From: | Mccormickbarge, Steven Orth NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20046B986 | List: |
| References | |
| 50-341-93-15, NUDOCS 9308090092 | |
| Download: ML20046B988 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
i Report No. 50-341/93015(DRSS)
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Docket No. 50-341 License No. NPF-43 Licensee: Detroit Edison Company
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6400 North Dixie Highway
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Newport, MI 48166 facility Name:
Fermi Nuclear Power Plant, Unit 2 Inspection At:
Fermi Site, Newport, Michigan Inspection Conducted: July 19-23, 1993
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Inspector:
S. K. Orth Date
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Approved By: O /d /7)
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7/30/9 3 (). W. McCormick-Barber, Kcting Chief Dite '
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Radiological Controls Section 1
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Inspection Summary IrLspfction on July 19-23. 1993 (Report No. 50-341/93015(DRSS))
Areas Inspected:
Routine, announced inspection of:
(1) the chemistry program
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(IP 84750) including, organization, reactor systems water quality control programs, quality assurance / quality control program in the laboratory, post
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accident sampling system, and nonradiological confirmatory measurements; (2)
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the radiological environmental monitoring program (REMP) (IP 84750); and (3)
review of previous inspection findings (IP 84750).
Results:
One non-cited violation was identified concerning post, accident i
sampling system training (Section 5). The licensee demonstrated excellent analytical abilities in the nonradiological confirmatory measurements
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comparisons (Section 4). Laboratory quality control and the administration of
the REMP continued to be well maintained. Reactor water chemistry parameters continue to improve (Section 6).
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i 9308090092 930730
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PDR ADOCK 05000341
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1.
Persons Contacted
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R. McKeon, Plant Manager
R. Stafford, Manager, Nuclear Assurance
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R. Eberhardt, Superintendent, Radiation Protection L. Goodman, Director, Nuclear Quality Assurance
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S. Bartman, General Supervisor, Chemistry
R. Baum, Supervisor, Radiological Engineering i
R. Newkirk, Supervisor, Licensing i
J. Nowloth, Superintendent, Maintenance
R. Henson, Supervisor,-Scheduling R. Matthews, Supervisor, Shift Testing
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J. Tibai, Principal Compliance Engineer
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P. Lovallo, Senior Chemical Engineer l
R. Pospiech, Analytical Engineer i
A. Holmberg, Nuclear Training Specialist
R. Nearboof, Chemical Engineer
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J. Pendergast, Compliance Engineer
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W. Kropp, NRC Senior Resident Inspector
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K. Riemer, NRC Resident Inspector The above personnel were present at the exit meeting on July 23, 1993.
The inspector also interviewed other licensee personnel in the -
course of the inspection.
2.
Licensee Action on Previous Inspection Findinos j
(OPEN) IFl 50-341/92008-01: A spiked liquid sample was to be supplied to the licensee, and the analyzed results were to be reported to the l
Region III office for comparisons. The licensee received the sample l
from the NRC reference laboratory just prior to this inspection.
The
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sample will be analyzed for gross beta activity, strontium 90, and iron 55. The results of these analyses will be followed and compared in j
future inspections.
3.
Manaaement Oraanization (IP 84750)
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The inspector reviewed changes in the licensee's organization and management control structure.
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Since the last inspection, the chemistry department was transferred from i
the operations department to the radiation protection department. A plant-wide reorganization in April 1993 resulted in several additional changes at the chemistry supervisory level. The supervisor of chemistry / environmental was replaced by a former supervisor of the radiation protection staff. The remainder of the departrent was reorganized into three sections, each headed by a senior engineer who reported to the chemistry supervisor.
In comparison to the former
organization, one senior engineering position was eliminated. The
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former senior analytical engineer was reassigned as the senior environmental engineer, and a former training supervisor
(chemistry / radiation protection /GET) returned to the chemistry l
department as the senior analytical engineer.
A chemical engineer was
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promoted to the position of senior chemical engineer.
Finally, two j
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technicians and two engineers were transferred out of the chemistry
group.
j The inspector discussed the extensive changes with the licensee and the j
adequacy of turnover from the former organization.
Although the
qualifications of personnel were good, the turnover appeared marginally
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adequate. The inspector discussed this with the licensee at the exit
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I interview and indicated that these changes may be unsettling to the
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chemistry group. The effect of these changes will be followed in future
chemistry inspections.
No violations or deviations were identified.
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Confirmatory Measurements (IP 84750)
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The inspector submitted chemistry samples to the licensee for analyses
as part of a program to evaluate the licensee laboratory's capabilities to monitor nonradiological chemistry parameters in various plant
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systems.
These samples were prepared, standardized, and verified for
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the NRC by the Analytical Chemistry Division of Oak Ridge National l
Laboratory and were analyzed by the licensee using routine methods and
equipment.
Three dilutions were made for each sample by licensee personnel, as
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necessary to bring the concentrations within the ranges normally f
analyzed by the licensee's laboratory. The results are presented in
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Table I which also contains the agreement criteria.
These criteria are
based on analyses of the standards and on the relative standard deviations (RSD) derived from the 1986 interlaboratory comparisons study
(Table 2.1, NUREG/CR-5422). The acceptance criteria are such that the l
ratio of the licensee's result and the standard value should be within 2 i
standard deviations (SD) of the standard value for agreement and between 2 and 3 SD for a qualified agreement. A qualified agreement may indicate a bias in the assay.
j The licensee determined nine analytes at three concentrations each.
Of
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i the 27 analyses, all of the licensee's values were in agreement.
The
inspector observed good analytical technique demonstrated by licensee personnel performing the analyses.
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The licensee prepared a sample containing one milliliter of the anions i
from analyte A in Table 1 diluted with reactor feed water to a volume of one liter.
This sample was divided into two aliquots to be analyzed by
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the licensee and the NRC reference laboratory for chloride and sulfate.
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i The licensee determined the concentrations of chloride and sulfate at L
20.1 and 19.9 parts per billion (ppb), respectively. The remaining
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aliquot will be analyzed by the NRC reference laboratory, and a
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i comparison of results will be made following that analysis.
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No violations or deviations were identified.
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5.
Trainina and Oualification of Personnel (IP 84750)
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The inspector discussed the chemistry technician training program with the training supervisor and lead chemistry trainer.
Continuing training
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was provided quarterly for the chemistry technicians and consisted of a i
three year cycle of topics and special subject requests-submitted by the i
chemistry organization. Over the three year cycle, all of the initial i
training modules would be reviewed by chemistry management, with
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selected areas incorporated and/or expanded into continuing training.
i Additionally, required topics, e.g. semiannual post accident sampling system (PASS) training and annual radiation worker training, were included in continuing training.
l Technicians were required to attend classroom and on-the-job training-and successfully pass examinations to meet this requirement. A
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technician wh did not obtain a score of 80 percent on the examinations completed a review session and was re-evaluated.
The inspector reviewed the licensee's training records and training r
reports, which indicated that all technicians were current in their post
accident sampling system (PASS) training. However, audits (93-0101 and-l 93-0060) performed by the licensee in January and February 1993, respectively, reported various deficiencies in PASS training.
On January 15, 1993, four chemistry technicians were identified by the
auditor as out of qualification.
Subsequently, training was performed in February 1993; discussions were held with the technicians stressing
their accountability for training requirements; and the tracking of PASS
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training was entered into a formal plant tracking system.
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Chemistry audit 93-0060 identified weaknesses in the proficiency of
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chemistry technicians performing a PASS drill and deficiencies in the
PASS sampling and analyses procedures. A task force assigned to review
the finding determined that training for a procedure revision in 1992, I
which divided the one PASS procedure into seven sub-procedures, was inadequate.
The required reading did not fully ensure the capability of
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the technicians to utilize the procedures in obtaining PASS samples.
Following the review of the deficiency, the seven PASS procedures were
consolidated into three procedures and extensive classroom and on the job training was completed in the second quarter of 1993.
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Failure to maintain PASS training qualifications is a violation of
Technical Specification (TS) 6.8 5 which requires the licensee to have a l
program, including training, procedures, and maintenance, to ensure the i
capability to obtain and analyze a PASS sample.
Since the violation would have been categorized as a Severity Level IV, the licensee identified the violation, and the licensee's corrective actions appear to be adequate, the violation meets the non-citing requirements of Section VII.B.2 of 10 CFR 2, Appendix C.
One non-cited violation was identified.
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Water Chemistry Control Proaram (IP 84750)
The inspector reviewed the licensee's water chemistry control program.
Administrative limits on water quality were defined in procedure NPP-
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l CH1-01, " Administrative Control of Chemistry Specifications", Revision 2, September 11, 1992, and the licensee's Chemistry Specifications which met, and sometimes exceeded, the Electric Power Research Institute (EPRI) BWR Owners Group Guidelines. The inspector reviewed selected'
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trends in water quality over the period of January 1992 through July l
1993 and found chemistry parameters to be well maintained.
Reactor water chemistry parameters appeared to improve over the review period.
Reactor water conductivity decreased from approximately 0.130 to 0.087 micro-Siemen/cm (uS/cm) with an EPRI achievable limit of 0.20
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uS/cm.
Reactor water chloride and sulfate levels have also decreased from early 1992 to less than the lower limit of detection (1 ' ppb) and 2
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ppb, respectively, with EPRI achievable values of 15 ppb for both.
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Feedwater chemistry parameters were generally maintained below the EPRI achievable values.
The level of silica in the reactor water was at or above the EPRI achievable limit of 100 ppb.
Silica is a diagnostic parameter indicative of demineralizer effectiveness.
The inspector discussed the silica concentration with a licensee representative who indicated that
the levels resulted from extending the average run times of the l
condensate demineralizers to 30 days.
Based on the above water chemistry, the extended demineralizer did not appear to have adversely
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affected water chemistry.
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The inspector reviewed the licensee's documentation of the February 9, 1992, chemistry excursion resulting from a condenser tube rupture, l
initially documented in Inspection Report No. 50-341/93004(DRP).
At 1749 hours0.0202 days <br />0.486 hours <br />0.00289 weeks <br />6.654945e-4 months <br /> on February 9, 1993, high conductivity alarms initiated in the control room (CR). An investigation by the CR and chemistry staff determined that a tube leak had occurred in the southeast quadrant of the main condenser.
The CR staff reduced power and began draining the east end of the condenser to isolate and correct the leak, but failures I
of the condenser waterbox pump down system inhibited the condenser drainage. Chemistry continued sampling and trending the water parameters, and at about 0330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br /> on February 10, 1993, the chloride
concentration (286 ppb) had exceeded the licensee's action level 3
concentration (200 ppb).
Subsequently, at 0406 hours0.0047 days <br />0.113 hours <br />6.712963e-4 weeks <br />1.54483e-4 months <br />, a reactor shutdown was properly commenced. A review of the chemistry parameters for the above time period indicated that all required action level statements were followed and that reactor fuel warranty specifications were not exceeded.
The inspector reviewed the boron concentration data for the standby liquid control tank and verified that concentrations and volumes were within the limits of TS.
No violations or deviations were identified.
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Implementation of the Laboratorv Guality Assurance /Ouality Control (0A/0C) Proaram (IP 84750)
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Chemistry quality control was very good.
The inspector reviewed the
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chemistry quality control program as defined in NPP-CH1-02, " Chemistry i
Quality Verification and Quality Control of Chemistry Equipment",
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Revision 4, June 15, 1993. The licensee continued to maintain statistically based control charts for the laboratory instruments and to
participate in both an interlaboratory and intralaboratory cross-check
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programs.
The inspector reviewed selected control charts for the laboratory
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instrumentation. Control charts appeared to be well maintained and to show normal distribution. The inspector noted that when new control charts were placed into the instrument binders the former control charts were removed. The inspector discussed with the licensee the need to i
maintain the old control charts until the new ones had a. sufficient amount of data to identify performance trends. The licensee acknowledged the observation and placed copies of the old control charts
with the new ones for reference.
The licensee calibrated the laboratory instruments at fixed frequency or after maintenance and when the instrument was found to be out of control. Calibration standards were independent of performance standards.
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The licensee's results in the interlaboratory cross-check program were very good. However, the inspector noted that the interlaboratory program unknowns were analyzed exclusively by the analytical engineer and not by chemistry technicians.
Procedure NPP-CH1-02 did not clearly state who was assigned the responsibility for these analyses.
The licensee agreed to review procedure NPP-CH1-02 and make the necessary revisions to ensure that the analytical responsibilities were accurately
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stated. This revision will be reviewed in future inspections (IFI 341/93015-01).
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No violations or deviations were i4ntified; however, one inspection
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followup item was identified.
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8.
Post Accident Samplina System (PASS) (IP 84750)
The inspector toured the licensee's PASS system and discussed the maintenance of the system with a licensee representative. Weaknesses in
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the operability and maintenance of the PASS system were identified by the licensee in audit 93-0106, including the lack of readiness of the emergency operations facility laboratory and a small leak in the PASS small volume sampler.
A licensee representative indicated that neither of the above concerns rendered the system inoperable nor affected sample representativeness. Repairs were completed in a timely manner following the audit findings.
Licensee management's attention to tne PASS increased as a result of the audit findings.
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The inspector reviewed comparisons between the PASS analyses and normal plant sample point analyses. Semiannual comparisons of conductivity and isotopic analyses indicated that PASS samples were representative of reactor coolant.
No violations or deviations were identified.
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9.
Radioloaical Environmental Monitorina Proaram (HEMP) (IP 84750)
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The inspector toured several air and water sampling stations and
examined the REMP, including the revised 1990 annual report and the current 1991 and 1992 annual reports. The REMP was implemented in e
accordance with the TS requirements, and in several instances, sampling exceeded the TS requirements.
Samples which were not obtained were documented in the report as required. The review of the annual reports did not indicate any radiological release to the environment in excess of TS reporting limits.
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The inspector observed the licensee's sample collector performing i
routine air filter replacements. The collector was familiar with the
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sample stations and competent in the replacement procedures. The air sample stations were all operable and within the calibration dates affixed to the samplers. The collector properly verified the absence of inleakage into the sampling train after installing each replacement air
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filter head.
The licensee has had historical difficulties in maintaining the
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operability of the environmental water sampling equipment.
A weekly sampling equipment check was implemented to improve the performance of
these samplers.
If the performance checks indicated a sampling problem,
a grab sample was taken. However, the inspector questioned the adequacy of taking that sample from the composite sample container instead of directly from the water supply. A grab sample from the comoosite container would not be representative of the missed sample. The
licensee acknowledged the inspector's concerns and revised the REMP sampling procedure to require a grab sample from the sample point of entry. While observing the weekly checks, the inspector noted problems in the performance of water sampling pumps. At the Fermi 1 water i
treatment plant, a valve was closed upstream of the sampling pump j
preventing sample collection.
The chemistry supervisor indicated that i
chemistry procedures did not prohibit manipulation of that valve and
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that the valve would have been opened when the treatment plant was running.
Subsequently, the valve was opened and tagged to ensure it would not be closed. At another station, the inlet line appeared to i
have an obstruction, which was cleared by the sample collector.
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Overall, the water samplers have improved since 1990 but still warrant attention.
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No violations or deviations were identified.
10.
Audits and Appraisals (IP 84750)
The inspector reviewed chemistry audits 92-0060 and 93-0106 conducted in February of 1992 and 1993, respectively.
In addition, the 1991, 1992, and 1993 environmental monitoring audits (91-0157, 92-0105, and 93-0113)
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were reviewed.
The audits appeared to be technically sound and l
performed in very good depth. The chemistry audits, in particular, appeared to be performance based. Corrective actions were generally timely and effective, especially concerning REMP activities.
However, the inspector noted that chemistry findings in both 1992 and 1993 identified procedural usage concerns. The chemistry supervisor acknowledged the inspectors concern and indicated that several steps
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were being initiated to resolve the problems, including a revision to
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chemistry operating standard 116, " Chemistry Laboratory Procedure Use l
Guidelines", and discussions with the technicians regarding the use of
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procedures.
No violations or deviations were identified.
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Exit Interview The scope and findings of the inspection were reviewed with licensee
representatives (Section 1) at the conclusion of the inspection on July 23,1993.
Licensee representatives did not identify any documents or processes reviewed by the inspector as proprietary. The following matters were specifically discussed by the inspector:
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the excellent results of the nonradiological confirmatory
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measurements comparisons, (Section 4);
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the 1992 and 1993 audits findings concerning procedural use and
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adherence (Sections 10);
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maintenance and training of the PASS system, specifically the
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inadequacies identified by the licensee in 1992 and 1993 chemistry audits (Sections 5 and 8); and
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the REMP program (Section 9).
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Attachment:
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Table 1, Nonradiological Interlaboratory
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Test Results, July 19-23, 1993
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TABLE 1 Nonradiological Confirmatory Measurements Results
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Fermi 2 Nuclear Power Plant July 19-23, 1993 i
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Analyte Method Conc Ratio Acceptance Ranges Result 2RSD 3RSD D2h l
Chloride A
0.994 0.933-1.067 0.900-1.100 A
B
1.033 0.919-1.081 0.887-1.113 A
C
0.988 0.926-1.074 0.895-1.105 A
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Sulfate A
0.994 0.895-1.105 0.842-1.158 A
B
1.038 0.895-1.105 0.868-1.132 A
C
1.031 0.900-1.100 0.867-1.133 A
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Sodium J
0.987 0.863-1.137 0.784-1.216 A
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K
1.088 0.859-1.141 0.788-1.212 A
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1.052 0.862-1.138 0.789-1.211 A
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Silica S
Spec
0.960 0.906-1.094 0.859-1.141 A
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T
0.917 0.906-1.094 0.859-1.141 A
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U 175 0.996 0.909-1.091 0.860-1.136 A
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RRul Iron G
ICP 1.5 0.980 0.904-1.096 0.854-1.146 A
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H
0.980 0.903-1.097 0.857-1.143 A
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0.976 0.903-1.097 0.855-1.145 A
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Copper G
ICP 1.5 0.935 0.904-1.095 0.859-1.141 A
H
0.938 0.904-1.096 0.857-1.143 A
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0.940 0.904-1.096 0.857-1.143 A
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Nickel G
ICP 1.5 0.945 0.936-1.064 0.906-1.094 A
i H
0.948 0.938-1.062 0.908-1.092 A
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0.948 0.938-1.062 0.907-1.093 A
i Chromium G
ICP 1.5 0.960 0.905-1.095 0.855-1.145 A
H
0.950 0.903-1.097 0.854-1.146 A
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0.954 0.903-1.097 0.853-1.147 A
Boron D
Titr
1.010 0.979-1.021 0.968-1.032 A
l E
1.010 0.979-1.021 0.968-1.032 A
F
1.016 0.979-1.021 0.968-1.032 A
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Methods: Titr - Titration
- Ion Chromatography l
- Inductively Coupled Plasma
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Conc:
Approximate concentration analyzed.
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Ratio of Licensee mean value to NRC mean value.
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The standard deviation (SD) in the sixth and seventh columns represents the
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coefficient of variation obtained from averaging licensee data from the preceding cycle (Table 2.1 of NUREG/CR-5244). A result is considered to be in agreement if it
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falls within the 2 SD range; a qualified agreement if it lies outside 2 SD, but within 3 SD; and in disagreement if it is outside the 3 SD range.
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Result:
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A = Agreement: Licensee value is within 2 SDs of the NRC mean value.
A+ = Qualified agreement, licensee is between 2 and 3 SDs of i
the NRC value.
D = Disagreement: licensee value is outside i 3 SDs.
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