IR 05000440/1985058

Insp Repts 50-440/85-58 & 50-441/85-21 on 850826-29,0923 & 26.No Violation or Deviation Noted.Major Areas Inspected: Preoperational Radiological Environ Monitoring Program, Including Implementation & Results

ML20138B715
Person / Time
Site:	Perry
Issue date:	10/07/1985
From:	Holtzman R, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138B713	List: IR 05000440/1985058 ML20138B706
References
50-440-85-58, 50-441-85-21, NUDOCS 8510220006
Download: ML20138B715 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-440/85058(ORSS); 50-441/85021(DRSS)

-Docket Nos. 50-440; 50-441 Licenses No. CPPR-148; CPPR-149 Licensee: Cleveland Electric Illuminating Company

~ Post Office Box 5000 Cleveland, Ohio 44101 Facility Name: Perry Nuclear Power Plant, Units 1 and 2

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Inspection At: Perry Site, Lake County, OH Inspection Conducted: August 26-29, 1985 (at the Site)

September 23 and 26, 1985 (by telephone)

/0/7/gs-Inspectors: M. J. Destmann Date R B Holt an 10/ 7 /

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Approved By: M. C. Schumacher, Chief Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on August 26-29,'1985 (Reports No. 50-440/85058(DRSS);

50-441/85021(DRSS))

Areas Inspected: Routine announced inspection of: (1) preoperational radiological environmental monitoring program (REMP) including implementation and results, q'uality assurance, and management controls; (2) chemistry and radiochemistry program including procedures,. organization, staffing qualifi-I cations and training, and quality assurance; and (3)~1icensee actions taken regarding previously identified inspection items. The' inspection involved

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59 inspector-hours onsite by~two NRC inspectors.

l Results: No violations or deviations were identified.

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DETAILS

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1. Persons Contacted '

15. Kensicki, Technical Superintendent, Perry Plant Technical Department (PPTD)

1F. Stead, Manager, Nuclear Engineering Department (NED) ,

1R. Stratman,~ General Supervising Engineer, Radiation Protection Section (PPTD)

IJ. Jaskill, Lead Quality Engineer, Operational Quality Section, l Nuclear Quality Assurance Department (NQAD) i IN. Lehman, Staff Analyst (PPTD)

1E. Riley, General Supervising Engineer, Construction Quality Section (NQAD) .

10. Green, Senior Project Engineer, Systems and Equipment Nuclear Design and Analysis Section (NDAS) (NED)

1G. Dunn, Associate Radiation Protection Analyst (PPTD)

1,20. Reyes, Plant Chemist (PPTD)

1M. Tackacs, Licensing Engineer (NDAS) (NED)

1J. Webb, Associate Environmentalist (NDAS) (NED)

1S. Wojton, Senior Lead Engineer, Environmental and Auxiliary Systems (NDAS) (NED)

G. Barna, Senior Engineer Technician, Quality Audit Unit (NQAD)

R. Zucker, Associate Engineer (NDAS) (NED)  !

2E. Traverso, Chemistry Supervisor, Radiation Protection ;

Section (PPTD)

J. Krylow, Engineering Technician and Site Environmental Monitor (NDAS) (NED)

D. Heck, Skills Training Supervisor, Perry Training Section (PPTD)

D. Goddard, General Coordinator, Skills Training Unit, Perry Training Section (PPTD)

R. Luse, Supervisor, Support Services, Perry Training Section (PPTD) <

C. Shelton, Senior Radiation Protection Technician, Chemistry Unit, Radiation Protection Section (PPTD)

J. Braun, Junior Engineer, Chemistry Unit, Radiation Protection Section (PPTD)

1K. Connaughton, NRC Resident Inspector The inspectors also interviewed several other licensee personnel during the course of the inspection, including Chemistry and Health Physics unit personne Denotes those present at the plant exit interview on August 29, 198 Present during telephone conversation on September 23 and 26, 198 !

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2. Licensee Action on Previous Inspection Fir. dings (Closed) Open Item (50-440/84016-01; 50-441/84015-01): Licensee to find alternate REMP services to analyze environmental samples. The licensee's Nuclear Quality Assurance Department performed an audit (PIA 85-08) of the Applied Science Laboratory (ASL) on March 11-15, 1985 which was designed to evaluate the adequacy and effectiveness of the contractor's QA program and its compliance with NRC Regulatory Guide 4.15, Revision 1. The licensee identified two findings which were closed out on May 29, 1985. The contractor has now been placed on the Perry Plant approved suppliers lis (0 pen) Open Item (50-440/84016-02; 50-441/84015-02): Review of QA/QC results of spiked and split samples provided to chemistry technicians. The licensee had not yet fully implementated procedure RAP-0204, " Chemistry Unit Analytical Quality Control Program", dated May 1, 1984. Chemistry technicians had not yet analyzed spiked or split radiological or nonradiological samples. Chemistry staff, not the technicians, performed the analyses of NRC confirmatory samples and nonradiological samples from Applied Science Laboratories, a licensee contracto This item was discussed at the exit meeting. The licensee committed to have at least six technicians fully qualified and tested and procedure RAP-0204 implemented by the end of September 198 (Closed) Open Item (50-440/85008-01; 50-441/85006-01): Management approval of 13 draft sampling procedures in the REMP. The licensee prepared 16 REMP procedures involving sampling of various environ-m' ental media, maintenance and calibration of air samplers and administrative controls in managing the REMP. The procedures were approved by management and became effective on June 17, 1985. No problems were noted during a review of the 16 procedure (Closed) Open Item (50-440/85008-02; 50-441/85006-02): Licensee to check into backup alpha / beta counting capability. This item was discussed with licensee representatives who stated that the Tennelec Model LB-5100 automatic multisampler gross alpha / beta counter in the Health Physics Unit would serve as backup to the two gas flow propor-tional counters in the Chemistry Unit. The inspectors observed that daily QC checks with accompanying control charts were kept on the Model LB-5100. The licensee estimated that the two manually-operated Nuclear Measurements Corporation proportional counters would be used for less than ten samples per week. The licensee's present equipment is adequate to handle this workload. This item is considered close . Management Controls, Organization, Staffing, Training, and Qualifications Licensee's management controls for implementing the requirements of the REMP were reviewed. No changes in organizational structure and responsibilities of licensee personnel in the Nuclear Design and Analysis Section in the Nuclear Engineering Department in implementing'the REMP

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have occurred since the previous inspection.1 These responsibilities are described in the licensee's procedure REMP 001 " Administrative Description"

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dated June 17, 1985. The licensee's Site Environmental Monitor collects the environmental samples and ships them to Applied Science Laboratory, the licensee's contractor, for analysi ~

No problems were noted during review of management controls of the REM The organization of the Chemistry Unit in the Radiation Protection Section of the Perry Plant Technical Department has changed since the previous inspection. D. Reyes has recently been appointed Plant Chemis Five chemistry staff and 18 technicians report to the Plant Chemist. This staffing of the Chemistry Unit prior to fuel load appears to meet the commitments of the FSA Qualifications of the Chemistry Unit personnel were reviewed. Review of the position description and resume of the Plant Chemist indicates he meets the qualification requirements of ANSI /ANS 3.1-1978. A chemistry supervisor with several years' operating experience at another nuclear plant plus two other technically qualified chemists with B.S. degrees in chemistry and two junior chemists provide technical support to the Plant Chemis Eighteen technicians, most of whom have had experience in the nuclear navy, provide additional support and perform the daily plant sampling and analysis in the laboratory and counting room.' The inspectors determined that six technicians have had three or more years experience at the Perry

! Plant and meet the experience requirements of ANSI /ANS 3.1-197 The inspectors also reviewed the training program for the chemistry technicians which includes on-the-job experience, supervisory observation, and completion of a formal program of lecture and laboratory work. The program is described in the recently issued Departmental Training Proce-d.ure for Chemistry (0M14:TM 7.4, August 30,1985) which replaces the program described in RAP-0201. The procedure describes qualifications,

. training, and certification requirements for three categories of techni-cians: chemistry analyst, chemistry technician, and senior chemistry technician. The licensee has. identified four technicians as qualified for laboratory analyst, ten as chemistry technician, and four as senior chemistry technician. Based on discussion with Training Section

personnel and a review of records, the inspectors concluded that the

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training program is satisfactory.

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Ten technicians have completed the 320-hour formal chemistry training

& program and a 120-hour Technical Systems Upgrade Course. Six technicians hired early in 1985 have also completed the Technical Systems Upgrade

' Course and are in the process of completing the 320-hour chemistry progra The technicians a e concurrently involved in completing on-the-job training qualification cards requiring demonstration of_ proficiency in performance of all required laboratory analyses. Testing of technician competency by having them analyze spiked and split radiological and non-

Inspection Report 50-440/85008; 50-441/85006

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radiological samples in accordance with the QA program (RAP-0204) is to be accomplished prior to fuel load. This matter continues to be tracked under Open Item 50-440/84316-02; 50-441/84015-02. (Section 2b)

No violations or deviations were identifie . Implementation of the Radiological Environmental Monitoring Program (REMP)

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The inspectors discussed the implementation of the REMP with licensee representatives and reviewed monthly reports for 1985 to date to assure requirements in Table 6.1-3 of the licensee'r, Environmental Report -

Operating License Stage (ER-OL) are met. All samples were collected and results documented in the reports. Weekly log sheets accounted for all samples and included explanations for missing samples. No anomalies or unusual trends in the results were noted. The licensee acknowledged the inspectors' comments and agreed to revise the format of the monthly reports to be able to observe trends in results and to make the data easier to review. No problems were observed during a tour of the environmental stations, including air samplers, TLD, milk and several l water compositors at public water supply intakes. Several NRC TLDs were

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also observed. Air samplers had current calibration stickers. The licensee plans to install an additional air sampler near Lockwood Road near the site boundary in the Northeast Sector from the plant locatio The State of Ohio also plans to install an air sampler in the same location in conjunction with the cooperative agreement between the State and the NRC. The licensee also agreed to split a liquid discharge sample with the State as part of the environmental program conducted by the State in the cooperative agreement made with the NR l The inspectors also reviewed the procedures manual and QA manual prepared by the licensee's contractor, Applied Science Laboratory (ASL). Both manuals have been approved by the licensee. The contractor agreed to participate in the EPA cross check program as identified in the Technical Specifications to be issued at the time of FLOL. The licensee also had recently conducted a land census of milk animals. The licensee presently collects milk from three farms and one home where goats are kept. No problems were noted. The licensee is scheduled to perform an annual-audit of ASL in September 1985.

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Review of the overall licensee's REMP indicates that the licensee has

met the REMP program commitments prior to issuance of the FLO No violations or deviations were identifie S'. Chemistry and Radiochemistry The licensee has provided adequate floor, hood, and bench space in the cold and hot laboratories and counting room. Additional office space is being built across the hall from the present chemistry office to alleviate previously noted crowded office space. Additional laboratory space for-oil analyses, presently being done at the licensee's corporate laboratory,

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is also planned. The existing temporary ventilation system in the hot laboratory will be removed and will be replaced with the plant HVAC system prior to fuel, loa Chemistry instrumentation has been calibrated in accordance with Procedure OM1E: RAP-1202, " Control and Calibration of Chemistry Equipment, Services, and Reagents", dated August 31, 1983. One instrument, the Dionex ion chromatograph, was not operational pending its upgrade to permit simultaneous anion and cation analyses. Licensee representatives expect it to be operational by October 1, 1985. The calibration will be reviewed during a subsequent inspection. (0 pen Item 50-440/85058-01; 50-441/85021-01). The inspectors noted that the chemistry instruments were of good quality, but that the number of instruments onsite, such as pH and specific ion meters, appeared to be limited. Licensee representa-tives stated that instruments from the nearby corporate laboratory would be available if neede The licensee appeared to have sufficient nuclear counting equipment to perform the required radiological analyses. This included three Canberra Series 85 gamma spectrometers each with a high purity germanium detector and associated computers. One system is set up in an auxiliary counting room for emergency situations. Other equipment included a liquid scintillation counter, a single channel analyzer with a sodium iodide detector, and two manually operated NMC PCC-11T gas proportional alpha /

beta counters. A Tennelec Model LB-5100 automatic gross alpha / beta counter used by the Health Physics unit has been designated as backup for the manual alpha / beta counters. As noted during a previous inspection2 , the counting equipment had been calibrated.and the licensee achieved all agreements in counting spiked samples provided in the NRC confirmatory measurements progra Significant weaknesses were identified in the area of quality contro The licensee had defined a QA program in Procedure RAP-0204, " Chemistry Unit Analytical Quality Control Program," dated May 1, 1984. As noted in Section 2b, this program has not yet been implemented to test the quality of technicians' analytical performanc Weaknesses were noted in revie.w of QC charts for daily performance checks of the liquid scintillation counter (LSC) and the gamma spectrometer For these instruments, the licensee uses five percent warning limits and ten percent control limits rather than the standard practices of using limits based on standard deviation3. The limits used are too loose to permit early identification and resolution of counter problems. An illustration of this was noted in the QC data for the LSC where there was a noticeable drift from the expected value that warranted investigatio Inspection Report 50-440/85008; 50-441/85006 3 e.g., ASTM, " Standard Practices for the Measurement of Radioactivity,Section II - Radioactivity", pp. 325-364, in 1984 Annual Book of ASTM Standards, Section 11, Water and Environmental Technology, ilol. 11.02 l (Water II)

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However, the drift was within the five percent warning limit and had not been noted by the licensee. Inspector review of QC data for the gamma spectrometer indicated the standard deviation was in the range of one percent, again indicating that five percent is an excessively wide warning limi In a telephone conversation on September 25, 1985, a licensee represen-tative made a commitment to modify procedure RAP-0204 to use standard deviations in conformance with standard practice (0 pen Item 50-440/85058-02; 50-441/85021-02)

The inspectors reviewed the following chemistry instructions which have been approved by the General Supervising Engineer of the Radiation Protection Section:

Procedure N Date Approved Title OM 12A: CHI-11 05/10/85 Chemistry Task and Calibration Tracking Program CHI-17 03/09/85 Conductivity Measurements CHI-20 06/28/85 Dissolved Oxygen, Chemet Kit CHI-28 03/26/85 Iodine-131, 132, 133, 134, 135 j CHI-31 03/26/85 Iron by Atomic Absorption CHI-45 04/15/85 Strontium-89, 90 CHI-73 04/09/85 Dead Time Determination for Counting Equipment OM 128: CHI-2 10/04/85 Radioactive Source / Sample Preparation OM 12C: CHI-41 05/20/85 Radiation Protection Section Computer Digital Equipment Cor PDP 11/44 No problems were identified during the inspector's review of these instruction No violations or deviations were identifie . Exit Interviews The inspectors met with licensee representatives (Section 1) at the conclusion of the inspection on August 29, 1985. The inspectors discussed the scope and findings of the inspection. The licensee acknowledged the need to fully implement the QA/QC program in chemistry and to provide the technicians with spiked and blind samples to verify the accuracy of their measurements and to demonstrate their competence in analytical measure-ments. The licensee agreed to complete this work for six technicians by the end of September 1985. Additional discussions regarding control charts were held with licensee representatives on September 23 and 26, 198 . . .- - . . . - - .

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i ~Thel. inspectors: discussed the likely informational content of the inspection-report with regard to documentation processes reviewed by the inspectors

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F during the inspection. Licensee representatives did not identify any such

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