IR 05000440/1985070
| ML20205F924 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/05/1985 |
| From: | Holtzman R, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205F896 | List: |
| References | |
| 50-440-85-70, NUDOCS 8511130065 | |
| Download: ML20205F924 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
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Report No. 50-440/85070(DRSS)
-Docket No. 50-440 License No. CPPR-148 Licensee:
Cleveland Electric Illuminating Company Post Office Box 5000 C1eveland, Ohio 44101 Facility Name:
Perry Nuclear Power Plant, Unit 1 Inspection At:
Perry Site, Lake County, Ohio
. Inspection Conducted:
October 15-18, 1985 (at the Site)
October 23 and 24, 1985 (by telephone)
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H/f/ff-Inspectors:
M.
.'Oestmann Date R B oltzm.n kY/
D6te" 0.
a w ks f!8f
Approved By:
M. C. S6humacher, Ch' f
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Radiological Effluent and Date Chemistry Section Inspection Summary Inspection on October 15-18, 23 and 24, 1985 (Report No. 50-440/85070(DRSS))
Areas Inspected:
Routine announced inspection of:
(1) chemistry and radiochemistry program including proced_ures, organization, training, and quality assurance; (2) water chemistry control, including sampling and analyses of water quality, facilities and equipment, and chemical processes and practices for controlling chemical impurities, and chemicals; and
- (3) review of licensee actions on previous inspection findings.
The inspection involved 50 inspector-hours onsite by two NRC inspectors.
Results:
No violations or deviations were identified.
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8511130065 851106 PDR ADOCK 05000440
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. DETAILS
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Persons Contacted
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1J.cWaldron, Manager, Perry Plant Technical Department--(PPTD), Cleveland
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Electric : Illuminating Company (CEI)
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1S;:Kensicki, Technical Superintendent,-PPTD, CEI
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'1C.LShuster, Manager, Nuclear _ Quality Assurance Department-(NQAD), CEI
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1T.'Swansiger,RSupervisor, Operational Quality Section, NQAD, CEI
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.;4 1R.LNeuendorf,J0perations Audit. Coordinator, NQAD, CEI
~1T.~ Boss ~ Supervisor, Quality Audit, NQAD, CEI
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2N._Lehman, Staff Analyst,-PPTD, CEI~
2F.: Sondgeroth, Senior Engineer, Nuclear Engineering Department (NED), CEI
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. 1B. Liddell, Operations Engineer, PPTD, CEI l10. Reyes, Plant Chemist, PPTD, CEI:
15.- Wojton,: General Supervising Engineer, Radiation Protection Section, sPPTD, CEI
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L. J. - Jaskiel, Lead Quality Engineer, Operational Quality Section, NQAD, CEI
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' 2G. Dunn, Associate Radiation Protection Analyst, Chemistry Section, PPTD,
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.;J. Webb, Associate Environmentalist, Nuclear Design and Analysis Section
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(NDAS),'NED,CEI
' E. Traverso, Chemistry Supervisor, Radiation Protection Department, PPTD, CEI
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1J.[Grobe,NRCSeniorResident. Inspector LThe~ inspectors'also interviewed several other licensee personnel during
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- the course'of.the' inspection,' including Chemistry.and Health Physics section personnel.
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2 Denotes those present at the plant exit interview on October. 18, 1985.
2 Telephone conversations on October 23 and 24,.1985.
2.
Licensee Action on Previous Inspection-Findings
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-(0 pen)'Open. Item (50-440/84-16-02; 50-441/84-15-02):
Review of QC/QA
.results of. spiked and split samples provided to chemistry technicians.
The licensee made progress, but has not fully implemented procedure
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RAP-0204, " Chemistry Unit Analytical Quality Control Program,"
, Revision 0, May 1, 1984.
Six chemistry technicians have been tested
with spiked radiological samples and one of these technicians-had
_. analyzed'one' set of cross check samples from Applied Science
- Laboratory, a. licensee contractor.
These technicians have not yet
- been tested for.two'of the analyses, (potentiometric analysis for boron.in the standby liquid control system (SLC), and low-level ~
chloride. analysis using the ion chromatograph).-. This item was
' discussed at the' exit meeting.
The licensee stated that these itechnicians would be qualified by the fourth week of October, 1985.
.This item will remain open, pend ng comp et on of boron and chloride i
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analysis by six technicians.
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(Closed) Open Item (50-440/85058-01; 50-441/85021-01): The installation of a upgraded Dionex Ion Chromatograph to permit-simultaneous analyses of both anion and cation' species.
The licensee installed a new double-column ion chromatograph which is
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operational for the analyses of chloride, fluoride and sulfate.
The six technicians have been trained to operate the instrument, but
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the'QC tests on their analytical abilities have yet to be completed (Section 2.a).
'c.
(Closed) Open Item (50-440/85058-02; 50-441/85021-02):
Modification of procedure RAP-0204 to use standard deviations for QC charts of check source data for-gamma spectrometers, the liquid scintillation counter and the single-channel analyzer.
The licensee changed the-basis of the limits on these charts from a fixed percentage, e.g.,
i 10%, to those based on standard deviations (s.d.) derived from counter data, 2 s.d. for warning limits and 3 s.d. for. control limits.
The procedure was mcdified to reflect this change (Revision 1) and management approval was in process during the inspection.
3.
1 Management Organization and Controls and Training
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The management of the Radiation Protection Section has changed since the previous inspection.1 Mr. S. Wojton is the new General Supervising
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Engineer of this Section.
Prior to this he was Senior Lead Engineer, Environmental and Auxiliary Section in the Nuclear Design and Analysis Section'of the Nuclear Engineering Department.
Mr. Wojton has a masters degree in chemical engineering.
Both the Plant Chemist and the Plant Health Physicist report to Mr. Wojton.
.No other changes to the staffing of the Chemistry Section has occurred since the previous inspection.2 The staffing of this Section appears to o
meet'the commitments of the FSAR.
R. Zucker replaced S. Wojton and has overall responsibility for the
. conduct of the radiological environmental monitoring program (REMP).
No problems were identified due to these organizational changes.
S_ix technicians have undergone a one week training program on the Sentry post-accident sampling system (PASS) during October.
The inspectors observed three of these technicians using the PASS during an emergency drill during this-inspection.
No problems were noted and the technicians appeared knowledgeable in the use of this system.
During this inspection, these six technicians were also receiving training in boron analysis and anion analysis (chloride, sulfate, nitrate) using the ion chromatograph.
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In Sep+ ember they completed their training in radiochemical analysis
workit. yon different blind samples for the QA/QC program.in RAP 0204 (see Sections 2.a and b).
Completion of the boron and anion analysis training i
i Inspection Reports No. 50-440/85058; 50-441/85021
.2 Ibid
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for the six technicians'will be required prior to the fuel load date.
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- that time the' licensee will have met his commitment to have six-. technicians'
-fully trained prior to the fuel-load operating. license (FLOL).
A licensee-representative stated that an additional nine technicians will F
be. fully trained by December 31,-1985 and five by June 1, 1986 to complete the. training of all. technicians.
Progress of the training program will Econtinue~to be followed under Open Item No. 50-440/84016-02.
-The inspectors also discussed with licensee representatives the importance.
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Chemistry Section during the first six months of operation.
A licensee-
. representative stated that retaining a General Electric. radiochemist
' consultant to assist in providing additional oversight of laboratory i
activities was budgeted for six months after fuel load.
.No: violations or deviations were identified.
r 4. -. Water Chemistry Control
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The': inspectors reviewed the licensee's water chemistry control program t
which is presente'd in procedure OM1E: RAP-1101 " Chemistry Sampling
- Frequencies land Analysis Program," dated October 21, 1985.
The procedure
details chemistry monitoring requirements and: limiting conditions of
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operation, both required (technical specification limits).and administra -
tivei and includes responsibilities for implementing the program; log
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sheet' forms outlining. sampling and analytical;results of various chemical
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parameters from various plant systems; action levels to be taken for out
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of' specification or administrative limits; and provisions for trend analysis in'dete'rmining overalll performance of a system based upon tracking of chemical-and/or radiochemical parameters.
This procedure satisfactorily addresses.the important elements of a water chemistry
- control program as-presented in the BWR Water Chemistry Guidelines.
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inspectors determined that licensee management is.awara of the importance of-maintaining ~the proper water chemistry'in each system.
In the exit-interview the licensee agreed to issue a corporate policy
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regarding water chemistry control within six months.after,the issuance
This item is not' critical for the of a FLOL (0 pen Item 50-440/85070-01).'
FLOL.
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The inspectors determined through review of-selected log sheets, that the water chemistry program is being implemented.
Log sheets reviewed included those for reactor water, reactor. water cleanup system (RWCU),
condensate storage tank:(CST), feedwater, daily process chemistry,-
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condensate. water, and the closed cooling and heating system.
Whenever
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an out-of-specification limit was noted on a log sheet, the technician
'promptly notified the chemistry management and the shift supervisor to alert them of the plant condition.
Prompt remedial action was taken to'
correct the situation. - No problems were identified during review of the log. sheets.
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The inspectors also reviewed the status of five system sampling panels operated by the Chemistry Unit:
the Turbine Plant Sampling System (TPSS),
the Reactor Plant Sampling System (RPSS), the Auxiliary Boiler Sampling Panel, the Radwaste Sample Panel, and the Post Accident Sampling System (PASS).
All of the panels had been satisfactorily tested and inline monitors calibrated using appropriate standard solutions.
In the TPSS the inspectors reviewed the sampling points for the condenser hotwell pump discharge, condensate filter system effluent header, conden. sate demineralizer effluent header and condensate storage tank where grab samples were taken by technicians for analyses of pH, conductivity and dissolved oxygen.
No problems were noted in these sampling points or process monitors.
The remaining sampling points on this panel were not functional because of the shutdown condition of the plant.
They serve to measure specific conductivity, pH, sodium and dissolved oxygen from various locations of the condenser.
Further, the Plant Chemist stated that tests of the extraction pumps showed them to be undersized and that it would be necessary to replace them before use of these sampling points was possible.
The sample chiller was also not operational.
The schedule for replacement was not available, but the chemist stated that it would be after FLOL.
Operation of these points did not appear to be necessary until steam is produced.
This is Open Item No. 50-440/85070-02.
No problems were noted in a review of procedure OM3A:
50I-P33, " Turbine Plant Sampling System," dated August 23, 1985, which includes a complete description of the operating instructions for each sample point, as well as determination of condenser leak locations using sodium alarms and conductivity readings on process monitors.
The Plant Chemist appeared to be knowledgeable about each facet of the sample panels.
The Associate Radiation Protection Analyst was also well informed in the operation of the Reactor Plant Sampling Panel. This system described in procedure OMSA:
S0I-P35, dated May 7, 1985, continuously monitors reactor water conductivity and it has the capability for the collection of grab samples for the determination of pH and conductivity in the reactor water cleanup influents and effluents (A and B trains), control rod drive water and reactor water recirculation systems.
Technicians had been collecting grab samples from this panel, which was temporarily shutdown during the time the reactor was drained.
The monitors have been calibrated and the panel has been fully tested.
Review of log sheets for samples from these panels indicated that there were no problems in water chemistry control.
A discussion was held with a licensee representative on October 24, 1985 to clarify the status of the TPSS and RPSS panels.
No violations or deviations were identified.
5.
Chemical Control Program The inspectors noted that the Chemistry Section has developed a program for the control of chemicals in the plant in accordance with procedure OM1A: PAP-0803 " Chemical Control Program," dated August 2, 1985.
The program is designed to limit the number and amount of material in the plant to reduce the probability of contamination of various plant systems and is based on INPO Report CY-703 " Good Practice for Control of
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Chemicals in Nuclear Power Plants," November 1983.
Implementation of.
this program is underway as indicated by review of log sheets for chemical permits and chemical requisition cards.
No violations or deviations we.re identified.
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Chemistry and Radiochemistry Programs The inspectors reviewed the chemistry laboratory programs and changes since the last inspection.3 The laboratory facilities are essentially complete; the permanent ventilation system has been completed and the large temporary air conditioner blocking part of the hot laboratory was being removed.
The chemistry staff has moved to new office space which provides considerably more room.
This space appears to be quite adequate.
The old office space is being used by the technicians for their desk work.
The QC/QA program as described in procedure RAP-0204 " Chemistry Unit Analytical Quality Control Program," Revision 0, dated May 1, 1984, has been partially implemented.
This procedure has been revised to include:
(1) an additional reference, NRC Inspection Procedure 84725, " Radiological Chemical Confirmatory Measurements;" (2) a variation in the analyses to be performed (boron from the SLC tank by the mannitol potentiometric method, rather than by use of a hydrometer); and (3) extensive revision of the section on counting room calibration maintenance to take into account the inspectors' previous suggestions to use s.d. to determine control limits (see Section 2.c).
Extensive action guidelines were also added to this section for the maintenance of the QC charts. A licensee representative stated that the management approval process was almost complete.
The procedure is weak since it does not address the use of replicate measurements and the maintenance of records on technician testing.
The licensee commitment to the QC programs appeared to be limited to analytical procedures relating only to technical specification requirements such as radiological analyses and those for chloride and boron (in the SLC).
Other analyses required for proper maintenance of the system, such as those for determining the concentrations of sulfate, silica, and fluoride, and other parameters listed in RAP 1101 (see Section 4) are not included in this program.
The QC records on technician performance were reviewed by the inspectors.
One technician analyzed radiological cross check samples from Applied Science Laboratory (ASL) for gamma isotopic analyses, gross alpha, gross beta,. tritium, and Fe-55 and obtained acceptable results in comparison with those of ASL.
He and five other technicians were tested for their ability to analyze spiked samples for the following parameters:
a.
I-131 by radiochemical separation and gamma isotopic analysis.
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1 Gamma isotopic-analysis with a Marinelli breaker, involving two separate groups of samples; only one sample was set up for each group and then all the technicians counted each of the samples separately.
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Gamma isotopic analysis of a filter paper.
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Tritium using liquid scintillation counter (LSC).
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Gross beta.using a gas proportional counter.
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Gross alpha using a gas proportional counter.
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pH (10 technicians).
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Conductivity (10 technicians).
The results of the analyses were within acceptable ranges in most cases (e.g., the s.d.s were within the range of i 1 to i 5% of the means and comparable to the s.d.s derived from counting statistics).
Some of the
. analyses, however, had poor results, such as those for Fe-55, involving a separation procedure, that had a 25% coefficient of variation (c.v., the ratio of s.d. to mean value).
Only two technicians participated in this analysis.
A second set of analyses had a more reasonable c.v. of 8%.
The gross alpha analyses showed a c.v. of 29% on one set, and 22% on a second set.
The uncertainty was due mainly to analyst variability, since the counting statistics were better than 1% s.d.
The variability on the gamma isotopic analyses of particulate filters was a moderately high 7-11% c.v., but it appeared to be due to poor counting statistics.
One value of the conductivity results was an outlier; the technician repeated the measurement and obtained an acceptable value.
Overall the results of
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the checks on the technicians were acceptable. While some weaknesses were'noted above, these six technicians appeared to be capable of doing the required analyses within limits acceptable for operation of the plant.
The results of the tests on the analyses for boron for the SLC tank and the low-level chloride using the ion chromatograph were not available during.this inspection.
In telephone conversations on October 23 and 24
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the licensee representative stated that these tests had been completed.
However, because the boron results appeared to be unsatisfactory and no correspondence on them was available, these results will be reviewed in a subsequent inspection, (see Section 2.a).
The licensee appears to be only minimally committed to QC in the
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QC checks are performed only on equipment and analyses required for the T/S.
QC checks are not planned for other analyses, such as sulfate, fluoride, silica, and copper, that are important to
" the proper operation of the system, and are recommended by such groups as the BWR Users Group (BWR Water Chemistry Guidelines, Final Report, EPRI, April 1, 1984).
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The QC procedure RAP-0204'is minimally acceptable in that there are no requirements for replicate measurements as recommended in Regulatory Guide 4.15,.which was a reference.in this procedure.
The. lack of commitment-was further demonstrated by the untimely. implementation of
..this procedure.
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.No violations or deviations were identified.
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~ Exit Interview
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- The inspectors met with the licensee representatives (Section 1) at the
~ conclusion of the inspection on October 18, 1985 and discussed the scope and_ findings of the inspection. -The inspectors expressed their concerns about'the slow implementation of the technician training and QC/QA-programs, and the_ limited scope of the QC program.
The licensee would not commit.to any specific improvement in this area, but stated that they were committed to quality work.
The inspectors noted that a previous licensee audit had had 'a finding on the lack of implementation of the
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.QC/QA program.
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The licensee agreed to prepare, within six months of the FLOL, a corporate policy'on water chemistry control.
Additional discussions on the status of the technicians' QC tests and to clarify the condition of the TPSS and RPSS sampling panels were held with a licensee representative on October 23 and 24, 1985.
The inspectors discussed the likely informational content of the inspection report with regard to documentation and processes reviewed by the inspectors during the inspection.
Licensee representatives did not identify any such documents or processes as proprietary.
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