IR 05000440/1992025
| ML20034G995 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/03/1993 |
| From: | Michael Kunowski, Schumacher M, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20034G993 | List: |
| References | |
| 50-440-92-25, NUDOCS 9303150032 | |
| Download: ML20034G995 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION s
REGION III
Report No. 50-440/92025(DRSS)
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Docket No. 50-440 License No. NPF-58 Licensee: Cleveland Electric Illuminating Co.
10 Center Road Perry, OH 44081 Facility Name:
Perry Nuclear Power Plant, Unit 1 Inspection and Meeting At:
Perry Site, Perry, Ohio Inspection Conducted: January 4 - February 22, 1993 Meeting Conducted: January 7, 1993 Inspectors: 8 A ImM '
Ma.~cI ( / f M M. A. Kunowski Date d1JKlJ n1L1 L tse3 N. Shah Date
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d Approved By:
M. C. Schumacher, Chief Date Radiological Controls Section 1 Inspection Summary Insoection on January 4 - February 22. 1993 and Meetina on January 7. 1993 (Report No. 50-440/92025(DRSS))
Areas Reviewed:
Routine, announced inspection of the radioactive waste and
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shipping programs (Inspection Procedures (IPs) 84750 and 86750) and the
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radiation protection program (IP 83750).
It also included review of other radiological matters such as the September 1992 ALARA team inspection results and the radiological significance of a recent fuel leak. An inspector from the State of Ohio was present on January 5,1993, during a tour of the Interim Radwaste Storage Facility (IRSF).
Results: No violations were identified.
Radiation protection program implementation was satisfactory. Housekeeping was not impressive, especially in the turbine building where many oil and water / steam leaks were noted and personnel incurred hour-long delays in exiting to let noble gas daughters decay; doses to the individuals involved appeared negligible. Airborne releases were up in 1992 owing to the fuel and steam leaks, but both releases and doses remained within technical specification limits. Contamination in a minor stream onsite was ascribed to sediment dredged from the eaergency 9303150032 930305 PDR ADOCK 05000440
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service water (ESW) intake and inadvertently released via a nearby storm sewer when a holding basin failed.
Problems with recordkeeping and document quality were noted in several areas including release of material from the radiological controlled area and updating of the offsite dose calculation program to reflect the latest land use census. Two non-cited violations were also identified for problems with an effluent release point flow rate monitor and a control room ventilation radiation monitor. Construction of an interim radioactive waste storage facility was nearly complete.
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DETAILS 1.
Persons Contacted Cleveland Electric Illuminatina T. P. Barton, Corporate Radiological Assessor
- P. W. Bordley, General Supervisor, Reactor fuel Management Unit
@*R. R. Bowers, Corporate Health Physicist
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- R. Caldwell, Director of Nuclear Activities, Ohio Edison Company
@W.- E. Coleman, Manager, Quality Assurance Section
- K. P. Donovan, Manager, Licensing & Compliance Section
- C. R. Elberfeld, Operations Analyst
@*J. J. Grimm, Plant Chemist and General Supervisor, Chemistry Unit
@*#H. L. Hegrat, Supervisor, Compliance Unit
- T. S. Hogan, Compliance Engineer
@*#D. P. Igyarto, General Manager, Perry Plant
- S. F. Kensicki, Director, Perry Nuclear Engineering Department
- J. T. Ratchen, Lead Supervising Specialist
@*C. Reiter, General Supervisor, Radiation Protection Technical Support Unit
@*C. A. Shelton, Chemistry Analyst, Radiation Protection Section
- F. R. Stead, Director, Perry Nuclear Support Department
@*J. J. Traverso, Health Physicist, Radiation Protection Section
@*L. L. VanDerHorst, Plant Health Physicist and Radiation Protection Manager
@*#P. Volza, Manager, Radiation Protection Section-
- B. D. Walrath, Manager, Performance Engineering Section
- W. J. Wright, Manager, Instrumentation & Controls Section l
NRC Personnel l
D. C. Kosloff, Senior Resident Inspector i
- A. Vegel, Resident Inspector l
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@*C. E. Norelius, Director, Division of Radiation Safety and Safeguards
@*M. C. Schumacher, Chief, Radiological Controls Section 1 l
@Present at the Management Meeting on January 7, 1993.
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- Present at the Exit Meeting on January 8, 1993.
- Present at the Exit Meeting on January 22, 1993.
2.
Licensee Event Reports (LERs) and Action on Previous Inspection Findinos (IPs 83750 and 84750)
(Closed) Inspection Followup Item (IFI) 50-440/91015-02(DRSS) and LER 91-012:
Inoperable turbine building / heater bay (TB/HB) stack effluent flow rate monitor. On May 10, 1991, the licensee declared the TB/HB stack flow monitor inoperable after a routine channel check found that indicated flow was approximately 20% less than expected (345,000 efm). A licensee followup investigation determined that while
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the monitor electronics were operating properly, a slow degradation in indicated flow existed since 1988.
System engineers had been aware of the degradation but had not informed plant chemistry, who use the flow rate value for offsite dose calculations, because it was within a ten percent acceptance band used by the engineers. The root cause of the degradation was non-uniform air flow across the monitor's' pitot tube array owing to turbulence and debris in the tubes.
During the refueling outage (March-June 1992), the tubes were cleaned and calibrated against-actual flow measurements taken with a hot wire anemometer. A minimum acceptable flowrate was also incorporated into plant procedures, and will be updated annually via actual measurements of the stack flow. The licensee confirmed that doses had remained well below technical specification (TS) limits, submitted revised dose values in the semiannual effluent report, and reemphasized the importance of good communication to the chemistry and engineering groups.
Although this event is a violation of TS 3.3.7.10(b), which specifies required actions when the effluent flow rate monitor is inoperable, it had low safety significance, was identified by the licensee, and corrective actions appeared effective.
In accordance with Section VII.B of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy,10 CFR Part 2, Appendix C), this violation is not being cited.
(Closed) LER 92-009:
Inoperable Control Room Ventilation Monitor. On March 30, 1992, during the third refueling outage, the licensee started a modification of the control room heating and ventilation (HVAC)
control logic.
Because this work resulted in inoperablity of the i
control room ventilation radiation monitor (CRVM), the HVAC system was
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operated in the isolation mode in accordance with TS 3.3.7.1(b).
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April 19, 1992, following suspension of incore activities and in
'l accordance with TS 3.7.2(b)(2), the HVAC system was removed from
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isolation mode; however, the CRVM was not returned to service nor were alternative monitoring actions taken, contrary to TS 3.3.7.1(b).
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April 25, 1992, the HVAC system was returned to normal operation with
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the CRVM still inoperable, but this was immediately identified by the
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licensee who returned the CRVM to service. At first, it was assumed that TS 3.3.7.l(b) had only been violated on April 25, 1992, but in a subsequent investigation, the licensee identified the April 19th event.
Confusion in understanding TS applicability appeared to be the root cause of the violation. A review of operator logs and discussion with operators confirmed that the status of the monitor had been communicated on April 19, 1992, but that operators had incorrectly assumed that the action statements for TS 3.3.7.l(b) and 3.7.2(b)(2) were identical.
This discrepancy was discussed with the operators immediately after the event and will be included in continuing training as a long term corrective action. The licensee is also considering amending the two TSs to prevent future confusion.
Although failure to comply with the TS requirements is a violation, it had low safety significance, was identified by the licensee, and
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corrective actions appeared effective.
In accordance with Section VII.B of the " General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy, 10 CFR Part 2, Appendix C), this violation is not being cited.
(Closed) Violation No. 50-440/91015-01(DRSSl: This violation was written for the use of an inadequate procedure to calibrate the liquid radioactive waste (radwaste) discharge flow rate device. Corrective actions were appropriate and included procedure revision, retraining of instrumentation & controls (I&C) personnel, and discussion of the problem with system engineering, I&C, main control room, and radwaste personnel.
(Closed) Violation No. 50-440/91015-03(DRSS): This violation was written for ineffective corrective action for a failure to control high radiation area doors.
Installation of local audible and visual alarms and new locksets on the doors has been completed; no similar events have occurred since the violation was issued.
(Closed) Violation No. 50-440/91015-04(DRSS): This violation was written for ineffective corrective action for a failure to evaluate the radiological conditions prior to work behind jet shielding. A detailed evaluation of this problem by the licensee found problems-with the initial corrective action. Additional improvements were made including modification of the work order process to allow RP to incorporate requiremer.ts into the work order before starting the job.
10 CFR 21 Report:
Eberline AMS-3A Beta Air Monitors: The licensee uses the similar Model AMS-3 monitor to provide local alert of elevated local airborne concentrations which would then be quantified by analysis of a grab sample.
The station had been notified by the manufacturer.of the Part 21 report citing the potential problems in relying on these instruments during emergency or accident conditions. At Perry they are not used to alert for general building airborne activity problems (this is done by installed building ventilation exhaust monitors) or for emergency evaluations.
Based on these considerations, the licensee made.
no changes to the monitors but proposed improved technician surveillance to minimize blockage of the air intakes'so as to avoid bypass of the filter.
In telephone discussions after the inspection, licensee representatives stated that hardware corrections would also be made.
3.
Audits and Appraisals (IPs 84750 and 86750)
The inspectors reviewed selected quality assurance (QA) audits including PA 92-15/16 on the Process Control Program and Packaging and Transportation of Radwaste; PA 92-24 on the Radiological Environmental Monitoring Program and Effluent Monitoring; and PA 93-03 on the Offsite Dose Calculation Manual. The audits were largely performance-based and conducted by knowledgeable and experienced personnel. No significant health and safety problems were identified, but discrepancies in radwaste shipment reco"ds were noted which still persist. During this inspection, the insper. tor noted missing signatures on radwaste records
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and the inclusion of _ extraneous and confusing records with' shipping documents (Section 5.b).
The licensee's 'recent discovery (Section 6) of its failure to update the MIDAS program with current lar.d use census information also underscores the need for additional management attention to document qual.ity control. This matter was discussed at the exit interview and will be reviewed in subsequent routine inspections.
Also reviewed were licensee audits of vendor programs. These were performed triennially by the licensee's quality engineering group and consisted of direct observations by licensee staff or reviews.of similar audits performed by other licensees through the Nuclear Utilities Procurement Issues Committee (NUPIC). NUPIC is an industry group that audits vendor programs on a biennial basis, using specialists drawn from member utilities. The inspectors noted no problems in their review of selected vendor audits.
No violations of NRC requirements were identified.
4.
Staffina (IPs 83750. 84750. and 86750)
The licensee reorganized the Radiation Protection Section by creating a technical support group to take over selected activities (such as instrumentation and software QA) from the existing chemistry and health physics units.
In addition, an individual with five years experience supervising the corporate Radiological and Environmental Engineering Unit was reassigned to the Radiation Protection Section as special projects coordinator. The effectiveness of the new organization will be reviewed during future routine inspections.
No violations of NRC requirements were identified.
5.
Imolementation of the Solid Radioactive Waste and Transportation Proorams (IP 86750)
The inspectors reviewed the licensee's program for processing, shipp_ing, and storage of solid radwaste, as described in the Process Control Program and administrative procedures PAP 1304 " Radioactive Shipment Criteria" and PAP 1309 " Shipment of Radioactive Waste for Disposal."
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Waste Generation and Processina Primary waste streams include Dry Active Waste (DAW), solid mechanical filters, and spent resin from the liquid processing systems.
DAW was packaged in bulk and usually shipped to an offsite contractor for volume reduction before burial. The licensee is planning to compact such waste onsite in the Interim Radwaste Storage Facility (Section 5.c).
Spent resins were pumped from settling anks into high integrity containers (HICs) or liners and dewatered onsite using a vendor
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system. This system has an NRC-approved topical report and is
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operated by licensee personnel with help from the vendor. The i
licensee plans to purchase the system and is training its
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operators and preparing pertinent procedures, i
Solid mechanical filters were also dewatered onsite using the same
vendor dewatering system. While regular HICs were used, the
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licensee is considering purchasing a specially designed HIC for future dewatering.
This HIC has channels for segregating filters by dose rate and provides a higher water level to increase shielding.
It has been used by other utilities with good results.
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A number of significant steps were taken towards radwaste reduction: launderable nylon bags replaced disposable plastic.
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bags for trash collection; DAW reduction methods were emphasized to workers; and condensate demineralizer run times were i
significantly increased through better liquid radwaste processing, j
Additional efforts include better management of plant water usage
and further reductions in spent resin volume.
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Waste Characterization. Packaaina. and Shionina All solid radwaste, except DAW, was shipped directly to burial.
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In 1992, 152 shipments (166 m') were made compared to 75 (337 m')
in 1991.
Each shipment was recorded on a shipping log, properly l
documented, and reviewed by both health physics and quality
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control. No shipping incidents have occurred since the previous
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inspection.
Shipping activities were overseen by the radwaste shipping i
coordinator or designee; both attended biennial vendor training on i
shipping regulations. The RADMAN computer program was used to generate shipping papers, track radwaste shipments, and calculate waste curie content. Resin and filter activities were determined by directly scaling isotopic activity in a measured sample.to the shipment; for DAW, a dose-to-curie conversion was used.
A database of radwaste correlation factors was maintained by the licensee.
Scaling factors were generated annually by a vendor, and compared to historical results by the licensee. A review of current factors by the inspector did not identify any problems.
The inspectors found that shipping files contained a number of unnecessary documents and minor record discrepancies that create additional paperwork and may cause confusion while reviewing shipment packages. They also found that PAPS 1304 and 1309 incorrectly assigned signatory responsibility of shipping papers to the radiation protection manager instead of the radwaste shipping coordinator. Corrective actions are already underway, should prevent recurrence, and will be reviewed during future inspections.
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Interim Radwaste Storaae Facility l
Several tours (including one with a State of Ohio' inspector) were
made of the radwaste processing and storage buildings currently
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under construction. These buildings along with an adjacent
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outdoor area for storing radwaste in massive concrete containers (termed onsite storage containers or OSSCs)-constitute the i
licensee's Interim Radwaste Storage Facility (IRSF). A review of-
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construction drawings and discussions with licensee staff.
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indicated construction was proceeding as planned. The inspectors noted that the buildings had also been inspected by the Lake
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County building inspector several times during 1992. -The l
buildings are expected to be ready for processing and staging of i
radwaste around March 1993 but the licensee stated that money had i
been allocated for continued shipment to the Barnwell, South
Carolina burial site until mid-1994.
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No violations of NRC requirements were identified.
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Gaseous Radioactive Waste (IP 84750)
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Gaseous radwaste was discharged from four points:
turbine
building / heater bay vent, offgas vent pipe, and Unit I and 2.
l vents. The licensee reported noble gas releases (390 Curies (Ci))
for 1992 were a factor of three higher than 1991 owing to leaky
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fuel and steam leaks (Section 9). Reported doses remained less l
than ten percent of annual limits.
Iodine releases were up ten-fold during the same period and calculated i
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maximum thyroid dose offrite increased to about 40% of the TS 3.11.2.3 annual limit (15 millirem). This was to a hypothetical individual i
continuously at the most affected boundary sector but drinking milk from
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the most affected milk animals wherever located. Most was attributed to
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releases in September and October when a fuel leak increased efter a reactor scram on September 10.
For a brief period at the end of
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October, the licensee considered that calculated dose may have' exceeded the limit, but discovered in review that the large turbine building i
I ventilation flow rate had been inappropriately. used in conjunction with the of? gas release concentration, and that the incorrect milk animal-l
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locations had been used in the computer dose program (MIDAS). With the proper data, the calculated dose was well under the limit as noted
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The licensee's review also identified that land use census information, although collected as required, and noted in the ODCM, had not been updated into HIDAS since its initial entry in 1985-1986. Corrective i
actions included counseling of the individual responsible for the
erroneous calculation, revising procedures to ensure that MIDAS is
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properly updated, and a review of previous release information to identify similar problems. Other program improvcments are planned and l
will be reviewed during future routine inspections.
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The inspectors also observed a determination of offsite dose and performed a confirmatory calculation against the licensee's methodology; no problems were identified. MIDAS has the capability of using.online monitoring of count and flow rates but the licensee elects to calculate
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dose by manual input-of grab sample data; real time' meteorological data i
are used.
No violations of NRC requirements were identified.
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Liouid Radwaste (IP 84750)
The inspectors reviewed effluent release data and instrumentation
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calibration records with no significant problems identified.
Liquid releases in 1992 contained approximately 9.3 Ci of tritium and 0.13 Ci of other nuclides compared with 10.6 and 0.29 Ci, respectively, in 1991.
Doses via the liquid pathway were well within TS limits.
In its semiannual effluent report for the second half of 1992, the
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licensee described an unmonitored liquid release via a minor stream (MS)
that traverses the site enroute to Lake Erie. Sediment contaminated
with cobalt-60 was found in spots along the stream bed; it was not found on samples from beach sand where the stream enters the lake or in water
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samples from the stream. A licensee investigation identified the source as sediments from the emergency service water (ESW) intake forebay which were contaminated by leakage between the service water discharge (the path for normal liquid radwaste discharges) and the ESW. The two are connected by design to provide an emergency water source; however, the
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large sluice gates between them do not seat properly allowing diluted radwaste to leak by and contaminate sediments collected in the forebay.
The sediment is dredged periodically and put into two temporary aboveground holding ponds and, until contamination was discovered, was disposed of onsite; on one occasion, in about 1989, a holding pond broke and released sediment into a storm sewer that drains into the MS.
Licensee representatives stated that the ESW forebay sediment was not recognized as contaminated before prior to the investigation.
Currently, the only residual contamination along the MS appears to be
about 28 nanocuries in a single spot of several square feet in the i
stream bed. The licensee has no plans to remove the material, which is i
below environmental reporting levels, but states it will monitor the
stream as part of its environmental monitoring program with disposal i
deferred until decommissioning.
Contaminated sediment continues to accumulate in the forebay and the two holding ponds contain about 180 microcuries in 4500 cubic feet of recently accumulated sediment.
The licensee would like to dewater and store the sediment in OSSCs in its outside storage area, an action it believes justified on a risk-benefit basis. The licensee also stated that it expects to decide by mid-1993 on how to fix the leaky gates in order to eliminate or greatly reduce the problem. At the exit interview, NRC representatives acknowledged the proposed actions, but noted that leaving the material
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onsite will require a hazards evaluation by the-licercee. The matter i
will be reviewed under Inspection Followup Item (IFI)
l No. 50-440/92025-01(DRSS).
No violations of NRC requirements were identified.
8.
Mixed Waste Control The inspectors reviewed the licensee's classification and handling of mixed waste, consisting of hazardous chemical waste contaminated with low levels of radioactivity, because of concern by the State of Ohio Environmental Protection Agency that some may have been transferred to a
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treatment and disposal facility, North East Chemical Corporation (NEC)
of Cleveland, not authorized to receive it. The-concern arose after Perry began using the more sensitive environmental lower limits of detection (LLD) in its analyses rather than the effluent LLD formerly
used. The change followed a July 1991 technical meeting of Region III l
utility personnel where NRC representatives reiterated guidance to use the environmental LLDs to confirm the presence or absence of
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radioactivity in bulk material sent to hazardous waste facilities. The change meant that some of the material shipped as non-radioactive based on effluent LLDs might have been considered radioactive if analyzed
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under the environmental LLDs.
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Discussions and a review of records indicated that approximately five i
30-gallon drums of sodium pentaborate (a non-hazardous material) and two 55-gallon drums of oil (likely a hazardous material) were released from the RCA when the effluent LLDs were routinely used and eventually sent i
to NEC.
Because of a poorly organized record system, the licensee could l
not identify exactly which drums came from the RCA and would have been
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subject to radioactive' analysis. However, examination of general l
records of such analyses indicated that_ the sensitivities actually
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achieved using the effluent LLDs were generally within a factor of one
to two of the environmental LLDs specified in NRC guidance.
In either case, the LLDs in question were below the EPA-specified levels for i
drinking water.
Records indicated that other waste oil had been.
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transferred to the licensee's Lakeshore fossil fuel plant for burning
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and had also been released from the RCA using the effluent LLDs;
similarly, a health and safety problem was-not present.
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As a result of the review of LLDs, the licensee agreed to revise its
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recordkeeping system to allow better correlation of transfer and radiological analysis records. This matter will be reviewed during a
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future inspection (IFI No. 50-440/92025-02(DRSS)).
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No violations of NRC requirements were identified.
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9.
Fuel Leak
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Perry has had several fuel leaks:
two in the first operating cycle j
(from initial fuel loading to first refueling outage), one in cycle 2,
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and two in cycle 3.
Shortly after the start of cycle 4 (June 1992), the i
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e licensee saw evidence of a fuel defect which worsened after a scram in mid-September. This leak became the most significant radiologically as i
its effect was exacerbated by in-plant steam leaks (Section 6).
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the steam leaks were repaired during a short outage in late October and during a power reduction in early November.
In December, the licensee decided to undergo a midcycle outage starting January 9, 1993, to examine the fuel and remove leaking elements. This examination identified a significant defect in a single element.
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In-plant, steam leaks caused slightly increa, sed radiation levels and an j
increase in contaminated areas owing to short-lived noble gas daughters.
Noble gases and daughters adhering to clothing frequently delayed workers from leaving the RCA until the isotopes decayed sufficiently to
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allow them to pass the whole-body friskers. The doses to the involved
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individuals have been small. The inspectors observed numerous steam leaks, particularly in the turbine building, during several tours and
experienced the imposed jelays for exiting.
The inspectors also observed numerous oil leaks and areas with poor housekeeping and material conditions, including some where the presence of tools, gloves, and debris on the floor suggested weaknesses in radiological control practices.
r No violations of NRC requirements were identified.
10.
Manaaement Meetinas l
On January 7, 1993, the NRC Region III Director of the Division of Radiation Safety and Safeguards and several members of his staff met
with the plant general manager and members of his staff to discuss radiation protection items of interest including the recent ALARA inspection (Inspection Report 50-440/92019) and ongoing dose reduction efforts. The licensee reported that station dose for 1992 was 570 person-rem, slightly higher than the goal of 551; 295 personal contamination events were recorded for the same period.
Currently, about 6.7% of the readily accessible plant area was contaminated.
The scope and findings of the inspection were reviewed with the licensee (Section 1) oo January 8.
Topics included the radiological consequences of the leaky fuel (Sections 6 and 9); repair of the leaking ESW gates; disposition of the resulting contaminated silt (Section 7); correction of the TB/HB stack flow rate monitor (Section 2); operational plans for
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the IRSF and the outside storage pad (Section 5.c); inplant housekeeping and material conditons (Section 9); and documentation problems concerning potentially mixed waste (Section 8), radwaste shipments (Section 5.b), and MIDAS data (Section 6). The licensee acknowledged the inspectors' comments and did not identify any likely inspection report material as proprietary.
On January 22, 1993, the scope and findings of a followup inspection of the fuel leak and offsite dose consequences were reviewed with licensee representatives (Section 1). Additional information regarding mixed waste and offsite dose calculation methodology was obtained.
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Accompanying the inspector were two specialists from Region III Division-of Reactor Safety and one from NRC Headquarters.
Specific issues reviewed by these individuals are discussed in Inspection Report No. 50-440/92026(DRP).
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