ML20205P175

Insp Rept 50-341/99-06 on 990315-19.No Violations Noted. Major Areas Inspected:Licensee Plant Support Performance Re Gaseous & Liquid Effluents,Liquid Waste Processing,Esf Filtration & CR Heating Ventilation & Air Conditioning

ML20205P175
Person / Time
Site:	Fermi
Issue date:	04/14/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205P174	List: ML20205P169 ML20205P175
References
50-341-99-06, 50-341-99-6, NUDOCS 9904200057
Download: ML20205P175 (12)

See also: IR 05000341/1999006

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U.S. NUCLEAR REGULATORY C'OMMISSION

REGIONlli.

Docket No: 50-341.

License No: NPF-43

Report No: 50-341/93006(DRS)

Licensee: Detroit Edison Company

Facility: Enrico Fermi, Unit 2

Location: 6400 N. Dixie Hwy.

Newport, MI 48166

Dates: March 15 to 19,1999 3

Inspector: M. Mitchell, Radiation Specialist

Approved by: Gary Shear, Chief, Plant Support Branch

Div;3 ion of Reactor Safety

990 57 990414

PDR K 05000341 4l

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EXECUTIVE SUMMARY

- Enrico Fermi, Unit 2

NRC Inspection Report 50-341/99006

This announced inspection included aspects of the licensee's plant support perforniance

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regarding gaseous and liquid effluents, liquid waste processing, engineered safety feature

(ESF) filtration, control room heating ventilation and air conditioning (HVAC), and solid waste

management and shipping. The report covers a one-week inspection concluded on

March 19,1999, conducted by one radiation specialist under the direction of the Branch Chief.

Overall, tha effluents monitoring, liquid waste processing, ESF filtration and solid radioactive

waste handling and shipping programs were wellimplemented.

Plant Support

e The gaseous effluents program was implemented in accordance with the offsite dose

calculation manual (ODCM) and site procedures. Dose assessment calculations were

accurate, and offsite doses were snaintained well below regulatory limits and license

commitments. (Section R1.1)

e The licensee maintained the liquid radioactive waste handling systems in excellent

condition and the solid waste processing areas in acceptable condition. Some minor

housekeeping issues were appropriately corrected by the licensee immediately during

the inspection while others were ide.1tified for correction as part of longer term projects. <

(Section R1.2)

e Overall, the maintenance and testing program for the standby gas treatment system

and control room ventilation filtration systems was effectively implemented. The

licensee performed system testing in accordance with Technical Specification

requirements, and test results indicated acceptable system performance. (Section

R2.11

e The licensee maintained effluent and piucess radiation monitors in accordance with {'

license requirements. Monitor calibrations allowed the licensee to effectively assess

release of radioactive effluents in accordance with regulatory limits. (Section R2.2)  ;

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e Self-assessments were comprehensive, performance-based, and identified areas for '

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improvemen' '; the effluent monitoring and transportation programs. The quality

assurance tausit identified some minor problems, and the staff took appropriate and

prompt action to assess each finding, and to correct the identified problems. (Section )

R7.1) )

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Report Details

IV. Plant SuDDOrt

R1 Status of Radiation Protection and Chemistry Controls

R1.1 Implementation of the Radioactive Effivents Proaram

a. Inspection Scope UP 84750)

The inspector reviewed applicable procedures, effluent release data, the offsite dose

calculation manual (ODCM), and the 1997 Annual Radioactive Effluent Release Report.

The inspector also interviewed staff regarding the calculation process for determining

the dose consequence to members of the public and conducted a comparative dose

calculation.

b. Observations and Findinos

The inspector reviewed the methodology for determining the concentrations and

radioactivity content of the gaseous effluents. The Radiation Protection (RP) staff

utilized System Particulate lodine Noble Gas (SPING) monitors located at the various

effluent release points (reactor building vent, turbine building vent, etc.) to obtain the

grab samples and radiation data to verify offsite dose assessment. The noble gases

present in the effluent and their corresponding concentrations were verified by gamma

spectrometry analysis of grab sa nples. The RP staff recorded the noble gas monitor

reading at the time the grab sample was collected, compared this reading to the

average noble gas monitor reading for the previous month, and calculated the noble

gas content and evaluated differences, if necessary.

Gaseous particulates and iodines were determined by gamma spectrometry analysis of

weekly air filter and charcoal cartridge composite samples collected by the SPING

monitors. For the total gaseous effluent volume determination, the flow rate was

assumed to be the maximum rate achievable with all fans in operation.. Using the

maximum achievable flow rate was a conservative approach. No mouifications were

made to vent systems or the monitoring equipment that would require changes to the

conservative assumptions. The RP staff also collected weekly grab samples for tritium

enalysis (all results were below the lower limit of detection). Particulate strontium 89

and 90 analysis was conducted on quarterly composites of the SPING air filters by a

contracted vendor. The gaseous radionuclide concentrations were well below the 10

CFR 20, Appendix B, Table 1, Column 2 limits.

The inspector noted that calculations for dose consequence to members of the public

were conducted in accordance with the methodology dercribed in the ODCM.

Radiation protection staff used a computer program for the dose assessment. The

inspector reviewed in RP validation of this spreadsheet and verified that the new

spreadsheet calculations were nearly identical to the previous spreadsheet and hand

calculations.

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The inspector obtained monthly radioactive effluent release data from plant personnel

and performed a comparison of the licensee's dose calculation to the NRC's PC Dose

computer program. The results are presented below:

Particulates/lodines to the Cridcal Receptor (Wholebody Child All Pathways)

NRC Value 9.87E-5 mrem

Fermi Value 1.31E-4 mrem

These comparative results were in good agreement (i.e., a factor of 2). In addition, these

dose assessments are well below the Licensee's ODCM limits.

As a matter of site practice, the licensee has not released radioactive liquid effluents to

any unrestricted area since May 1994, and the inspectors noted that plant personnel

reviewed the decant line effluent monitor located in the Cirewater Pump House daily to

ensure adherence to this practice. The inspector conducted a walkdown of the liquid

effluent monitoring equipment to ensure proper condition and operational integrity. The

equipment was found in operable and well maintained condition.

c. Conclusions

The gaseous effluents program was implemented in accordance with the ODCM and site

procedures. Dose assessment calculations were accurate, and offsite doses were

maintained well below regulatory limits and license commitments.

R1.2 Radioactive Waste Processina and Storaae

a. Inspection Scope (IP 86750)

The inspector reviewed the processing and storage of solid radioactive wastr

(radwaste). The inspection consisted of interviews with cognizant personnel, :., well as

walkdowns of the radwaste storage areas, radwaste control room and radwaste

processing equipment.

b. Observations and Findinas

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The inspector noted that the solid radwaste processing and storage areas were clean

and organized. The High-Leve Storage Area of the Offsite Storage Facility was

observed by remote camera dui ng the weekly waste operator inspection. The areas  !

were well organized. The licensee inspected the area at this frequency primarily to

maintain surveillance of several barrels containing sludge material that have either

leaked or bulged and of two high integrity containers. It was observed that these barrels

have been placed !n overpack containers to prevent any discharge or release should

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7 . During walkdowns, minor housekeeping issues were brought to the attention of the staff. I

% o For example, in the visible traffic areas there was an accumulation of dirt and debris

Mp under the floor grating which appeared to have potential to block the floor drains. The

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staff stated that the amount of debris was not sufficient to block the four inch floor drains.

They also stated that the plant management has authorized significant resources to

address the housekeeping and operationalissues of the department this year.

Additionally, the inspector verified dose rates in the storage areas with survey maps and

postings and found no inconsistencies.

I The inspector conducted a walkdown of the liquid radwaste handling systems and control

room. The material condition was excellent. The piping and valves to all used

equipment, as well as unused and abandoned equipment did not exhibit extensive leaks,

or other material condition concerns. The inspector did note that two evaporator rooms

that are no longer used did contain chairs and a lockf 1 evaporator room contained foam

pads in an area not readily visible from the room floor. While no people were observed in

the rooms and it was not evident how long the items had been in place, these items

indicated potential resting or sleeping areas in these low dose areas (less than 0.1

mR/hr). The staff took immediate action to remove these items from these low dose i

areas and notified security to increase surveillance. l

c. Conclusions

The licensee maintained the liquid radioactive waste handling systems in excellent

condition and the solid wastes handling areas in acceptable condition. Some minor

housekeeping issues were appropriately corrected by the licensee immediately while

others were identified for correction as part of longer term projects.

R2 Statur of Radiatior Protection and Chemisky Facilities and Equipment

R2.1 Enaineered Safety Feature (ESF) Filtration Testina

a. Inspection Scope (IP 84750)

The inspector reviewed the licensee's testing and maintenance programs fe: the control

center heating, ventilation and air conditioning filter units (CCHVAC) and standby gas )

treatment system (SGTS). The inspector interviewed personnel and reviewed the l

documents used in the testing program.

b. Observations and Findinas

The inspector walked down the CCHVACs, the SGTS filtration units, and the control room

monitoring equipment and reviewed selected surveillance records. The inspector verified

that test results for divisions 1 and 2 of the SGTS and CCHVAC were in compliance with

Technical Specifications (TS). The inspector found all control room indications and alarm

systems to be operable.

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The inspector also reviewed the licensee's method for tracking the total run time of the

SGTS to avoid exceeding the 720-hour total run time requirement for testing. Specifically,

a procedure worksheet was used which contained a self checking log. This has

prevented any inadvertent oversight during the period reviewed.

During a walkdown of the SGTS, the inspector found that silicone based sealant had

dripped onto one of the air actuated damper mechanism's housing during application.

The system engineer took immediate action to determine if this finding had any effect on

operability and if there were any other similar problems on the systems. As a result of this

review, no operational problems were ider.tified.

c. Conclusions

Overall, the maintenance and testing program for the standby gas treatment system and

control room ventilation filtration systems was effectively implemented. The licensee

performed system testing in accordance with Technical Specification requirements, and

test results indicated acceptable system performance.

R2.2 Effluent Radiation Monitorina Instrumentation

a. Insoection Scope (IP 84750)

The inspector reviewed the operability and testing of the effluent radiation monitors. This

review consisted of walk-downs of the monitor systems, a review of calibration records

and procedures, discussions with the responsible system engineer, and a review U

operability trends. Specifically, the inspector reviewed calibration data for the following

radiation maaitors:

(1) Reactor Building exhaust vent monitor;

(2) Turbine Building exhaust vent monitor;

(3) Offgas Stack monitor;

(4) Service Building ventilation monitor;

(5) Radwaste Building ventilation monitor;

(6) Onsite Storage Building monitor; and

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(7) Decant Service Water monitor

b. Observations and Findinos

The inspector performed walk-downs of the process and effluent radiation monitors with 3

the responsible system engineer and members of the RP staff. The total availability of the

effluent monitoring systams was also reviewed. The licensee used seven independent

effluent monitoring systems. The availability for each system was well above 95 percent.

This high availability indicated implementation of an excellent maintenanw program for

the equipment. When air effluent systems were placed out of service, the staff

maintained the grab sample monitoring more frequently than the required 9-hour ,

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intervals. No pathway was unmonitored at any time.

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The inspector evaluated the licensee's equipment problem trending program associated

with radioactive effluent monitoring. The system engineer stated that they had not

developed a tracking mechanism to identify the common failure modes of these monitors

and the frequency of each failure mode since there were not enough events to properly

trend. The system engineer also indicated that evaluations were in progress on the

- Decant Service Water monitor flow switch problems related to humidity in the Circwater

Building. This matter was being pursued by the system engineer and he anticipated that

a different type of flow monitoring system will be installed pending management support.

The inspector concluded that acceptable attention was given to correcting the issues with

these monitors as they developed.

The inspector also reviewed selected calibrations of the effbent radiation monitors and

found the calibrations to be properly performed. The licensee had performed a primary

calibration for each monitor to establish an energy dependenes calibration, and an activity

calibration. At the prescribed frequency, the licensee also performed secondary

calibrations to verify the adequacy of the primary calibration and to justify its coatinued

use. During the secondary calibrations, the licensee measured the response of the

radiation monitor to a single radioactive source, which was related to the primary

calibration. If the monitor did not respond within the licensee's acceptance criteria, the

licensee performed corrective actions (e.g., adjusted the monitor's high voltage supply or

replaced the monitor). To ensure the monitor responded properly to the anticipated

mixture of radionuclides, the licensee compared the monitor's response to the analytical

capabilities of the radiochemistry laboratory. A conversion factor was calculated which

related the detector response to the release rate of the radioactive gases (i.e.,

microcuries per cubic centimeters).

The inspector reviewed selected 12-month channel calibrations and quarterly channel

functional tests for the above monitors. The calibrations were performed as required by

the TS and ODCM. Certain alarm setpoints, which were calculated in accordance with

the ODCM, were also verified. The inspector noted that the licensee used the monitor

indications to dciermine the quantity of radioactive noble gases released from the sit

c. Conclusions

The licensee maintained effluent and process radiation monitors in accordance with

license requirements. Monitor calibrations allowed the licensee to effectively assess

release of radioactive effluents in accordance with regulatory limits.

R4 Staff Knowledge and Performance in Radiation Protection and Chemistry

R4.1 Shioment of Radioactive Material (IP 86750)

During the inspection, the licensee conducted a shipment of radioactive material

(Shipment No. 98-0062, laundry). The inspector interviewed the licensee staff that

prepared the shipment for transport and observed proper implementation of the shipping

requirements. Specifically, the inspector reviewed the shipping documents and noted that

they contained the information required by 49 CFR Part 172 and 173.

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R7 Quality Assurance in Radiation Protection and Chemistry Activities

R7.1 Quality Assurance

a. Insoection Scooe (IP 84750)

The inspector assessed the effectiveness of the licensee's identification and resolution of

effluent monitoring problems identified through scheduled audits. Specifically, the

inspector reviewed the results of self-assessment activities conducted in February 1999.

b. Observations and Findinas

An audit of the gaseous and liquid monitoring program and transportation program was

conducted during February 1999. The audit consisted of field observations and a

programmatic review conducted by a team of ths licensee's quality assurance staff and

specialist personnel from other utilities. At the time of the inspection, the audit findings

had not been formally documented, however, the audit team had conducted an exit

meeting and presented the findings to station . management. The inspector interviewed a

member of the audit team regarding the findings. The findings indicated an adequate

depth and scope to the audit in both the effluent and the transportation programs. As a

result of the audit the licensee staff initiated several Condition Assessment Resolution

Documents (CARDS) to gather additional information and to determine if changes to

current practices were warranted. The inspector reviewed the CARDS and discussed the

more significant findings with the assigned staff member. For most of the CARDS the

information gathered clearly closed the finding. Not all the CARDS had been completely

addressed at the time of the inspection due to the scope of the follow-up, but each one

was being rigorously addressed by the staff. This response to the audit findings was

appropriate and timely.

c. Conclusions

Self-assessments were comprehensive, performance-based, and identified aress for

improvement in the effluent monitoring and transportation programs. The quality

assurance audit identified some minor problems, and the staff took appropriate and

prompt action to assess each finding and to correct the identified problems.

R8 Miscellaneous Radiation Protection and Chemistry issues

R8.1 (Closed) Violation 50-341/98007-02: Failure to comply with Radiation Work Permit

(RWP) requirements. Corrective actions for the violation included the following: (1) hold

informal training for craft personnel to address the issues (RWP requirements, f

terminology and reasons for the steps, key custody requirements, lessons teamed) and l

(2) include these events in the outage review critique to develop staff input for corrective j

action; These corrective actions were reviewed by the inspector and they appear to have i

been effective; no similar incidents have occurred since they were taken. This item is

closed.

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R8.2 (Closed) Inspection Follow-up Item 50-341/97015-01: Reactor water c!ean-up pump

(RWCU) room material condition affecting pump disassembly and radiation dose. The

design of the RWCU leads to frequent pump seal changes. This job continues to

contribute significantly to station dose. The licensee continues to evaluate seal changes

and evolution dose reduction. The licensee has increased the replacement frequency

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from six months to as high as seventeen months. To reduce dose, the licensee

implemented the following actions: (1) conduct pump impeller removal in the hot

machine shop, a low dose area; (2) use temporary shielding around the pump casing; (3)

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conduct post-job lessons leamed and As Low As Reasonably Achievable (ALARA)

reviews; (4) conduct historical dose trending per evolution versus increase in dose due to

depleted zine oxide addition program; and (5) classify this evolution as (C)(1) under the

maintenance rule program, for tracking with the highest level of attention. These actions

have rasulted in control of dose during a period when dose rates on the RWCU have

increased 360 percent. This item is closed.

X1 Exit Meeting Summary

The inspectcr presented the inspection results to members of licensee management at the

conclusion of the inspection on March 19,1999. The licensee acknowledged the findings

presented. The licensee did not identify any items discussed as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED

Mr.ensee

S. Bartman, Supervisor Radiation Protection

S. Booker Work Control Superintendent

J. Bosnyac, HVAC System Engineer

R. Bourdua, QA Auditor

L. Craine, Supervisor, Environmental Health and Safety

L. Crissman, General Supervisor, Radiation Protection

W. Dempsey, Radwaste Crane Operator -

P. Fessler, Assistant Vice-President Nuclear Production

R. Gillmore, Supervisor, Radiological Health

K. Harsley, Nuclear Licensing

E. Kokosky, Radiation Protection Manager

G. Macadam, Radiation Protection, In-plant Safety Assessor

N. Peterson, Nuclear Licensing Director

M. Pavelek, RP instrument Technician

-J. Plona, Technical Manager

M. Offerle, General Supervisor, Radwaste

W. Ostrom, QA, Auditor

P. Smith, Nuclear Licensing Principle Engineer

S. Stasek, Supervisor ISEG

T. VanderMey, Radiological Engineer

D. Varwig, RP Safety Consultant

D. Williams, Assistant Radiation Protection Manager

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S. Campbell, Senior Resident inspector i

M. Mitchell, Radiation Specialist

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G. Shear, Chief, Plant Support Branch ,

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INSPECTION PROCEDURES USED

IP 86750 Occupational Radiation Exposure

IP 84750 Radiological Waste Treatment, and Effluent and Environmental Monitoring

IP 92904 Followup - Plant Support

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- . LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

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Opened

None

Closed

50-341-98007-02 NOV Failure to comply with RWP requirements.

(Section R8.1)

50-341-97015-01 IFl RWCU material condition affecting pump-

disassembly and radiation dose. (Section R8.2)

Discussed

None

LIST OF ACRONYMS USED

ALARA As Low As Reasonably Achievable

CARD Condition Assessment Resolution Documents

CCHVAC Control Center Heating, Ventilating and Air Conditioning

DAW Dry Active Waste

ESF Engineered Safety Feature

HVAC Heating, Ventilating and Air Conditioning

IFl Inspection Followup Item

NOV Notice of Violation

Radwaste Radioactive Waste

OCDM Off-Site Dose Calculation Manual

RP Radiation Protection

RWCU Reactor Water Clean-up

RWP Radiation Work Pennit

SPING System Particulate lodine Noble Gas

STGT Stand By Gas Treatment

TS Technical Specification

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PARTIAL LISTING OF DOCUMENTS REVIEWED

24.404.02 (revision 27)" Division 1 Standby Gas Treatrnent Filter and Secondary Containment

Isolation Damper Operability Test";

64.080.102 (revision 5)"Radwaste Effluent Radiation Monitor Radiological Calibration";

64.080.121 (revision 8)"Offgas Sample Chamber Radiation Monitor Cannel A Calibration";

64.080.122 (revisic7 8)"Offgas Sample Chamber Radiation Monitor Cannel B Calibration";

64.080.203 (revision 9)" Standby Gas Treatment Exhaust Process Radiation Monitoring Systern

Calibration, Division 1";

64.080.204 (revision 7)" Standby Gas Treatment Exhaust Process Radiation Monitoring System

Calibration, Division 2";

64.080.218 (revision 8)"Onsite Storage Building Ventilation Exhaust Process Radiation

Monitoring System Calibration";

64.080.302 (revision 8)" Area Radiation Monitor Channel 6 Calibration";

64.080.303 (revision 8)" Area Radiation Monitor Channel 15 Calibration";

64.080.304 (revision 8)" Area Radiation Monitor Channel 16 Calibration";

64.080.305 (revision 7)" Area Radiation Monitor Channel 17 Calibration";

64.080.403 (revision 8)" Control Center Makeup Air Manifold Radiation Monitor Division 1

Calibration";

64.080.404 (revision 9)" Control Center Makeup Air Manifold Radiation Monitor Division 2

Calibration";

64.080.437 (revision 8)" Reactor Building Ventilation Exhaust Radiation Monitor Division 1

Calibration";

64.080.438 (revision 9)" Reactor Building Ventilation Exhaust Radiation Monitor Division 1

Calibration";

64.080.601 (revision 10)" Source Checks for Liquid and Gaseous Radiation Monitors";

64.120.026 (revision 17)" Standby Gas Treatment exhaust Division 1 Accident Range Radiation

Monitoring System Calibration / Function";

64.120.026 (revision 7)" Standby Gas Treatment exhaust Division 2 Accident Range Radiation

Monitoring System Calibration / Function";

64.713.019 (revision 9)" Radiological Effluent Routine Surveillances";

65.000.506 (revision 14)" Shipping Low Specific Activity (LSA) Radioactive Material";

67.000.502 (revision 7)"Eberline SPING Radiation Monitors General Si mpling";

67.000.503 (revision 3)"Offgas Vent Pipe Sampling";

3-D10-RWC (revision 3)"RW Building Vent Exhaust Radiation Upscale";

3-D12-RWC (revision 5)"RW Building Vent Exhaust Radiation Upscale Trip";

4-D1-RWC (revision 4) " Waste Collection Tank Level High"; and

5-D14-RWC (revision 4)" Reactor Building Floor Drain (Torus) Sump D065 Level High".

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