IR 05000341/1986002

Insp Rept 50-341/86-02 on 860113-17 & 0203.No Violation or Deviation Noted.Major Areas Inspected:Gaseous & Liquid Radioactive Program,Including Effluent Release Records & Repts of Effluents & Effluent Control Instrumentation

ML20137U083
Person / Time
Site:	Fermi
Issue date:	02/12/1986
From:	Hueter L, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137U055	List: IR 05000341/1986002 ML20137U050
References
50-341-86-02, 50-341-86-2, NUDOCS 8602190050
Download: ML20137U083 (8)

Text

'

..

U.S. NUCLEAR REGULA' TORY COPNISSION

REGION III

Report No. 50-341/86002(DRSS)

Docket No. 50-341 License No. NPF-33 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Fermi 2 Inspection At: Fermi Site, Newport, MI Inspection Conducted: January 13-17 and February 3, 1986 AY NL.jJ.}lHueter Inspector: # ~ '# ' N Date Yh . h O'"## " p-j3.J6 Approved By: . C. Schumacher, Chief Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on January 13-17 and February 3, 1986 (Report No. 50-341/86002(DRSS))

Areas Inspected: Routine, unannounced inspection of gaseous and liquid radio-active program including: effluent release records and reports of effluents; effluent control instrumentation; procedures- for controlling releases; coolant chemistry and activity; gaseous effluent filtration, review of occurrences involving radwaste releases and equipment, and operability of liquid waste system The inspection involved 41 inspector-hours or. site by one NRC inspecto Results: No violations or deviations were identified.

3 8602190050 060212 PDR ADOCK 05000341 G PDR

- _ _ _ _ - _ _ - _ - - - _ _ - _ - _ _ - - - _ _ _ - _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - -

m -.

,

DETAILS 1. Persons Contacted 2F. Agosti, Vice President, Nuclear Operations 12R. Anderson, Supervisor, Radiological Engineering S.'-Bartman, Acting General Supervisor, Chemistry 12J. Conen, Engineer, Licensing 12R. Eberhardt, Rad Chem Engineer 12E. Griffing, Assistant Manager, Regulation and Compliance 13G. Overbeck, Superintendent, Operations 2D. Pendergast, Consultant, Management and Ongoing Development 2E. Preston, Operations Engineer 12F. Reimann, Radiological Assessor 1M. Parker, NRC Resident Inspector 1 Attended the January 17, 1986, exit meetin Telephone conversation February 3, 198 aTelephone conversation February 7, 198 The inspector also contacted other plant staff during this inspectio . Gaseous Effluents The-inspector reviewed selected licensee records relating to airborne radioactivity releases for the period March 1985 through December 198 Licensee surveillance, analyses, and release quantification appeared to be in accordance with applicable station procedures and regulatory requirements given in Technical Specification Table 4.11.2.1.2-1. Two licensee identified and corrected exceptions involving surveillances are discussed belo Initial criticality was attained for Unit 2 in June 198 The unit.has been in an outage since October 198 A maximum power level of about 5%

was attained for a short period during startup tests before the outag No activity has been detectable in gaseous effluents other than trace quantities of natural occurring radon and its daughter product The licensee utilizes a Nuclear Data Standard Applications Sof tware System (LRW GRW) to quantify and control (comparison of actual dose with Technical Specification dose criteria) gaseous releases from each pathway (stack) as well as from all pathways c.ombined. Normally iodine and particulate data are updated weekly while noble gas data are updated'

monthly. Updating may be more frequent if needed as indicated by significant increase in monitor readings. The system also has provision for accounting for gross alpha, tritium and strontium 89 and 9 '

.

!

Another Nuclear Data Standard Applications Software System (RRRGS) is used to generate the semiannual effluent repor License Event Report (LER) 85-020-00, dated June 27, 1985, described failure to obtain required (Technical Specification Table 3.3.7.12-1)

grab sample from the Reactor Building (RB) exhaust while the RB effluent monitor was inoperable for a 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> period beginning about 1300 on June 3, 1985. Earlier on June 3, control room indication of all effluent monitors was lost and a two hour surveillance schedule was established to verify monitor operabilit This surveillance was not documented in the Nuclear Supervising Operator's log and the surveillance was not continued during succeeding shifts. The event occurred before initial criticality and no radioactivity was release Licensee corrective measures included discussions with operators regarding the importance of communicating both orally and through log entries. This was reinforced by a memo placed in the required reading file and the LER was reviewed in the requalification program for licensed personne On November 11, 1985, the licensee submitted to NRC, LER 85-070-00 regarding failure to comply with Technical Specification 4.11.2. requirements for 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> drywell grab samples when purging containment through other than the standby gas treatment system (SGTS). The surveillance requirement was exceeded by about 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> between October 11 and 13th while purging the drywell through the reactor building ventilation system. Chemistry technicians collected samples at required intervals but failed to recognize that the sampling pathway used had been isolated from the drywell and were therefore invali The cause of the problem was failure of chemistry technicians to follow prerequisites in Chemistry Procedure 78.000.69 to verify correct sampling system alignment. Licensee corrective measures included discussion with chemistry technicians and additional training regarding the importance of following all steps of procedures, including prerequisites. The applicable procedure was also revised to include a specific checkpoint to verify proper line up and flo Corrective actions specific to these licensee identified problems appeared satisfactor Generic actions to reduce the frequency of personnel errors were discussed with licensee management following the inspectio No violations or deviations were identifie . Liquid Effluents The inspector reviewed selected licensee records relating to liquid radioactive releases for the period March 1985 through December 198 Licensee surveillances, analyses, and release quantification appeared to be in accordance with applicable station procedures and regulatory requirements given in Technical Specification Table 4.11.1.1.1-1 with certain licensee identified and corrected exceptions discussed belo Only low levels of activity of a few isotopes have been identified in reactor water to date, namely Co 58 and 60, Cr 51, Mn 54, I 131 and

'

.

tritiu The most significant of these have been Co 58 and tritiu Owing to processing, most liquids are recycled; the remainder is batch released for reasons such as excess plant volume and chemical content (including organic content). In general, no identifiable activity has been detected in releases to date. The licensee has established a goal of zero liquid discharge. Currently, about 95% of processed liquids are recycle The licensee utilizes Nuclear Data software systems (like that used for gaseous releases) to quantify and control liquid releases on a batch basis and to generate the semiannual liquid effluent report The LER-85-007-00, dated May 24, 1985, described failure on two occasions between April 23 and 25,1985,- to obtain required (Technical Specification

'

3.3.7.11.b) eight hour grab samples. These samples were required while discharging radwaste sample tanks via the circulating water reservoir decant line with the decant line radiation monitor inoperable. The plant had not reached initial criticality and no radioactivity was expected and samples taken confirmed this. Further, the radwaste monitor on the radwaste line (before dilution) from the radwaste sample tanks was operating in both cases). The cause of the problem in one case was failure to recognize the requirement to sample due to a misunderstanding by the control room operator concerning the applicability of the-technical specification to the decant line monitor. As a corrective measure, a memo addressing the event and the need to consult technical

' specifications directly was made required reading for licensed operator In the second case, the chemistry . technician was late in obtaining the sample owing to unforeseen time delays. As a corrective measure, chemistry personnel were required to read a memo describing the event and its causes. Also, a procedure has been written and implemented which addressed technical specification surveillances and includes precautions concerning the importance of time intervals associated with technical specification sampling requirement LER-85-080-00, dated December 31, 1985, (updated January 17, 1986)

describes a similar failure to obtain required eight hour grab samples while discharging two radwaste sample tanks on November 27 and 28 with the decant line monitor inoperable (not turned on). The non-licensed operator (NPPO) failed to turn on the sample pump that provides flow to the decant line monitor because neither he nor the Nuclear Supervising Operator (NS0) used Procedure 50P 23.626 during system line up. It was mistakenly believed that the absence of a low flow alarm for the monitor was an indication that the monitor was in operation. fhe NSO and his supervisor, the Nuclear Assistant Shift Supervisor (NASS) were counseled and issued a written record of an oral reprimand regarding their failure to assure that system lineup was performed using the 50P. A standing order was written (and is to remain in effect until appropriate procedure revisions can be made).which requires double verification (one by a licensed operator) of operability of effluent monitors before a release is initiate A modification is being processed to change the alarm logic to enable the low flow alarm when the decant pump switch (rather

.

than the sample pump switch) is in the ON position. This will alert the control' room of low sample flow-to the radiation monitor whenever the decant pumps are running (decant pump switch ON), regardless of the status of the sample pump switc Samples taken from both tanks before the releases were initiated identified no detectable activit Further, the liquid radwaste effluent line radiation monitor, with capability to automatically terminate a release from the waste sample tanks whenever the setpoint limits are exceeded, was operational throughout both release The inspector reviewed the radiological aspects of an inadvertent draining of about 1.2 million gallons of water from the circulating water reservoir (CWR) to Lake Erie on October 17, 1985, as described in DER NP-85-0545. The event resulted from operation of the general service water system using a procedure having an error (wrong valve number). A sample of reservoir water contained no detectable activity. Further, the system is expected to remain free of' radioactivity. Therefore, this event had no radiological consequence Recognizing that the CWR could become a future potential release path, the licensee is adding a prerequisite (grab sample of CWR) to the procedure for operating the general service water system. Also, the procedure was corrected and measures taken to improve the technical review process for procedure The inspector reviewed radiological aspects of currently available data regarding a licensee internal Deviation Event Rt. port DER NP 85-0596 (also being tracked by the licensee by Radiological Incident Deficiency Report 85-11-1) involving a spill of between 17,000 and 35,000 gallons of water from a ruptured seam around the top of the condensate storage tank on November 17, 198 The plant had been shut down since October 11, 1985, for maintenance and installation of NRC required equipment. The release occurred af;er an electrical buss was deenergizea for work in connection with the installation of some equipmen With the buss deenergized, the control room level indicators were lost for the condenser hotwell and for the condensate storage tan The hotwell reject valves automatically opened and water was pumped from the hotwell into the condensate storage tank at.about 2600 gpm. The spill, lasting an estimated ten minutes, was identified by security personnel and was terminated by operations personnel who also made an ENS notificatio The liquid spilled into the concrete diked area having a clay / gravel bottom. Two drums (about 100 gallons) of the spilled water was recovered before the remainder soaked into the soil. Samples from the condensate storage tank showed a concentration of 1.3 E-6 pCi/ml for gamma emitters, principally-Co 58, (about 1.4% of MPC for release to an unrestricted area) and 1.8 E-5 pCi/ml for tritium (about 0.6% of MPC for release to an unrestricted area) or about 2.4 pCi of tritium total and about 0.2 pCi of gamma emitters based on a 35,000 gallon spil A sample of spilled water in the diked area had a somewhat lower concentration, 2 E-7 pCi/ml of Co 58. Preliminary data on some surface soil samples showed 1.6 E-6 pCi/gm Co 58 and 3.7 E-7 pCi/gm Co 6 "

.

A program of soil boring samples both inside and outside the diked area was begun in late December after evaluation of underground piping and cable locations but was stopped after an electrical cable was hi After further evaluation the licensee plans to resume core sampling about February 1. Initial samples have been sent to Teledyne for evaluatio Results are not yet available.- The licensee plans to issue a status report regarding plan of action by the first week of February. This matter was discussed at the exit and will be reviewed during subsequent inspection (0 pen Item 341/86002-01).

Corrective actions specific to these licensee identified problems appeared satisfactory. The November 17, 1985 CST rupture is still being evaluated. Generic actions to reduce the frequency of personnel errors were discussed with management representatives following the inspectio No violations or deviations were identifie . Reactor Coolant Chemistry / Radiochemistry The inspector reviewed the licensee's reactor coolant chemistry and radiochemistry data for the period of January through December 1985 (preoperation through five percent power) to determine compliance with technical specification chemistry limits in Table 3.4.4-1 and specific activity limits in Technical Specification 3. Chlorides, conductivity and pH have all remained well within technical specification limits and in general within the more restrictive EPRI guides. The dose equivalent I-131 activity reached a maximum in early September of about 3 E-6 pCi/gm. The licensee has not yet reached the plant condition requiring determination of 100/E pCi/g The licensee has a program for plotting and trending coolant chemistry parameters along with the changing technical specification criteria based on plant mode of operatio The licensee appears to now have implemented a good program for-controlling technical specification required surveillance The program includes scheduling, followup before it is too late to meet requirements, documentation, and three levels of revie Each surveillance procedure shows the technical specification criteria and reference for comparison with the measured or calculated valu No violations or deviations were identifie . Air Cleaning Systems Although technical specifications require testing of only the control room emergency filtration system (T.S. 3/4.7.2) and the standby gas treatment system (T.S. 3/4.6.5.3), the licensee also tests the other engineered safety feature (ESF) ventilation system (the technical support center (TSC)) as well as other plant filter train The non-ESF systems have HEPA filters but not charcoa Records showed that tests

-

1 I

were completed in early 1985 and met applicable technical specification criteri The licensee plans to replace or relocate four non-ESF filter housings befure the first refueling to upgrade the filter housing (two systems) and for ALARA reasons in the other two case No violations or deviations were identifie . Effluent Control Instrumentation The inspector reviewed calibration records and setpoints for gaseous and liquid effluent monitors with no problems being note The effluent monitor setpoints have been conservatively established at about twice background readin However, less restrictive, but permissible, setpoints are being established for three monitors all of which initiate ESF actuations. This action is being taken because of an occurrence in early January 1986 in which the control room HVAC emergency filtration system was initiated owing to an apparent anomalous spike on the radwaste building gaseous effluent monitor. The licensee stated that an LER will be forthcoming regarding the ESF actuation and that the problem of the anomalous spikes is being pursued with the vendo No violations or deviations were identifie . Startup - Comparison of Reactor Coolant Water Quality and Radioactive Effluents with Technical Specification Requirements As noted previously, the licensee has attained a maximum power level of five percent to dat As noted in Section 4, reactor coolant water quality has remained within technical specification requirements to dat Further, both gaseous and Ifquid effluents have remained within technical specification requirements to date as noted in Sections 3 and 4, respectivel . Startup - Comparison of Effluent Monitor Readings Against Known Effluent Concentrations To date, the absence or near absence of plant generated gaseous and liquid activity has not permitted meaningful comparison of effluent monitor readings against measured effluent concentration . Startup - Demonstrate that Gaseous and Liquid Radioactive Waste Systems Operate Per Design The inspector reviewed the liquid radioactive waste system to evaluate its operability in accordance with design. This system is comprised of two subsystems, the waste collection system (equipment drains and run off) and the floor drain collection syste Preoperational tests were completed and the system turned over to Nuclear Production on June 1, 1985. f x test exceptions remain open involving four pieces of equipment (oil co41escer, etched disc filters, filter aid system, and radwaste

L

,

, . . -

evaporators). The licensee plans to have this equipment operational in six months and this matter will be reviewed during a future inspectio (0 pen Item 341/86002-02).

The liquid radwaste system in general is operating satisfactorily and with the use of parallel or backup systems the licensee has been able to recycle an estimated 95% of liquids. A vendor liquid processing system has been onsite since before startup but has never been used and it is planned to return it to the vendor soo No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 3 and . Exit Interview The inspector summarized the scope and findings of the inspection ~with licensee representatives (Section 1) at the conclusion of the inspection on January 17, 1986,. and in subsequent telephone conversations on February 3, and 7, 1986. The inspector noted that personnel errors in one form or another were involved with the four LERs and two DERs having potential radiological consequences that were reviewed during this inspection and questioned the licensee regarding a generic approach to resolution of these recurring problem In response, the 1icensee representatives noted that two programs recently undertaken will address the recurring problem of personnel errors. To address NRC concerns regarding recent operational occurrences, the Reactor Operations Improvement Plan (ROIP) was initiated 12 to improve performance and provide corrective action in six broad areas including consequences of error Secondly, the licensee is developing a Radiological Improvement Plan (RIP)

that will similarly review the activities of the Radiological Controls and Chemistry group to enhance trend and problem. identification to permit early application of corrective measures. This plan is expected to be in place near the end of the first quarter of 198 The inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify such documents or processes as proprietar Letter dated October 19, 1985 - W. H. Jens to J. G. Kepple Letter dated November 27, 1985 - W. H. Jens to J. G. Kepple L_.__ _~__s