IR 05000155/1987019

Insp Rept 50-155/87-19 on 870803-07.Violations Noted.Major Areas Inspected:Chemistry Program,Including Mgt Organization & Training Qualifications,Procedures & QA & Chemistry Lab & Water Chemistry Control

ML20238D919
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/04/1987
From:	Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20238D913	List: IR 05000155/1987019 ML20238D911 ML20238D916
References
50-155-87-19, NUDOCS 8709110503
Download: ML20238D919 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/87019(DRSS)

Docket.Ni 50-155 License No. DPR-6 Licensee: Consumerc Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant Inspection At: Big Rock Point Site, Charlevoix, Michigan Inspection Conducted: August 3-7, 1987 (Onsite)

h. b. , aw N Inspectors: R. B. R61tzman

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h h/87 Date ,a+uube-J. E. Hbuse f///B7 Date . Y Approved By: M. humacher, hief MS7 Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on August 3-7, 1987 (Report No. 50-155/87019(DRSS))

Areas Inspecte Routine announced inspection of the chemistry program, including: (1) management organization and training qualifications, procedures and quality assurance; (2) the chemistry laboratory and water chemistry control; (3) confirmatory measurements of nonrociolgical samples, and (4) review of LER 87009 relating to the release of a dirty liquid radwaste tank without proper radiological monitorin Results: No violations or deviations were identified in five of the six areas inspected. One apparent violation was identified in the area of radwaste operations for failure on July 4 and 5,1987, to properly initiate a radwaste tank release when the Radwaste Effluent Monitor was inoperable due to the monitor discharge valve being close B70904 PDR ADOCK 05000155 O PDR

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DETAILS Persons Contacted

• T. W. E1 ward,. Plant Manager

• C. R..Abel', Production and Performance Superintendent

• L.' Beer, Chemistry / Health Physics Superintendent

• J. Garrett, Chemistry / Health Physics Supervisor

'4 *T. R. Fisher, Senior QA Consultant,'QA-NA

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R. J. Alexander, Technical Engineer, Licensing Interface R.'L. Burdette, Senior Health Physicist R.'Bearss', Chemistry / Rad Protection Technician (CRPT)

L. Darrah, Shift Supervisor o D. Staton,' Shift Supervisor A. Colby, Auxiliary Operator The inspectors also interviewed other licensee personnel in the course of the inspectio * Denotes those present at the plant exit interview on August 7, 1987.

L 2. ' Management Controls and Organization The Superintendent of- the Chemistry / Health knysics Depurtii;6nt reports directly to the Plant Manager, and is supported by the director of the chemistry laboratory, the Chemi'stry/ Radiation Protection Supervisor, a Senior Health Physicist, a General Engineer, the ALARA Coordinator, and the General Nuclear Emergency Planner. .-The Senior Health Physicist is knowledgeable in chemistry and among his other duties, provides support to the Chemistry Program. The Department has 12 Chemistry / Health Physics Technicians (CHPT), who split their time about equally between health physics and chemistr The Superintendent, Supervisor and Senior Health Physicist appear to be qualified under the standard ANSI N18.1-1971 (T/S 6.1.1). However, only about four of the CHPTs have had-the three years of experience required for qualificatio Except for one trainee, the remaining CHPTs will qualify within another year. The staffing appears to be adequate to perform the chemistry operations required for this plan A licensee representative stated that the technician training program has been modified according to INPO criteria and is in place for accreditation; INP0 has scheduled a site visit for October 198 No violations or deviations were identifie = _ _ _ - _

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3. Water Chemistry Control Program i The plant does not presently have a formal water chemistry control program based on the BWR Owners Guidelines, either as a corporate policy statement or as a procedure. They do have administrative limits based mainly on the Technical Specifications (T/S), but their actual action limits (not formalized) are similar to those of the Guideline i No list of "Out-of-Specification times" is maintained since the only formal ;

specifications were those in the T/S which have values several orders of '

magnitude greater than the normal operating conditions; e.g., the T/S limits for chloride and conductivity were 1 ppm and 10 pmho/cm compared to operational conditions below 20 ppb and 0.08 pmho/cm, respectivel :

The licensee maintains trend charts for various chemical parameters, including specific conductivity, chloride, turbidity, dissolved oxygen, boron, and silica in water from the reactor systems: the reactor, condensate storage tank, condensate pump discharge, demineralized effluent, and reactor cooling water. The data on the charts demonstrate ,

that these parameters are maintained at low values, especially when at power. The pH values were also trended and were generally maintained within a narrow band. The inspectors noted that only a limited number of chemical parameters are measured. However, this lack of analyses is compensated for by the tight limits maintained on conductivity (less than 0.08 pmho/cm in reactor water). Controlling this parameter also controls the limits on the concentrations of the critical ionic species, such as chloride and sulfate, and shows that neither is greater than 20 pp The inspectors also noted that some of the plots, especially those for conductivity were too compressed to give a good picture of the variabilitie Licensee representatives agreed to look into modifying the plots. This will be followed in subsequent routine chemistry inspections of the water quality control progra Overall, the water quality control program appears to be adequate in controlling the critical parameters of the reactor system. The licensee agreed to review the BWR Guidelines and to submit by November 15, 1987, a letter or other document establishing a more formal progra This will >

be followed under Open Item (No. 50-155/87019-01). l

No violation or deviations were identifie )

J 4. Implementation of the Chemistry Program j i Laboratory Operations j The inspectors reviewed the chemistry programs, including physical facilities and laboratory operation Bench space was marginally adequate and housekeeping was goo The laboratory was in the

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i-radiologically-controlled area of the plant and both radioactive L and nonradioactive analyses were performed in the same general l areas. The laboratories were reasonably well equipped, includin a Photochem organic carbon analyzer, a Bausch and Lomb Spectronic 2000 Spectrophotometer, a Cahn TA4100 balance, a Hellige Turbidimeter, a Leeds and Northrup Conductivity Bridge and a Perkin-Elmer Model 306 Atomic Absorption Spectrophotometer. While the laboratory lacked an ion chromatograph, an_ instrument essential for the determination of low levels (< 20 ppb) of the corrosive chloride and sulfate ions'

it appears to be unnecessary if the conductivities continue to be maintained at the low levels presently found in this reactor system (Section 3). ,

Equipment maintenance schedules and records were documented in a logbook available in the laboratory and appeared to be curren Reagents prepared in house were appropriately labeled and referenced in a reagent logboo ' Quality Assurance / Quality Control'in the Laboratory The inspectors reviewed the nonradiological laboratory QA/QC program for measurements control. The licensee maintains control charts on  ;

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instrument performance for each set of analyses, including silica, chloride, copper, iron and phosphorus. Control limits are set at '

90 to 110% recovery, i.e., the apparent concentration of the analyte in a control sample relative to that known to be in the sample. The inspectors noted some concerns that the control limits were set arbitrarily at 110% of the recovery value, with no statistical bases, but since the system appears to be working this was not pursued to any extent. They also noted that the determinations were based on graphical calibration curves where most of the measurements done were in very small regions of the plots, thereby limiting the accuracie The inspectors suggested that the scales could easily be expanded to improve both the readabilities and accuracies of the measurements. The licensee representatives noted that they would consider these suggestions. This will be followed in subsequent routine chemistry inspection The licensee maintains an interlaboratory crosscheck and technician testing program with a vendor (Environmental Resources Associates)

to assist in the laboratory QA program. Samples are received monthly and each technician is tested yearly on various analyses, including conductivity, chloride, pH, hardness, copper and iron. A review of selected data showed fairly good agreement based on vendor acceptance l limits of the licensee results with those of the vendo No violation or deviations were identifie !

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5. Nonradiological Confirmatory Measurements The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to Technical Specifications and other performance criteria. These samples had been prepared, standardized, and periodically reanalyzed (to check for stability) for the NRC by the Safety and Environmental Protection Division of Brookhaven National Laboratory (BNL). The samples were analyzed by the licensee using routine methods and equipmen The samples were diluted by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate in a manner similar to that of routine sample The results are presented in Table 1 and the criteria for agreement in Attachment These criteria for agreement are based on comparisons of the mean values and estimates of the standard deviations (s.d.) of the measurements. Consideration was given to the fact that the uncertainties (s.d.) of the licensee's results were not necessarily representative of the laboratory's because they were obtained by one analyst over a short period of time. Consequently when the licensee s.d. was less than that of BNL, and a disagreement resulted, the BNL value was substitutert for that of the licensee in calculating the s.d. of the ratio Z (S inz Attachment 1).

The licensee also prepared two samples to be split with BNL. Reactor water was spiked with chloride and samples of feedwater were spiked with copper and iron. The licensee will determine the analytes in each and the results will be sent to Region III for comparison with the values determined by BNL. This will be followed under Open Item (No. 50-155/87019-02).

The licensee analyzed five sets of samples with three concentrations each of boron, chloride, iron, copper and silica. Twenty of the 21 analyses resulted in agreement with the BNL Values. The analytical procedures for boron and silica were conventional, but those for the other analytes were older turbidimetric and calorimetric methods not usually used today in nuclear plant laboratories. These methods, nevertheless, yielded results with precisions and accuracies such that only the result from the sample with the low copper concentration was in disagreement. Copper and iron analyzed by atomic absorption spectrophotometry (AAS), a more modern technique in the process of being implemented by the licensee, were all in agreemen Significant biases relative to the BNL values of about 11 to 14% i occurred in the two lower-level chlorides (turbidimetric), in the lower-level calorimetric iron and silica, and in all the calorimetric copper analyses, while other analyses had biases of 6% or les l

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Overall,.the precision and accuracy were comparable to-those,of BNLLand

' generally good. Most of the weaknessesfappeared to be inherent in the

! calorimetric and-turbidimetric methods, which were generally'within acceptable limits,-and not due to technician technique The licensee ~used multiple point calibration curvec for.all analyses,.which appeared to contribute to overall performance. .The use of independent-

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- controls, i'.e. , standards for the control samples from different sources or manufacturing: lots than the calibration standards,.was discussed with

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the licensee as a means of monitoring analytical performance. This item

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will be followed under Open Item (No. 50-155/87019-03).

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No violations or deviations were identifie ~ Licensee Internal. Audits The inspectors reviewed the findings of the most recent internal audit of the licensee QA Department, QT-86-10. The report had one finding relating g to the safety of the storage of acids and bases side by side, and four observations, one to check the mixing time in the Liquid Poison Tank required to obtain a representative sample of the sodium pentaborate solution, and a second relating to the. calibration of the inline conductivity cells in the reactor system when the electronics of these cells are. calibrated. The remaining observations relate.to the specifications of gases and bulk chemicals. The Chemistry Department responded to the QA findings in a timely manne No violations or deviations were identifie . Licensee Event Report (LER)

The' inspectors reviewed LER 87009 involving the failure to monitor a planned effluent release-from.the No.'l Dirty Radwaste Receiver Tank on July 4-5, 1987. On July 4, 1987, a sample was taken from.the tank and a radiological analysis made te determine the allowable release rate from the tank in accordance with T/S 13.1.2.1. The Shift Supervisor then M authorized the plant operators to release the tank contents in accordance with Plant Procedure 0-RWS-2, " Liquid Radwaste Release to Discharge Canal, Dirty Waste Receiver Tank," Revision 10, November 5, 1985. On July 5, l 1987 at 0045. hours, following shift turnover, the control room operator l observed that the Radwaste Effluent Monitor (REM) reading appeared to be 1 abnormally low and an auxiliary operator was dispatched to check the valve ]

lineup. He reported that the REM discharge valve had been closed, resulting in no flow through the monitor, and that the release'was essentially complete at that time. The release valves were closed and the Chemistry Department sampled the residual contents of the tank and q the canal discharge tank. This absence of flow was the cause of the low readings on the monitor and resulted in operation outside the requirements 1 of T/S 13. I i

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The licensee attributed the root cause of the event to personnel error resulting from a series of misjudgments. First, the auxiliary operator, who had lined up the valves and started the release, had not opened the discharge valve to.the monitor. He checked the valve, but it was very tight and sufficient torque was not applied to remove the gete from the seat which lead him to believe that it to was already open. .Further, after starting the release, he did not check the sight glass to verify-the flow to the monitor. Finally, although the control room operator had noted an increase in the monitor reading, he failed to recognize that it was smaller than expected for a batch releas Subsequent to the release, the Chemistry Department checked the activity remaining in the tank and that in the canal discharge tank and concluded, based on the activities found before and after the release, the release-rate of 14 gpm, and the dilution with over 50,000 gpm that the the activity at the point of release was within the limits of 10 CFR Part 20, never exceeding 0.26 MP The licensee took several corrective actions to prevent recurrence of the event by counseling and giving disciplinary warnings to the employes involved, by issuing a memorandum describing the occurrence and corrective actions to prevent a recurrence, initiating changes in the procedure and setting up plans for improved training of the operator This event appears to be a violation of Big Rock Point Radiological Effluent Technical Specification 13.1.1 that requires that the Radwaste Effluent Monitor-be in service at all times. However, the action statement for this specification does permit effluent releases via this pathway with the monitor inoperable, provided that prior to initiating a release: At least two independent samples are analyzed in accordance with Specification 13.1.2.2, and the release rate calculations and discharge line valving are verified by at least two technically qualified members of the Facility Staf Contrary to the above, on July 4 and 5, 1987, a planned release was initiated without the Radwaste Effluent Monitor being valved into service as required by TS 13.1.1. Normally, the NRC would not assess a violation for this event because it was identified and reported by the licensee, it fits in Severity Level IV, was corrected promptly and was not a violation that could reasonably be expected to have been prevented by corrective action for a previous violation. However, because the licensee missed three opportunities to correct the situation, namely, by checking the valve, observing the flowmeter, or properly interpreting the mointer, reading, this considered a violation (Violation No. 50-155/87019-04).

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. .. Open Items Open items are matters which have been discussed with the licensee, whic will.be reviewed'further by the inspectors, and which involve some action-on the part of_the NRC or licensee, or both. Open it. ems were disclosed 1 during the it;spection in Sections 3,_5, and ' Exit Interview The scope and findings of the inspection were reviewed with licensee  !

representatives (Section 1) at the conclusion of the inspection on  !

August 7, 1987. The inspectors discussed the results of the l nonradiological confirmatory measurements in Section 5. They stated that the matter of the improper monitoring of the radwaste release discussed in Section 7 (LER 87009) would probably be considered a violation of Technical Specification During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. Licensee representatives did not identify any such documents or processes as proprietar Attachments: Table 1, Nonradiological Interlaboratory Test Results, August 3-7, 1987 Attachment 1, Criteria for Comparing Analytical Measurements l

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DRAFT TABLE 1 l

Nonradiological Interlaboratory Test Results Big Rock Point Nuclear Plant August 3-7, 1987 c

Analyte Analysfs Oilution NRC Licensee Ratio Comparison Method 1:x (x) Y i s.d.(n) X i s.d.(n) Z i Concentration, ppm B Titr 33 (7) 1019 i .019 i 0.011 A 33 i 46(7) 3053 1 12 1.010 1 0.016 A 33 (7) 5108 1 18 1.033 0.018 A*

Cl- Turb 1000 24.1 1 3.1(7) 20.5 i 1. 5 0.851 1 0.13 A 1000 37.4 1 1.2(7) 4 .0 1.123 1 0.088 A 1000 80.5 1 2.2(8) 84.0 1 .043 1 0.047 A Silica Spec 2000 54.3 1 5.6(7) 62 14 1.142 1 0.139 A 1000 109 1 7.0(7) 115 i0 1.055 0.062 A 1000 160 1 5(7) 169.7 1 .044 1 0.040 A Cu Spec 50 4.68 1 0.24(12) 5.60 1 0.30 1.197 0.089 0 50 9.66 1 0.49(14) 10.7 1 0.70 1.108 0.092 A 50 14.5 1 0.6(12T 16,2 1 0.52 1.115 1 0.058 A+

Cu AAS 20 4.68 i 0.24(12) 4.83 1 0.076 1.032 i 0.055 A 20 9.66 1 0.49(14) 10.2 * 0.19 1.053 1 0.057 A 20 14.5 1 0.6(12) 15.2 1 0.03 1.047 0.043 A Fe Spec 50 4.89 1 0.35(13) 5.53 1 0.06 1.131 1 0.082 A '

50 9.55 1 0.34(14) 10.0 1 0.26 1.047 1 0.052 A 50 1 .42(13) 14.8 1 0.13 1.012 1 0.030 A Fe AAS 20 4.89 1 0.35(13) 5.03 1 0.15 1.029 0.080 A 20 9.55 1 0.34(14) 9.90 1 0.10 1.037 0.038 A 20 14.7 1 0.42(13) 14.9 1 0.058 1.016 1 0.029 A Value i standard deviation (s.d.); n is number of BNL analyse The number of licensee analyses is 3 unless otherwise note Analytical methods: Titr - titration Turb - Turbidimeter Spec - Spectrophotometric A = Agreement D = Disagreement

• Substituted the BNL uncertainty for licensee's uncertaint + Borderline of acceptance limi _

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ATTACHMENT 1 Criteria for Comparing Analytical Measurements This attachment.provides criteria for comparing results of the capabilit,y test Theacceptancelimitsarebasedontheuncertainty(standarddeviation)olthe ratio of the licensee's mean value (X) to the NRC mean value (Y), where c (1) Z = X/Y is the ratio, and I^ i-(2) S is the uncertainty of the ratio determined from the - -

pfopagationoftheuncertaintiesoflicensee'smeanvalue,

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Sx , and of the NRC's mean value, S .1

y Thus,

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z _ 52x 52 y so that 72- F , _yz_,

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y2 (X2 The results are considered to be in agreement when the bias in the ratio (absolute value of difference between unity and the ratio) is less than.or equal to'twice the uncertainty in the ratio, l'l-Z l < 2*S z-

, National Council on Radiation Protection and Measurements, A Handbook of Radioactivity Measurements Procedures, NCRP Report No. 58, Second Edition, 1985, Pages 322-326 (see Page 324).

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