IR 05000155/1992025
| ML20128E188 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/01/1992 |
| From: | Steven Orth, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20128E181 | List: |
| References | |
| 50-155-92-25, NUDOCS 9212080018 | |
| Download: ML20128E188 (8) | |
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l U.S. NUCLEAR REGULATORY COMMISS!0N
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REGION 111 i
Report No. 50-155/92025(DRSS)
Docket No. 50-155 Lic'nse No. DPR-6 Licensee:
The Consumers Power Company 212 West Michigan Avenue Jackson, M1 49201 facility Name:
Big Rock Point Nuclear Plant inspection At:
Big Rock Point Site, Charlevoix, Michigan in:pectlon Conducted:
November l6-20, 1992 c...
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Inspector:
S. K. Orth Date
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'> v Approved By:
M. C. Schumacher, Chief Date Radiological Controls Section 1 insjlection Summar_Y DLsng_tjon on November 16-20. ISR_(flenort No. 50-305/91 'HDRSSL)__
arnLinipnifd; Routine announced inspection of: (1) the chemistry program (IP 84750) including, organization, reactor systems water quality control programs, quality assurance / quality control program in the laboratory, and nonradiological confirmatory measurements and (2) the Radiological Environmental Monitoring Program (REMP) (IP 84750).
Bnultn The licensee's nonradiological measurements continued to be good.
Quality control of analytical measurements and water quality were adequate.
The licer. set 1ad undergone a organizational change which had removed radiation protection technician duties from the chemistry technicians (Section 2).
9212000018 921201 PDR ADOCK 0500
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DETAILS
1.
Enttons Contacted
'G. Withrow, Engineering Superintendant
'E. Bogue, Chemistry and Health Physics Superintendent
'J. Beer, Chemistry and Health Physics Superintendent
'W. Trubilowicz, Operations Superintendent
'R. Burdette, Senior Health Physicist
'R. Hill, Senior Performance Assessor
'D. Houghes, Executive Engineer
'M Bourassa, Senior Licensing Technologist C. Barsy, Chemistry Technician D. Parish, Chemistry Technician
'Present at the Exit Meeting on November 20, 1992.
The inspector also contacted other licensee employees in the course of the inspection.
2.
liangementlontrol and Ornanization (IP 84750)
The inspector reviewed 1. Chemistry Unit organization and discussed it with the licensee. The chemistry and health physics department had been separated into a chemistry unit and a health abysics unit effective July of 1990.
Both units continued to report to tie chemistry and health physics superintendent, who reports to the plant manager.
Of the former
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pool of chemistry / health physics technicians, four technicians have become exclusively chemistry technicians.
This group appeared to be very stable, the newest member having been in the group for four years.
This number appears to be adequate to perform the necessary coverage for this area.
The position of Chemistry and Health Physics Superintendent was being transferred to a new individual.
This person appears to have an adequate background in both chemistry and health physics.
She will formally take over the position on January 1, 1993, follov.ng what will be approximately three months of turnover from the former superintendent.
No violations or deviations were identified.
3.
Confirmatory Measurements (IP 8471Q1 The inspector submitted chemistry samples to the licensee for analyses as part of a program to evaluate the laboratory's capabilities to
monitor nonradiological chemistry parameters in various plant systems with respect to regulatory and administrative require =nts.
These samples had been prepared, standardized, and verified for the NRC by the Analytical Chemistry Division of Oak Ridge National Laboratory.
The
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samples were analyzed by the licensee using routine methods and equipment.
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Three dilutions were made for each sample by licensee personnel as
I necessary to bring the concentrat!ons within the ranges normally l
analyzed by the laboratory, and were analyzed in a manner similar to l
that of routine samples.
lhe results are presented in Table I which I
also contains the criteria for agreement.
These criteria are based on
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analyses of the standards and on the relative standard deviations (RSD)
derived from the results of the plants participating in the 1986 interlaboratory comparisons (Table 2.1, NUREG/CR-5422).
The acceptance criteria are such that the ratio of the licensee's result an the standard value should be within 2 Standard Deviations (SD) of the standard value for agreement and between 2 and 3 SD for a qualified agreement. A qualified agreement may indicate a bias in the assay.
The li ansee determined five analytes at three concentrations each and one at two concentrations. Of the initial 17 analyses 12 were agreements, 3 were qualified agreements and 2 (chloride and baron) were disagreements.
After evaluating the licensee's cross check program results and their quality control trend ch;rt:,, the licensee and the inspector noted that there may have been a bias from a poor calibration standard.
The chloride analytes were reanalyzed after the instrument was recalibrated with a new calibration standard which r?vnted in three agreements.
It appears that the extreme dilutions, approximately 8000 to 1, required to bring the boron sample into the licensee typical working range contributed to the boron disagreement. When the licensee reanalyzed this analyte using a two-step dilution process instead of one vary extreme dilution, the one boron disagreement resulted in a qualified agreement. As this is the concentration of boron which would be analyzed to ensure reactor shutdown following the injection of the liquid boron poison the licensee agreed to place additional emphasis in performing analyses at this concentration range.
Tt.e inspector observed the chemistry technician performing the sample dilution and analyses and noted that good laboratory technique were used.
No violations or deviations were identified.
4.
Training _and Oyalificnion of Personnel (IP 84750.)
The inspector reviewed the licensee's training as required by administrative procedure 1.7.1, " Chemistry and Radiation Protection Technicians On-The-Job Training Program", Revision 6, October 24, 1991, and " Big Rock Point Chemistry / Health Physics Department On-The-Job Training Manual", Revision 7, August 25, 1992.
These documents contained adequate criteria and standards for the training of chemistry technicians.
The chemistry technician qualification program was comprised of three qualification levels.
Technicians must be qualified for a specific task via the qualification cards prior to performing that task independently.
Each task had a comprehensive listing of specific standards to be achieved for that task. The inspector discussed the current level of
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technicians' qualification with the litensee.
Two chemistry technicians were fully qualified at all levels. The remaining two technicians had only a minimal amount of the final qualification level to complete.
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No violations or deviations were identified.
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Wlist Chemistry Co_n_1rol Proaram (IP 8475Q1 5.
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The inspector reviewed the licensee's water chemistry control program.
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The licensee maintained administrative limits on water quality, as
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defined in administrative procedure 5.21, " Water Chemistry Guidelines",
Revision 2, July 23, 1991, which me the CPRI BWR Owners Group Guidelines.
The inspector reviewed selected trends in water quality over the period of January of 1991 through November of 1992 and found most chemistry parameters to be well maintained, following a sulfuric acid contamination of the demineralized water storage tank, the sulfate level and conductivity in the prirnry system, condensate storage tank, and demineralized water stwage tank became highly elevated.
The description of the event and the licensee's proposed corrective actions wer: documented in Ins)ection Report No. 50-
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155/92015(DRP). At the time of this inspection, tie licensee had met thir commitments with the exception of the installation of a reverse osmosis makeup system.
The 'icensee expected this system to be i
installed by November of 1993.
Until that time, the licensee will continue to obtain makeup water from an f 'erim system.
A review of selected data for the )ast year indicated that water quality was good.
With the exception of tie excursion discussed above, reactor coolant chloride and sulfate averaged less than.1 and 3 parts per billion (ppb), respectively, with EPRI guidelines of 15 ppb for both.
The reactor water conductivity averaged 0.10 micro Siemen/cm (uS/cm)
with EPRI guidelines of 0.20 uS/cm.
Feedwater dissolved oxygen and condensate conductivity were maintained within the EPRI guidelines of 20-50 ppb and 0.08 uS/cm, respectively. However, the total feedwater iron and copper level were maintained either near or above the EPRI action levels.
The licensee did not view this as a significant problem; however, they did acknowledge that these levels contribute to radiation doses in the plant.
The licensee had ordered a new type of ion exchange resin which they postulate will reduce the levels.
The chemistry and plant management reviewed the chemistry parameters on an appropriate frequency and took necessary actions when action levels were exceeded.
No violations or deviations were identified.
6.
Imnlementation of the laboratorv OA/0C Proaram (IP 84750)
Chemistry quality control was adequate. The inspector reviewed the-chemistry quality control program as defined in CLP-06, " Control Charts", Revision 0, May 14, 1991. The licensee continued to maintain statistically based control charts for most of the laboratory instruments, to participate in an interlaboratory cross-check pogram, and to perform semiannual technician proficiency testing.
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The licensee maintcined control charts for each instrument, with the exception of the atomic absorption spectrophotometer (AAS), with warning and control limits set at i 2 and 3 standard deviations, respectively.
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The inspector reviewed selected control charts and noted that the
control criteria for the AAS appeared excessive.
The acceptance criteria had been arbitrarily set at i 20 percent of the mean and had not been trended. Af ter discussions with members of the licensee's staff, this criteria was re-evaluated.
The licensee established a control chart with statistically determined acceptance criteria.
The 2 standard deviation warning level was determined to be about i 10 and 7 percent ior iron and copper, respectively.
Overall, the performance data showed normal variation about tho mean values for each instrument. The chloride analysis did show an overall positive bias which was resolved in the course of this inspection, as noted in Section 3.
The licensee had recently aurchased the instrument for this analysis and had contributed some of t11s error to fine tuning the instrument's performance. Overall, the licensee's actions adequately addressed the performance problem. Other biases in performance were properly noted, and appropriate actions were taken.
The inspector discussed the calibration of laboratory instruments with
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licensee personnel.
Most calibration standards were independent from i
the aerformance check standards.
The licensee was still in the process of o]taining independent performance check standards for the AAS.
The licensee's performance in their analytical cross-check program was adequate.
The inspector reviewed the licensee's results from 1991 through 1992 in which the licensee obtained 21 agreements in 27 comparisons.
The licensee applied the technicians performance in the cross-check program as an indicator of technician proficiency.
The review of results from the licensee's chemistry technician testing program indicated that the technicians were tested as required and that
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their performance was adequate. -Corrective actions were documented for analyses outside of the acceptance criteria.
No violations or deviations were identified.
7.
Post Accident Samplina System (PASS) (IP 84750)
The inspector toured the licensee's ;' ASS system.
Liquid PASS samples are obtained from a valve on the bottom of the core spray heat exchanger.
Annually, a sample is drawn to determine any corrosion in the sampling equipment. The sample can only be obtained when core damage is estimated to be less than ten percent. Accident assessment beyond ten percent is obtained via containment air monitors / samplers and area radiation monitors.
No violations or deviations were identified.
8.
Badiolocical Environmental Monitorina proaram (REMP)
LIP 84750)
The inspector examined the REMP, including the 1991 Radiological Environmental Monitoring Report, and toured several air sampling stations.
The REMP has been implemented in accordance with the Technical Specifications (TS) requirements, and in several instances, sampling exceeded the TS requ. ements.
Samples which were not obtained
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were documented in the report as required.
The review of the report did
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not indicate any abnormal radiological ralease to the environment.
The inspector toured several of the air sampling stations with licensee's sample collector. The sample collector appeared to be knowledgeable about the program and demonstrated good technique in air filter replacement.
He had developed a performance chart for each of the air pumps to indicate degrading pump performance.
The sample collector also adequately implemented the p"ocedure to evaluate air inleakage of the sampling train. However, the inspector noted that the air inlets were in a position which could cause them to be encased in snow.
The sample collector made the necessary adjustments to prevent this.
No s'olations or deviations were identified.
9.
Audits and Appraisals (IP 847521 The inspector reviewed chemistry audits QT-90-15 and QA-91-24 conducted in July of 1990 and August of 1991, respectively, in addition the 1991 environmental monitoring audit, QT-91-05, and the qualification of auditors performing chemistry audits were reviewed.
The audits appeared to be technically sound and performed in sufficient aepth.
The-inspector noted that the audit findings were evaluated by the licensee's staff and properly resolved in a timely manner.
The nditors appeared to be well qualified based on education, experience,
~ caining.
No violations or deviatiens were identified.
10.
Exit Interview
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N e scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on November 22, 1992. During the exit interview, the inspector discussed
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the likely informational content 'or the inspection report with regard to l
documents or proc sses revie"ed during the inspection.
Licensee representatives did not ioentify any such documents or processes as prc rietary-The following matters were.specifically discussed by the
intr ctor:
a, nonradiological sample split results, stressing the difficulty encountered due to the great difference in the concentrations between the supplied samples and the boron samples normally analyzed and the inaccuracies due to the chloride calibration (Section 3);
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the chemistry quality control program (Section 6); and c.
plant water chemistry, including corrective actions following the sulfuric acid contamination of the demineraitzed water makeup system (Section 5).
tachment.
Table 1, Nonradiological Interlaboratory Test Results, November 16-20, 1992
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TABLE I Nonradiological Confirmatory Measurements Results Big Rock Point Nuclear Station November 16-20, 1992 I
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5 Analyte Method Conc Ratio Acceptance Ranges Result 1 2f.I; i 3RSD
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LWD Chloride A
1.178 0.933-1.067 0.000-1.100 D
B
1.116 0.917-1.0f!
0.879-1.121 A+
C
1.086 0.526-1.0'i4 0.895-1.lf A+
Rerun A
0.973 0.933-1.067 0.900-1.100 A
40 0.927 0.917-1.081 0.879-1.121 A
C
0.962 0.926-1.074 0.895-1.105 A
Sul f ate A
1.010 0.895-1.105 0.842-1.158 A
B d. 0 0.931 0.895-1.105 0.868-1.132 A
C
0.973 0.900-1.100 0.867-1.133 A
Baron
Titr 1250 0.968 0.979-1.021 0.968-1.032 A+
E 375 1.072 0.979-1.021 0.968 1.032
f 625 1.010 0.979-1.021 0.968-1.032 A
Rerun f
375 1.027 0.979-1.021 0.968-1.032 A+
PMB Iron G
AA/fL 0.5 1.050 0.904-i.096 0.85
.146 A
1.0 0.998 0.903-1.097 0.857-1.143 A
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'.5 0.943 0.903-1.097 0.855-1.145 A
Copper G
AA/fL 0.5 1.052 0.904-1.095 0.859-1.141 A
1.0 1.015 0.904-1.096 0.857-1.143 A
1.5 0.963 0.904-1.096 0.857-1.143 A
Silica S
Spec 0.15 0.985 0.906-1.094 0,859-l.141 A
T C.60 0.994 0.909-1.091 0.860-1.136 A
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Methods:
Titr - Titration IC
- lon Chromatography Spec
- Ultraviolet / Visible Spectrophotometry AA/FL _ Atomic Absorption Spectrophotometry (flame)
2, Conc: Approximate concentration analyzed.
3.
Ratto of Licensee mean value to NRC mean value.
4.
The standard h "iation (50) in the sixth and seventh columns represents the coefficient of variat; m obtained from averaging licensee data from the preceding
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f cycle (Table 2.1 of NUREG/CR-5244). A result is considered to be in agreerent if it o
falls within the i 2 SD range; a qtalified agreement if it lies outside 2 SD, but within i 3 SD; and in disagreement if it is outside the i 3 SD range.
5.
Result:
A = Agreement: Licensee value is within 12 SDs of the NRC mean value.
A+ - Qualified agreement, licensee is between 2 and 13 SDs of the NRC value.
D - Disagreement: licensee value is outside 13 SDs.
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