IR 05000206/1988015
| ML13316B912 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/03/1988 |
| From: | Tenbrook W, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B911 | List: |
| References | |
| 50-206-88-15, 50-361-88-14, 50-362-88-15, NUDOCS 8806220103 | |
| Download: ML13316B912 (12) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-266/88-15, 50-361/88-14, 50-362/88-15 Docket Nos. 50-206, 50-361, 50-362 License No. DPR-13, NPF-10, NPF-15 Licensee: Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre Nuclear Generating Station, Units 1, 2 and 3 Inspection at:
San Clemente, California Inspection Conducted:
May 16-20, 1988 Inspected by: 41'/( <
'
63 tP W. K. TenBrook, Radiation Specialist Date Signed Approved by:
(
- P. Y s, Chief Date Signed Faciliti Radiological Protection Section Summary:
Areas Inspected:
Routine unannounced inspection of plant water chemistry control and chemical analysis, radiochemical analysis, post-accident sampling, quality assurance of plant chemistry activities, and followup of Unresolved and Open Item Inspection procedures 92701, 84725 and 79701 were use Results:
Within the scope of the inspection, the licensee's program in the areas of chemistry and radiochemical analysis appeared adequate to fulfill its safety function. An improving trend was noted in the results of radiological confirmatory measurements (See Section 3).
One followup item was identified regarding the absence of correction factors to account for radioactive decay on particulate and iodine sampling media during sampling of air and gaseous effluent (See Section 3).
No violations or deviations were identifie PDR ADOCK 05000206 DCD
DETAILS Persons Contacted Licensee C. Couser, Compliance Engineer J. Davison, Chemistry Foreman, Unit 2/3
- Heflin, Chemical Engineer
- S. Jones, Engineer, Quality Assurance J. Joyce, Chemistry Technician, Unit 2/3
- R. McWey, Chemistry Supervisor, Unit 2/3
- J. Mortensen, Supervisor, Chemical Engineering
- J. Noyes, Technical Administration Supervisor, Chemistry
- P. Penseyres, Supervisor of Chemistry D. Todd, Technical Administrator
- R. Warnock, Assistant Manager, Health Physics
- M. Wharton, Assistant Manager,Technical V. Woodall, Chemistry Foreman, Unit 1
- J Young, Chemistry Supervisor, Unit 1
- M. Zenker, Compliance Engineer USNRC A. Hon, Resident Inspector
- J. Tatum, Resident Inspector
- Present at Exit Interview on May 20, 198.
Followup of Unresolved and Open Items (92701)
Open item 50-361/87-12-01 (Closed).
This item involved the inability of a particular Unit 2/3 gamma detector system to identify Cs-134, Cs-137 and Mn-56 in reactor coolant system (RCS) sample Inadequate resolution of the detector in question was implicated in the disagreement. The inspector observed that all detectors used for RCS surveillance met the licensee's criterion for resolution, and the detector in question was no longer in us The followup intercomparison for Mn-56 in RCS suspended solids was acceptable for all licensee detector system Cs-134 and Cs-137 were not identified in RCS liquid or suspended solid samples by the licensee or NRC during followup intercomparisons due to dominant short-lived activit However, Cs-134 and Cs-137 were commonly identified by the licensee in routine half-life check analyses of decayed reactor coolant and suspended solid The intercomparisons for Cs-134 and Cs-137 in liquid waste were satisfactor Thisitem is close Unresolved Item 50-361/87-12-02 (Closed). This item concerned a measurement disagreement for 1-132 in RCS suspended solid Further investigation by the inspector suggested that propagation of the uncertainty in the reference half-life for 1-132 over the lengthy decay time (greater than 10 half-lives, including NRC counting time) was the
probable cause of the disagreement. The followup intercomparison for 1-132 in suspended solids was satisfactory for all licensee detector system This item is close No violations or deviations were identified in this part of the inspectio.
Quality Assurance and Confirmatory Measurements for In-Plant Radiochemical Analysis (84725)
The regional mobile laboratory trailer was brought onsite for gamma isotopic intercomparisons with the licensee's counting laboratorie Sample types commonly analyzed for compliance with regulatory requirements were analyzed by the licensee and the NRC, and the results were compared using the NRC verification test criteria (see enclosure).
The first sample obtained was reactor coolant. The inspector observed the sampling operation in the Unit 2/3 chemistry laboratory. The Chemistry Technician performing the sampling followed the current Radiation Exposure Permit (REP) and the instructions posted in the work area. The Technician prepared three one gram aliquots of coolant from the original sample for analysis by the Unit 1, Unit 2/3 and NRC laboratories. The results of the intercomparison are presented in Table Table 1 1 gm Reactor Coolant Licensee/NRC Nuclide NRC uCi/ml NRC % Error Range Unit 1 Unit 2/3 Na-24 1.02 E-2.75-1.33 1.06 0.90 1-131 6.26 E-2.80-1.25 1.06 1.06 1-132 3.46 E-2.80-1.25 1.21 1.41 1-133 8.59 E-2.85-1.18 1.05 1.03 1-134 4.38 E-2.75-1.33 1.10 1.32 1-135 5.46 E-2.75-1.33 1.10 1.10 Cs-138 1.80 E-1.75-1.33 1.10 1.20 Ba-139 1.04 E-2 1.50-2.00 0.74 0.77 The intercomparison for reactor coolant was generally adequat Long-lived fission and activation products were not identified by the licensee or NRC due to dominant short-lived activity in the coolan The 1-132 activity provided by the Unit 2/3 laboratory was not in agreement. The Unit 2/3 analysis did not resolve the 669.8 keV and 671.6 keV 1-132 gamma rays from the predominant 1-132 emission at 66 keV, resulting in the total activity for the three emissions being assigned to the 667.7 keV gamma ra This disagreement appeared to be spurious, as it did not occur in other intercomparisons involving 1-132 measurements by Unit 2/ The second sample analyzed was suspended solids from 100 ml of reactor coolant deposited on a 47 mm particulate filter. The filter was
exchanged for analysis between the licensee and NRC laboratorie The results of the intercomparison appear in Table Table 2 Suspended Solids from 100 ml Reactor Coolant Licensee/NRC Nuclide NRC uCi/ml % Error Range Unit 1 Unit 2/3 "a" Unit 2/3 "b" Na-24 2.28 E-5 3.1 0.75-1.33 0.85 0.93 0.84 Cr-51 8.34 E-5 6.9 0.60-1.66 0.82 0.90 0.78 Mn-56 4.39 E-5 13.2 0.60-1.66 0.81 1.17 1.05 Co-58 1.40 E-4 1.0 0.80-1.25 0.90 0.84 0.83 Co-60 7.12 E-6 10.0 0.60-1.66 0.80 1.10 0.72 As-76 6.23 E-6 19.5 0.50-2.00 0.81 W-187 1.42 E-5 13.8 0.50-2.00 0.92 0.68 1.01 Np-239 2.45 E-5 3.2 0.75-1.33 0.95 1.00 1.33 Nb-95 4.02 E-5 2.1 0.75-1.33 0.93 0.92 0.90 Zr-95 4.41 E-5 3.0 0.75-1.33 0.89 0.79 0.91 Nb-97 5.15 E-5 2.0 0.75-1.33 0.92 0.86 0.84 Zr-97 4.59 E-5 2.1 0.75-1.33 0.93 0.92 0.97 Tc-99m 3.74 E-6 7.8 0.60-1.66 1.01 0.70 0.77 1-131 4.03 E-4 0.4 0.85-1.18 0.96 0.89 0.89 1-132 2.39 E-4 0.7 0.80-1.25 1.07 0.85 0.91 1-133 5.28 E-4 0.4 0.85-1.18 0.94 0.90 0.87 1-134 2.93 E-4 5.0 0.75-1.33 0.92 0.82 0.81 1-135 3.29 E-4 1.8 0.80-1.25 0.93 0.92 0.87 Cs-138 7.01 E-4 8.9 0.60-1.66
-
0.85 0.79 Ba-139 9.47 E-4 1.1 0.80-1.25 0.96 0.95 0.93 The intercomparison for the suspended solids filter was acceptabl The first two analyses, performed by the Unit 2/3 laboratory, did not identify As-76 as it was obscured by the compton background. The last two analyses, performed by the NRC and Unit 1, were able to detect As-76. The Unit 1 analysis did not identify Cs-138 due to deca The third sample obtained was a charcoal cartridge of Unit 2 containment atmosphere. The cartridge was exchanged between the NRC and the licensee. The Health Physics Department also participated in the intercomparison. The results are presented in Table Table 3 Containment Atmosphere Charcoal Cartridge Licensee/NRC Nuclide NRC uCi/ml % Error Range Unit 1 U 2/3 "a" U 2/3 "b" U 2/3 HP Br-82 7.22 E-11.75-1.33 0.84 0.90 0.86 0.83 1-131 2.42 E-9.85-1.18 0.92 0.97 0.92 0.93 1-133 1.58 E-10.80-1.25 0.88 0.92 0.91 0.91
The initial intercomparison of the charcoal cartridge sample was acceptable. The NRC laboratory performed an additional analysis of the cartridge employing a correction factor to account for decay of activity captured on the sample prior to the collection of the sampling media. The results of the intercomparison appear in Table Table 4 Charcoal Cartridge (NRC results corrected for decay during sampling)
Licensee/NRC Nuclide NRC uCi/ml,% Error Range Unit 1 U 2/3 "a" U 2/3 "b" U 2/3 HP Br-82 2.51 E-10.75-1.33 0.24 0.26 0.25 0.24 1-131 3.23 E-9.85-1.18 0.69 0.73 0.69 0.70 1-133 9.22 E-10.80-1.25 0.15 0.16 0.16 0.16 The intercomparison ratios obtained indicated that the licensee's analytical software did not correct for radioactive decay of sampled nuclides prior to removal of the sampling media. The licensee confirmed that this was the case. Although entries for time and date of initiation and termination of sampling are provided in the licensee's analytical software, the software vendor had not provided a decay correction algorithm employing these entrie The ratios for 1-133 in Table 4 are especially divergent based on the short half-life of 1-133 and the seven day sampling perio The inspector and the chemistry staff discussed the need for sampling period decay correction where the ratio of nuclide half-life to sampling time is smal Some issues were raised by the licensee regarding the accuracy of such a correction when effluent concentration varies significantly during sampling. Under these circumstances, the sampling decay correction could overestimate or underestimate the average concentration over the sampling period. However, it was agreed that the method used by the licensee would only be accurate if all effluent activity were to be deposited immediately before the end of sampling. In all other cases, the licensee's method would tend to underestimate the average effluent concentration over the sampling perio The licensee stated they would evaluate their methods for decay corrections involving particulate and iodine sampling media, implement sampling period corrections in their analytical software, and apply the sampling period correction to those samples where decay effects could be significant. This matter will be tracked as an Open Item (50-361/
88-15-01) pending completion of the licensee's corrective action The next sample obtained was one liter of liquid radioactive wast The results of the intercomparison are given in Table Table 5 One Liter Liquid Waste Licensee/NRC Nuclide NRC uCi/mi % Error Range Unit 1 Unit 2/3 "a" Unit 2/3 "b" Cr-51 1.89 E-6 2.50-2.00 1.15 0.85 0.64 Mn-54 3.89 E-7 1.60-1.66 1.16 0.86 1.15 Co-58 2.12 E-5.80-1.25 1.04 0.96 1.01 Co-60 1.35 E-6.75-1.33 1.06 1.06 1.09 Ag-110m 2.74 E-7 1.50-2.00 0.87 0.74 0.94 Sb-124 7.44 E-7 1.60-1.66 1.18 1.01 1.54 Cs-134 9.32 E-7.75-1.33 0.86 0.82 0.88 Nb-95 6.42 E-7.60-1.66 1.01 1.14 1.14 Zr-95 4.27 E-7 1.50-2.00 0.93 0.87 1.09 Sb-125 3.91 E-6.75-1.33 1.04 0.94 0.94 1-131 1.63 E-6.75-1.33 1.07 0.95 1.06 Cs-137 1.25 E-6.75-1.33 1.19 0.92 1.12 The intercomparison for liquid waste was acceptabl The final sample compared was one liter of gaseous waste from a waste gas decay tank. The licensee and NRC gas sample containers were connected in series and a sample of the tank contents was purged through the containers. The Unit 1 laboratory did not participate in the intercomparison. The results of the intercomparison are given in Table Table 6 One Liter Gaseous Waste Licensee/NRC Nuclide NRC uCi/ml % Error Range Unit 2/3 "a" Unit 2/3 "b" Ar-41 7.50 E-6.75-1.33 1.11 0.90 Kr-85m 2.89 E-7 1.60-1.66 1.00 0.71 Xe-133 3.22 E-4.85-1.18 1.02 1.01 Xe-133m 2.36 E-6 1.50-2.00 1.41 0.62 Xe-135 3.84 E-6.75-1.33 1.05 0.98 The intercomparison for gaseous waste was acceptable. The comparison ratios for gaseous waste were superior to those obtained in the previous inspection, principally due to proper splitting of the gas sample as opposed to exchanging the licensee's container between the NRC and licensee laboratorie The inspector reviewed records of quality control (QC) checks of radioanalytical instruments in the Unit 1 and Unit 2/3 chemistry laboratories to.verify that QC activities were conducted according to established procedures. The following areas were reviewed:
S0123-III-4.5, Rev. 3, "Operation and Calibration of Units 1, 2 and 3 Nuclear Data Spectrometer."
Daily checks of efficiency, energy calibration, resolution and background were performed at low and high gamma energies. Control charts were kept for background, efficiency and energy calibration checks. Calibration frequency was not specified in the procedure. However, the inspector verified that calibrations were perforified annuall S0123-III-4.9.2, Rev. 2, "Operation of the Eberline BC-4."
Daily background and beta source response checks were performed. Control charts were kept for both QC check S0123-III-4.9.3, Rev. 2, "Operation of the Eberline SAC-4."
Daily background and alpha source response checks were performed. Control charts were kept for both QC check S0123-III-4.10.2, Rev. 3, "Operation and Calibration of the Beckman LS 9800 liquid scintillation counter."
Logs and control charts of daily background and tritium efficiency checks were maintaine The inspector examined records of the licensee's interlaboratory comparison program for radiochemical analysi Liquid, solid and gaseous samples containing alpha, beta and gamma emitters were intercompared. The agreement criteria are basically those used by the NRC for radiochemical confirmatory measurement Reports from the licensee's contract laboratory for the 2nd quarter, 1987 to the 1st quarter, 1988, showed consistent agreement between the licensee and their contract laborator The inspector examined the licensee's procedures and records regarding surveillance testing of the Post-Accident Sampling Systems (PASS) at each Unit. Procedure S0123-III-8.1, Rev. 6, "Post-Accident Sampling System and Unit 1 Dedicated Safe Shutdown System Routine Surveillances", describes-the frequency of surveillances and acceptance criteria for analytical intercomparisons with routine sampling result From April, 1987 to April, 1988, PASS surveillances had been performed at intervals meeting or exceeding those specified. Quarterly intercomparisons for radioisotopic activity in the RCS and containment atmosphere were acceptabl The inspector observed several instances where surveillances were repeated in response to inadequate results from boronometers, hydrogen meters, pH meters and dissolved oxygen analyzers. The surveillance results indicated that the reliablility of these components of the PASS was poor. Procedure S0123-III-8.8, "Alternate Methods of Post-Accident Parameter Sampling", provided approved backup methods for RCS boron, pH, dissolved oxygen and hydrogen analyses as well as containment atmosphere hydrogen when reliability of the primary PASS method could not be demonstrated. The Chemistry Department was preparing a request for a system design change to replace or improve the PASS methods and instrumentation used for boron, pH, oxygen and hydrogen analyse The inspector reviewed SCE Quality Assurance Audit Report SCES-063-87, dated March 4, 1988, covering RCS water chemistry and PASS. The audit
emphasized compliance with chemistry-related technical specifications; 10 CFR 50, Appendix B design criteria affecting chemistry; and the EPRI PWR primary water chemistry guideline The scope and depth of the audit was adequate. Minor issues raised in the audit were tracked by Problem Review Reports (PRRs).
Some PRRs had not been closed due to the short interval between the audit and the inspectio No violations or deviations were identified in this part of the inspectio.
LWR Chemistry Control and Chemical Analysis (79701)
The inspector reviewed the licensee's chemistry control procedures for and secondary water chemistry at Units 2 and The following procedures were examined:
S0123-III-1.1.1, Rev. 4, "Unit 1 Chemical Control of Primary Plant and Related Systems."
S0123-III-1.1.23, Rev. 11, "Units 2/3 Chemical Control of Primary Plant and Related Systems."
Each of these procedures implemented the provisions of the RCS chemistry technical specification surveillance requirements, the Westinghouse owners group chemistry guidelines, and substantially implemented the EPRI Primary Water Chemistry Guideline The following secondary water chemistry control procedures were revi ewed:
S0123-III-2.1.1, Rev. 4, "Unit 1 Steam Generator & Condensate/
Feedwater Chemistry Control and Sampling Frequencies."
S0123-III-2.1.23, Rev. 5, "Unit 1 Steam Generator & Condensate/
Feedwater Chemistry Control and Sampling Frequencies."
These procedures provided sampling schedules, control limits and corrective actions consistent with the Steam Generator Owners Group and EPRI Guidelines. The procedures meet the requirements of technical specifications 6.8.4.d.i, v, and vi for each Uni The inspector reviewed available laboratory records of RCS and secondary water chemistry surveillances at each Unit. Table 7 describes the conditions observed in reactor coolant and steam generator blowdown at Unit 1 in Mode 5/6:
Table 7 Summary of Unit 1 Water Chemistry Conditions Analyte Reqd Frequency Action Level Frequency Observed Conditions RCS Cl 3-per Week
>150 ppb 3 per Week 2-4 ppb RCS pH 3 per Week 4.2-1 per Week 5.8-RCS Activity Weekly 100 uCi/cc Weekly
<1E-2 uci/cc RCS DEI N/A N/A Weekly
<9.3,>1 Shiftly 10.0-1 SG Hydrazine 3 per Week
<50 ppm Shiftly 100-200 ppm SG Na 3 per Week none Shiftly 10-60 ppb SG Conduc per Week
>160 uS/cm Shiftly 60-300 uS/cm The inspector noted several conditions beyond the normal range. The Unit 1 Chemistry Supervisor explained that the "normal range" control limits established for Unit 1 steam generators in wet layup were not properly suited to secondary plant operations involving phosphate addition as a buffering agent. The licensee, the steam generator vendor and EPRI were discussing proposed changes to the chemistry contol limits to accomodate phosphate addition effects on conductivity, pH and hydrazine level Tables 8 and 9 describe the chemistry conditions observed at Units 2 and 3, respectivel Table 8 RCS and Feedwater Chemistry Conditions at Unit 2 (Mode 1)
Analyte Reqd Frequency Action Level Frequency Observed Conditions RCS Cl MWF
>150 ppb MWF
< 5 ppb RCS Fl MWF
>150 ppb MWF
<5-7 ppb RCS 0 Daily
>10 ppb Daily
< 5 ppb RCS pH Daily Boron/Lithium Daily 6.5-Coordinated RCS Ac MWF 100 uCi/gm MWF 4-5 uCi/gm RCS DEI Weekly
>1 uCi/gm MWF 0.1 uCi/gm FW pH Daily
<8.8,> Continuous in-line FW Cat Cond Daily
<0.2 uS/cm Continuous in-line 0.06 uS/cm FW Na Weekly
>3 ppb Continuous in-line 0.12 ppb FW 0 Daily
>10 ppb Continuous in-line <1 ppb FW Fe Weekly
>20 ppb Weekly 3-9 ppb FW Cu Weekly
>2 ppb Weekly 0.5 ppb
Table 9 RCS and Steam Generator Water Chemistry Conditions at Unit 3 (Mode 5/6)
Analyte Reqd Frequency Action Level Frequency Observed Conditions RCS Boron Daily None Daily 2400 ppm RCS pH Daily
>9.0,< Daily 5.3-RCS Cl MWF
>150 ppb MWF
<5-13 ppb RCS Fl MWF
>150 ppb MWF
<5-10 ppb RCS 0 MWF
>100 ppb Daily in Mode 5 RCS Vented RCS Ac MWF
>100 uCi/gm Daily in Mode 5 0.06 uCi/gm RCS DEI MWF
>1 uCi/gm Daily in Mode 5 1 E-3 uCi/gm SG pH MWF
<9.8,>1 MWF SG hydrazine MWF
<75,>100 ppm MWF 100 ppm SG Na MWF
>1000 ppb MWF 3-100 ppb Water chemistry conditions for the primary and secondary systems at Units 2 and 3 were within administrative control limit The conditions observed and the surveillances performed satisfied the requirements of TS 3/4.4.6 and TS 3/4. The inspector reviewed records of quality control (QC) checks of selected analytical instruments in the Unit 1 and Unit 2/3 chemistry laboratories to verify that QC activities were conducted according to established procedures. The following areas were reviewed:
S0123-III-4.8.2, "Operation and Calibration of the Orion 811 pH meter."
Two point standardizations were documented prior to each analysis as require S0123-III-4.2, "Operation, Calibration and Maintenance of Laboratory Analytical Balance."
This procedure required weekly calibration checks of analytical balance The inspector observed that Unit 2/3 hot lab and turbine lab balances were not always calibrated at the prescribed frequency. Occasionally periods of ten to twelve days elapsed between calibration The inspector informed the Supervisor, Technical Administration, of these discrepancies, who indicated that the personnel responsible for balance QC checks would be instructed to perform the checks at the stated frequenc S0123-III-4.7.2, "Operation and Calibration of the Dionex 2020i Ion Chromatograph."
Daily blanks and standardizations using chloride and sulfate standards and weekly sodium and ammonia standards were performed. Duplicate analyses using independent standards were performed at the same frequency and the results were logged on control chart SO123-III-4.1, "Operation and Calibration of the Varian 475 AA Spectrophotometer."
Daily blank and Li, Cu and Fe standardizations were performed. Duplicated analyses of each standard analyte using independent standards were logged on control chart The inspector observed that several secondary analytical reagents on Unit 2/3 hot laboratory and turbine laboratory shelves were past their expiration dates. The inspector informed the Supervisor, Technical Administration, who immediately disposed of the reagents. No primary analytical reagents were observed to be past their manufacturer's expiration date. The secondary standards involved were used to calibrate in-line instrumentation for continuous indication. The bench instrument results were checked routinely against the response of the in-line monitors, and no significant discrepancies were observed. Two boron standards did not have an expiration date, but were determined not to have been used for any TS-related boron analysis. The licensee agreed that expeditious disposal of old reagents would be emphasized amongst laboratory personnel and technical administrator The inspector examined records of intercomparisons between the licensee and their contract laboratory for non-radioactive analytes. Boron, Fl, Cl, and various other analytes were compared on a quarterly basi Intercomparison performance was satisfactory. Occasional disagreements were investigated by technical administration, and corrective actions were taken as appropriate to improve accurac No violations or deviations were identified in this part of the inspectio.
Exit Interview The inspector met with licensee representatives on May 20, 1988, to discuss the preliminary findings of the inspection. The licensee was informed that no violations or deviations were identified and Open Items identified in the previous inspection would be closed. The findings regarding decay corrections of air sampling media were conveyed to Chemistry and Health Physics management, and the inspector confirmed a licensee commitment to evaluate such corrections and implement them for air and effluent sample analyses as appropriat II
Enclosure Criteria for Accepting the Licensee's Measurements Resolution Ratio
<4.5
-
7.0
-
15.66 16 -
0.75 -
1.33 51 -
200 0.80 -
1.25 200 0.85 -
1.18 Comparison Divide each NRC result by its associated uncertainty to obtain the
- resolutio (Note:
For purposes of this procedure, the uncertainty is defined as the relative standard deviation, one sigma, of the NRC result as calculated from counting statistics.) Divide each licensee result by the corresponding NRC result to obtain the ratio (licensee result/NRC). The licensee's measurement is in agreement if the value of the ratio falls within the limits shown in the preceding table for the
- ocorresponding resolution.