IR 05000255/1987017
| ML18052B242 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/13/1987 |
| From: | Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052B241 | List: |
| References | |
| 50-255-87-17, NUDOCS 8708200343 | |
| Download: ML18052B242 (11) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/87017(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades site, Covert, Michigan License No. DPR-20 Inspection Conducted:
June 29 through July 2 and-July 14-15, 1987 (On-site)
July 1 and 16, 1987 (Telephone discussions)
R., e *
N-d!i.Ari\\.Ay1.,
Inspectors:
R. 8. -H-~1-b'.i~~;
Approved By:
~/
~/
-
J. E. House
WD5Ji A
~,")/l
.!~'(
M. c. s~het°Chief Radiological Effluents and Chemistry Section Inspection Summary f)//3/?7 Ddte 7
'
Date
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Date Inspection on June 29 through July 2 and July 14-15, 1987 and telephone discussions on July 7 and 16, 1987 (Report No. 50-255/87017(DRSS))
Areas Inspected:
Routine announced inspection of the chemistry program, including (1) procedures, training and quality assurance, (2) the chemistry laboratory and water chemistry control, and (3) confirmatory measurements of nonradiolgical sample Results:
No violations or deviations were identified, but the licensee's chemistry quality assurance program showed several weaknesses affecting the reliability of chemical measurements.
8708200343 870813 PDR ADOCK 05000255 G
- DETAILS Persons Contacted P~ Hoffman, Palisades Pl~nt Manager, CPCo 1, 2 R. M. Rice, Operations Manager, CPCo 1J. ~. Lelois, Plant Technological Director, CPCo 3 K. Haas, Rx Engineering Superintendent/Acting Operations Manager, CPCo 1R. P. Margo), QA Administrator~ CPCo 1,2,2s. Pierce, Plant Chemisti CPCo 1, 3 J. Hager, Nuclear Licensing Analyst, CPCo A. Callaway, Chemistry Technician (CT), CPCo E. Dehn, CT, CPCo C. Graffinius, CT, CPCo 1, 3 E. R. Swanson, Senior Resident Inspector, NRC The inspectors also interviewed other licensee personnel in the course of the inspectio Den~tes those present at the plant exit interview o~ July 2, 198 Denotes those present_at a telephone discussi~n July 7and16,*198 Denotes those present at the plant exit interview July 15, 198.
Management Controls and Organization The licensee had reorganized the Chemistry Department since the previous inspection. 1 The position of Chemistry Superintendent, has.been eliminated and the Plant Chemist now reports directly to the Operations Manage The Environmental Coordinator, and two chemistry Laboratory Supervisor~, one Rad and the other Non-Rad, report to the Plant Chemist and supervise the 13 Chemistry Technicians (CT).
The staffing appears.to be adequate to perform the required chemistry operation No violations or deviations were identifie * 3., Water Chemistry Control Program The i nspettors r.evi ewed aspects* of the water chemistry program, including control limits and t~end charts of the chemical paramete~s. The limits for the system appear to be consistent with those of the PWR Steam Generator Owners guidelines !ind t_he plant Technical Speciffcation The licensee had trend charts for the chemistry parameters for both the primary and secondary systems, including pH, specific conductivity, and the 1 Region III Inspection Report No. 50-255/8601 I
.*!
concentrations of dissolved oxygen, sodium, chloride and fluorid The primary system analyses also included boron, lithium and hydrogen, and radiological parameters, and the secondary system analyses cation conductivity, hydrazine", sulfate, sodium and magnesium. (The latter two were for monitoring condenser cooling water inleakage).
The licensee also maintained a: list of 11Hours Out-of-Specification 11, i.e. the nuniber hours that various steam generator and auxiliary system parameters were out of specifications, as defined by the S/G Owners-EPRI Guidelines when the power was greater than 35%.
Only limited data were available, because the plant was not at power for about a year prior to April of this year, but they appeared to be meeting their goal of less than 800 hour0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />s/year; the actual operating experience was lower and comparable to the industry average value of 459 hour0.00531 days <br />0.128 hours <br />7.589286e-4 weeks <br />1.746495e-4 months <br />s/yea This program will be followed under the chemistry reviews in future i~spection No violation or deviations were identifie.
Implementation _of the Chemistry Program Laboratory_ Operations The inspectors reviewed-the chemistry programs, including physical facilities and laboratory operations. Housekeeping was good and the laboratories were reasonably well equippe Space in the hot chemistry laboratory was marginally adequate for the existing workload and instrumentation with little bench space available for additional
~quipment. The instrumentation included an Orion 701A Ionalyzer, an Altex 2000 Ion Analyzer, a Perkin-Elmer Model 5000 Atomic Absorption Spectrophotometer (P-E), an HP 5880 Gas Chromatograph, and a Metrohm Herisan Dosimat E 535 Auto Titrato The cold laboratory was larger and somewhat less crowde Its instrumentation included a Dionex 2010i Ion Chromatograph, a Bausch and Lonib Spectronic 2000 UV/visible Spectrophotometer and a P-E with flame and graphite furnace attachment Reagents prepared in-house were labeled and had expiration date A few bottles of purchased atomic absorption (AA) standards were not receipt-date The Plant Chemist stated that the reagents are checked monthly and that he will review those reagents in questio Instrument maintenance schedules are computer-generate Quality Assurance/Quality Control in the Laboratory
.Within the last few months, the licensee instituted control charts-for many of the nonradiological analyses, including pH, chloride and sulfate on the ion chromatograph, plus silica and hydrazine on-the UV spectrophotomete He plans to add QC charts ~or other analyses as experience is gained in the use of the charts *and decisions are made on the control parameters to use.
- The importance of properly maintained control charts to a credible
- m~asurements control program was discussed with licensee representatives during the 1nspettion and at the exit intervie In this rega~d, the inspectors noted that the licensee 1s current practice of arbitrarily _setting control limits at +/-20%-of mean values was a poor practice with little statistical basi As. noted in Section 5, this practice contributed to disagreements in*
confirmatory measurements comparisons on nonradiological sample An interlaboratory crosscheck program is maintained with the EPA and a vendor (NWT, Inc.) to assist in t~e laboratory QA program. However, because of the limited si~es of the check samples, only about 80% of the CTs are checked quarterly with 6-8 nonradiological unknowns sample The inspectors* review of the results from the NWT samples showed the accuracies of licensee 1s values to be generally good and about equal t6 or somewhat better than those of nine other similar laboratorie The inspectors discussed the incomplete testing of the technicians with the Plant Chemist who agreed to work up a schedule to permit these unknowns performance checks for a 11 of the CTs. The development of _this program will be followed in subsequeht inspections under Open Item 50-25~/87017~0 Counting room QA/QC The inspectors also reviewed the QA/QC program for the radiological analyse Since the last inspection of this program,2 the licensee instituted the use of control charts to trend the background and performance checks. on the two gross alpha/beta counters, the gross gamma counter and the liquid scintillation counte Control limits wereset at +/-5% of the mean.count These charts provide a substantial improvement in the QA/QC progra However~ the inspectors stressed that the +/-5% limits do not provide full control of the instrumentation; the inspectors* reviews of the charts indicated that instrument variabilities were substantially lower than these limit The licensee representative agreed to consider the use of limits based on statistical analysi Control charts for the gamma spectrometers are not maintained regularl Functional checks are made with a Ho-166m source with 12 gamma peaks ranging in energy from 80 to 1427 KeV, with each line having three parameters (energy, intensity and FWHM) which must be
- within the control limits for a succe~sful functional chec The system is unnecessarily complex, requires much calculation effort to maintain, and results in frequent failure of the acceptance criteria for purely statistical reason Moreover, the data are stored in the computer and available for control charts but the chemist only prints them annually, or when problems are found with the syste This use does not conform to good laboratory practice of trending instrumental performance regularl The inspectors pointed out that quality control over this system could be substantially improved with less effort by:
2Region III Inspection Report No. 50-255/87016
- *
- printing the charts at regular intervals, e.g., at least monthly; limiting the number of records to be maintained by using only the. data (energy, efficiency and FWHM) from one lower energy line and from one higher energy line; and using only relatively int~nse li~es that will give a good measure of instrumental performance, i.e., the variabilities in-the counting statistics will not_ overwhelm those of the instrumen The inspectors also noted that the energy calibrations might be more stable if only the more intense lines ones were used in these calibrations, since the calibration programs do not weight the-calibration points by the counting statistic The licensee representatives agreed to implement the regular use of QC charts and to consider the other sugg~stions. *Progress in the radiological QA/QC program will be followed in subsequent inspections.(Open Item No. 50-255/87017-02).
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No violation or deviations were identifie Nonradiological Confirmatory Measurements The inspectors submitted chemistry samples to the licensee for analysis as part of a.program to evaluate the laboratory 1s capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to various Technical Specification and other regulatory and administrative requirement These samples had been prepared, standardized, and periodically reanalyzed (to check for s_tabi l ity) 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 th~ criteria for a~reement 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 1 s results were not necessarily representative of the laboratory 1s because they were obtained by one analyst over a short period of tim Consequently when the licensee s.d. was less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the lic~nsee in calculating the s.d. of the ratio Z (Sz in Attachment 1).
The licensee also prepared three samples to be split with BN To these were added analytes-supplied by the inspector Reactor water was spiked with the anions, chloride and sulfate, and sampl~s of condensate and feedwater were spiked with copper, iron and chromium ion The licensee wi 11 determine the a,na lytes in each and the results wi 11 be sent to Region III for comparison with the values determined by BN This will be followed under Open Item No. 50-255/87017-0 The licensee performed 36 analyses (including six repeat analyses discussed below) of which 12 were in disagreement with the BNL result These disagreements indicated the presence of a number of problem The six ion chromatographic measurements of chloride and sulfate were in disagreement and biased low by 12.5-36%, an effect-caused by instrumental drift and the large acceptance criterion of +/-20% permitted by licensee procedur The licensee had not calibrated the instrument for several days prior to the run, but had performed functional checks with '50-ppb and 10-ppb standard The 50-ppb standards gave readings that weie low by about 17%, but since they were within the +/-20% laboratory acceptance criterion, the chloride and sulfate analyses were performed without r~calibrating the instrumen Subsequently, the instrument was recalibrated and single analyses of the chloride and sulfate at each concentration were performe This resulted in five agreements in six analyse The licensee agreed to reanalyze a second set of chloride and sulfate standards and report the results to Region III.by telephone (previous Open Item No. 50-255/87017-03).
The three chromium results were in disagreement, all with high biases of 24-43%.
The cause was likely a nonlinear response curve, a problem that could be alleviated by the use of a multipoint calibration curve, and/or the 20% acceptance criterio Two of the hydrazine results were i disagreement due, in part, to the high precision of both the BNL and licensee values that allowed little leeway in the results to obtain agreemen While the boron,results were in agreement, the inspectors noted that there was no independent control for the boron analysis. * The sodium hydroxide titrant is standardized against a boron standard, with no other tests done, such as to check the titrant against a second boron standard, or, do the original standardization of the NaOH against an acid standard and then to do a functional check with a boron standard~ The inspectors discussed their concerns with the licensee representative, who agreed to review the methodology and to consider the above modification In summary, several weaknesses were seen in the licensee's measurement control program that contributed to disagreement **
- The arbitrary acceptance criterion of +/-20% appears to be excessively generous and without statistical foundation; crit~ria based on
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accepted standard statistical methods should be used to establish control of analytical measurement '
' The use of one~point (plus zero) calibration curves in situations where the instrumental behavior was not linear, e.g., the chromium analyses. Multiple poi~t calibration curves should be used if a
- suitably-1 i near response of an instrument cannot be verifie If a one-point calibration is used because of instrumental limitations, functional check standards should be used to verify acceptable instrument b~havior over the range of intended us.
Independent controls must be included in analytical procedure The functional check standards should be from different sources (lots) from the calibration standards in order to verify'the quality of the calibration materia These problems were discussed in detail at the exit interview and by telephone after the inspectio No violations or deviations were identifie.
Open Items Open items are matters which have been discuss~d with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part -Of the NRC or licerisee, or both. Open items were disclosed during the inspection in Sections 4 and * Exit Interview The scope and findings of the inspection were discussed with licensee representatives (Section 1) on July 2 and July 15, 198 Telephone discussions were held on July 7 and 16, 1987. * The inspectors emphasized their concerns with basic weaknesses observed in the licensee's measurement controls program, including the excessively wide acceptance criteria (+/-20%)
used for instrument performance checks, unverified assumption of linear instrument response curves, absence of control charts on some analyses, particularly boron, and tha lack of independent functional check standard Licensee representatives indicated their belief that existing measurement controls were adequate and that the change discussed would be too costly and unnecessary to meet commitments and regulatory requirement. -
However, they agreed to consider, these items and to submit a letter to Region III by August 28, 1987, indicating improvements they will undertake and giving a schedule for implementatio This matter will be pursued_ in subsequent inspections No. 50-255/87017-04.
During.the exi f interview,* the inspectors.discussed the 1 i ke ly informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio Licensee representatives did not identify any such documents or processes as proprietar Attachments: Table 1, Nonradiological Interlaboratory
- Test Results, June 30-July 2, 1987 Attachment 1, Criteria for Comparing Analytical Measurements
i
TABLE 1 Nonradiological Interlaboratory Test Results Palisad~s Nuclear Gene~atigg Plant June 30-July 2, 1987 Anal-Analys~s Oil u-NRC Licensee Ratio Comp~ri-
'yte Method ti on, son l:x Y +/- s.d.(n)
X +/- s.d.(n)
Z +/- +/-2 s. (x)
Concentration 2 EEm B
Titr 1 1000
+/- 10(7) 1025
+/- 15 1. 025 +/- 0. 018 A
1 3024
+/- 46(7)
3080
+/- 19 1.,019 +/- 0. 017 A
- 1 4947
+/- 61(7)
5050
+/- 83 1.021 +/- 0.021 A
Cl IC 1000 24.1 +/- 3.1(7)
15.4 +/- 0.51 0.639 +/- 0.153 D
1000 37.4 +/- 1. 2(7)
31.1 +/- 0.85 0.832 +/- 0.035 D
1000 8 +/- 2.2(8)
7 +/-.872 +/- 0.040 D
.. Cl dIC 1000*
24.1 +/- 3.1(7)
2 +/- o.66(1)' o.a3o +/- 0.110 (Rerun)
1000 37.4. +/- 1. 2(7)
41.1 +/- 1.1(1) 1. 099 +/- 0. 046 D
1000 80.5 +/- 2.2(8)
88.0 +/- 3.3(1) 1. 093 +/- 0. 051 A
Sul f-IC 1000 20.0 +/- 0.9(7)
17.5 +/-.875 +/- 0.047 D.
ate 1000
. 41. 5 +/- 2.4(8)
33.4 +/-.805 +/- 0.055 D
1000 80.8 +/- 3. 0(7)
6 +/- 0. 2*
0.803 +/- 0.030 D
Sulf-IC 1000 20.0 +/- 0.9(7)
18.7 +/- 0.5(1) 0.935 +/- 0.049 A
ate d
1000 41.5 +/- 2.4(8)
3 +/- 1.2(1) 0.892 +/- 0.059 A
(Rerun)
1000 80.8 +/- 3.0(7)
80.9 +/- 0.2(1) 1. 001 +/- 0. 037 A
Sil-Spec 1000 54.3 +/- 5.6(7)
54.3 +/- 1. 2 1. 000 +/- 0. ilO A
ica 1000 109
+/- 7. (7)
.10 +/-.006 +/- 0.065 A
1000 160
+/- 5.(7)
166
+/-.038 +/- 0.054 A
Cu AAS
4.8 +/- 0.24(12) 4.97 +/- 0.47 1. 062 +/- 0.114 A
9.66 +/- 0.49(14) 10.9 +/- 1. 04 1.12 +/- 0.12 A
14.5 +/- 0.6(12) 14.9 +/- 1.55 1. 032 +/- 0.115 A
. Fe AAS
4.89 +/- o.35C1a) * 5.o9 +/- o.63 L 041 +/- 0.15 A
9.55 +/- 0.34(14) 11.1 +/- 0.81 1.162 +/- 0.09 A
. 20 14.7 +/- 0.42(13) 15. 4 +/- 1. 22 1.048 +/- 0.087 A
Cr AAS
5.1 +/- 0.3(6)
6.4 +/-.255 +/- 0.084 D
9.41 +/- 0.3(6)
13.5 +/-. 1.43' +/- 0.056 D
14.3 +/- 0.8(6)
17.8 +/-.245 +/- 0.081 D
Anal-Analys~s Dilu-NRC Licensee Ratio yte Method tion, l:x Y +/- s.d.(n)
X +/- s.d.(n)
z +/- s. (x)
Na AAS*
250 4.58 +/- 0.5(6)
5.48 +/- 0.50 1.197 +/- 0.17 250 9.23 +/- 0.8(6)
9.07 +/- 0.66 0.983 +/- 0.11 250 14.4 +/- 0.8(6)
14.9 +/- 1. 2 1.033 +/- 0.10 NH3 SIP 500 87.6 +/- 5.3(7)
100
+/-.142* +/- 0. 092 500 314
+/-- 26. (7)
308
+/- 1.981 +/- 0.091 500 938
+/- 85.(7) 1015
+/- 7. 082 +/- 0.12 Hyd-Spec 1000 22.3 +/- 1. 4(7)
19.2 +/-.861 +/- 0.056 razine 1000 56.9 +/- 0.7(7)
46.8 +/- 1. 4 0.823 +/- 0.027 1000 104
+/- 1(7)
+/-.904 +/- 0.009 Value+/- standard deviation (s.d.); n is number ~f BNL analyse The number of licensee analyses is 3 unless otherwise note Analytical methods:
Titr - titration *
A = Agreement D = Disagreement IC
- Ion chromatography Spec - Spectrophotometric SIP
- Specific ion probe Recalibrated instrument and reran a sample only onc Substituted the BNL uncertainty for licensee 1s uncertaint comperi-son
+/-2 s.d:
A A
A
A A
A
A D
D
ATTACHMENT 1 C-riteria for Comparing Analytical Measurements This attachment provides criteria for comparin9 results of the capability test The acceptance limits are based on the uncertainty (standard deviation) of the ratio of the licensee's mean value (X) to the NRC mean value (Y), where (1) Z = X/Y is the ratio, and (2) S is the uncertainty of the ratio determined from the propagation of the uncertainties of licensee's mean value, Sx, and of the NRC 1s mean value, SY. 1 Thus, S 2 s 2 s 2
.
z _ x
~ so that rr- - xr + vr'
J s 2 s 2 ~
s = z. (i_ + l z
\\ :x2 v2 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 uncertai~ty in the ratio, I 1-Z I.:£ 2*Sz. National Council on Radiation Protection and Measurements, A Handbook of Radioactivit~ Measurements Procedures, NCRP Report No. 58, Second Edition, 1985, Pages 322-326 (see Page 324 ).
4/6/87