IR 05000255/1989023
| ML18054A964 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/30/1989 |
| From: | Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A963 | List: |
| References | |
| 50-255-89-23, NUDOCS 8909110334 | |
| Download: ML18054A964 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/89023(DRSS)
Docket No. 50-255 License No. DPR-20 License~: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
July 26-28 and July 31 through August 1, 1989 (Onsite)
~
Inspectors:
J. E. House Approved By:
R. 8. H<~tt--v-R. B. Holtz4;n* -
?r~f Radiological Controls and Chemistry Section Inspection Summary
¥-:r~ - r"t Date o/3°/f9 Jtate ~0J Date Inspection on July 26-28 and July 31 through August 1, 1989 (Report No. 50-255/89023(DRSS))
Areas Inspected:
Routine, unannounced inspection of:
(1) the chemistry program, including procedures, organization, and training (IP 84750);
(2) primary and secondary systems water quality control programs (IP 84750);
(3) quality assurance/quality control program in the laboratory (IP 84750);
(4) nonradiolgical confirmatory measurements (IP 79701); and (5) the radiological environmental monitoring Program (REMP) (84750).
Also reviewed were past open items, audits and the qualifications of the new Chemistry Superintenden,
Results:
The licensee 1s secondary system water quality control program appeared to be adequate to control chemistry parameter The initial confirmatory measurements results were fair owing to some problems in operation and measurement QA/QC for certain instrument After recalibration, reanalyses gave substantial improvement and licensee representatives agreed to take additional measures to correct these problems. *
No violations or deviations were identifie :.:*'.
- DETAILS Persons Contacted
- R. M. Rice, Operations Manager, Palisades
- D. D. Hice, Chemistry Superintendent
- T. A. Chartrand, Chemistry Supervisor
- J. R. Brunet, License Analyst J. E. Paver, Support Supervisor R. Erickson, Chemical Engineer C. T. Hillman, Staff Engineer M. Sullivan, Lead Chemistry Technician
- E. R. Swanson, Senior Resident Inspector, NRC The inspectors also interviewed other licensee personnel in the course of the inspectio *Denotes those present at the plant exit interview on August 1, 198.
Licensee Action on Previous Inspection Findings (Closed) Open Item No. 50-255/87017-02:.Licensee to implement regular use of QC charts on the gamma spectrometer systems and to use only a few lines in the routine source check The licensee is presently using three of the more abundant.peaks in the Ho-166m source, at energies of 184, 711 and 810 keV to check energy and sensitivity calibration stabilit They also track centroid and peak width (FWHM) on those peaks to assess counter operabilitie The results are stored and processed by a Nuclear Data ND 9900 analyzer syste The control charts of these parameters are plotted monthly and are checked on the terminal at least weekl Licensee representatives noted that the chart parameters (mean and standard deviation) are updated with each entry (daily).
They agreed to consider doing so less frequently, probably quarterly, so that data trends are less likely to be missed.. The licensee had agreed previously (Region III Inspection Report No. 50-255/89010) to revise the procedures to reflect laboratory practice.
This development will be followed in subsequent inspections under Open Item No. 50-255/89023-0 (Open) Open Item No. 50-255/88015-01:
Licensee to investigate analytical disagreements with Brookhaven National Laborator Although the licensee 1s QA/QC program has continued to improve, results from the confirmatory measurements program (21 agreements in 33 analyses initially) indicated that some instrument problems still exist (Sections 6 and 7).
Resolution of these problems will be fol~owed under this Open Item.
c.
(Closed) Open Item No. 50-255/88015-02:
Licensee to implement independent controls and control chart statistic The licensee has developed statistically-based control charts and is setting up a control program with independent standards (Section 7). (Closed) Open Item No. 50-255/88015-03:
Licensee to modify the nonradiological intralaboratory comparison program to -include acceptance criteria and to insure that all technicians are tested twice per yea The licensee has implemented acceptance criteria and a review of selected data suggests that technicians ~re.t~sted twice per yea * (Closed) Open Item No. 50-255/88015-04:
Licensee to investigate a suspected defective boron standar The licensee notified the ~endor and issued a report under the provisions of 10 CFR Part 2.
Management Controls and Organization (IP 84750)
The Chemistry Department's organization was similar to that described in the previous inspection report 1.
The head of the Department, the Chemistry Superintendent is supported by a Laboratory Supervisor, a Support Supervisor and three Chemical Engineer The Hot and Cold Laboratories are each supervised by Lead Technicians who are supported by 13 technicians.. Due to turnover of technicians, only five are qualified under ANSI N 18.1-197 The new Chemistry Superintendent replaced the previous one who transferred to a new positio The new Superintendent appears to be adequately qualifie~ as a chemis He has a B.Sc. in Mechanical Engineering and an A. A. in,Chemical Techno 1 og He* has had severa 1 years experience as a chemistry supervisor at a non-operating nuclear plant (Midland) and four years operations experience at an operating Nuclear Plan His training included the General Electric BWR Training Program and he has GE and company SRO Hot License Certification This transition is being facilitated by his predecessor, the former Plant Chemical Engineer, providing assistance and guidanc The management structure appeared to be adequat The licensee is developing a chemistry self assessment program using criteria from the INPO Chemistry Guideline Licensee representatives stated that this program should assist the chemistry laboratory in improving the quality of its operations, in general, and the QA/QC program, in particula The licensee's Chemical Technician training program is scheduled for re-accreditation next yea No violations or deviations were identifie Region III Inspection Report No. 50-255/8801.
Water Chemistry Control Program (IP 84750)
The inspectors reviewed the water chemistry control program based on Procedure No. COP 11, 11Secondary System Chemistry, 11 Revision 11, March 15, 198 The specifications of the administrative limits on the parameters of the various systems are derived from and appear :to be consistent with the relevant EPRI Steam Generator Owners Group Guide).ines (SGOG).
Licensee management of secondary water system parameters is similar to that described in the previous inspection report The licensee had in.stalled a new secondary water sampling panel "i'n the cold chemistry laboratory with in-line monitors for hydrazine, pH, dissolved oxygen, sodium, and specific and cation conductivit This system also has sampling ports for grab samples to be taken for the laborator Data from these samples were used for trending chemistry parameters; data from in-line monitors were also stored.in the computer*data base and could also be used for trending. A new computer system and software have* been acquired by the licensee for data handlin The licensee does not have procedures describing trend charts and their use This is a weakness in the trending progra Licensee representatives stated that secondary chemistry parameters were reviewed daily by the Chemistry Superintenden The Operations Manager reviews chemistry trends mainly when problems or abnormal trends are encountere *
The inspectors *reviewed trend charts of chemistry parameters and noted that the plotting of charts appeared to be slo Licensee representatives stated that'this was caused by having only one manual feed plotter availabl An additional plotter with automatic paper feed has been ord~red to speed the plotting proces The steam generator (S/G) water quality is maintained by feed and bleed (blowdown) since the plant does not use condensate polisher A review of selected data for the previous year indicated that the licensee maintains secondary water chemistry parameters generally within the Owners Group Guidelines and overall secondary water quality appeared to be goo *
No violations or deviations were identifie.
Implementation of the Chemistry Program (IP 84750)
The inspectors reviewed the chemistry programs including physical facilities and laboratory operation Since the last inspection, construction of a new cold chem*istry laboratory was completed and the laboratory was in us A new computer-controlled gradient ion chromatography (IC) system has been acquired for the cold laborator The new laboratory appeared to be well equipped and provided adequate working spac Ibi *
The inspectors observed several technicians analyze the confirmatory measurements sample They appeared to be generally knowledgeable about the work, followed the procedures and appeared to do well in the analyse Overa 11, the 1 aboratory appeared to be.adequate for the proper *operatJ.OJl of the plant and to be operating satisfactoril.... /*,:>*:
No-violations o~ deviations were identifie.
Nonradiological Confirmatory Measurements (IP 79701)
The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the'laboratory's capabilities to inonito 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 periddi cally reanalyzed (to check for stability) for the NRC by the Radiological Sciences Division of Brookhaven National Laboratory (BNL).
The samples were analyzed by the licensee using routin~ methods and equipmen A single dilution for each sample was *made 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 (SD) of the measurement Modifications made to these criteria (Attachment 1 Notes) are based on the consideration that the uncertainties (SD) of the licensee 1s results were not necessarily representative of the laboratory 1s because they were obtained by one analyst*over a short period of tim The licensee also prepared a sample' of secondary system water spiked with the anionic analytes fluoride, chloride and sulfate to be split with BN The licensee determined the concentrations of the analytes and the results will be compared to those determined by BN This will be followed under Open Item No. 50-255/89023-0 The licensee qetermined 11 analytes at three concentrations eac The initial results were fair with 21 agreements in 33 comparisons (64%).
The disagreements were in the s~lfate and the two lower-level chloride samples, the ammonia, iron and middle sodium sample The chloride and sulfate disagreements appeared to be due, in large part, to software configuration problems in obtaining the baselines with the gradient elution systems used on the I The reruns of the chlorides were in agreement, but the analyst believed some of the sulfate results to be unreliable and thus reported only one of the values from the rerun The disagreements in the ammonia determinations were due to a defective calibration standard, as shown by recalibration with a new standard.
The laboratory personnel noted that they often had difficulties with the iron analyses by graphite furnace atomic absorption spe*ctrophotometry (GFAAS) and they are trying to resolve the proble This appears to be a generic problem with this type of analysis and may be due to the BNL sample matrix which in addition to the iron contains copper, nickel and chromiu The precision of the sodium analysis is generally poor at ~he low *.
concentrations used here apparently due to sample contaminatio __
- ,.
..
- ,
- .*,'
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Some particular problems were identified in this inspection ~ome of which appear to be related to various deficiencies of the QA/QC Program djscussed in Section The litensee does not use independent st~ndards, so that a change in a stock standard solution could go unnotice The difficulties in the ammonia analyses may have been an example of this lack; this also indicates a need for greater care in the making of the standards. 'The laboratory is in the process of obtaining standards to implement such a progra The sulfate analyses appeared to have problems, due possibly to the software operating the ICs, to the calibration standards, or to the QA/QC program in which the control charts appeared to the inspectors to have excessively wide control limit Following equipment recalibration the licensee obtained 28 agreements in the 33 analyses (85%).
The licensee is in the process of assessing and rectifying the problems identified in the analyse Progress in the improvements in the analyses will continue to be followed under Open Item No. (50-255/88015-01, Section 2).
No violations or deviations were identifie.
Implementation of the QA/QC Program in the Chemistry Laboratory (IP 84750)
The inspectors reviewed the nonradiological QA/QC program that is required by the Chemistry Program Manual. The licensee had developed statistically-based control charts for all assays using a computer data bas Although the statistically~based charts were an improvement, the inspectors noted several concern The charts lacked mean value lines, apparently a software problem which could be easily modifie Chart parameters, i.e.,
mean values and standard deviations had been determined approximately one year ago and were still in us These parameters should be updated quarterly using at least 30 data points obtained during the previous quarte An additional concern was that the control charts were not reviewed routinely by laboratory personne Procedures establishing
"
control charts needed to be upgraded and made consistent with the current computerized data base methods. Licensee representatives agreea to review and improve the quality of the control chart Multiple-point calibration curves were in use on most assays; however, single-point curves were still in employed on the atomic absorption spectrophotometer (AAS).
Due to non-linear responses in calibration curves, multiple-point curves would provide im~~oved accurac The licensee has agreed to investigate the use of multiple-point calibration curves for the AA *
The licensee had previously agreed to implement independent controls on all or most assay Although the program was under development and some reagents had been obtained, the procedure needed to implement the program had not been written. The licensee 1s current practice used function checks prepared from the same stock solutions used for calibratio The independent control program will be reviewed in subsequent inspection~..
. ':**.*,
The licensee has a vendor-supplied i nterl aboratory comparison program.*.. A review of selected data from the previous year suggested that the licensee had, in general, performed adequately on the quarterly cross ~heck Approximately 75% of the analyses were within +/-10% of the vendor 1s valu In a few cases, large biases (~100%) were observed which indicate major analytical problem Implementation of multiple point calibration curves, independent controls and routine review of control charts should minimize these analytical difficultie The inspectors reviewed the technician testing progra From a review of selected.data it appeared that all technicians were tested at least semiannuall This program is outlined in a memorandum dated April 12,
- 1988, 11 Basis Document for Acceptance criteria of Interlaboratory Cross Check Program
This document establishes a statistically-based acceptance criterion using existing analytical dat One weakness that the inspectors noted was the lack of a procedure defining parameters and acceptance criteria. This will be followed in subsequent inspection In summary, the licensee 1s overall QA/QC system has the basic elem~nts of a satisfactory program and has improved from the last inspectio However, program weaknesses remain which appear to relate to the difficulties noted in the confirmatory measurements comparisons progra Possible improvements to the QA/QC program include reduction of the wide bands on the QC chart control limits to be achieved by more frequent determination of the chart parameters, and by calibrating the instruments more often; more detailed routine assessment of the chart data and hardcopy output of the QC charts; the use of mJltipoint calibration curves on the AAS; and control of the QA/QC operations by procedure:
Licensee representatives agreed to address these matters via letter by October 1, 198 This will be followed under Open Item No; 50-255/89023-0 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 bot Open items disclosed during the inspection are discussed in Sections 2, 6 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 1, 198 The inspectors discussed the Open Items in Section 2,
observations on the quality control program, the confirmatory measurements and the secondary water trending program Licensee representatives agreed to consider modifications and improvements of these programs, as discussed
.in Sections 6 and 7, and to outline these changes in a letter to Region III by October 1, 198 During the exit interview, the inspectors discussed the likely *informational content of the inspection report with regard to. documents or,processet reviewed by the inspectors during the inspectio Licensee representatives did not identify any such documents or processes as.proprietary;'* :':*'
Attachments: Table 1, Nonradiological Interlaboratory Test Results, July 26 through August 1, 1989 Attachment 1, Criteria for Comparing Analytical Measurements (Nonradiological)
TABLE 1 Non radio 1 ogi ca 1 Interlaboratory Test Results Palisades Nuclear Generating Plant July 26-August 1, 1989 Analyte Arialyt~cal NRCa Licenseea Ratio
- Comparisonc
.
- ~
,;.
Method Y +/- SD X +/- SD Z +/- SD
+/-2 SD Concentration EEb Fluoride IC 11. 3 +/-
1. 0 10.1 +/-.898 +/- 0.091 A
21.2 +/-.3 +/-
1. 0 0.960 +/- 0.048 A
41.4 +/-.9 +/-.964 +/- 0.052 A
f, Chloride IC 9.3 +/-.8 +/-. 276 +/- 0. 068 D+
1 +/-.8
+/-.118 +/- 0. 048 D+
38.2 +/-.1 +/-
1. 4 1. 075 +/- 0. 040 A
(rerun) +/-..l +/-.086 +/- 0.048 A+
II 18.7 +/-.4 +/-.930 +/- 0.037 A+
II 3 +/-.5
+/-. 005 +/- 0. 022 A
Sulfate IC 9.75 +/-
0.70 14.3 +/-.467 +/- 0.149 D*
19.2 +/-.3
+/-. 321 +/- 0.132 D*
39. 0 ' +/-
1. 2 4 +/-.279 +/- 0.079 D
(rerun)
9.8 +/-.5
+/-.969 +/- 0.099 A
Fe AA/FU 9.30 +/-
0.25 12.1 +/-. 301 +/- 0. 049 D*
19.9 +/-.4 +/-.126 +/- 0. 020 D*
29.2 +/-.3 +/-. 378 +/- 0. 050 D*
Cu AA/FU 10. 0 +/-.8 +/-.080 +/- 0.045 A+
2 +/-.4
+/-.012 +/- 0.038 A
3 +/-.6
+/-. 020 +/- 0. 027 A
Na AA/FL 6.05 +/-
0.70 5.50 +/-.909 +/- 0.169 A
10. 6 +/-.4 +/-. 358 +/- 0. 095 D
15.8 +/-.7 +/-
1. 6 1.247 +/- 0.124 A
(rerun)
10. 6 +/-. 2 +/-. 057 +/- 0. 071 A
Li AA/FL 492
+/- 10 516
+/-
1.048 +/- 0.030 A*
1500
+/- 35 1457
+/- 25 0.971 +/- 0.028 A
2065
+/- 50 1917
+/- 21 0.928 +/- 0.045 A+
(rerun) 2065
+/- 50 2077
+/- 15 1. 006 +/- 0. 025 A
Ammonia SIE 208
+/- 10 330
+/-
1. 587 +/- 0. 085 D*
1200
+/- 12 2100
+/-
1. 784 +/- 0. 035 D*
1968
+/- 92 3500
+/-
1. 778 +/- 0. 092 D*
(rerun)
208
+/- 10 197
+/-
0.947 +/- 0.048 A
II 1200
+/- 12 1177
+/- 23 0.981 +/- 0.022 A
1968
+/- 92 2017
+/- 29 1. 025 +/- 0. 050 A
Analyte Analyt~cal NRCa Licenseea Ratio Comparisonc Method Y +/- SD X +/- SD Z +/- SD
+/-2 SD Hydrazine Spec 9.95 +/-
0.15 10. 0 +/-.005 +/- 0.018 A
24.9 +/-.0 +/-
0~1 1. 002 +/- 0. 011 A
50.0 +/-.7 +/-.974 +/- 0.015 A
Silica Spec 21.1 +/-.0 +/-.947 +/- 0.050 A
52.0 +/-.0 +/-.962 +/- 0.037 A
157
+/-
153
+/-
0.975 +/- 0.040 A
Concentration 2 ~~m Borond Titr 1002
+/- 10 994
+/-
0.992 +/- 0.010 A
2970
+/- 23 3011
+/-
1. 014 +/- 0. 008 A
4919
+/- 47 4951
+/- 10 1.007 +/- 0.010 A Value +/- standard deviation (SD); number of BNL analyses is 6 to The number of licensee analyses is 3 unless otherwise note Analytical methods: A = Agreement D = Disagreement Ti tr IC AA/FU AA/FL SIE
- titration
- Ion chromatography
- Atomic absorption Spectroscopy (furnace)
- Atomic absorption Spectroscopy (flame)
- Specific Ion Electrode NRC(BNL) values replaced by mean values of plants in Region II *Substituted the BNL uncertainty for licensee 1s uncertaint +Substituted 3% relative SD for BNL and licensee 1s SD ATTACHMENT 1 Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing resul.ts of the capability test The acceptance limits are based on the uncertainty (standard deviation) of the ratio of the licensee 1s 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
pfopagation of the uncertainties of licensee 1s mean value, Sx, and of the NRC 1s mean value, SY. 1 Thus,
5z
5x
~ so that rr = xz- + vz-'
,
s = z * ~
+ :.y__
($2 52J~
z x2 y2 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,.
National Council on Radiation Protection and Meas~rements, A Handbook of Radioactivit~ Measurements Procedures, NCRP Report No. 58, Second Edition, 1985, Pages 322-326 (see Page 324).
4/6/87
.. ATTACHMENT 1 NOTES The uncertainties may be modified in cases of disagreement:
a *.
If the licensee's SD, S is smaller than that of the NRC,
~he NRC 1s relative standard devia~ion (RSD) (S /Y) will be substituted for that of the licensee (S /X), and theYagreement criteria recalculate x If a disagreement and the RSDs appear to be unreasonably low, RSDs*
of 3% will be substituted for those of both the NRC and the license This will not be done for the boron analyses where the expected RSDs are 0.5-1%.
I Due to some uncertainties in the values of the 1987 (87) boron standards, the mean values of the concentrations obtained by the plant.laboratories in Region III are used as the NRC value These results appear to have resolved the problem of the consistently negative biases between the licensees and BNL boron analyse The licensees generally reported similar values of the 1000-ppm standard with a relatively~mall RSD*of
+/-1.7%, although the analytical methods differed.