IR 05000255/1990009
| ML18054B524 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/22/1990 |
| From: | House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054B525 | List: |
| References | |
| 50-255-90-09, 50-255-90-9, NUDOCS 9004060321 | |
| Download: ML18054B524 (10) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
,./~::*Report No. 50-255/90009(DRSS)
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- ,.-'*Docket No. 50"':'255
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licensee:
Consumers Powe; Company 212 We~t Michigan Avenue.
J~c~_~on,- MI 49201
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Facility Name?:~ Palisades Nuclear Genef~ti_ng,;Plant'*.*'.:~**:'.. *.
Irlsp'ection At:
Palisades Site, Covert, Michigan
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Inspection Conducted:
March 5-8, 1990 (Onsite)
March 15, 16, 19 and 20, 1990 (Telephone discussions)
~/A:~/~c£v Inspectors:
J. (- House
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M. C. Schumacher Approved By: ~/~~A-M. C. Schumacher, Chief Radiological Controls and Chemistry Section Inspection Summary
.g?-~/70 Date
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Date Inspection on March 5-20, 1990 (Report No. 50-255/90009(DRSS))
Areas Ins ected:
Routine announced inspection of post accident sampling monitor (PASM system (IP 92701); chemistry *.selfc::a_ss~s.sm~nt1~r.ograll!.*(IP 79701);* 'Chemistry
,( f.;\\:qual i ty assurance program (IP 79701}; t~nd;;~r~yl~vfCt>.f~~~p~ij~~.'.t,~pls: (IP. 92701)..
.~f,~&JR~sults:
~abo~atory personnel demonstt~;ted the -~P~.t~~j,Ji~~.W~i§.'f~~~.E! PASJi,,system i***>:by.::s-co ll ectrng*1~reactor coo 1 ant samples.'~*:.lj~e cchemrstry,*c:~.~\\l:f*f-'as,sessment. pr,9gram
.. ;~~pe~red to be pro~ressing on schedu~e ~ri~-~'.-1~~ora,t<>,r~.'~gy,~ntyj~~$.s~ran~~, ;-:
{tontrnued to show improvemen No v1olat1ons p_r dev1at1ons were *1dent1f1ed *
9004060321 900322 PDR ADOCK 05000255 Q
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-* DETAILS P~rsons Contacted
. 2 K. Berry, Di rector, Nuclear Licensing, * CPCo - "'*,
1' 2J. Brunet, Licensing Analyst, *cPCo **
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1>2.r. Chartrand, Chemistry Supervisor, CPCo :;?,* Dehn.~ Chemistry Technician, CPCo 2 R. Frisch, Nuclear Licensing, CPCo 20. Jones, Quality Assurance, CPCo 1M. King,;Engineering Supervisor, CPCo_.
2C. Kozup, Technical Engineer, CPCo 1R. McCaleb, Quality Assurance Director, CPCo 1J. McElrath, Senior Engineer, CPCo *
1R. Orosz, Engineering & Maintenance, CPCo 1 K. Osborne, Systems Engineering Superintendent, CPCo *
1T. Saarela, Senior Systems Engineer, CPCo 1J. Schepers, Quality Assurance, CPCo 1G. Slade, Plant Manager, CPCo J. Heller, Resident Inspector, NRC 1Present at the Exit Meeting on March 8, 1990.
. 2Present during telephone discussions March 15-20, 1990.
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- Licensee Action on Previous Inspection Findings (IP 92701)
(Closed) Open Item (50-255/88015-01):
Licensee to investigate analytical disagreements with Brookhaven National Laboratory (BNL).
Instrument calibration appeared to be the cause of the disagreement The licensee has reviewed these disagreements and modified the laboratory quality
- assurance program to include independent controls, improved control charts and implemented multiple point calibration curves.for most instrument An exception is the atomic absorption spectrophotometer for
.which t~e manufacturer-does not retommend a multiple point curve but the independent control provides an additional check poin The licensee was having some baseline adjustment problems with the new gradient elution ion chromatograph (IC) and additional operating e~perience was needed:
- co: Review of the IC control.charts :indicated.the *neecf.~'for.. more_ frequent
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calibration which the Hcensee.agreed to dq. -.
.-T~e'-J_~i~,en~~,e,.~,-~ Chemistry-
-Self Assessment Program (Section 4)"'i\\also *intludes<<qaboritory quality*
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assurance. This area will continue to -~e J~eviewed_:in--t,outine inspection (Closed) Open Item (50-255/89010-01):
Licensee to describe a plan for improving management oversight of vendor._ra91ologh::al laboratory s,~rvi_ce The licensee 1 s response in a letter dated -:August l~ 1 :cl98_9_, *_ St?lted;J_b,at *
the most recent quality assurance ~audit/of'lhe vendor:t5-**laboratory wa~-
done in the latter part of 1988 and that another audit*.which would- -
include the Corporate Health Physicist had been scheduled for October 198 The 1988 audit was conducted by Illinois Power Co. in late 1988 and had been reviewed as acceptable by Consumers Power C.2
- ~.I The vendor laboratory was audited as scheduled, October 30 through November 1, 1989, and included vendor QA, personnel training, calibration records, control charts, crosscheck results and laboratory observation The audit appeared generally thorough, detailed and appeared to probe for programmatic weaknesses in the vendor's quality assurance progra Nine audit comments were listed and -1 icensee_ff~Pr~$~J'lt:~~i:,v.es:1~~t~~~~d~:that?-tb~ *
~en~or was expe~ted to m~ke : correct i:(!ras,-::~whicb~tbe:Jl~ e~ns*ee ~oul d:~revlew in its.next.. audi The i nspectqr.s ~r:i.oted ::,th.~t l!thEr~:~Q91J*~,-Jwh1c;h-:;*are$ ~¥r-**
performeq_: u99er the auspices of..,the* C9rppr~te. -Q~ ::G.t:9i;rj:f,/~o,;;:Qo_t ;~ClRP~~r :1:.o be we 11 coo'rdi nated with the pl ant laboratory :.groupsi.'.whc>'-use the v~ndor services.. _* Jhe importance of getting.*fop_µt-;Jr..oii(4hese gro.ups befqre..
auditing,*,.~n_d_ routing the audit rep()r~~--~o the_m.after,w~r.ds. was dfs¢.u~_sed
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(Open) Open Item (50-255/89010-02):
Licensee to analyze a spiked'primary coolant system (PCS) sample and a liquid wastebatch release composite sample for gross beta, H-3, Sr-89 and Sr-90, and report results to Region III for comparison with the NRC reference laborator The licensee achieved all agreements (Table 1) on the spiked PCS sample except for Sr-90 which was below the licensee's LL The composite results were in disagreement except for tritium (H-3) and Sr-90 which was below the licensee's required LLD. This sample was apparently allowed to stand for perhaps 30 days before counting samples were prepared from it thus allowing plateout to occur and bias the results. These results were discussed with licensee representatives who agreed to review batch release data to confirm that significant release quantification errors were not occasioned by the underestimate of gross beta activity. The licensee also agreed to perform another sample split and comparison with the NRC reference laborator (Closed) Open Item (50-255/89010-03):
Licensee to*provide an updated action plan confirming the timetable for completion of the PASM System upgrade The plan was submitted under cover letter dated August 15, 1989 and discussed with licensee representatives the same mont The inspectors reviewed the most recent action plan update (January 23, 1990)
during the current inspectio Overall, licensee progress appeared satisfactor (Closed) Open Item (50-255/89023-01):
Licensee,t,9 revise Gamma
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Spectroscopy Procedure CH 4. 3 The. prevJpl.1$.. p~a~1:*i~e '"'as,to up~a,te -
the mean and standard deviation fo~. the,,control '.,char,ts,;with each,'.~ntry.
.. The 1 i censee, has revised. this; proceCi~'re *'to/ne:ttect'.;:;~*~,fe$$:'.,~tr~queot~i:' :~0.i:~I--~
- Jif}i-. *updating (~iuarterly) of control ;~hart~-~-P~ta~~t~rs*~*.;!f.*;*£:*~,,..... *'**:.:*--
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(Closed~ Open.Item (50:255/89023-0~):
Lft~nsee to.s~ik~.steam ge_o,~~~t()r water with anions, spli_t.samples with Bro9khgyen National labora_t~r..y;JBNL),
- analyze *;and* send *results to'**Region IIJ. :.. Jhe'f1jcer:is.ee* _has *comple*t~~*;:ttt~.
- split samples with BNL,(Tab*le 2). **compa:ris"on[:ofttle': licensee's ri!fsUlts*
with the BNL results produced agreements for.,;chforide and *fluoride* * No comparison was possible for sulfate as BNL did not report a specific number, just less than 20 pp **
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(Closed) Open Item (50-255/89023-03):
Licensee to address laboratory quality assurance topics by letter, including control chart parameters, multiple point calibration curves, water chemistry parameter trending procedures and to define acceptance criteria for the interlaboratory comparison pr~gram. The licensee.sub!llittEl9 an acti.on pl~.n and a.. time table.. for the completion of'.*a'".se*rte(.of *~C).(ii:f.;i~~t.tons t'o*"tlle.laboratory
- con'trol program. * The inspector tevi*:ewed "the'..:~completed '.p'ortions ofo~tnis plan and.they appeared to be adequ'ate.; * ~
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Post Accident Sampling Monitor :system (PASM) {JP...,-g2701)
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Prior to :the inspection, a meeting*,~~s ~elctiJl.1 ~egi~n :UI.... wjth *14.~eosee representat.ives (February 26, 199Q) "during. wJii~h Mle ~most *recent: ~~SM*
Upgrade Action *1 i st was reviewed: The. 1 i censee**'s 'tinietabl e appeared to be reasonable and progress on sch~dule..
- µnrell~ble component modification was on track with completion scheduledfor *the '.1990 maintenance outag Meanwhile, the licensee operates PASM about twice monthly which provides training as well as surveillance on the syste Licensee representatives stated that these surveillances were indicating no problem with leaking Swagelok fitting *
The inline monitoririg project is basically complet Problems with operation of the dissolved oxygen (DO) analyzer and the gas chromatograph (GC) appear to have been resolved with the assistance of the system and instrument manufacturer The inspectors noted completion of procedure modifications and technician training on the system given by the licensee and the vendo The licensee is in the process of formally closing this facility change ite Problems that persist with the operation of the inline pH and conductivity monitors did not affect system availability for post accident use. but were of interest for routine samplin These problems were being worked on by the license The project to evaluate PASM design and implement needed changes has been partly complete Alternate systems are now evaluated by the licensee as a regular participant in the Sentry Owners Grou PASM sample comparison with NSSS samples is also done regularly during the twice monthly testin Licensee representatives indicated that the target date for deciding on replacement of globe valves with ball or plug valves has been deferred to 1992 because of inability*so.far to identify valves on the market
.. capable of meeting system des'igrf'criteria~ SThey indicated that *Uncertainty
.in.valve.. stem position indication\\~j*s it.he:,*P.rirwipal.cPnce.rri,,<,;not.~Je~k~g >
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- .PASM wor.k.orders continue to receive *i:na,jriten~11cct!~prioidty~*by being *put on the Operaiions Concerns list ~ased on the decijiri~ 6f the plant chemis Licensee *representatives stated that problems that**may affect system avai labi,l i.ty will.be repaired on overtime ;i{;)le~~~sary.,.. '.:P:.reventiv,~,., \\*.
- ,. maintenance on.the PASM ~ystem has. been.~!Jpgrade-µ,.,by. con~r.acting fJ)'r~'~<<,.
regula*r visits.*by the vendor~ For :i990":' quarterly;fyJsits' *are :scHedifle The availability of vendor repres*entat*ives ;for emergency response has *
also served to enhance availability of PASM spare part The licensee's comprehensive evaluation of the PASM spare parts program has been deferred to August 199 The licensee has also completed a number of administrative upgrades such as P&ID revisions and is scheduled to complete a project to upgrade the equipment data base and Q list with reference to PASM by October 199 Several miscellaneous improvements have been completed or should be during the 1990 maintenance outag *
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At the request of the *NRC i nspec:;i,o~s,e:t-the. l~ice)1se,e operated *the PASM
,~ s,ystem t~. demonstrate the taking 19_f ~liqµi't~al;(d ;,g~~-~"()U~~;~,a.mple~.* ~~.od ::,.; :.'*
tran~_p9rt~):)g:;;;them to :the la,po~ato.rY;,,fP,_r.1-,pa:j-y~~.s~~1~(Ac,~!fir1;:!:C9o,nt1~;!ll11~nt~.*,
samples wet:'~ not drawn but the*necessary P~!ec_µrJ~or steps *were pertforme ;~<,.
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Ov.erall, ~he;0.procedure seemed.to go.~mc;mthly and_,,'li~f!nsee:,collecti~~n
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Overall~ the l.icensee has made significant:prdg
r,ess~"i,"ff~Yupgrading_.the reliability of the PASM syste The licensee's continued progress will_
be reviewed in subsequent inspection (Open Item 50-255190009-01) * "**
No violations or deviations were identifie.
Chemistry Self Assessment Program (IP 79701)
The inspectors reviewed the licensee's Chemistry*Self Assessment.Program, -
conducted from July through September 198 The report (December 15, 1989)
addresses all chemistry related activities and represents an in depth look at the interaction of chemistry with various organizational group The s~lf assessment was developed, in part, as a response to reviews and inspections by INPO and the NR Standards used were derived from INPO 88-021 "Guidelines for Chemistry at Nuclear Power Stations, 11 and Chapter XIV of INPO 85-017 "Guidelines for the Conduct of Operations at Nuclear Power Stations.
The assessment was conducted by four full time persons including a contractor and numerous individuals on a part-time basi The report identifies 21 weaknesses, 43 improvements.and 11 strengths which have led to 264 planned actions.. An action tracking plan was developed which provides a timetable for completion of planned action Not only has the assessment identified program weaknesses but also addresses these findings with solutions and an implementation timetable.
. The inspectors, during discussions*:,with* licensee *representatives, *.noted**
_ ;..:..;.;*., *that.one area being addressed:was *coomiunication betwee)'r chemi~tr,Y.:<and *'
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Improving the in~~f!Change amQ,~.!h$!rganizati~ri~1 grpups,..
,~~{:;~Li{.\\~:* should.'contr.ibute to imp roved ~,plant: ~~r.f 9_rman~~, -iwhich 15: ~a>goal ;:9'f At.he
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This pro.gram is a major undertaking and ha~ required considerable 'e.ffQrt
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in future i rfspect ions for its contri but i o.ns ':ttf.. imp roved pl ant perf;ofnianc ~Zf.,
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No violations or deviations were 1dentifie =- *
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,*.*,;: Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee, or bot An open item disclosed during the inspection is discussed in Section~-
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Exit Inter.view
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. *.; The scope and findings of the inspectiontwere reviewed with licensee representatives (Section 1) at the conclusion of the inspection on March 8, 199 The inspectors discussed the following:
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- the post accident samp l i.ng system the chemistry self assessment program the closing of open items from previous inspections
.During the exit interview, the inspectors discussed the likely 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, Radiological Interlaboratory Split Sample Results, First Quarter, 198.
Attachment 1, Criteria for Comparing Radiological Measurements Table 2, Nonradiological Interlaboratory Split Sample Results, August 1989 Attachment 2, Criteria for Comparing Analytical Measurements (Nonradiological)
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TABLE 1
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u. s. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM *
FACILITY: PALISADES FOR THE !ST QUARTER 1989
- sAMPLE NUCLIDE NRC VAL. NRC ER LIC.VA LI"C.ER RATIO RESOL. RESULT LIQUID G BETA 2.98E-05 1.lOE-06 2.27E-05 O.OOE+OO 0.76 2 A PCS H-3 8.07E-04 1.00E-05 8.87E-04 1.00E-06 1.10 8 A SPIKE SR-89 *
8.40E-08 9.00E-09 6.50E-08 9.90E-09 0.77 A SR-90
- 5.00E-09 4.00E-09 (5.00E-08 O.OOE+OO 10.00 N LIQUID G BETA 5.40E-06 2.00E-07 7.40E-07 O.OOE+OO 0.14 2 D COMP H-3-2.43E-02 3.00E-04 2.50E-02 1.ooE:-04 1.03 8 A SR-89 1.33E-07 1.30E;_08 (5.00E-08 O.OOE+OO 0.38 1 D SR-90 1.40E-08 5.00E-09 (5.00E-08 O.OOE+OO 3.57
- N REEMENT ISAGREEMENT N=NO COMPARISON
- =CRITERIA RELAXED
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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS *
Thfs attachment provfdes crfterf a for c011paring results of capability tests and verification measurement The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra *
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In these crfteria, the jodgment limits are variable in relation to the comparison of the NRC 1s value to its associated one sigma uncertaint As that ratio, referred to fo this program as 11Resolution 11, increases, the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement should be considered acceptable as the resolution decrease The values in the ratio criteria may be rounded to fewer significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement
<4 NO COMPARISON*
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o. 75 - 1.33 51 - 200 0.80 - 1.25 200 -
0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques,
- and for some specific nuclide These may be factored into the acceptance criteria and identified on the data shee..
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TABLE 2 Nonradiological Interlaboratory Split Sample Results Palisades Nuclear Generati~g Plant August 1989., '. *'*:*-*:*
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- Ratio x +/- so z +/- so.
Concentration, ppb Fluoride Chloride Sulfate ICG ICG ICG 12.6 +/-.8+/- < 20 Value +/- standard deviation (SD):
14.5 +/-. 4 +/- 1. 6 43.9 +/-.151 +/- 0. 078 0.967 +/- 0.048 Licensee SD for Fluoride is a Relative Standard Deviation (RSD) of 5% and was derived from SD of control chart Licensee SD for Chloride was based on three analyse BNL SD is an RSD of 3.0% for Chloride and 5% for Fluorid Analytical method:
ICG - Ion chromatography (Gradient) A = Agreement D = Disagreement N = No Comparison Possible
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ATTACHMENT 2 Criteria for Comparing Analytical Measurements This attachment provides criteria for comparin~ results of the capability test The acceptance limits are based on the uncerta1nty {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
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propagation of the uncertainties of licensee's mean value, Sx, and of the NRC's mean value, Sy. 1 Thus, 5z
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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 uncertainti in the ratio,. * National Council on Radiation Protection and Measurements, A Handbook of Radioactivit~ Measurements Procedures, NCRP Report No. 58, Second Ed1tlon, 1985, Pages 322-326 (see Page 324).
4/6/87