IR 05000255/1992009
| ML18058A253 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/29/1992 |
| From: | House J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18058A252 | List: |
| References | |
| 50-255-92-09, 50-255-92-9, NUDOCS 9203090017 | |
| Download: ML18058A253 (8) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/92009(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company 27780 Blue Star Memorial Highway Covert, MI 49043 Facility Name:
Palisades Nuclear* Generating Plant Inspection At:
Palisades Site, Covert, MI Insp~ction Conducted:
February 10-13, 1992 Inspector: ~
J. E. House Approved By:
.
- ~ S..J!{
w~fliam.Snell, Chief Radiological Controls SEttion Inspection Summary License No. DPR-20
,,2.-2?--12-0ate z./z...J/YL Date Inspection on February 10-13, 1992 (Re ort No. 50-255/92009(DRSS))
Areas Inspecte :
out1ne announce inspection o :
t e c em1stry program, including procedures, organization, and training; (2) primary and secondary systems water qua 1 i ty contro 1 programs; ( 3) qua 1 ity assurance/qua 1 ity contra 1 progra;:i h Ht laboratory; (4) nonradiolgical chemistry comparisons; and (5)
open items (IP 84750).
Results:
The licensee's water quality control program was very good as was overall water quality following the steam generator (S/G) replacement projec The nonradiological chemistry comparison results were very good (all
agreements) indicating improvement in the laboratory QA/QC progra Th *
inspector noted thc.t the water quality program and ana lyt i cal chemistry performance were strength Ne violations or deviations were identifie PDR ADDCK 05000255 G
- DETAILS Persons Contacted
.
1s. Baker, Laboratory Supervisor 1P. Donnelly~ Director, Plant Safety and Licensing 10. D. Hice, Chemistry Superintendent C. Hillman, Licensing 1T. Moore, Chemical Engineer 1R. M. Rice, Operations Manager 1J. R. Schepers, Assessment Specialist 1G. B. Slade; Plant General Manager M. Sullivan, Laboratory Performance Analyst 1R. Bywater, Reactor Engineer, NRC The inspector also inte~viewed other licensee personnel in the course of the inspectio oenotes those present at the plant exit intervie\\'1 on February 13, 199.
Licensee Action on Previous Inspection Findings (IP 84750) (Closed) Open Item No. (50-255/90009-01): Monitor licensee progr.ess in the PASM system upgrad This program has been complete Parts for two inorerablf instruments have been obtained. A damaged probe for the dissolved oxygen meter will be replaced during the present out~s~. The gas chromatograph has been repaired and will be calibrated during the outag (Close~) Open Item No. (50-255/90022-01):
Licensee to resolve instrullient calibration problem The laboratory Quality Assurance Program has improved (Section 6).
The use of independent controls along with increased emphasis on proper instrument calibration resL< lted i r. *imr;roved ptrformance in the chemistry comparison program (all agreements). Management Controls, Organization and Training (IP 84750)
There were no significant changes in the Chemistry *Department organization since the previous inspection (Region III Inspection Report No. 50-255/90022).
Laborr~tory management personnel appeared to be knowledgeable, well qualified for their positions and-responsible for improve1:1ents in the chemistry comparisons and QA program Licensee repre~*.t:-1rtdt~ves s*,~,~~-*'!C *-.hc.c*c
~1ersonr1el turnover is. lo Currently there are eleven Chemistry Technicians; three are Level 1, five are Level 2 and three are Senior Technician The licensee's training program was reaccredited by INPO as of September 199 f~O violat10r1S r.r cic-vic;tions.were identifie,,
(_
- v/ater Chemistry Control Program (IP 84750)
The inspector reviewed the water chemistry control program which is basrd o:~ Pn1cedun:s COF' 11, "Secondary System Chemistry," Revision 14, February 5, 1991; and CH L7, Chemistry Trending Program, Revision 0, February 14, 199 Administrative limits on the chemistry parameters appeared to be consistent with the EPRI Steam Generator Owners Group Guidelines (SGOG).
The licensee replaced both steam generators (S/G) during a September
. 1990 - March 1991 outag Additional modifications to the secondary side included reo"lc,cernent of the Admiralty brass condenser with stainless steel component Copper tubing in feedwater heaters was also replaced with stainless steel and the heaters were chemically flushed to remove any copper in the system that had plated out. Three deep bed demineralizers were installed during this outage for processing S/G blowdown which is then returned to th~ hotwel The addition of this system is a strengt The licensee* has an 1n-linE- :.: 1st2n
- oc:.:"~.::c..
i1:
GraL san;ples cJn i.\\ 1'.:c' re oha ined frcr:
this syste The licensee has computer based trend charts and recentl~*
added a real time datd niar;2:0er.ient SJStH: tht:.t is urri~:ctrc'. :ia 111c1drn, to the vendor v1ho prepares a monthly water quality report for plant miH1agemen This is µart c;f a S/C r;:aintenance contract. Chemistry parameters are reviewed daily by chemistry personne The Chemical Engineering Section Head prepares a monthly report of chemistry parameters for plant managemen ~later qua 1 ity fc l lov,*i ng the S/G rep 1 a cement project was very goo The Chemistry Performance Index (CPI) which incorporates condensate dissolved oxygen, S/G sodium and cation conductivity values (all normalized)
indicated that the secondaD' water system cleaned up within three months following the March 1991 startu The CPI dropped steadily from approximately 1.2 immediately after startup (1.0 would be operating at the upper limits of the Electric r*c*1*ffr Resec.rch Institute (EPRI)
Guidelines) to approximately 0.25 in June 1991, and has continu8d to fluctuate about thc.t. lE\\*e Tht iatest monthly CPI, January 1992, was 0.20 which surpasses the industry average of 0.34 for plan.ts of this type and thE: industry top quartile of 0.2 Licensee nprE:sentat1ves stated that higher then expected levels of fluoride had contributed to the
conductivity and this_ had been traced to 1;1elds in the condenser 1-1hich was refitted viith stainless steel components during the S/G replacement outag Primary system chemistry v1as good; chloride and fluoride levels were approximately 20 ppb (150 ppb guideline), dissolved oxygen was less than 5 ppb (10 ppb guideline) and dissolved hydrogen was maintained within the recommended rang S/G blowdown caticn conductivity was above the 0.8 uSiemen/cm guideline following startup, but by late August it had dropped below this leve Sodium v1as uride"' 4 ppb (20 ppb guideline), cnlorid2.3.nc.::ulfate le'J\\0
';
3 *
6.
hed fol len to u1*1cN 2 (!lid 5 pfJb r:* Se:µtcr.1LEY (20 ppb guidelines)' however neither species was over the guideline following startu Fluoride levels following startup wcrt:
ilf'~'roxilil~i-:1~i/ 200 rrl (th_-rt cl-.: _,;;
fluoride guidelines) but have decreased steadily, and from October 1991 to the present were unot:r 10 ppb, indicating good cleanui:;.
Th decreasing CFI parallelled the d~creasing fluoride levels in S/G blm1duw Fe.ed1*1ater iror1 2nd C(;prer were under 5 and 1 ppb with guidelines of 20 and 2 ppb respectivel Installation of additional water purification equipment (S/G blowdown demineralizers) and the rapid clean up of the secondary systems js a reflectio~ en the increased emphasis that licensee management has placed on chemistr No ~iolations or deviations were identifie Nonradiological Confirmatory,Measurements (IP 84750)
The inspector submitted chemistry samples to the licensee for analyses as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chenis'Lrj' parametc:rs in \\'arious r*lant systems with respect to regulatory and administrative requirement These samples had been prepared, standarC:ized, dnd 1*ct'icH"lic.:.lly rean&ly2ed (tc chE:ck for stabi 1 ity) for the NRC by the Safety and Environmenta 1 Protection Divis-;01! 0*1 f'r:)r:il:h0vt** Narior.al Laboratory (BNL).
The samples were analyzed by the licensee using routine methods and equipment.
The samples were diluted by licensee personnel as necessary to br'ir19 the concentrat iOns within the ranges normally analyzed by the lab oratory, and run in triplicate in 2 wanner similar to that of routine sample The results are presented in Table 1 with the criteria for agreement presented at the end of the tabl ThPse criteria arE: derived from the BNL results of the present samples and the relative standard deviations (RSD) derived from the results of the 1986 interlaboratory comparisons from the various plant laboratories in the study (Table 2.1, tlUREG/CR-5422).
The acceo+.311u: criten:.:.*1u*r, 'Jc:i*
- h~ *1icensee 1 s value should be within + 2 SD of the BNL value for agreement and between 2 and 3 SD fer qualTfie~ agreemen A q~alified agreement 8dj indicate a deficiency in the assa The licensee perforr1:~r! 26 analyses of 9 analytes at various concentrations and all 26 coffiparisons (Table 1) were agreements (25) or qualified agrf'e1i1ern:s (1).
The inspector noted to licensee representatives that these results were very good and represented' considerable improvement over the last nonradiological chemistry comparisons in which thEre were only 19 agreements out of 30 comparison No violations or d~vi~tinns ~ere identifie Implementation of the Chemistry QA/QC Program (IP 84750)
The insrE:ctor reviewed the chemistry QA/QC program as defined in Procedure CH 1.3, Laboratory Qualit.Y Control Program, Revision The licensee employs statistically based control charts, independent controls
and multiple point calibration curve The laboratory quality control program continues to improv Control charts are statistically based with the mean value and +2 SD (warning limit) and +3 SD (control limit)
plotte No significant-assay biases could be determined from a review of selected control charts. Calibration curves fur spectrorhctcr.1etl'ic a~says had been changed from % Transmission vs Concentration tc Absorbance vs Concent~at1011. Tht ~ew format appeared to be easier to read and interpret \\'1hich improves the accuracy of these assay In addition, technicians no longer use % Transmission and Absorbance interchangeably on the central chart The licensee has a vendor supplied interlaboratory comparison progra Samples are supplied on a quarterly basis and the results from the previous year were very goo Approximately 64% of the licensee's results were within +5% of the vendoi and 95% were within 12%.
The licensee also *
participated-in an extended version of this program in which addi.tiOnal unknowns are provided by the vendor (most plants participating in the program do not receive these additional samples).
The results of those analyses were equally goo The Intralaboratory Comparison (technician testing) Program requires that technicians be tested twice per yea Unknowns were prepared and ~esults analyzed by la!Joratory supervisors. Acceptance criteria were derived from INPO standards. Technicians whose results are outside of the acceptance range are required to repeat the analyse A review of selectE:d data fron1 the past year indicated that the technicians performed we 11 c-.tid the prcgra1T. operated satisfactory. These testing programs, along with modifications in the instrument calibration program, have resulted in an o'terall improvement in the laboratory quc.lHy assurance progra No violations or deviations were identifie.
Analyses-Required by Technical Specifications (IP 84750)
The inspector reviewed trends of boron analyses required by Technical Specification~~ (T/S).
Thest included the Safety Injection and Refueling Water l&~ks (T/S range 1720-2000 ppm~, Spent Fuel Pool (T/S range at least 1720 ppm), Safety Injection Tanks (T/S range 1720-2000 ppm) and the Co11centratEd Boric Acid Tanks (T/S range 10,928-17,483).
Data from the past 12 months ihdicated that boron concentrations in these vessels were within the rt:~uired ra11ge No viulations or deviations ~ere identified_ Post Accident Sample Monitoring System (IP 84750)
The inspector reviewed the operation of the Post Accident Sample Mcritcrin£ System (PAs~n \\dth licensee_ representatives. Chemistry Technicians are required to receive training on the system twice per year, and a review of chern~stry records indicated that this was done.
Licensee representatives stated that the PASM is activated twice per mont A t*eview of ~tlected PASM sample date was compared with grab samr 1 e* analyses fer boron, pH, hydrogen and gamma spectroscop Both the
- nonradiological and the radiological comparisons indicated that the PASM samples were representative of the bulk reactor coolant. A Field Service Report (vendor) from December 1991 was reviewed and indicated that the PASM system was operating as require Some difficulties were experienced with the Gas Chrorrwtc:graph' but the problem was identified as a faulty circuit board which was replace The licensee had indicated by letter to Region III that the quarterly vendor maintenance would b~ reduced to semiannual, however, performance of the PASM system would be closely monitore Overall system performance for the past year was goo PASM system operation and maintenance including the reduced vendor servicing will be followed in subsequent inspection No violations or deviations were identifie.
Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on February 13. 199 The inspector discussed results of the chemistry comparisons, improvements in the laboratory quality control program, the water quality program and the PASM syste During the exit interview, the inspector discussed the likely information:.;l r.nntent of the i*-!;pe.::.;:i'.'J*; *rerort \\*ti~*h n:giHd 1c dr:cuments or processes reviewed by the inspector during the inspectio Licensee representatives did not ident ifj ;1i*;v S!)C:h c'.ncL:r*q ~:~, J,
- )* _;Cfsses r
- .s proprietar Attachment: Table 1, Nonradiological Chemistry Comparison Results, February 10-13, 19~2
Analyte Fluoride A
B c Chloride I\\
B c Sulfate A
B C*
Iron G
H I
Copper G
H I
Ammonia M
N
Hydrazine P Q
R Silica s
T P.c, ro n D
E F
Table 1 Nonradiological Chemistry Comparison Results Palisades Nuclear Plant February 10-13, 1992 Method 1 Concn 2 Ratio3 Acceptance Ranges 4 Result
+ 2RSD
+ 3RSD
£££ IC
1.050 0.875-1.125 0.813-1.187 A
1.065 0. 875-1.125 0.813-1.187 A
1. 057 0.875-1.125 0.813-1.187 A
0. 94C C.933-1.067. 0.900-1.100 A
'10 0.931 0. 917-1. 081 0.879-1.121 A
0.915 0.926-1.074 0.895-1.105 A+
0.953 0.895-1.105 0.842-1.158 A
0.939 0.895-1.105 0.868-1.132 A
0.907 0. 900-1.100 0.867-1.133 A
MVFU b
0.990 0. 904-1. 096 o*.854-1.146 A
J. 6 1. 031 0. 903-1.097 0.857-1.143 A
1.083 0.903-1.097 0.855-1.145 A
- AA/FU
0.960
. 0.904-1.095 0.859-1.141 A
0.978 0.904-1.096 0.857-1.143 A
1.002 0.904-1.096 0. 857-1.143 A
IC 200 o. 971 0. 902-L 098 0. 856-1.147 A
3100 1.032 0.902-1.098 0.856-1.147 A
5000 1. 06C 0.902-1.098 0.856-1.147 A
Spec
1.049 0. 922-1. 078 0.888-1.118 A
0.974 0.922-1.078 0.888-1.118 A
1.025 0. 922-1. 078 0.888-1.118 A
Spec
1.094 0. 906-1. 094 0.859-1.141 A
100 1.030 0.909-1.091 0.860-1.136 A
££!!!
Ti tr 1000 0.992 0.979-1.021 0. 9-68-1. 032 A
3000 0.998 0.979-1.021 0.968-1.032 A
5000
. 0. 987 0. 979-1. 021 0.968-1.032 A
-
L Methods:
Titr
. IC Spec AA/FL AA/FU
- Titration
- Ion Chromatography
- Spectrophotometry
- Atomic absorption spectrophotometry (flame)
.
- /l.tomic absorption spectrophotometry (graphite furnace) Cone: Approximate concentration analyze.
Ratio of Licensee mean value to NRC mean valu.
The SD in the fifth and sixth columns represents the coefficient of variation obtained from averaging licensee data from the preceding cycle (Table 2.1 of NUREG/CR-5244).
A result is considered to be in agreement if it falls within the + 2 SD range; a qualified agreement if it lies outside + 2 SD, but within + 3 SD; and in disagreement if it is outside the : 3 SD rang.
Result:
A = Agreement: Licensee value is within +2 SDs of the NRC mean valu A+= Qualified agreement, licensee is between+ 2 and +3 SDs of the NRC valu D = Disagree~ent: licensee value is outside + 3 SD