IR 05000255/1993006
| ML18058B769 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/16/1993 |
| From: | Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18058B771 | List: |
| References | |
| NUDOCS 9304210364 | |
| Download: ML18058B769 (10) | |
Text
APR 16 1993 Docket No. 50-255 Consumers Power Company ATTN:
Gerald General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
Dear Mr. Slade:
SUBJECT:
ROUTINE CHEMISTRY INSPECTION AT THE PALISADES NUCLEAR PLANT This refers to the routine safety inspection conducted by Dr. J. House of this office on April 5 thro~gh 8, 1993.
The inspection included a review of authorized activities for your Palisades facility.. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed report.
- Areas examined duririg this inspection are identified in the report. Within the,se areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel..
No violations of NRC requirements were identified during the course of this i nsp.ect ion.
- In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room:
We will gladly discuss any questions you have concerning this inspection.
Enclosure:
Inspection Report
No. 50-255/93006(DRSS)
See Attached Distribution
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Sincerely,
Ori&inar Si&ne4 B_y William Snell
William Snell, Chief
Radiological Controls Section 2
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Snell
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- Consumers Power Company
Distribution
REGION I I I
Report No. 50-255/93006(DRSS)
Docket No. 50-255
licensee: Consumers Power Company
27780 Blue Star Memorial Highway
Covert, MI
49043 *
Facility Name:
P~lisades Nuclear Plant
Inspection At:
Palisades Site, Covert, MI
Inspection Conducted: April 5-8, 1993
Inspector: ~
&~
Approved by: w;)frl~t*e?Qe
Radiological Controls Section 2
Inspe~tion Summary
Date
License No. DPR-20
Inspection on April 5-8, 1993 (Report No. 50-255/93006(DRSS))
Areas Inspected:
Routine, announced inspection of the chemistry program
including:
audits,_quality assurance, chemistry comparisons, radiological
environmental monitoring program (REMP), dry cask fuel storage, and an
inspection followup item.
Results:
The licensee's performance in the chemistry comparison program was
excellent (31 agreements in 32 comparisons).
The laboratory QA/QC program was
well managed.
The water chemistry program and plant water quality were very
good; the licensee removed a total of only 30 pounds of sludge from both steam
generators at the end of the first refueling outage following steam generator
replacement which was very good. Audits were performance based and. thorough.
The REMP was well managed, and the radiation monitoring program for dry cask
fuel storage appeared adequate. * *
930421= 6~b~55
"
a
DETAILS
1.
Persons Contacted
- B. Baker, Chemistry Supervisor
G. Foster, Mechanical Equipment Supervisor
- K. Haas, Radiological Services Manager
D. Malone, Radiological Services Superintendent
- J. McElrath, Chemical Engineering Section Head
- M. Mennucci, Health Physics Technical Supervisor
- T. Palmisano, Operations Manager
- T. Popp, Project REMP Coordinator
- M. Sullivan, Chemistry Performance Analyst
- J. Heller, Senior Resident Inspector, NRC
The inspector contacted other licensee personnel during the inspection.
- Present* at the exit meeting on April 8, 1993.
2.
Licens~e Action on Previous Inspection Fihding CIP 84750)
(Closed) Open Item (50-255/91016-0ll:
The lice.nsee will split a liquid
radwaste sample and have their vendor laboratory analyze for tritium,
strontium-89, strontium-90, and gross beta.
The results will be sent to
Region III for comparison with results from the NRC reference
laboratory.
No comparisons could be made as the NRC reference
laboratory did not analyze the sample. This item is* closed.
3.. Management. Organiz~tion, and Training (IP 84750)
The chemistry superintendent reports to the operations manager.
A
.laboratory supervisor, a performance analyst, a chemistry support
specialist, a chemical engineering section head, and the environmental
coordinator report to the superintendent.
Five senior chemistry
technicians and six technicians report to the laboratory supervisor.
One of the technicians is on loan to the systems engineering group and
one technician is in training. All technicians, except for the one in
training, meet the American National Standards Institute Nl8.l-1971
criteria for technicians.
Due to low staff turnover, the laboratory has an experienced technical
staff with approximately 45% of the personnel at the senior technician
level. This is not an automatic promotion based on time in grade, but
is a promotion based on experience, knowledge, and laboratory skills and
requires the approval of chemistry supervision.
The laboratory has
strong ma.nagement support as evidenced by recent equipment purchases
including a new graphite furnace atomic absorption spectrophotometer and
modifications to an ion chromatograph.
The chemistry staff was very
capable and is a strength.
No violations or deviations were identified.
4.
Water Chemistry Control Program (IP 84750)
The licensee's water chemistry program conforms. to the Electric Power
Research Institute (EPRI) guidelines for primary and secondary water
chemistry. A review of selected trend chart data from the previous
12 months indicated t.hat primary system chemistry parameters were well
within the guidelines. Fluoride, chlbride, sulfate, and dissolved
oxygen levels averaged less than 20 parts per billion (ppb), 20 ppb,
20 ppb, and 2 ppb with EPRI guidelines of 50 ppb, 50 ppb, 50 ppb, and
5 ppb, respectjvely. Dissolved hydrogen was maintained within the EPRI
window.
The laboratory recently reduced the lower limit of detection
(LLD) for chloride, fluoride, and sulfate from 20 ppb to 1 ppb by
upgrading the Ion Chromatograph; This provides ~more realistic
estimate of these anions in the primary coolant since the actual
concentrations of these anions appeared to be much lower than the
previous d~tection limits of 20 ppb.
Secondary system chemistry was very good with steam generator (S/G)
blowdown levels of sodium, chloride, sulfate, silica, and conductivity
averaging l~ss than 4 ppb, 4 ppb, 3 ppb, 100 ppb, and 0.8 micro
Siemen/cm (µS/cm) with guidelines of 20 ppb,.20 ppb, 20 ppb, 300 ppb,
and 0.8 µS/cm, respectively. * Feedwater dissolved oxygen, iron, and
copper levels averaged less than 0.5 ppb, 2 ppb, and 2 ppb with
guideline levels of 5 ppb, 20 ppb, and 2 ppb,* respectively. Hydrazine
levels were ac(equate for removing dissolved oxygen from steam generator
Chemistry parameters were reviewed daily by chemistry
management and a ~eport of selected parameters was sent to plant
management.
The chemical engineering section prepares a monthly report
of chemistry trends and significant observations are forwarded to plant
management for review. A contractor reviews chemistry data daily and
prepares a monthly report for plant management.
The licensee's water
quality program is ex~ellent.
The chemistry department monitors corrosion products in the steam
generators. A licensee representative stated that during the last
refueling out~ge, 14 pounds of sludge was removed from one steam
.generator (S/G) and 16 pounds was removed from the other S/G.
This was
very good when compared with the previous (1987) sludge lancing of the
original steam generators during which approximately 4438 pounds of
sludge were removed from both generators.. In addition~ no S/G tubes had
- to be plugged during the most recent outage.
The licensee uses boric
- acid to reduce corrosion and morpholine for pH control in the steam
generators.
- The inspector compared boron concentrations in various plant systems
during the past 12 months with Technical Specification (T/S)
requirements.
The spent fuel pool concentration met the 1720 parts per
million (ppm) minimum; the boric acid storage tanks were within the T/S
range of 6.25-10%; the safety injection refueling water tank was within
the 1720-2500 ppm range; and the b~ron concentration in the safety
injection tanks were within the 1720-2500 ppm window.
No violations or deviations were identified.
5.
Chemistry Comparison Program CIP 84750).
6.
The inspector submitted chemistry samples to the licensee for analysis
- as part of a program to evaluate the laboratory's capabilities to
monitor nonradiological chemistry. parameters in various plant systems
with respect to regulatory and administrative requirements. These
samples had been prepared and standardized for the NRC by the Analytical
Chemistry Division of Oak Ridge National Laboratory (ORNL).
The samples * *
were analyzed by the licensee using routine methods and equipment.
Three dilutions were prepared from each sample by licensee personnel in
order to bring the concentrations within the ranges normally analyzed by
the laboratory. A single analysis wa*s performed on each dilution in a
manner similar t6 that of routine samples.
Th~ results are presented in
Table 1 which also contains the criteria for agreement.
These criteria
are based on ORNL analyses of the standards and on the relative standard
deviations (RSD) derived from the results of nuclear power plants
participating in a 1986 interlaboratory comparison (Table 2.1,
NUREG/CR-5442, Evaluation of Non-Radiological Water Chemistry at Power
Reactors).
The acceptance criteria were that the licensee's value
should be within 2 Standard Deviations (SD) of the ORNL ~alue for
agreement and between 2 and 3 SD for qualified agreement.
A qualified
agreemen_t may indicate a bias in the assay.
The licensee analyzed ten unknowns at three concentrations and one at°
two contentrations. Of the 32 comparisons, 31 were agreements
(Table 1). The three hydrazine results had larger biases than are
usually. seen; however, only the middle hydrazine concentration was a
disagreement. *When the three hydrazine unknowns were redil uted and
analyzed with no calibration or reagent changes, the results
(agreements) were within two percent of the reference values ~hich was a
si.gnificant improvement.
This indicated that a dilution error produced
the original disagreement and biases. Overall, licensee performance in
the chemistry comparison program was excellent.
- *
No violations or deviations were identified.
Chemistry Quality Assurance/Quality Control CIP 84750)
The inspector reviewed the chemistry quality assurance (QA) program
defined by Laboratory Quality Control Program, Procedure 1.3,
Revision 3, March 5, 1990.
The program incorporated statistically based
- control charts, independent controls, and multiple point calibration
curves. Control charts were reviewed by technicians when performing an
assay and weekly by supervisors. Data from selected.control charts was
randomly scattered about the mean indicating that instrument performance
was under statistical control. Concentrations of the independent
controls were in the ranges of plant samples which is a good practice.
Control charts were manually plotted, were neat, and provided an easy
appraisal of instrument performance.
The 1 i censee had two* 1 aboratory cross check. programs.
The first was a
vendor supplied interlaboratory cross check program which.measured
overall laboratory performance. This program was well organized and
incorporated licensee developed acceptahce criteria which*were based on
industry standards.
Each unknown was analyzed by five technicians and
their results were compared to the acceptance criteria. Technicians
whose results were outside of the criteria reanalyzed the un~nowns. The
average values for the five technicians were then compared to the
vendor's values using the acceptance criteria. The second program was
an intralaboratory cross check program in which unknowns were prepared
by laboratory supervisors. Technicians were required *to be tested twice
per year in this program.
From a review of selected data it appeared
that all technicians were tested twice annually. lhe licensee's quality
assurance program was very well managed.
No violations or deviations were identified.
7.
Audits CIP 84750)
8..
Surveillance S-AP-92-014 was.conducted March 3-June 30, 1992, to assess
the adequacy of hazardoui waste generation and control practices.
The
auditors reviewed chemical inventories, shelf lives, chemical usage,
types of chemical waste p~oduced, waste reduction, and disposal efforts~
There were no major _findings, although a number of minor observations
for program improvement were made.
Audit PT-92-07.assessed the
effectiveness of the Radiofogical Services Department in meeting
applicable T/S, procedures, *and regulatory criteria. Auditors reviewed
the REMP operation including procedures, equipment condition,
observation of $ample collection, and data acquisition. There were no
findings for the REMP.
The audit and surveillance were detailed; and
the audit teams appeared to be very knowledgeable.
No violations or deviations were identified.
Radiological Environmental Monitoring Program CIP 84750)
The inspector reviewed the Radiological Environmental Monitoring Program
(REMP) as defined by Procedure HP 10.1, Radiolog.ical Environmental
Monitoring Program Surveillances, Revision 3, January 1, 1993.
The 1991
Annua 1 Operating Report appeared to com*p ly with the REMP requirements.
All of the required samples were collected and analyzed, except as noted
in the repo~t. Missing samples were documented and the causes were
investigated as requited by procedure.
..
A tour of selected air sampling stations was conducted with the REMP
coordinator who was responsible for oversight of the REMP including
contractor performance in filter media changeriut and maintenance -0f the
air samplers.
The equipment was in very good condition and calibrations
were c,urrent.
The coordinator was a health physicist with power plant
.experience and was very knowledgeable of the REMP.
No violations or deviations were identified.
9:
Dry Fuel Storage Radiation Monitoring CIP 84750)
The dry fuel storage area is a concrete pad with a locked security fence
surrounding it. Three guard stations have been built around this fenced
area.
The dry fuel storage location is designated a radiological
controlled area (RCA) and will not be included tn the REMP.
This is a *
conservative approach as considerably more monitoring is required for an
RCA than is performed in the REMP, and the REMP program is designed to
detect any radiological releases from the plant including the dry fuel.
storage area. Monitoring wi 11 include contamination surveys,
thermoluminescent dosimeters (TLOs), and electronic dosimeters (EDs). *
TLDs and EDs will be placed at variotis locations around the fenced pad
including the guard stations and the administration building. The*
operations depa~tment will monitor cask vent tempefatures daily.
The
radiation monitoring plan appeared to be adequate.
No virilations or deviati6ns we~e identified.
10.
Inspection Followup Items
Inspection Followup Items are matters which have been discussed with the
licensee, which w111 be reviewed further by the inspector, a*nd whith
involve some action on the part of the NRC or licensee or both.
One
Inspection Followup Item is closed in Section 2.
11.
Exit Interview
The scope and findings of the inspection were reviewed with licensee
representatives (Section 1) at the conclusion of the inspection on
Aprjl 8, 1993.
The jnspector discussed the Ihspection Followup Item in
. Section 2, licensee performance in the chemistry comparison program *
along with observations on laboratory quality assurance, the water
chemistry program, radiation monitoring for dry fuel storage, and the
REMP.
During the exit interview, the inspector discussed the likely
informational content of the inspection report with regard to documents
or processes reviewed during the inspection.
Licensee representatives
did not identify any such documents or processes as proprietary.
Attachment: Table 1, Chemistry
Comparison Results, 2nd
Quarter 1993
"*
J
'"
TABLE 1
Nonradiological Chemistry Comparisons Results
Palisades Nuclear Generating Plant
April 5-8, 1993
Analyte
Method1 Conc2
Ratio3
Acceptance Ranges4
Result5
+/- 2RSD
+/- 3RSD
filU2
,---.
Fluoride
A
0.956.. 0.875-1.125
0. 813-1.187.A
B
0.955
0. 875-1.125
0. 813-1.187
A
c
0;950
0.875-1.125
0. 813-1.187
A
A
0.954
0. 933-:-1. 067
0. 900-1.100
A.
B
0.916
0. 919-1. 081
0.887-1.113
A+
c
0.946
0.926-:-1.074
0.895-1.105 *A
Sulfate
A
0.925
0.895-1.105
0.842-1.158
A
B
. 0.927
0.895-1.105
0. 868-1.132
A
c
. 20
0.959
0. 900-1.100
0.867-1.133
A.
G
AA/FU
1.076
0. 904-1. 096 * 0.854-1.146
A
H
l.o3e
0.903-1.097
0.857-1.143
A
I
1.047
0. 903-1. 097
0.855-1.145
A
G
AA/FU
1.031
0. 904-1. 095
0.859-1.141
A
H
0.963
0. 904-1. 096
0.857-1.143
A
I.
0.. 973
0. 904-1. 096
0.857-1.143
A
J
AA/FU
1.047
0. 863-1.137
0.784-1.216
A
K
1.013
0.859-1.141
0.788-1.212
A
L
0.997
0.862-1.138
0. 789-1. 211
A
JJ
AA/FL
500
1.099
0. 859-1.141
0. 788-1.212
A
KK
1000
1.045
0.859-1.141
0. 788-1. 212
A
2000
1.026
0.868,.-1.142
0.787-1.213
A
Ammonia
M
Spec
1000
0.984
0. 902-1. 098
0.. 856-1.147
A
N
3000
1.045
0. 902-1. 098
0.856-1.147
A
5000
1.048
0. 902-1. 098
0.856-1.147
A
Hydrazine
p
Spec
0.901
0.922-1.078
0. 888-1.118
A+
Q
100
0.864
0. 922-1. 078
0. 888-1.118
D
R
250
1.070
0.922-1.078
0.888-1.118
A
Rerun
p
Spec
0.989
0.922-1.078
0. 888-1.118
A
Q
100
1.006
0. 922-1. 078
0. 888-1.118
A
R
250
0.986
0.922-1.078
0. 888-1.118
A
Analyte
Method1 Conc2
Ratio3
Acceptance Ra~ges
Result5
+/- 2RSD.
+/- 3RSD
Silica
T
Spec
u
100
250
1.001
1.053
0.906-1.094 * 0.859-1.141
A
0.909-1.091
0.860-1.136
A
RIDTI
D Titr
1000
1.004
0.979-1.021
0. 968-1. 032
E
3000
1.028
0.979-1.021
0. 968-1. 032
F
5000
1.009
0.979-1.021
0. 968-1. 032
E
Rerun 3000
1.005
0.979-1.021
0. 968-1. 032
1.
Methods: Titr - Titration
- Ion Chromatography
Spec - Ultraviolet/Visible Spectrophotometry
AA/FL
Atomic Absorption Spectrophotometry
- Flame
AA/FU
Atomic Absorption Spectrophotometry
Furnace
2.
Cone: Approximate concentr~tion analyzed.
3.
Ratio-of Licensee mean value to NRC mean value.
A
A+
A
A
4.
- The relative standard deviations {RSD) in the sixth and seventh columns.*
represent~ the trieffjcient 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 range.
5.
Result:
A = Agreement: Licensee value is within +/-2 SDs of the NRC mean
value.
- A+ = Qualified agreement, licensee is between +/-2 and +/-3 SDs of
the NRC value.
D =Disagreement: licensee value is outside +/-3 SDs.
2