IR 05000293/1987014

Radiological Controls Insp Rept 50-293/87-14 on 870224-27.No Violations Noted.Major Areas Inspected:Radiological Control for Outage,Secondary Water Chemistry & Licensee Action on Previous Findings in Area of post-accident Sampling

ML20206D600
Person / Time
Site:	Pilgrim
Issue date:	04/01/1987
From:	Mark Miller, Nimitz R, Pasciak W, Shanbaky M, Zibulsky H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206D568	List: IR 05000293/1987014 ML20206D564
References
50-293-87-14, NUDOCS 8704130382
Download: ML20206D600 (18)

Text

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a U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-14 Docket N License N DPR-63 Category C

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l Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts i

Inspection Conducted: February 24-27, 1987 Inspectors: hA utA k M'

H. Zibulsk9, Chemist 4-I- T7 date j

M oko M' 4'-/-77 M. Miller, Tenior Radiation Specialist date

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k NL 4 I M7 R. Nimitz, Senior Radiation Specialist date Approved by: M. Shanbaky;" Chief M/

~J V!/!$'7 date~

Facili s Radiation P otection Section

) #7 /t e ~A '{~$I i asct'ak, Chief date

Effluent Radiation Protection Section Inspection Summary: (Report No. 50-293/87-14) Inspection on February 24-27, 1987

Areas Inspected

Routine Radiological Controls Inspection. Areas inspected were: Radiological Control for the Outage; Secondary Water Chemistry; and

licensee action on previous findings in the area of post-accident sampling,

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analysis and effluent monitoring.

Results: No violations were identified, i

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' 8704130382 DR 870403 ADOCK 05000293 PDR

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Details Individuals Contacted BECO

• K. Roberts, Nuclear Operation Manager N. Brosse, Maintenance Super intendent

• P. Smith, Chief Technical Engineer

• T. Sowdon, Radiation Section Manager

• P. Hamilton, Senior Compliance Engineer

• J. Jerz, Inspection Coordinator

• S. Hudson, Operation Section Manager

• R. Canatas, Chemistry Group Leader

• E. Gordon, Environmental and Radiological Health Section Group Leader

• R. Grazio, Field Engineering Section Manager

"R. Sherry, Chief Maintenance Engineer

• C. Gannon, Chief Radiological Engineer NRC

• McBride, Senior Resident Inspector

• Denotes those individuals attending the exit meeting on February 27, 1987

The inspectors contacted other individuals during the course of the inspectio . Purpose of Inspection The purpose of this inspection was to review the following:

Licensee action on NRC findings described in Inspection Report 50-293/85-27, Post-Accident Sampling, Analysis and Monitoring Capability;

Radiological Controls for the Outage;

Secondary Water Chemistr During the inspection, the licensee was provided " spiked" chemical samples to demonstrate his capability to properly analyze the sample . Licensee Action on Findings From NRC Inspection Report 50-293/85-27 3.1 (Closed) Follow Item (50-293/85-27-01) Licensee to demonstrate the adequacy of sample purge time See paragraph '

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3.2 (0 pen) Follow Item (50-293/85-27-02): Demonstrate the adequacy of the sample dilution method and related equipment. Data was not available to demonstrate the adequacy of the sample dilution method and related equipment. Sampling dilution is a key element in the quantification of sample results. The inspector reviewed the licen-see's dilution methods to ensure quantification of sample result The dilution technique was acceptable. The licensee expects to demonstrate adequacy of the sample dilution method related to the PASS panel and chemical analysis equipment when plant conditions enable sampling of the torus using the Residual Heat Removal System sampling line. Tne resuits of this comparison will be reviewed after plant start u .3 (Closed) Follow Item (50-293/85-27-03): Determine volume of the coolant collection ball valve. The licensee installed a new ball valve and determined its volume. The licensee revised the dilution factor and revised the time and motion study to reflect the higher dose rate for the new volune. The new volume is reflected in pro-ceedure .4 (Closed) Follow Item (50-293/85-27-04): Repair and/or replace the flow control check valve. After the primary system tests had been successfully conducted, the flow control valve stuck open in a fixed position (0.6 GPM). The design flow rate of 1 GPM could not be at tained. The licensee issued a maintenance request on September 29, 1985 to repair flow control valve (FCV-627). Repairs were completed on February 15, 1986 and the MR tag was removed. Surveillance test-ing conducted in December,1986, verified FCV-627 was operable but could not verify 1 GPM flow rate. The licensee stated they would complete additional testing after start-up to determine optimum flow rate and revised system purge times, if necessar .5 (Closed) Follow Items (50-293/86-27-01 and 85-27-05): Demonstrate the adequacy of system purge times. Data had not been presented to demonstrate the adequacy of the purge times specified in procedure Adequate purge time is needed to ensure representative sampling. The licensee reviewed the General Electric Design Criteria, optimum sample flows and piping length and size for the reactor coolant, and containment atmosphere sampling lines to determine purge times were within the recommended system purge times. Procedures 5.7.4. through 5.7.4.1.14 were revised to specify these calculated purge times. The inspector reviewed the PASS sample results and compared them to the normal reactor coolant sample. The comparison indicated representative samplin .6 (Closed) Follow Item (50-293/85-27-06): The capability to obtain a representative sample of containment atmosphere should be demon-strated. The inspector reviewed the licensee's Core Damage Estimate Procedures which had been reviewed as part of NRC's Safety Evaluation Report. The licensee does not rely on containment iodine or partic-ulate measurements in their assessmen Therefore, the measurement

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is not required. The licensee maintains the capability to collect containment grab samples. However, the licensee had documented that the accuracy of the iodine gaseous sample is not crucial, since it is not used in the Core Damage Estimate Procedur .7 (Closed) Follow Item (50-293/85-27-07): Establish correction factor for containment air sampler rotometer reading to correct for differ-ences in air density created by sampler pump suction. The licensee revised procedures 5.7.4.1.9 through 5.7.4.1.11 to include a formula to correct the rotometer readings where applicabl .8 (Closed) Follow Item (50-293/85-27-08): The detection limit and sensitivity of the chloride analysis method should be clearly de-fined. Procedures should be revised to include provisions for the retention of the undiluted sample for up to 30 days for more detailed chloride analysis. The inspector provided the licensee with three chloride standards to evaluate the licensee's capability to analyze post accident samples for low level chloride. All results were in agreement with the NRC values. (See Table 1 for details). The in-spector reviewed procedure 7.11.3, Revision 6, " Analysis of Liquid Samples for Chloride Under Accident Conditions," and determined that the detection limit, sensitivity of the ion chromatograph, dilution factor and long term storage were defined. The licensee will have expanded storage when the recently purchased shielded cabinets are installe .9 (0 pen) Follow Item (50-293/85-27-09): Obtain and maintain supplies necessary to conduct boron analysis with carminic acid method. The licensee had obtained the chemicals necessary to conduct boron an-alysis with the carminic acid method. However, the analysis of NRC spiked samples indicated two out of three disagreements. The licen-see had committed to an accuracy of 110%. (See Table 1 for details).

The carminic acid method is a back-up analytical method to the li-censee's plasma spectrometry method which showed very good agreemen The inspector reviewed procedures 7.11.1 " Analysis of Liquid Samples for Boron (by Spectrophometry)," and 7.10.1, " Quality Control of Chemistry Laboratory Data." The inspector noted that these proced-ures did not reference the standard boron stock solution concentra-tion or the recommended calibration solutions. Procedures 7.10.1 did not require sample preparation (e.g. twenty minute color development)

in a shielded area. The licensee stated that these concerns would be addressed and that the method would be practiced to ensure a 110%

accuracy could be maintained. This matter will be reviewed during a subsequent inspectio .10(0 pen) Follow Item (50-293/85-27-10): Clarify commitments and capa-bilities relative to pH analyse The licensee stated that they do not intend to analyze post accident samples for pH. The licensee stated that their safety evaluation of this position would be docu-mente The licensee's position differs from the guidance in RG.1.97,

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Revision 3 and the licensee's Safety Evaluation Report issued by NR This matter will be reviewed during a subsequent inspecto .11 (Closed) Follow Item (50-293/85-27-11): Review and evaluate the need to perform isotopic analyses of dissolved gases. If a need is identified, provision should be made to conduct isotopic analyses on dissolved gases. The inspector reviewed the licensee's Core Damage Procedure and the generic owner's group Core Damage Procedur These procedures do not require an isotopic analyses on dissolved gases to determine the extent of nuclear fuel damag i 3.12 (Closed) Follow Item (50-293/85-27-12): The use of dissolved gas or hydrogen analysis data in the assessment of core damage should be specified. Also procedures to reflect sampling technique and gas volume to be collected should be revised. The licensee had clearly  ;

established that hydrogen analysis data would be used in the assess-ment of core damage. Procedures 7.11.8, Revision 1, " Analysis of Dissolved Gas Sample Under Accident Condition," and 5.7.4.1.2, " PASS Undiluted Liquid Sample and Dissolved Gas Grab Sample," were reviewed by the inspector. These procedures require a 2cc gas sample ar,d the use of a shielded syringe to minimize extremity exposures. The 11-censee modified the gas chromatograph to be a closed loop injection port. This modification ensures a constant gas volume will be ana-lyze .13 (Closed) Follow Item (50-293/85-27-13): Establish a routine main-tenance program for the PASS. Not all components of the PASS have i been included in a regular surveillance / calibration program. Also, '

there does not appear to be a formal administrative procedure for  :

assuring that non-safety related equipment, such as the PASS, is in- '

corporated in routine maintenance. The licensee developed a routine maintenance program for the PAS Procedure 8.E.66, Revision 0,

" Post Accident Sampling System Instrumentation Calibration," was ap- t proved on March 6, 1987. The procedure references all PASS instru- i mentation. The licensee stated the procedure will be implemented and all surveillances completed prior to start-u .14 (Closed) Follow Item (50-293/85-27-14): Estabitsh a spare parts program for the PASS. The inspector rcviewed the licensee's spare parts program for the PASS, which was coordinated with the BWR Owner's Group. The inspector determined that adequate provisions

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L were being made by the licensee to ensure PASS availabilit .15 (Closed) Follow Item (50-293/85-27-15): Establish PASS sample ship-ping procedures. The inspector reviewed approved procedures which addressed handling, packaging and off-site shipment of PASS samples using the PIMs shipping cask. The licensee had a copy of the Cert-ificate of Compliance for the cask but was unable to produce a letter showing they were a register user. The licensee drafted the request to be an approved user to the NRC on March 6, 198 ,

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3.16 (Closed) Follow Item (50-293/85-27-16): Complete arrangement for back-up off-site analyses of samples. A formalized agreement between the licensee and Millstone for back-up off-site analysis of PASS samples was in effect as of December 5, 1985. The agreement provides back-up support to analyze diluted samples with total activity not exceeding one curi .17 (Closed) Follow Item (50-293/85-27-17): Establish provisions for detection of leakage across chiller.* Provisions have not been made for the detection of leakage of reactor coolant into the chiller cooling water. The pressure differential between the sampling and the cooling lines could result in the buildup of significant activity in the chiller in the event of such a leak. The licensee reviewed the need to establish provisions for the detection of leakage across the PASS chiller to prevent cross contamination of a clean system. The licensee concluded that the PASS chiller was dedicated to the PASS and would not affect any other cooling water. Area radiation moni-tor, RE507 would alert personnel in the area if radiation levels were rising in the sampling area. The inspector agreed with the licen-see's resolution, since the chiller was a self contained unit and would not affect a clean system, if the chiller leake .18 (Closed) Follow Item (50-293/85-27-18): Provide provisions to pre-clude PASS from exceeding its design temperature specification. The inspector noted that precautions for monitoring PASS temperature and taking actions to preclude an over-temperature situation had been included in applicable PASS sampling procedure .19 (Closed) Follow Item (50-293/85-27-19): Improve the safety of the access to the PASS. The inspector verified that a safety cage had been installed. Individuals wearing self contained breathing appa-ratus would have access to the PASS and the safety cage should pre-vent a person from falling backwar .20 (Closed) Follow Item (50-293/85-27-20): Establish alarm set points for the PASS area radiation monitor. The licensee revised procedure 6.5-305, " Post Accident Sampling System Source Calibration of PASS Radiation Monitoring Instruments," to include alarm set points to ensure conformance with 10 CFR 50 GDC-19 criteri Sample collection procedures were revised to identify set point to personnel and action to be taken upon alar .21 (Closed) Follow Item (50-293/85-27-21): Evaluate the need to install charcoal filters in the exhaust hood of the chemistry laborator The inspector reviewed a calculation performed by the licensee dated February 24, 1986. The results showed there was no need to install a charcoal filter in the exhaust hood of the chemistry laboratory based on GDC19 exposure guideline ___

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3.22 (0 pen) Follow Item (50-293/85-27-22): Calibrate PASS radiation mon-itor in accordance with manufacturer's specifications. Detector voltages were not set in accordance with manufacturer's specifica-tion. Also, there was no in-situ check of the instrument response following detector reinsta11ation. The license revised procedure 6.5-305 " Post Accident Sampling System Source Calibrater of PASS Radiation Monitoring Instrument," to be consistent with manufacturers recommendation. However, procedures do not require checking of de-tectors in-situ following bench calibration in the laboratory and re-insertion of the detector in the shield. The licensee initiated procedure changes to provide for an in-situ calibration check. This will be reviewed during a subsequent inspectio ~3.23 (Closed) Follow Item (50-293/85-27-23): Reevaluate the time and motion studies for collection of PASS samples. Initial time values were estimated. The licensee performed a worse-case time and motion study using procedure 5.7.4.1.4, " Post-Accident Sample System Undi-luted Liquid Sample and Dissolved Gas Grab Sample from Residual Heat Removal System." Results of the study indicate samples can be col-1ected and analysed within the exposure constraints of 10 CFR 50 GDC-19, 3.24 (Closed) Follow Item (50-293/85-27-24): Clarify use of pressure in procedures. Procedures 5.7.4.1.9 through 5.7.4.1.14 related to post accident sampling were revised on July 30, 1986 to specify recording the pressure in units of inches of Hg when sub-atmospheric conditions existed. Pressure in units of psig could also be used, if the samp-ling was performed at atmospheric condition .25 (0 pen) Follow Item 50-293/85-27-25: Establish reliable back-up power for the chiller. The licensee had not finished their evaluation of a backup method for cooling the PASS. This item will be reviewed dur-ing a subsequent inspectio .26 (Closed) Follow Item (50-293/85-27-26): Identify and provide " carry-ing devices". Procedures 5.7.4.1.2 and 5.7.4.1.4 were revised to identify a shielded lead container for transporting PASS samples to the chemistry laboratory. The inspector verified the container was located at the PASS pane .27 (0 pen) Follow Item (50-293/85-27-27): Licensee to clearly establish high range noble gas monitor read out range and monitor overlap. The licensee provided a description of the ranges of the high range noble gas monitor ranges. The ranges meet NUREG-0737. The licensee re-viewed the overlap of the detector read-outs. The read-outs were found not to overlap during certain circumstances. The licensee indi-cated this matter would be reviewed and resolved as appropriate. This matter will be reviewed during a subsequent inspectio .28 (0 pen) Follow Item (50-293/85-27-28): Evaluate the ability of the low range effluent monitor to recover af ter being off-scale for an ex-tended period of time. The evaluation of this matter is not complete _ _ _ _ _ _ _ _________________ ________

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The evaluation is in station review. This matter will be reviewed during a subsequent inspectio .29 (Closed) Follow Item (50-293/85-27-29): Licensee to consider the possible effect of radiciodines deposited within duct work and it:

effect on effluent monitor readings. The licensee performed calcu-lations to determine the effect of todine plate out on detector reading. The results indicate that plate out effects were not sig-nifican .30 (0 pen) Follow Item (50-293/85-27-30): Establish provisions in proce-dures for the sampling of the main stack and the reactor building vent (similar to those now contained in proceduresfor sampling the turbine building vent) for the measurement of samples of radiation levels up to and including design basis, so as to accomplish contin-uous sampling throughout a post-accident sequenc The licensee has not made provisions to analyze the initial samples from the sample points or estimate the activity contained on these samples if the sample activity causes excessive dose rates. The licensee will change-out this initial sample and take a short dura-tion grab sample. This practice does not appear to be in conformance with the sampling and analysis guidance of NUREG-0737, Table II.F.1- This matter will be reviewed during a subsequent inspectio .31 (0 pen) Follow Item (50-293/85-27-31): Licensee to perform time and motion study to determine personnel exposure during sampling of ef-fluent release paths. The licensee performed a time and motion study for collection of grab samples from the Mainstack, Reactor Building and Turbine Buildings using current sampling and analyses procedure The results indicate personnel exposure results are within 10 CFR 50 GDC-19 requirements. The licensee did not address analysis or meas-urement of the initial sampl (See Item 3.30) This will be re-viewed during a subsequent inspectio .32 (Closed) Follow Item (50-293/85-27-32) Provide monograms and proce-dures whereby measurements of the collected radioiodine activities can readily be translated into release concentrations and rate The licensee revised procedures to include nomograms to estimate radioto-dine activity collected on cartridges. Procedures revised were 5.7.3.3, 5.7.3.4 and 5.7. .33 (0 pen) Follow Item (50-293/85-27-33): Licensee to evaluate the capa-bilities of the Reactor Building Vent to collect representative sam-pies considering the range of stack flows and develop correction factors if needed. The licensee revised Procedure 5.7.3.4, "Samp-ling, Transport, and Analyses of Effluent Iodines and Particulates from the Reactor Butiding Vent Under Emergency Condition," to include

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permission for adjustment of the sample flow rate to ensure collec-tion of an isokinetic sample. However, no guidance is included in the procedure to correct initial post accident effluent sample act-ivities taken prior to adjustment of sample flow rate for subsequent samples. This item will be reviewed during a subsequent inspectio .34 (0 pen) Follow Item (50-293/85-27-34): Evaluate the capabilities of the sampling system to collect representative samples under accident condition. The licensee was unable to locate data for this matte This item will be reviewed udirng a subsequent inspectio .35 (0 pen) Follow Item (50-293/85-27-35) This item contains five sub-items. The item and findings are discussed below:

Item 1 (0 pen) Provide shielding for effluent sample holder The licensee performed an evaluation of the need for shielding for replacement sample holders. The evaluation did not address the in place sample holder or its transport to the lab for analysi This item will be reviewed during a subsequent inspectio Item 2 (Closed) Provide appropriate labels and flow diagrams for the valves and indicators of the effluent sample panel The valves were labele The indicators were not. The licensee labeled the indicators prior to the end of the inspectio Item 3 (Closed) Evaluate the need to heat trace the Reactor Building

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Fent Effluent sample lin The license evaluated the need to heat trace the line. The evalua-tion indicated the line need not be heat trace Item 4 (0 pen) Review the need to provide for purging the in place effluent sample canister prior to their removal or transfer for analysi The licensee performed an evaluation of the need to purge the canis-ters. Based on the evaluation, a Plant Design Change request (PDC 86-83) was issued to install purge capabilities for the main stack and reactor building vent sample canisters. The PDC has not been implemented. This will be reviewed during a subsequent inspecito Item 5 (Closed) Add to manual dose assessment procedures nomograms to make it possible to estimate field iodine dose rates on the basis of measured radiotodine activity (or release rates derived therefrom).

The licensee added nomogram to procedures to allow for estimation of offsite radiotodine dose rates on the basis of measured radiciodine activity contained on sample cartridge ,

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3.36 (Closed) Follow Item (50-293/85-27-36) Establish and implement oper-ator training modules for operation and use of the Post Accident Mon-itoring (PAM) panel. The licensee established and implemented Module R0-02-08-01. The training was conducted during operator requalifi-cation for plant update trainin .37 (Closed) Follow Item (50-243/85-27-37): Train and qualify appropri-ate personnel in Procedure 5.7.5, " Estimating Core Damage". The licensee trained all Shift Technical Advisors in use of Procedure 5.7.5. The requirement for the training has been included in the initial training program and for requalificatio .38 (Closed) Follow Item (50-293/85-27-38): Include Torus Monitor Re-sponse curves in Procedure 5.7.5, " Estimating Core Damage." The Torus Monitor readings were being incorre:tly used with Drywell Monitor Response Curves. The licensee reiised Procedure 5.7.5,

" Estimating Core Damage" to include the Torus Monitor response curves. Procedures provide guidance for use of the curve .39 (Closed) Follow Item (50-293/85-27-39): Perfora, a review to deter-mine if radiation fields from primary piping in the drywell affect the core damage estimates. Damage estimates are derived from gaseous activity contained in the drywel The licensee performed an evalua-tion of the acceptability of original monitor response calculation The original calculations were found to be reasonable and that the monitor response would be acceptabl .40 (Closed) Follow Item (50-293/85-27-40) Licensee did not have any spare SAM-2s. The licensee obtained two additional SA&2s. The two are calibrated and in storage at the Emergency Operating Facility (EOF). Three others have been repaired. One of the three is cali-brated and ready for us .41 (0 pen) Follow Item (50-293/85-27-41): Procedures for calibration and use of SAM-2s did not clearly define efficiency and counts per minute (' cpm'). The licensee revised procedure No. 6.5.287, " Calibration of Eberline SAM-2", to describe ' cpm' as gross or net count rate as appro-priate. However, other procedures were not revised to properly describe use of " percent" efficiency and decimal efficiency for the SAM-2 when analyzing charcoal cartridge .42 (Closed) Follow Item (50-293/85-27-42): Procedures for determination of thyroid dose only determines dose from I-131. Other iodine iso-topes are not considered. The licensee resised Procedures 5.7.2.18,

"Offsite Dose Projection and Protection Action Guides for the General Public," and 5.7.2.19, "In-Plant I-131 Air Sampling and Analysis," to include provision for determination of total dose from all iodine isotope *

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3.43 (Closed) Follow Item (50-293/85-27-43): Licensee did not verify acceptability of air flow calibration devices used to calibrate iodine air samplers. The licensee revised procedure SI-RP.5701,

" Calibration of Radeco Model H809A Air Sampler," and Procedure SI-RP-5700, " Calibration of Eberline RAS-1 Regulator Air Sampler Flow Gauges," to include verification of calibration of air flow gauge The calibration of the air flow calibrator device is traceable to NBS via the licensee's vendor. The calibrations are periodically sent off to the vendor for calibration verification. Review indicates a need to include flow deviation due to flexible tubing. The error appears to be about 50% of that permitted by Regulatory Guide 8.25, 3.44 (Closed) Follow Item (50-293/85-27-44): Procedures for use of SAM-2s allow the use of the instruments in a 4 mr/hr fiel It was not clear that an acceptable Minimum Detectable Activity (MDA) could be met. The licensee performed calculations to determine the maximum background count rate that the SAM-2 could exhibit to meet a reason-able iodine MDA. Procedures for determination of iodine were revised to include precautionary statements relative to maximum background count rate that the SAM-2 could exhibit. Procedures revised were 5.7.2.9, 5.7.2.19, 5.7.2.11, and 5.7.2.1 .45 (0 pen) Follow Item (50-293/85-27-45): The model of the installed solenoid valves differed from the test model. The licensee tried to qualify the installed model by similarity. However, evaluation of similarities and differences between the installed model and the test model (e.g. organic materials used and their thermal aging effect, coil temperature rating, physical size and construction etc.) were not performed. The inspector noted the licensee completed a simil-arity analysis on November 11, 1985 and had filed that information in the Equipment Qualification r(ference file 30 The study concluded that all valves were qualified for their intended environment. The results of this study will be reviewed during a subsequent inspec-tio .46 (Closed) Follow Item (50-293/85-27-48): Post Accident sample System calibration program not in place. The licensee established a once per cycle calibration program for all PASS instrumentation on September 1, 198 This program will be implemented prior to start-u .47(Closed) Deviation (50-293/85-27-50): Drywell high rango monitor cables found in unprotected manner in deviation from the licensee's May 18, 1982 letter to NRC. The licensee implemented the corrective action described in his December 13, 1985 letter to NRC. This Deviation is close *

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12 Radiological Controls The inspector reviewed the adequacy, effectiveness and implementation of Radiological Controls. The review was performed with respect to criteria contained in 10 CFR 19, 10 CFR 20 and applicable licensee procedures. The following matters were reviewed:

Adequacy and implementation of Radiation Work Permits issued

Performance and evaluation of appropriate radiation, contamination,

and airborne radioactivity surveys to support on-going work ALARA planning and oversight of on going work

Communication

Posting, labeling and access control including high radiation area access control

Provision and use of personnel monitoring devices

• Respiratory Protection

Use of engineering controls

Posting of Notices to worker *

Supervisory oversight of work activities The evaluation of Itcensee performance in this area was based on:

discussions with personnel

review of documents

inspection performance of independent radiation surveys inspector observations of work in the following areas

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removal, transport, and rebuilding of Control Rod Drives

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welding of reactor vessel level instrumentatio The following matters needing licensee attention were identified:

The upper levels of the drywell could be subject to high radiation levels during fuel movement (e.g. fuel movement, fuel sipping, or fuel drop accidents).

The Itcensee was not able to provide an evaluation demonstrating that it was acceptable to allow personnel to enter the upper portion of the drywell during fuel movement. Personnel were working at the top of the biological shield. Dose rates in this area could be high during certain fuel movements. The licensee representatives indt-cated an evaluation had been previously performed but was not readily available. The inspector will review the evaluation during a sub-sequent inspectio (50-293/87-14-01)

Licensee personnel indicated this matter would be reviewed prior to further fuel movemen *

The posting as to where to find copies of the facility license and procedures was missing from the contractor site access poin *

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The licensee immediately replaced the posting and initiated a review of other 10 CFR 19.11 postin *

The inspector noted that a health physics technician entered into the drywell equipment hatch area (a clean area) without punching in on the key card reader. The technician had a se-curity guard's approval. However, the inspector questioned the acceptability of this practic The licensee immediately required all personnel entering the hatch to key card in and initiated a review of the acceptability of the practic The following was noted:

The licensee is currently planning for replacement of Dry Tube fhe licensee is reviewing a recent radiological incident at another BWR involving Dry Tubes in order to prevent a recomence of this incident at Pilgri . Secondary Water Chemistry program 5.1 Analytical procedures Evaluation

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During the inspection, standard chemical solutions were submitted to l

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the licensee for analysis. The standard solutions were prepared by the Brookhaven National Laboratory (BNL) for the NRC, and were ana-lyzed by the licensee using normal methods and equipment. The analy-sis of standards is used to verify the licensee's capability to monitor chemical parameters in various plant systems with respect to Technical Specification requirements and other regulatory require-ments. In addition, the analysis of standards is used to evaluate the licensee's analytical procedures with respect to accuracy and precisio The standard measurements comparison indicated that, with the excep-tion of one measurement, all of the results were in agreement under the criteria used for comparing results (see Attachment 1). The fluoride disagreemer,t was due to low uncertainty of the analyses the licensee determined at the concentration of the NRC standard. This disagreement was not viewed as significant. The results of the com-parisons are listed in Table 2.

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The inspector suggested that the licensee analyze sodium on a weekly basis with the other required metal analyses. The sodium determina-tion could be analyzed using the direct current plasma as are the iron, copper and chromium. The sodium is a good indicator of resin

intrusion. The licensee will consider using this new analysis. The l inspector reviewed the boron analysis procedure by mannitol tit.*a-I tion. The inspector suggested that the sodium hydroxide standard-l ization be made with potassium acid phthalate and to omit from the I

procedura that

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boric acid be dried in an oven before using it for the equivalence de-termination. Boric acid could easily be converted to the oxide if dried in an oven. The drying should be made in a desiccator over silica gel. The licensee stated they will revise the procedure to include these suggestion .2 Laboratory Measurement Control Verification of the licensee's measurement capabilities on actual plant water samples is done by splitting samples with the licensee and BN The feedwater system samples were taken for metal analyses, reactor water was taken for fluoride, chloride and sulfate analyses and the standby liquid control tank sample was taken for boron analy-sis. The feedwater samples were spiked with a standard solution of iron, copper, nickel and chromium and the reactor water sample was spiked with a standard solution of fluoride, chlorido and sulfat The standard spike solutions were prepared by BNL for the NRC. On completion of the analyses by BNL and the licensee, an evaluation will be made and the intercomparision will be documented in a subse-quent inspection repor The inspector reviewed and discussed with the licensee the statisti-cal module used by the licensee in their interlaboratory standards progra Two independent standard stock solutions for calibrattor and measure-ment control were not used. The licensee was using two aliquots from the same stock solution. This did not allow for .n analytical cross check on the continuing quality of the stancard silution The licensee agreed to maintain two standard stock solstion The calibration of the direct current plasma and tri *on chromato-graph was made with single point. If the calerat or curve is non-linear or the slope of the curve shifts, the licensw would be report-ing erroneous results. No less than three data points, exclud-ing zero, should be used to generate the calibratfor curves and the data points should be statistically fi . Inspection Exit Meetina The inspector met with licensee personnel denoted in $1ctiti 1 on February 27, 1987. The inspector summarized the purpose, s.cpe and find-ings of the inspectio No written material was provided to the license Licensee representatives indicated a review would be mac'e of the accepta-  ;

bility of allowing personnel above the bio-shield inside the drywell during fuel movement. The review is to be completed prior to farther fuel movement with personnel in this are . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ -

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Table 1

Comparison of Analytical Results Chemical Analytical NRC Licensee Licensee Parameter Procedure Value Value Commitment Comparison a

1 Chloride Ion Chromatography 12.11 .810.8 110% Agreement (ppb) 37.411.2t 38.6t0.2 210% Agreement ,

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80.51 .It0.4 t10% Agreement  !

i Boron Direct Current .985t.01 .97810 210% Agreement l Plasma 2.981.05 2.941.05 110% Agreement j (ppm) 4.871.06 4.94t.08 110% Agreement Boron Spectrophometry .9851.01 1.241.04 210% Disagreement 26% [

(ppm) 2.98t.05 2.861.17 110% Agreement  :

4.871.06 5.45t.28 110% Otsagreement 125 i

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Table 2 l

l Capability Test Results l Pilgrim Nuclear Power Station Chemical Analytical NRC Licensee Ratio Parameter Procedure Value Value (Lic/NRC) Comparison Resultsinpartsperbillion(ppb)

Chloride Ion Chromatograph 12.11 .810.8 0.8910.13 Agreement 37.4t .6i0.2 1.0310.03 Agreement 80.52 .li0.4 0.9710.03 Agreement Fluoride Ion Chromatograph 11.61 .410.7 0.9010.06 Agreement 43.51 .4t0.2 0.91t0.04 Otsagreement 83.51 .710.6 0.9810.03 Agreement Sulfate ton Chromatograph 10.0A .3i0.2 1.0320.06 Agreement 41.02 .710.3 0.9410.06 Agreement 80.81 .5t0.6 0.9720.04 Agreement

$11tca Spectrophotometric 54.3t .022.2 0.9610.11 Agreement 1091 .910.8 0.9920.06 Agreement 1601 .0 Agreement tron Direct Current 391i28 389112 0.9920.08 Agreement Plasma 764227 789213 1.03t0.04 Agreement 1176t34 118518 1.01i0.03 Agreement Copper Ofrect Current 374119 37216 0.9910.05 Agreement Plasma 773t39 768t6 0.9910.05 Agreement 1160148 1145t0 0.9910.04 Agreement l

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Nickel Direct Current 407t21 383t7 0.9410.05 Agreement Plasma 816124 80215 0.9810.03 Agreement 1224132 1170t19 0.9610.03 Agreement Chromium Direct Current 408124 36916 0.9010.05 Agreement Plasma 753124 740112 0.9810.03 Agreement 1144164 109417 0.9610.05 Agreement

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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests. In these criteria the judgement limits are based on the uncertainty of the ratio of the licensee's value to the NRC value. The following steps are performed:

(1) the ratio of the licensee's value to the NRC value is computed i

licensee Value (ratio = NRC Value ); ,

(2) the uncertainty of the ratio ts propagate If the absolute value of one minus the ratio is less than or equal to twice the ratto uncertainty, the resu ts are in agreemen (l1-ratio $ 5 2 uncertainty)

8 Z= , then + +

8(From: Bevington, P. R., Data Reduction and Error Analysis for the Physical Sciences, McGraw-Hill, New York,19t9)

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