IR 05000295/1986010

Insp Repts 50-295/86-10 & 50-304/86-09 on 860401-04,07,18 & 21.No Violation or Deviation Noted.Major Areas Inspected: Chemistry & Radiochemistry,Training & Qualifications of Chemistry Staff & Licensee Internal Audits

ML20210N761
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/30/1986
From:	Holtzman R, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210N743	List: IR 05000295/1986010 ML20210N738
References
50-295-86-10, 50-304-86-09, 50-304-86-9, NUDOCS 8605050249
Download: ML20210N761 (11)

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l U.S. NUCLEAR REGULATORY COMMISSION ,

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REGION III

Reports No. 50-295/86010(DRSS); 50-304/86009(DRSS)

Docket Nos. 50-295; 50-304 Licenses No. DRP-39; DRP-48 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Generating Station, Units 1 and 2

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Inspection At: Zion Site, Zion, IL 60099

Inspection Conducted: April 1-4, and 7, 18 and 21, 1986 l

}ll.f fj.tkrstw-Inspectors: M. J. Oestmann YSv/h Date

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e0 f % l R. B. Holtzm Date 08$

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Approved By: M. C. Schumacher, Chief Id[86 Radiological Effluents and Date  !

! Chemistry Section l Inspection Summary i Inspection on April l- 4, 7, 18 and 21, 1986 (Reports No. 50-295/86010(DRSS);

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50-304/86009(DRSS))

Areas Inspected: Routine, unannounced inspection of: (1) Chemistry and l Radiochemistry, including water chemistry control; quality assurance / quality control of sampling and analysis in the laboratory, observations of technician i performance in hot and cold laboratories, counting room, and sampling facilities; l (2) training and qualifications of chemistry staff; (3) licensee internal audits; l

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and (4) review on actions taken regarding a violation and of previously identified open item Results: No violations or deviations were identified.

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DETAILS 1. Persons Contacted

• Plim1, Station Manager, Zion

• Budowle, Assistant Superintendent of Technical Services, Zion

• W. Stone, QA Supervisor, Zion

• J. G. Murphy, Quality Control, Zion

• G. Trzyna, Rad / Chem Supervisor, Zion

• P. M. Zwilling, Lead Chemist, Zion M. Finney, Laboratory Foreman, Zion C. Doll, Auxiliary Systems / Radiochemist, Zion K. Miedlar, Analytical Chemist, Zion L. L. Schaeve, Primary Systems Chemist, Zion D. P. Hemmerle, Secondary Systems Chemist, Zion 0. Fick, Rad / Chem Technician (RCT), Zion M. Hagen, RCT, Zion G. Mazmanian, RCT, Zion M. Cairns, RCT, Zion W. Cramer, Training Instructor, Zion

• M. Holzmer, NRC Senior Resident Inspector, Region III

• L. E. Kanter, NRC Resident Inspector, Region III

• Attended exit interview on April 7, 198 . Licensee Actions On Previous Inspection Findings (Closed) Open Item (50-295/82030-06; 50-304/82027-06): Issuance of corrections to 1981 annual report. The licensee prepared errata to correct errors in the 1981, 1982, 1983, and 1984 annual report No errors were found in the reporting levels in Table 5.0-1 of the 1985 annual report. The levels are consistent with the Technical Specification Table 4.16-1 of Amendment No. 30 to DRP-39 and Amendment No. 27 to DPR-48. On March 24, 1986, the licensee was issued License Amendment No. 96 to OPR-39 and Amendment No. 86 to DPR-48 to include the Standard Radiological Effluent Technical Specifications (RETS) with revised reporting levels in Technical Specifications 3.16/4.1 These levels are consistent with those provided in the Offsite Dose Calculation Manual (ODCM). The new RETS will not be implemented until the fall of 198 This item is considered close (Closed) Open Item (50-295/84005-02; 50-304/84005-02): Licensee to prepare radwaste procedure on how correlation factors are applied in determining the classification of radwaste in accordance with 10 CFR Part 61 and 10 CFR Part 20.311 requirements. The inspector reviewed procedure RP-1520-7, " Classification of Radioactive Waste for Near-Surface Burial Site Disposal," Revision 3, dated December 21, 1984, which includes a description on how correlation factors are applied for determining waste classificatio This item is considered close l

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. (Closed) Open Item (50-295/84005-03; 50-304/84005-03): Licensee procedure to be revised to include investigation for tracking lost radwaste shipments in accordance with 10 CFR 20.311. The licensee revised procedure ZAP 13-52-8, " Preparation and Shipment of Radioactive Material," Revision 21, dated October 25, 1985, to include a method to investigate any lost radwaste shipments and to provide details to prepare the manifest. This item is therefore close (Closed) Violation, Severity Level V (50-295/85030-02; 50-304/85031-02):

Failure to take out-of-specification SAC-4 Scintillation Alpha Counter out of service and to notify Chemistry Supervision. The licensee's Chemistry Procedure ZCP 531-7, " Performance Test for the Eberline Model SAC-4 Scintillation Alpha Counter," was revised to allow for a second count, if the first one were out of the acceptable range (Revision 1, dated December 4,1985). The inspectors' review of the performance check data for the two SAC-4 counters since September 2, 1985, showed that the counters had been operated properly according to the revised procedur This item is considered close . Management Controls and Organization The inspectors reviewed the licensee's management controls and organization of the Radiation-Chemistry (R/C) Group for implementing the chemistry and radiochemistry program. The R/C Supervisor, who reports to the Assistant Superintendent for Administrative and Support Services, supervises the Lead Chemist and Lead Health Physicist. The Lead Chemist, in turn, supervises three other Chemists, a Radiochemist, an Engineering Aide, and a Laboratory Foreman. This Foreman and the Health Physics Foreman supervise the 34 Radiation Chemistry Technicians (RCTs) and direct on-the-job training and job assignments of the RCTs assigned to chemistry laboratories and health physic The RCTs are scheduled to rotate between the Health Physics and Chemistry Groups such that each RCT is out of the Chemistry Group for a period of about 10 weeks; this absence from the laboratory results in a loss of laboratory proficienc A licensee representative reported that the licensee has under consideration permanently assigning each RCT to one group or the other. As yet, no decision has been mad The Chemistry Staff has Group Coordinators to direct work assignment The Analytical Chemistry Coordinator is responsible for laboratory quality control and the blind sample program. The radiochemist is responsible for review of auxiliary system chemistry and for daily performance checks of counting equipment in the counting room. In addition, there are primary and secondary system chemists responsible for overall programs of the respective systems. The Chemistry Group organization and staffing appears to meet the commitments of the updated FSA .

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4. Training and Qualifications The training and qualifications of the Chemistry Group personnel in responsible positions were reviewed. The Lead Chemist and Group Coordinators have bachelor's degrees in Chemistry. The Chemistry Foreman has had about 11 years experience as a Radiation Protection Foreman, but only eight months as a Chemistry Foreman. From the inspectors' review of their qualifications and interviews with the Chemistry staff, it appears that they are knowledgeable in chemistry principles and practices and meet the requirements in Section 4 of ANSI /ANS 3.1-1978. No problems were noted in the qualifications of the chemistry staf On April 11, 1985, the chemistry staff attended a pilot training course on water chemistry control developed by the Byron Training Department in response to a corporate directive on PWR Secondary Water Chemistry Control (NSDD-501), dated September 9, 1983. This course is designed to make all levels of corporate and plant personnel aware of the importance of secondary water chemistry control on plant operation and will be presented to the technical support personnel in the near futur The training program for the RCTs was also reviewed and includes on-the-job

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experience, supervisory observation and completion of an annual two week requalification program. The RCTs have had up to 12 years experienc One newly hired RCT is in a 14-week formal training program at the Production Training Center at Braidwood. Inspectors' discussions with different RCTS and observations of their performance in sampling and analyses in the laboratories indicate that the technicians are adequately trained for their function The RCTs observed appeared to have a good understanding of their work and followed appropriate analytical procedures with no difficulty. The inspectors also determined that each shift had one

or more experienced RCTs to provide adequate coverage of chemistry /

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radiochemistry requirement No violations or deviations were identifie . Water Chemistry Control Program The inspector reviewed the licensee's PWR Water Chemistry Control Program (Nuclear Stations Division Directive (NSDD-501) issued on September 9, 1983). This program adequately addresses management policies, assignments of authority and responsibilities to implement the program, and provides appropriate guidance on operational chemistry limits designed to minimize localized corrosion in steam generators and turbine An analytical measurements program, performance monitoring of the program, data management and trending, and training requirements (Section 4) are include Management responsibilities described in this directive include providing adequate resources of staff, equipment, funds and organization to implement the program to avoid corrosion of the secondary system. Action levels are to be implemented whenever an off-normal value is detecte The inspectors confirmed that the licensee is currently satisfactorily implementing this program primarily through procedure A0P-12 " Secondary i

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System Chemistry Excursion," Revision 3, dated February 7, 1986, and ZCP 311-1 " Secondary System Analysis Requirements," Revision 19 dated September 11, 1985. The licensee has established Action Levels for off-normal conditions and performance trend plotting of the key parameter The inspectors reviewed the Chemistry Control Performance Monitoring program generated by the licensee's Technical Center that showed a significant improvement in plant performance particularly during the latter half of 1985. Trend plots reviewed were for cation conductivity, chloride, sodium, sulfate in steam generator blowdown, dissolved oxygen in the condensate, conductivity and silica in the water storage tanks, and chloride and dose-equivalent iodine in the reactor coolant (primary). At no time were Action Levels actually imposed because of the prompt corrective actions taken to bring the key chemical parameter within the limits set by the licensee. From discussion with licensee representatives and review of records, the inspectors confirmed that the Chemistry Group and the Operations Department work closely together to maintain tight controls over water qualit No violations or deviations were identifie . Other Management Programs The inspectors reviewed the licensee's program to restrict and control the use of chemicals throughout the plant to maintain system integrit This program is outlined in ZAP 13-51-2, " Station Chemical Control Program,"

dated December 9, 1985. This procedure follows guidance from INPO CY-703,

" Good Practice for the Controls of Chemicals in Nuclear Power Plants."

The Chemistry Group has the responsibility to restrict by quantity, area and disposal of chemicals used in the plant and to approve the use of restricted chemicals. Procedure ZAP 13-52-3 " Receiving and Storing Chemicals" and ZAP 13-52-5 " Safe Handling of Hazardous Chemicals," dated March 4, 1986, also are implemented to maintain control on receipt, use and disposal of chemicals. This program is a valuable asset to the long-term preservation and safety of the plant, and to the safety of the workers involved in handling chemicals used.

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No violations or deviations were identifie . Implementation of the Chemistry and Radiochemistry Program l

l The inspectors reviewed the primary and secondary chemistry programs, l including the physical facilities, laboratory operations, counting room, l procedures and practices followed in the cold and hot laboratories and l counting rooms.

Laboratory space, including fume hood space in both the hot and cold

! laboratories, appeared to be adequate. The air-conditioning system in the I laboratories was temporarily out of service and the temperatures were about 90 F. Repairs to the air-conditioning system are to be completed within a few weeks. The counting room, however, was properly air-conditioned to protect the electronic counting equipment. Each fume hood had a velometer to indicate that sufficient air flow was available during chemical operations in the hood Daily air flow checks are made to l assure that adequate ventilation is available.

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Housekeeping was goo The laboratories are well equipped with modern computerized instrumentation. Each instrument was found to be well-maintained, operable, and calibrated with current calibration sticker Chemical balances are calibrated every six months by a vendor. Reagent bottles were found to be properly labele No solutions or chemicals were found to have passed their posted expiration date The licensee has upgraded the analytical capabilities with new instruments of greatly improved sensitivities, including an atomic absorption spectrophotometer with a graphite furnace, two Hitachi uv/ visible spectrophotometers with an automatic sample changer, automatic boron titration equipment, gas and ion chromatographs, pH, and specific ion probes, and conductivity meter Log books were found to be satisfactorily maintained with each instrumen Th counting room has radiochemistry equipment of high qualit There were four ORTEC gamma ray spectrometers, each of which included a suielded Ge(Li) detector, three Canberra alpha-beta proportional nilti-sample counters, and two Packard liquid scintillation counter Etch instrument was found operable and in good conditio Selected chemistry procedures (ZCPs) for various analyses and surveillances (listed below) were being implemented and had been updated in 1985 and 198 No technical problems were noted during a review of the procedures and log sheets used in documenting the results. All of the analytical results were also being entered into a computer connected with the licensee's Technical Center for use in plotting trends of key parameters to monitor plant performance. Procedures reviewed included the following:

ZCP-100-12 Boron Determination By Automatic Titration ZCP-101-2 Dissolved Oxygen Using Chemetrics Kit ZCP-110-1 Silica Determination Using the Hitachi Model 110 Spectrophotometer ZCP-120-1 Fluoride Determination By Specific Ion Probe ZCP-130-1 Manual Flame Determination of Metals Using the Perkin-Elmer 5000 Atomic Absorption Spectrophotometer ZCP-130-3 Determination of Low-Level Metals Using the Perkin-Elmer 5000 Atomic Absorption and the HGA 500 Graphite Furnace ZCP-150-3 Conductivity Determination Using the Radiometer Model CDM83 Conductivity Meter ZCP-301-1 Primary System Surveillance Requirements ZCP-301-5 In-Line Instrumentation Surveillance Requirements ZCP-311-1 Secondary System Analysis Requirements ZCP-600-1 General Sampling Procedure ZCP-621-1 Reactor Coolant Chloride Determination ZCP-621-2 Dissolved Oxygen, pH and Conductivity Measurements ZCP-500-1 Laboratory Instrumentation Quality Control Calibration Schedule ZCP-510-1 Laboratory Instrumentation Quality Control Calibration / Maintenance Log and Data Sheet

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ZCP-510-2 Documentation of Standard and Standard Reagent Preparation ZCP-530-9 Daily Performance Check of the Canberra Proportional Counter Model 2201 and Model 2201 The inspectors observed several P. cts collect and analyze samples taken in the Primary Sarapling Room and in the Secondary Sampling Room. Each RCT observed appeared knowledgeable in following proper sample handling practices and followed appropriate procedures with no difficult The RCTs seemed to thoroughly understand the analyses they performed and they I satisfactorily logged the information on log sheets. These sheets listed I acceptance limits for key chemical parameters. If the value is outside the limit the RCT is to inform the Laboratory Foreman, who, in turn is to i notify the Shift Superviso Review of selected log sheets indicated no '

problems. The RCTs performing the analyses for cation and specific conductivity and pH measurements, boron, chloride, fluoride, sulfate, hydrazine, silica, and dissolved oxygen appeared to be skilled in laboratory practice and had a clear understanding of procedures involve Licensee representatives indicated that there had been no difficulty in maintaining the required chemistry parameters in the reactor coolant. The inspector confirmed through record review that the concentrations of dissolved oxygen, chloride, and fluoride in the reactor coolant in different operating modes did not exceed the limiting conditions for operations given in Technical Specification 3. Similarly, the inspectors confirned through observations and review of plant performance monitoring and log records, and discussions with licensee representatives, that the secondary water chemistry control has improved, particularly during 1985. At present, about 99% of the time, the licensee remains within the self-imposed limits included in his Secondary Chemistry Control Program which follows the PWR Owners Guideline No violation or deviations were identifie . Quality Assurance / Quality Control in Chemistry and Radiochemistry The inspectors reviewed the QA/QC program in the laboratory. Part of the program is presented in the ZCP-500 series (ZCP-500-1 to ZCP-540-3) that refer mainly to the calibration and maintenance of laboratory instruments and to the quality and labeling of chemicals and reagents. Daily performance checks are required for the counting instruments in procedures ZCP-530-9, ZCP-530-13 and ZCP-531-7 for the Canberra proportional counters, the Packard liquid scintillation counters and the Eberline SAC-4 Scintillation Alpha Counters, respectively. Control charts are kept only for the liquid scintillation counter Although check source data from the other counters were plotted by the AAIS, control limits are not shown, and on many of the plots the scales were too compressed to show the variabilities of the dat However, the QC program for the maintenance of the radiological instruments is good because of careful oversight of the radiochemist and because

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additional control is exercised by a 2-sigma limit imposed either automatically by AAIS or by the procedure in which the instrument is taken out of service until a satisfactory performance check is mad Daily or periodic performance checks are required in many of the non-radiological analytical procedures, including boron, chloride, fluoride, chromate and silica. An acceptance band is usually specified to be within 10% of the nominal standard value; for boron a much narrower 110 ppm for a 525 ppm standard (<t2%), is used. No problems were noted in review of the boron performance check The inspectors reviewed instrument performance data related to non-radiological measurements on auxiliary and secondary systems performed between June 1985 and March 1986. These analyses were for silica, chromate, hydrazine, ammonia, chloride, fluoride, and metal ions that are not addressed in the technical specifications. Most results were within the acceptance ranges. However, a considerable fraction of the results for chromate and metal ions (sodium, magnesium, and iron) were outside their acceptance limits with no indications that chemistry supervision had been notified in accordance with the applicable procedures, or that they had reviewed the results. Licensee performance improved over the period and licensee management indicated its awareness of a problem in this area and stated that this was addressed in the February 1986 INP0 audit. In response to this audit, the licensee plans, as stated in an internal document, "1986 Goals and INP0 Findings Response," to develop and institute by June 1986, improved procedures for reporting of analytical result These are to include control charts to aid in better identification of off-normal results. Licensee implementation of these improvements will be examined during subsequent inspections (0 pen Item 50-295/86010-01; 50-304/86009-01).

The station participates in a quarterly interlaboratory comparison program involving blind, non-radiological standards from a vendor, NWT, Inc. lii samples, containing four constituents of interest (Technical Specifications or PWR Owners Guidelines) are analyzed by a technician on each shift and submitted to the vendor who provides a comparison of the results with those of other plants in the program and with the "true" values. Results were highly variable. Copper, sulfate, and fluoride values deviated by less

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than 10% from the standards, while the station's boron value was 20% greater

, than the standard; the ten participating plants showed an aggregate mean l value 10% higher than the standard. The station also participated in a

recently instituted corporate program. Six (fluoride, aluminum, magnesium, l

sulfate, sodium, and iron) of eleven constituents in the first set of l

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samples differed by more that 20% from the standards. These programs are an improvement and help to demonstrate the strengths and weaknesses of the l

laboratory. The results to date indicate that additional effort is I warranted to improve confidence in the laboratory result Since 1984, the laboratory foreman has tested RCT competence in the analyses of boron, silica, chloride, sulfate, and sodium, as the RCTs rotate into the laborator Each technician is tested approximately once per year. Before 1986, the results differed considerably from the known values, averaging 25 to 50% off. The latest set, however, showed good

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precision for boron with an average deviation of about 1% and for silica

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about SL Despite recent improvements, this program also indicates the need to improve reliability of analytical result The licensee recognizes these problems and plans to increase the testing of RCTs to twice yearly.

This will be examined during a subsequent inspection. (0 pen Item 50-295/86010-02; 50-304/86009-02).

No violations or deviations were identifie . Water Sampling, Monitoring and Processing

, The inspectors reviewed the water treatment, sampling and monitoring programs and observed related equipment during a plant tour. The licensee has adequate sampling capabilities in both the Primary and Secondary j

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Sampling Rooms to perform the necessary chemistry functions for the plan No problems were noted when a RCT was observed collecting reactor coolant and steam generator blowdown samples in the Primary Sampling Room which were analyzed for gamma isotopic, boron, chloride, fluoride, dissolved j oxygen, and cation conductivity.

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! Another RCT exhibited proper sample handling practices during collection

of condensate pump discharge, SG feed pump discharge samples in the Secondary Sampling Room and samples from the waste water treatment facility, makeup

! water demineralizer system, lake intake and discharge system. The inspector j also observed that a number of in-line monitors were inoperable for specific i

and cation conductivity, sodium, pH, and dissolved oxygen. A licensee representative reported that the entire monitoring panel will be upgraded and replaced with all new monitors during the plant outage in the Summer 1986. The licensee has already upgraded the monitoring panel for the

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makeup water syste All monitors on the Makeup Demineralizer (MUD) par.el were found operable, well maintained, and calibrate The licensee also monitors the secondary system conductivity in the control room. The inspectors confirmed that the licensee is aware of the need to

, closely monitor key parameters of each system in order to maintain good

water quality in that system and is willing to expend the necessary efforts and resources to obtain good chemistry control of each syste No violations or deviations were identifie . Plant Systems Affecting Water Quality Control

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The inspectors reviewed the licensee's changes and improvements made to

{ inplant systems to improve water quality. The licensee has proposed 59

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recommendations in a task force study to improve water chemistry, of which 1' more than 40 have been completed, including the following:

i * both units condenser boot repair / design change i * gland sealing steam air leakage testing

• formalized air in-leakage program

• reduction of make-up plant effluent conductivity to <0.1 pS/cm

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• condenser repairs (wire clips, reweld baffles)

• request for new secondary in-line monitoring panels

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o e conducting hideout return tests of chemical contaminants e increased use of blowdown during startups and shutdowns

• establishing licensee Secondary Chemistry control program

• moisture carryover test Improvements have been made in the Makeup Demineralizer (MUD) in which the effluent is consistently below 0.1 microSiemens per centimeter (pS/cm),

and in reducing air inleakage through the condensers. The licensee also has not experienced any major raw waste intrusions from Lake Michigan for several year By increased SG blowdown, cation conductivity due to organics has been kept below 0.8 pS/cm during 1985. Other steps taken to improve secondary water chemistry control, include the use of demineralized water for condenser flushing, increased inspection for raw water intrusion, improved SG wet layup, and draining and cleaning the secondary storage tank. The inspector confirmed that the licensee has taken positive steps to maintain good water quality control to prolong the life time of the S No violations or deviations were identifie . Licensee Internal Audits The inspectors reviewed two audits of the Chemistry Group, QA-22-86-02 performed on January 6-10, 1986, and QA-22-86-10 on March 10-14, 1986, by the licensee's Quality Assurance Department. The former audit, involving a review of radiochemistry and chemical control, had one comment concerning the storage of a boron standard solutio This was closed out on March 6, 1986. One deficiency concerning the quality control of purchases of chemicals required for T/S related requirements remains open, but the licensee anticipates closing it by the end of April 198 The second audit checked the calibration of glassware, equipment, and standards in the Rad / Chem Departmen No deficiencies were found relating to the Chemistry Grou In addition, the inspectors reviewed several surveillances in which the auditors observed RCT activities associated with the startup of Unit 1 after an outage. No problems were identifie No violations or deviations were identifie . Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action by the NRC or licensee or bot Open items are discussed in Section 8.

l l 13. Exit Interview The inspectors reviewed the scope and findings of the inspection with the licensee representatives (Section 1) at the conclusion of the inspection on April 7, 198 The licensee acknowledged the inspectors' concerns and agreed to improve the quality control programs by implementing quality control charts for laboratory instruments and to more extensively test the analytical qualifications of the individual RCTs.

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Additional discussions concerning quality controls for auxiliary and secondary systems were conducted by telephone with licensee representatives on April 18 and April 21, 198 During the 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 consider the proposed content as proprietar _. . - . _ _ - . - _

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