IR 05000315/1985040
| ML17324A566 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/21/1986 |
| From: | Holtzman R, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17324A561 | List: |
| References | |
| 50-315-85-40, 50-316-85-40, NUDOCS 8601280145 | |
| Download: ML17324A566 (16) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/85040(DRSS);
50-316/85040(DRSS)
Docket Nos.
50-315; 50-316 Licenses No.
American Electric Power Service Corporation Indiana and Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
Donald C.
Cook Plant, Units 1 and
Inspection At:
Donald C.
Cook Site, Bridgman, MI Inspection Conducted:
December 9-12, 1985 Inspectors:
R.
B.
ol man v)i.pp~
M. J.
Oestmann Approved By:
M.
C.
Schumacher, Chief Radiological Effluents and Chemistry Section ate Date Date
>r~z5@
Ins'ction -Summar Ins ection on December 9-12 1985 (Re orts No. 50-315/85040 DRSS).
50-316 85040 DRSS di p
i f:.(1)
h i y
Rad>ochemsstry, including water chemistry control, quality assurance/quality control of sampling and analysis in the laboratory, observations of technician performance, and of laboratory, counting, room, and sampling rooms; (2) training and qualifications, of chemistry staff; (3) licensee internal audits; and (4) review of corrective actions taken regarding a licensee event report.
The inspection involved 66 inspector-hours onsite by two NRC inspectors.
Results:
No violations were identified in five of six areas inspected.
One apparent violation was identified in the area of laboratory quality assurance/
quality control for failure to perform quarterly analyses of unknowns containing boron and for failure to routinely test the individual technicians as required by Technical Specification 6.8.1.a (Severity Level V).
sso>aeo~4S,asozm PDR ADO', 05000315
PDR'
DETAILS 1.
Persons Contacted
"W.
AB AJ
- J p
"A.
A'J
~L J.
J.
J.
D.
K.
S.
S.
R.
W.
L.
T.
C AB
~Attended the exit interview on December 12, 1985.
2.
Licensee Action on Previous Findin s G. Smith, Jr., Plant Manager A. Svensson, Assistant Plant Manager, Operations F. Stietzel, equality Control Superintendent A. Kriesel, Technical Superintendent Physical Sciences A. McElligott, equality Assurance Engineer, American Electric ower Service Corporation (AEPSC)
A. Blind, Assistant Plant Manager, Maintenance M. Haglund, Chemistry Laboratory Supervisor Wojcik, Plant Chemistry Supervisor G.
Holmes, Administrative Compliance Coordinator E. Fryer, Environmental Coordinator Sampson, Assistant Superintendent, Operations Department Ersland, Senior Training Instructor Avery, Training Instructor Vogel, Senior Chemistry Technician Sterk, Chemistry Technician McLea, Chemistry Laboratory Supervisor Looker, Chemistry Laboratory Supervisor Lentz, Chemistry Laboratory Supervisor Shepherd, Senior Chemistry Technician Wright, Chemical Engineer, Mechanical Engineering Department (AEPSC)
L. Wolfsen, NRC Resident Inspector L. Jorgensen, NRC Senior Resident Inspector a ~
(Closed)
Licensee Event Report (LER) (50-315/85032):
Potential for non-conservative release setpoint determination.
During a July 10, 1985 review of release. procedures, the licensee identified a potential for violation of Technical Specification Surveillance Requirement 4.3.3. 10. 1 owing to conflicting instructions between procedures 1 OHP 4021.028.005
"Operation of the Containment Purge System" and 12 OHP 4021.023.022
"Release of Radioactive Gaseous Waste from Gas Decay Tanks" and the Offsite Dose Calculation Manual (ODCM) regarding the setpoint for gaseous release monitors.
The inspector determined that the licensee promptly revised the procedures to remove the conflicts and that the licensee's review of past releases had identified only one release (June 18, 1984)
where an incorrect setpoint was used but no release limits were exceeded.
This closes this LER.
b.
(Open)
Open Item (50-315/85037-01; 50-316/85037-01):
The licensee agreed to analyze a liquid waste sample for tritium, Sr-89, Sr-90, Fe-55, and gross beta and report the results to Region III.
Results are not yet availabl I
'1 f
N
c.
(Open)
Open Item (50-315/85037-02; 50-316/85037-02):
The licensee agreed to take preventive steps to resolve the sample collection problems at the public intakes for the radiological environmental monitoring program.
Results will be forthcoming.
d.
(Open)
Open Item (50-315/85037-03; 50-316/85037-03):
The licensee agreed to investigate the cause of elevated tritium levels in seven onsite well water samples and provide results of the investigation by June 1986.
Mana ement Controls Or anization Trainin and ualifications No changes in management controls and staffing organization have occurred sincethe previous, inspection.
Four chemistry supervisors, a chemist (currently vacant),
a performance engineer, and 19 technicians report to the Plant Chemistry Supervisor.
Six contract technicians are also available to perform routine chemical analyses.
The staffing appears sufficient in number to perform the necessary sampling and analyses of plant systems.
The inspector discussed with a licensee representative the current and the new chemistry training programs.
The licensee is developing new ones with the intention of seeking INPO accreditation in 1986 or 1987.
All senior technicians have recently completed the current two-year requalification program described in Procedure 12 THP 6020. LAB.134 "Chemistry Section Training," Revision 1 dated July 25, 1985, involving monthly in depth discussions of laboratory pr actices and plant systems.
At present special topics are being presented to the senior technicians.
A formal lecture program of 23 sessions involving laboratory theory and practices, chemical safety, system operations and other topics is being presented to the junior technicians and technicians.
The current training program appeared to be satisfactory.
However, the entire training program is being revised into 51 lesson plans involving 200 tasks for the technician to perform.
Formal lectures and on-the-job laboratory tasks to perform will begin in the spring of 1986.
It will include establishment of qualification cards for each technician.
The revised chemistry training program should improve the proficiency of the technicians and provide for upgrading their sampling and laboratory practices as needed (See Sections 5, 6, and 7).
No violations or deviations were identified.
Mater Chemistr Control Pro ram The inspectors determined that the licensee established and is adequately implementing a secondary water chemistry control program in accordance with the requirements in Sections 2.C.3.M and 2.C.7, of the operating Licenses for Unit 1 and Unit 2, res'pectively.
This program is summarized in Procedure PMI-6020, "Chemical/Radiochemical Control Program,"
Revision 1, July 16, 1985 'and detailed in the following chemistry procedures (12 THP 6020'):
Inspection Reports No. 50-315/85037; 50-316/85037
N I
LAB.037 "Techniques of Liquid Sampling," Revision 7, November 11, 1985, LAB.041 "Data Sheet Instructions," Revision 0, November 5, 1985, LAB.100 "Laboratory Surveillance Requirements,"
Revision 4, November ll, 1985.
These procedures adequately address the major elements of the PWR Owners Guidelines and include assignment of authority and responsibilities to implement the program and provide guidance tothe chemistry staff on operational chemistry limits designed to minimize localized corrosion in the steam generators and turbines.
The inspector also determined that these procedures satisfactorily address the analytical measurements program, performance monitoring of the program, documenting data, logging and trending of results, and includes action levels for the licensee to take to correct plant operation when monitored chemical parameters are confirmed to be outside the normal operating values.
The inspectors also reviewed the operational conditions of both Units and determined that there was close cooperation between the Operations Department and Chemistry Department staff in maintaining tight controls on the plant water chemistry during different modes of operation.
Licensee representatives indicated that there had been no difficulty in maintaining the required chemistry parameters in the primary reactor coolant of either Unit.
No technical specifications 3/4 3.7 for limiting conditions of operation for dissolved oxygen, chloride, and fluoride in reactor coolant were exceeded.
The inspectors also determined that the licensee adequately measures cation conductivity and pH, and the concentrations of chloride, hydrazine, ammonia, sodium, sulfate and dissolved oxygen in the secondary coolant system.
The inspector noted during review of trend plots of dif'ferent chemical parameters in the secondary system, that the licensee effectively improved his control of secondary chemistry during 1985.
This was indicated by the reduction of the number of occasions when administrative chemistry limits were exceeded during the year.
At such times in the licensee effectively implemented the necessary corrective Action Levels on plant operation as presented in LAB.041 until the desired secondary chemistry was obtained.
The licensee is using boric acid in the secondary system to neutralize caustic that may be present in the steam generators.
This use of boric acid is considered important in reducing SG tube degradation.
No violations or deviations were identified.
5.
Water Sam lin Honitorin and Processin The inspectors reviewed the sampling and monitoring programs and water treatment processes during a tour of the plan h I
I
)
The inspector observed a technician collecting samples from the Normal Sampling System (NSS) in the Sampling Room in which both the primary and secondary sides are sampled in one large hood.
The two sides are separated in the hood so that cross contamination of samples was unlikely.
However, during sample collection, the technician risked possible contamination of the sample collection bottle and of a conductivity meter with SG blowdown.
No towels were used to dry the bottle or the flow cell before removal from the hood, and the technician did not use the survey meter to monitor the operation.
The inspector discussed the observed poor practices with the technician and also with plant management during the exit interview.
The licensee agreed to provide the necessary training and provide closer supervisory oversight of technicians to improve sampling and analysis practices.
This item will be examined during a subsequent inspection (Open Item 50-315/85040-01; 50-316/85040-01).
A licensee representative discussed with the inspectors the new in-line monitoring program being developed for the plant.
At the present time new in-line conductivity and dissolved oxygen monitors are being calibrated to be put into the feedwater, condensate and blowdown system.
Once installed the data will be collected by computer in real time.
In the future the licensee plans to install hydrogen, sodium, pH and other monitors and establish a Chemistry Data Acquisition Center that can monitor 150 parameters at different sampling locations.
This center should be established in 1987.
Currently, in-line monitoring is provided for the condensate hotwell and steam generator blowdown with alarms and recorders in the control room.
A licensee representative also reported that the main condensers have been tubed with stainless steel to replace the copper arsenic alloy used previously.
The licensee has not seen any in-leakage of lake water into the condensers since the replacement occurred.
Sampling has shown less than 5 ppb sodium and dissolved oxygen in the hotwell condensate
.
During the next refueling outage the licensee plans to. replace the condensers of the turbine-driven feed pumps'ith stainless steel.
The licensee appears to be aware of the need to maintain tight chemistry controls over the secondary chemistry system to minimize SG tube degradation and appears willing to invest necessary funds to improve water chemistry monitoring and water quality control.
No violations or deviations were identified.
Chemistr and Radiochemistr Laborator Facilities Procedures and
~0erationa The Inspectors reviewed the chemistry and radiochemistry programs, including the physical facilities, laboratory operation, counting room practices, procedures and QA/QC practices in the laboratory.
The laboratory space and facilities were adequate.
Both chemistry and radiochemistry instruments were of good quality, well-maintained, operational and properly calibrated in accordance with licensee procedure 12 THP 6020. LAB.044 and 12 THP 6020. LAB.088.
No chemicals or reagents were identified with labels with expired date II h
I'l
Selected recently revised 'chemistry procedures (12 THP 6020.
) for various analyses and survei llances listed below were implemented and found current.
The procedures reviewed included:
LAB.003 Determination of Boron, Revision 5, June 13, 1985 LAB.004 Determination of Sodium Hydroxide Strength, Revision 3, February 25, 1985 Determination of Chloride (High Range),
Revision 4, March 13, 1985 LAB.014 Determination of Hydrogen, Revision 3, February 12, 1985 LAB.017 Determination of Lithium, Revision 3, April 4, 1985 LAB.019 Determination of Dissolved Oxygen, Revision 7, March 13, 1985 Colorimetric Determination of Soluble Silica in Mater Revision 3, May 9, 1985 Determination of Suspended Solids, Revision 4, August 15, 1985
. Determination of Total and Dissolved Solids, Revision 4, July 18, 1985 Techniques of Liquid Sampling, Revision 7, September 26, 1985 Techniques of Gaseous Sampling, Revision 5, August 16, 1985 Laboratory Surveillance Requirements, Revision 4, April ll, 1985 Low Range Boron Determination, Revision 4, April 4, 1985 Calibration of the Series
MCA with PDP ll/24 Computer and Ge(Li) Detector, Revision 1, April 25, 1985 LAB.141 Gamma Analysis Using the Series
MCA with PDP 11/24 Computer and Ge(Li) Detector, Revision 1, June 16, 1985 Steam Generator Met Layup Guide, Revision 0, May 30, 1985 Steam Generator Tube to Tube Sheet Crevice Flushing, Revision 0, September 9,
1985 Steam Generator Secondary Side Boric Acid Soak, Revision 0, November 7, 1985 LAB.006 LAB~ 024 LAB.027 LAB.037 LAB.038 LAB.100 LAB.112 LAB.140 LAB.155 LAB.156 LAB.159 No other problems were noted in the procedures.
The boron analysis procedure (LAB.003) appears deficient in its failure to specify the use of a boron standard with each set of analyses as a
quality control measure.
In practice, a 100-ppm boron standard is used for this purpose.
The licensee agreed to also consider using a standard with a concentration (about 1000 ppm) more consistent with that of many of the analyzed samples.
The inspector also identified a possible problem with bias introduced by a non-standard technique used to determine sample dilution.
Twenty five ml of deionized water measured with a volumetric transfer pipet (calibrated "to deliver," not "to contain") is removed from a 500 ml volumetric flask and replaced with sufficient sample to return the flask level to the "mark."
The difference between contained volume and delivery volume introduces a bias that has not been evaluated by the licensee.
Licensee representatives agreed to review these matters which will be reviewed in a subsequent inspection (Open Item 50-315/85040-02; 50-316/85040-02).
The inspectors observed several technicians perform laboratory analyses, for boron, chloride, fluoride, ammonia, hydrazine, trace metals, dissolved oxygen and conductivity.
A gas sample was collected and prepared for radioactivity measurements.
The technicians followed procedures and were well acquainted with each step of the procedure used in each analysis.
The instruments used were properly calibrated with current calibration stickers.
Standardized solutions were used for performance checks and calibrations to assure that high quality analyses were performed.
However, the inspectors'observed poor laboratory analytical practices by the technicians, such as 'using a leaky buret in the determination of boric acid concentrations and poor techniques for rinsing cuvettes used in spectrophotometric measurements.
The technicians recorded the analytical data on small pieces of paper rather than in a notebook and transferred the data from several sheets of paper to the official log sheets.
These techniques and practices were discussed with licensee management who agreed to promptly provide stronger management oversight and training of technicians in improvement of laboratory practices.
(Open Item 50-315/85040-01; 50-316/85040-01).
No violations or deviations were identified.
7.
ualit Assurance/ ualit Control of Anal tical Measurements a.
Nonradiolo ical Chemistr Measurements The inspectors reviewed 'the QA/QC programs in the chemistry laboratory based on Procedure 12 THP 6020. LAB.044, "Laboratory Quality Control,"
Revision 6, September 12, 1985.
This revision, which improves the descriptions and documentation of the laboratory QA practices, was in response to a 1984 Quality Assurance Department Audit QA-84-20.
This procedure is specific in some areas in its purview, such as control of chemicals and reagents, calibration of instruments, and maintenance of deionized water, but it is fairly general with respect to control of analytical methods.
It does not specify the use of control charts, nor the handling and trending of data.
Control charts are not used and the data are not trended regularly.
However, the laboratory maintains for each instrument a log book that contains information useful for quality control such as calibration, maintenance and analysis data.
The Plant Chemistry Supervisor stated that the plant also plans to initiate the use of control charts for nonradiological analyses and that an implementation date would be forwarded with the response to the report.
(Open Item 50-315/85040-03; 50-316/85040-03).
The QA/QC program described in Procedure
THP 6020 LAB.044,
"Laboratory Quality Assurance" is currently implemented using
"unknowns" obtained from a vendor, Environmental Resources Associates (ERA) or prepared by a Chemistry Supervisor.
Section 12 of this procedure requires a routine program to assure "reliability of proce-dural accuracy and individual technician technique,"
and requires that "each relevant procedure will be checked at least quarterly with
'unknowns'."
Contrary to this requirement, the licensee failed to provide unknown samples to check Procedure 12 THP 6020 LAB.003,
"Determination of Boron," and to routinely test individual techniques
II
p!
of all chemistry technicians during the period 1983 through December 1985.
This is a violation of Technical Specification 6.8.1a which requires implementation of written procedures recommended in Appendix A of Regulatory Guide 1.33.
(Violation 50-315/85040-04; 50-316/85040-04 - Severity Level V).
The inspector examined sel'ected QC tests using ".unknowns" done in 1984 and 1985 for pH, chloride, fluoride, sulfate, phosphate, trace metals, oil and grease, and conductivity.
Approximately 36K of the results were in disagreement with the values of the vendor, ERA.
Mhile a substantial fraction of the disagreements were on analyses for which attainment of good precision was difficult, such as oil and gr'ease, and phosphate analyses, a large fraction of the remainder, e'stimated to be 20X, were still in disagreement.
The inspector discussed with licensee representatives the need for improved performance, since some of the analyses, such as trace metal element analyses by atomic absorption spectrophotometry appeared to be fairly simple and reproducible and the acceptance limits were fairly large (~lOX of the value).
This item will be examined in a
'subsequent inspection (Open Item 50-315/85040-05; 50-316/85040-05).
The licensee's QA/QC program for the laboratory needs improvement.
In particular, there is need for improved trending of data, for implementation of control charts and other tests to demonstrate that
"
analyses are in a state of statistical control, and for ensuring the capability of individual technicians in the performance of required analyses.
.Radiolo ical Measurements The inspectors reviewed the QA/QC for radiological measurements program, based on Procedure 12 THP 6020 LAB.088, "Quality Control of Counting Equipment," Revision 7, June 14, 1985.
The operations of the instruments are controlled by an extensive program with check sources.
Control charts are maintained daily for the performance check sources on each instrument.
These charts have a line representing the mean value, and warning and control limits based on two and three standard deviations, respectively.
In addition, control is maintained with tests performed periodically, such as a
weekly chi-squared test based on 21 one-minute counts.
In general the results appeared to be good.
The warning limits were a quite narrow +EX of the count rate (coefficient of variation, CV).
Since January 1985 (the implementation date of the charts)
the check-source values were generally within the warning limits.
The licensee has implemented a program to check radiochemistry analyses by splitting liquid waste samples with a vendor and also by analyzing blind samples of various media provided by another vendor.
The two split samples (April and October 1985)
gave ll disagreements in 32 comparisons.
The disagreements involved mainly activation products and probably resulted from settling of suspended
C t
material in the unfiltered samples.
In a November 1985 comparison with the NRC on a filtered waste sample, the licensee achieved all agreements indicating satisfactory capability in performing these analyses.
The blind comparisons performed November 1985 on liquid, gas, and charcoal filter samples furnished by Analytics, Inc. also resulted in all agreements.
Overall, the gA/gC program for radiochemistry and the counting room appears satisfactory.
One apparent violation was identified.
8.
~0en Items Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector and which involve some action on the part of the NRC or licensee or both.
Open Items disclosed during the inspection are discussed in Sections 5, 6, and 7.
9.
~Ei I ti The inspectors reviewed the scope and conclusions of the inspection with licensee representatives denoted in Section j. at the conclusion of the inspection on December 12, 1985.
The inspectors noted that radiological and counting room quality assurance was generally satisfactory, but described shortcomings in nonradiological quality assurance, including a violation for failure to perform procedurally required gA tests for the boron analysis procedure.
Observed weaknesses in technician performance were also discussed.
In response to inspector comments the licensee agreed to:
improve management oversight and training of technicians in laboratory practices (Section 5 and 6),
evaluate the significance of the error introduced by the use of a nonstandard pipetting technique on the boron analysis and to consider the use of additional boron standards (Section 6),
implement the use of control charts for nonradiological analyses (Section 7).
During the inspection, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
Licensee representa-tives did not identify any. such documents or procedures as proprietar ~
~