IR 05000315/1993004
| ML17331A046 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/18/1993 |
| From: | Steven Orth, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17331A045 | List: |
| References | |
| 50-315-93-04, 50-315-93-4, 50-316-93-04, 50-316-93-4, NUDOCS 9302240110 | |
| Download: ML17331A046 (16) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION REGION II I-Reports No. 50-315/93004(DRSS);
50-316/93004(DRSS)
Dockets No. 50-315; 50-316 Licensee:
Indiana Michigan=Power Company 1 Riverside Plaza Columbus, OH 43216 Licenses No. DPR-58; DPR-74 Facility Name:
D.
C.
Cook Nuclear Plant, Units 1 and
Inspection At:
D.
C.
Cook Site, Bridgman, Michigan Inspection Conducted:
January 25-29, 1993 Date
/
P9 Approved By:
H.
C. Schumacher, Chief Radiological Controls Section
=>- if-5g Date Ins ection Summar Ins ection on Januar 25-29 1993 Re orts No. 50-315 93004 DRSS 50-316 93004 DRSS Areas Ins ected:
Routine, announced inspection of:
(1) the chemistry program (IP 84750) including, organization, reactor systems water quality control programs, quality assurance/quality control program in the laboratory, and nonr adiological confirmatory measurements; (2) the Radiological Environmental Monitoring Program (REMP) (IP 84750);
and (3) review of previous inspection findings (IP 84750).
Results:
The licensee's nonradiological measurements continue to be good.
guality control of analytical measurements was good.
The licensee continued to complete corrective actions addressing the licensee's audit concerns which challenged the effectiveness of laboratory quality control (Section 10).
The licensee has undergone an organizational change which the licensee expected to improve chemistry unit performance (Section 3).
The REHP continued to be properly implemented.
e
'7302240110 930218 PDR ADOCK 05000315
DETAILS Persons Contacted
- A.
- J
- J
- D
- J D.
J.
- K.
- L
- D
- S
- R Blind, Plant Manager Rutkowski, Assistant Plant Manager Wojcik, Chemistry Superintendent Loope, Radiation Protection Superintendent Wiebe, Safety and Assessment Superintendent Noble, General Supervisor Health Physics Fryer, General Supervisor Radioactive Material Control Haglund, Acting General Supervisor, Chemistry Support Umphrey, Acting Chemistry guality Assurance Supervisor Foster, Radiation Material Specialist Watkins, Health Physics Technologist Hershberger, Acting Chemistry Ppoduction Supervisor
- J.
Isom, Senior NRC Resident Inspector
- M. Schumacher, Section Chief, Radiological Controls Section
- The above personnel were present at the Exit Meeting on January 29, 1993.
The the inspector also contacted other licensee employees in the course of inspection.
2.
Licensee Action on Previous Ins ection Findin s
IP 84750 a.
Closed Ins ection Foll owu Item 315 90012-02 316 90012-02:
Further review of tritium migration in ground water affected by releases from the turbine room sump (TRS) releases to the onsite absorption ponds.
The licensee developed a procedure which requires additional monitoring upon reaching tritium concentrations of 10,000 picoCuries/liter (pCi/1) in the TRS including sampling of the onsite absorption pond and possibly of offsite monitoring wells to assess the effect on ground water.
The inspector noted that although historical data for 1980 to 1990 indicated that tritium was a fairly good indicator of total release, that the MPC fraction in the TRS release was actually dominated by the presence of iodine.
Licensee representatives were well aware of this and noted that each sample is analyzed by gamma spectroscopy which would evaluate this.
e b.
Closed Ins ection Fol 1owu Item 315 91021-01.
316 91021-01 The licensee was to analyze a liquid sample for gross beta, H-3, Sr-89, Sr-90, and Fe-55 and report the results to Region III.
The results are listed in Table
and the comparison criteria in Attachment c ~
The results indicated good comparisons for the gross beta, H-3, and Sr-89 analysis.
However, the Fe-55 and Sr-90 analysis were in disagreement with the NRC reference laboratory's results.
A spiked sample, prepared by the NRC's reference laboratory, will be analyzed by the licensee for Fe-55 and Sr-90.
Based on the original analysis, this item is closed.
The results of the spiked sample analysis will be followed under Inspect'ion Followup, Items No. 50-315/93004-01 and 50-316/93004-01.
0 en Ins ection Followu Item 315 92017-01 316 92017-01:
Review of radiological liquid releases from condensed airborne effluents through the Unit 1 blowdown startup flash tank which was discharged through a storm sewer to Lake Michigan.
The inspector collected sand samples from the areas where the south and north storm sewers emptied onto the beach.
Additionally, rock and water samples were collected near the south sewer outfall.
These samples were screened by gamma spectroscopy in the Region III laboratory and, subsequently, sent to the. NRC's reference laboratory for analyses.
The Region III results indicated naturally occurring background radioactivity in all sand, water, and rock samples.
Three of the sand samples collected in closest proximity to the south outfall contained positive cesium-137 activities of approximately 15 to 150 picoCuries/kilogram.
Rock samples collected in the area of the south outfall contained similar levels of radioactivity.
This matter was still under evaluation by the licensee and NRC.
This item will remain open and will be further reviewed in subsequent inspections.
Mana ement Control and Or anization IP 84750 The inspector reviewed the Chemistry Unit organization and discussed it with the licensee.
Since the last inspection, the chemistry group has undergone a reorganization to improve the performance of the department and correct the concerns noted in audits of the department.
The gA chemistry group was made independent of the chemistry production section.
Instead of reporting to the chemistry production supervisor, the gA group reported directly to the chemistry superintendent.
The gA group gained added personnel resources including three chemistry technicians, a procedure writer, and a planner.
The licensee formed an engineering section within the chemistry unit, responsible for reviewing procedures, analytical techniques, and.new instruments.
The-licensee expected this group to provide the decision-making formerly performed by their corporate group, who will be used as advisors.
The chemistry production supervisor was reassigned as the supervisor 'for the engineering section.
One of the chemistry supervisors within the chemistry production section was promoted to the
chemistry production section supervisor.
Discussions with the, licensee indicated that these individuals were qualified for the positions.
Shortly after the onsite portion of the inspection, the inspector was notified that the radiation protection superintendent had been named as the chemistry superintendent and had been replaced by the former general supervisor of health physics.
'Additional personnel changes also occurred in the chemistry production section.
The secondary chemistry supervisor position was filled by a
qualified individual from another utility.
The positions of primary chemistry supervisor and chemistry training specialist were filled by two of the licensee's senior technicians.
The chemistry production section consisted of 29 chemistry technicians.
One chemistry technician vacancy was to be filled in'he immediate future.
Of the
technicians, 16 technicians were recently hired and had riot yet attained the level of training necessary to be fully qualified as chemistry technicians.
The numbers of qualified technicians provided good coverage for the department.
The staffing levels of the chemistry unit'were good, but the extensive changes to the'chemistry unit could be temporarily unsettling.
Their impact will be rev'iewed in subsequent inspections.
No violations or deviations were identified.
Confirmator Measurements 'P 84750 The inspector submitted chemistry samples to the licensee for analyses as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters.
in various plant systems with respect to regulatory and administrative requirements.
These samples were prepared, standardized, and verified for the NRC by the Analytical Chemistry Division of Oak Ridge National Laboratory.
The
'samples were analyzed by the licensee using routine methods and equipment.,
Three dilutions were made for each sample by licensee personnel, as necessary to bring the concentrations within the ranges normally analyzed by the licensee's laboratory, and were analyzed in a manner similar to that of routine samples.'he results are presented in Table 2 which also contains the criteria for agreement.
These criteria are based on analyses of the standards and on the relative standard deviations (RSD) derived from the results of the plants participating in the 1986 interlaboratory comparisons (Table 2. 1, NUREG/CR-5422).
The acceptance criteria are such that the ratio of the licensee's result and the standard value should be within 2 standard deviations (SD) of the standard value for agreement and between 2 and
SD for a qualified agreement.
A qualified agreement may indicate a bias in the assa The licensee determined nine analytes at three concentrations each and two analytes at two concentrations.
Of the 31 analyses, 28 of the licensee's values were in agreement and 3 were in disagreement.
Six of the licensee's agreements were qualified agreements.
The licensee's initial analyses of the three ammonia samples were in disagreement.
The results in Table 2 indicated a very poor level of accuracy in the licensee's current method of analysis.
The licensee acknowledged this and indicated that ammonia concentration was not used as control or indicator.
The licensee reanalyzed the three ammonia unknowns after recalibrating the system using a four point instead of a two point calibration curve.
The analyses resulted in three agreements.
The licensee indicated that their analytical procedure would be revised to implement the change in the calibration method.
The licensee's primary method of analysis for metals was via a carbon furnace atomic absorption spectrophotometer (AAS).
Since the carbon furnace AAS was inoperable during the inspection, the licensee performed the analyses using a flame AAS, their backup instrument.
This method resulted in two qualified agreements in the sodium analysis and one qualified agreement in the lithium and iron analyses.
Overall, these analyses were conservatively biased and were good results for a backup system.
All of the hydrazine analyses exhibited a positive bias, The inspector discussed the analytical method and results with a licensee representative.
The licensee agreed to investigate the analysis and reduce sources of error.
The licensee prepared a sample containing one milliliterof the anions from analyte A in Table 2 diluted with steam generator blowdown to a
volume of one liter.
This sample was divided into two aliquots to be analyzed by the licensee and the NRC reference laboratory for chloride, sulfate, and fluoride.
The results will be submitted to the Region III office for comparison.
This will be followed under Inspection Followup Items No. 50-315/93004-02; 50-316/93004-02.
No violations or deviations were identified.
Trainin and uglification of Personnel IP 84750 The inspector discussed the chemistry technician training program with the chemistry training specialist.
Continuing training was provided three times a year for the chemistry technicians.
Training consisted of topics submitted by chemistry management, instruction on new instrumentation and methods, and review of the post accident sampling system (PASS)
analyses.
Technicians were required to attend classroom and on-the-job training and successfully pass examinations to meet this requirement.
A technician who did not obtain a score of 80 percent or greater on the examinations was retested.
Failure to achieve a score of at least 80 percent on the second exam required retraining and retestin The inspector reviewed the licensee's training records and training reports.
They appeared to be well maintained and indicated a good success rate.
No violations or deviations were identified.
Water Chemistr Control Pro ram IP 84750 The inspector reviewed the licensee's water chemistry control program.
Administrative limits on water quality were defined in procedure 12.THP.6020.LAB.041, Appendix B, Revision 17, which met, and sometimes exceeded, the Electric Power Research Institute (EPRI)
PWR Owners Group Guidelines.
The inspector reviewed selected trends in water quality over the period of June of 1991 through January of 1993 and found most chemistry parameters to be well maintained.
The primary system's water quality remained very good.
The reactor coolant system (RCS) chloride and sulfate concentration averaged 5 and 2 parts per billion (ppb), respectively, with an EPRI achievable value of 150 ppb for each.
The secondary water chemistry was maintained below the EPRI values, but was slightly higher than industry averages.
Steam generator blowdown chloride and sulfate concentrations averaged 6.5 and 4 ppb, respectively, with EPRI achievable values of 20 ppb for both.
These water chemistry parameter's remained below the licensee's administrative limits, except during reactor power excursions.
Daily, chemistry. technicians were to identify levels which exceeded the licensee's administrative limits and to notify chemistry supervision.
Chemistry parameters were reviewed by the laboratory supervisors and the assigned member of the engineering section on a weekly and monthly basis, respectively.
The licensee indicated that the slightly higher concentrations of chloride and sulfate in the secondary systems were due to low levels of organic impurities entering the secondary systems via the makeup water
'system.
The licensee planned to install -an interim reverse osmosis (RO)
water purification system in mid-February 1993.
If the RO system improve's the water chemistry, the licensee indicated that a permanent RO system would be installed.
The inspector reviewed the boron concentration data for the reactor water storage tank and the accumulators.
The boron concentrations were maintained within the limits of the technical specification.
No violations or deviations were identified.
Im lementation of the Laborator ualit Assurance ualit Control A
C Pro ram IP 84750 Chemistry quality control was good.
The inspector reviewed the chemistry quality control program as defined in 12.THP.6020.LAB.044,
"Laboratory guality Assurance,"
Revision 15, Hay 7, 1992.
The licensee continued to maintain statistically based control charts for the
laboratory instruments, to participate in an interlaboratory cross-check program, and to perform semiannual technician proficiency testing.
The inspector reviewed selected control charts fo'r the laboratory instrumentation.
Control charts appeared to be well maintained and to show normal distribution.
The inspector noted that select control charts exhibited minor biases within the
+
SD range, which may have indicated some minor problems with instrument operation or calibration.
Also the licensee's gC guidance, 12.THP.6020.010.004, did not include the investigation of trends within the region of + 1SD; the licensee should consider expanding the guidance for this region.
The licensee calibrated the laboratory instruments at fixed frequency or after maintenance and when the instrument was found to be out of control.
Calibration standards were independent of performance standards.
The licensee's results in the interlaboratory cross-check program were satisfactory.
The licensee achieved 26 agreements out of 38 analyses in this program over the last 2 years.
The licensee indicated that several of the disagreements resulted from interferences, normally not seen by the licensee in typical plant samples.
No violations or deviations were identified.
Post Accident Sam lin S stem PASS IP 84750 The inspector toured the licensee's PASS system and observed a
PASS training drill.
The licensee revised the PASS training, requiring participation of two member chemistry teams and health physics personnel, which better simulated actual PASS sampling.
The chemistry technicians appeared to be competent and familiar with the system and its operation.
The inspector discussed with the licensee the system's operability.
Overall, the maintenance and operability of the PASS system have been good with the exception of the inoperability of the high flow regulator and the gas chromatograph (GC).
The high flow regulator, EPI-430, had been inoperable for over one year, and the GC has been a problem; historically.
The licensee remained capable of collecting representative RCS samples from"the PASS; however, EPI-430 would have enabled an RCS sample to be obtained in a fraction of the time required with the low flow regulator line.
The licensee initiated a design change request on August 9, 1991, which was scheduled to be completed and installed by July of 1993.
The existing regulator had not been serviced.
Members of the licensee's management indicated that either the design change would be expedited or an interim measure would be initiated to regain operability of the high flow regulator.
Further, it was evident that the licensee was aggressively pursuing resolution to the GC's inoperabilit The inspector reviewed comparisons between the PASS analyses and normal plant sample point analyses.
Comparisons of dissolved oxygen, hydrogen ion concentration, and isotopic analyses indicated that PASS samples were representative of reactor coolant and that PASS dilution factors were accurate.
No violations or deviations were identified; Radiolo ical Environmental Monitorin Pro ram REMP IP 84750 The inspector toured several air sampling stations and examined the REMP, including the 1991 Annual Environmental Operating Report and preliminary 1992 sampling data.
Since the last inspection, the radiation protection department was assigned all responsibility for the REMP.
The REMP has been implemented in accordance with the TS requirements, and in several instances, sampling exceeded the TS requirements.
Samples which were not obtained were documented in the report as required..
The review of the 1991 report and 1992 data did not indicate any radiological release to the environment in excess of TS reporting limits.
The inspector observed the licensee's sample collector performing routine air filter replacements.
-The collector was familiar with the sample stations and competent in the replacement procedures.
The sample stations were all operable and were within the calibration dates affixed to the samplers.
The collector properly verified the absence of inleakage into the sampling train after installing each replacement air filter head.
No violations or deviations were identified.
Audits and A
raisals IP 84750 The inspector reviewed chemistry audits QA-91-21 and QA-92-14 conducted in October through December of 1991 and July through September of 1992, respectively.
In addition, the 1992 environmental monitoring audit QA-92-04 and the qualification of auditors performing chemistry audits were reviewed.
The audits appeared to be technically sound and performed in sufficient depth.
The chemistry audits, in particular, appeared to be performance based.
.The chemistry audits identified several deficiencies in the area of chemistry QA/QC.
The findings included failure to properly enter QC data on trend charts, failure to identify out of control data on trend charts and equipment log books, and inadequacies in procedures.
Although these findings are not significant safety concerns, the audits described pervasive weaknesses in the laboratory's QA/QC program.
The inspector reviewed the licensee's corrective actions which addressed the audit concerns.
Overall, the specific deficiencies in 1991 were
marginally addressed, as evidence by the unsatisfactory results of the 1992 audit.
The inspector discussed the audit findings with the chemistry superintendent.
The superintendent explained that all QC/QA data and operational data was recorded and evaluated; however, not all data was properly graphed or highlighted when out of control or out of specification, as required.
Consequently, the licensee had reorganized the chemistry unit to emphasize the role of QA/QC (Section 3).
The chemistry QA group was designated to perform internal audits of procedures and procedural compliance.
In addition, the chemistry superintendent emphasized to the laboratory supervisors their responsibilities for QA/QC practices.
The licensee included modules specific to laboratory-QA/QC in annual technician training and planned to develop a computerized analysis documentation system which was expected to eliminate the cumbersome result reporting process.
These corrective actions will be followed in subsequent inspections.
No violations or deviations were identified.
Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on.
January 29, 1993.
Licensee representatives did not identify any documents or processes reviewed by the inspector as proprietary.
The following matters were specifically discussed by the inspector:
the results of the radiological and nonradiological confirmatory measurements, specifically the biases seen in the hydrazine analysis and the disagreements in the ammonia analyses (Section 4);
b.
C.
d.
the concerns documented in the audits of the chemistry QA/QC program and the corrective actions (Sections 10);
maintenance and operability of the PASS system, specifically the inoperability of the high flow regulator on the liquid RCS line (Section 9);
and the resolution of the inspection followup items.
Attachments:
1.
Criteria for Comparing Analytical Measurements 2.
Table 1, Confirmatory Measurements Program Results, 1st Quarter 1993 3.
Table 2, Radiological Interlaboratory Test Results, January 25-29, 1993
ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICALMEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements.
= The criteria are based on an empirical relationship which combines prior experience and the a
REGION III CONFIRMATORY MEASUREMENTS PROGRAM FACILITY:
D.C.
COOK FOR THE 1ST QUARTER OF 1993 SAMPLE NUCLIDE NRC VAL. NRC ERR.
LIC.VAL.
LIC. ERR.
RATIO RESOL.
RESULT RAD WASTE TANK BETA ALPHA FE-55 H-3 SR-89 SR-90 1.01E-03 1.00E-08 1.35E-03 1.83E-02 1.90E-07 6.40E-08 4.00E-05 3.00E-08 4.00E-05 3.00E-04.
4.00E-08 1.60E-08 1. 20E-03
<4.47E-8 4.94E-04 1.90E-02 1.94E-07 2.93E-07 5.20E-06 4.94E-05 7.22E-05 4.46E-08 2.93E-08 1.19 0.00 0.37 1.04 1.02 4.58 25.3
.
A 0.3 N
33.8 D
61.0 A
4.8 A
4.0 D
TEST RESULTS,:
GREEMENT ISAGREEMENT
- =CRITERIA RELAXED N=NO COMPARISON
TABLE 2 Nonradiological Confirmatory Measurements Results, D.
C.
Cook Nuclear. Power Plant January 25-29, 1993 Analyte Method Conc Ratio Acceptance Ranges Result
+ 2RSD
+ 3RSD Chloride A
B C
6
0.950 1.016 0.959 0.933-1.067 0.900-1.100
'A 0.919-1.081 0.887-1.113 A
0.926-1.074 0.895-1.105 A
Sul fate Fluoride
.
A B
C A
B C
IC IC AA/FL 2.
10
6
400 800 1500 1.060 1.065 0.978-1.013 1.065 1.018
'1.000
0.989 0.901 0.895-1.105 0.895-1.105 0.900-1.100 0.875-1.125 0.875-1.125 0.878-1.122 0.904-1.096 0.903-1.097 0.903-1.097 0.842-1.158 0.868-1.132 0.867-1.133 0.833-1.167 0.833-1.167 0.824-1.176 0..854-1.146 0.857-1.143 0.855-1.145 A
A A'
A A
A A
A+
L 400 800 1500
10
1.000 0.992 0.944 1.159 1.149 1.128 0;904-1.095 0.904-1.096 0.904-1.096 0.863-1,137 0.859-1.141 0.862-1.138 0.859-1.141 0.857-1.143 0.857-1.143 0.784-1.216 0.788-1.212 0.789-1.211 A
A A
A+
A+
A Silica Hydrazine Ammonia Rerun S
T p
R M
N
H N
Spec Spec SIE
60
25 30-
0.5 0.3 0.5
'1.0 3.0 0.983 1.097 1.109 1.108 1.092 0.739 0.723 0.677 0.958 0.945 0.960 0.906-1.094 0.909-1.091 0.922-1.078 0.922-1.078 0.922-1.078 0.902-1.098 0.902-1.098 0.902-1.098-0.902-1.098 0.902-1.098 0.902-1.098 0.859-1.141 0.860-1.136 0.888-1.118 0.888-1.118 0.888-1.118 0.856-1.147 0.856-1.147
.0.856-1.147 0.856-1.147.
0.856-1.147 0.856-1.147 A
A A+
A+
A+
D D.
D A
A A
E F
AA/FL Titr
'1,
1.178 1.071 200
,
,
1.004 300 0.990 250 1.002 h
0.859-1.142
, 0.859-1:142 0;979-1.021 0.979-1.021 0.979-1.021 0.788-1.212 A+
'0.788-1.212 A
0.968-1.032 A
0. 968-1. 032 A
0.968-1.032 A
1.
Hethods:
Titr'
Titration IC Ion Chromatography Spec
- Ultraviolet/Visible Spectrophotometry AA/FL Atomic Absorption Spectrophotometry (flame)
SIE
- - Selective Ion Electrode 2.
Conc:
Approximate concentration analyzed.
3.
Ratio of Licensee mean value to NRC mean value.
4.
- The standard deviation (SD) in the sixth and seventh columns, represents the coe'fficient of variation obtained from averaging licensee data from the preceding cycle (Table 2. 1 of NUREG/CR-5244).
A result is considered to be in agreement if it falls within the
+
SD range; a qualified agreement if it lies outside
+
2 SD, but
. within + 3 SD; and in disagreement if it is outside the + 3. SD range.
5.
Result:
A
= Agreement:
Licensee value is within +2 SDs of the NRC mean value.
A+ = gualified agreement, licensee is between
+ 2 and
+3 SDs of the NRC value.
D
= Disagreement:
licensee value is outside
+ 3 SDs.