IR 05000322/1986011
| ML20209G766 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/04/1986 |
| From: | Bicehouse H, Davidson B, Kottan J, Mark Miller, Pasciak W, Zibulsky H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20209G758 | List: |
| References | |
| 50-322-86-11, NUDOCS 8609150070 | |
| Download: ML20209G766 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
l Report No. 86-11 Docket No.
50-322 License No. NPF-36 Licensee:
Long Island Lighting Company P. O. Box 618
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Shoreham Nuclear Power Station Wading River, New York 11792 Facility Name: Shoreham Nuclear Power Station Inspection At: Wading River, New York Inspection Conducted: July 28, - August 1, 1986 Inspectors:
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Irt, Wdiation Specialist Idate'
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. Davi:tson, Radiation Specialist date
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H. 81Tcehouse, Radiation Specialist date
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H. Zibuisky hemist date C7A T. 4 - ltfifah 8 -26 - 9(o J.
ottan a'dia ion Laboratpry Specialist date Approved by:
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W.J.Pa(fonServiceciak, Chief, Effluents Radiation date s
Protect Inspection Summary:
Inspection on July 28 - August 1,1986 (Report No.
50-322/86-11)
Areas Inspected: Special, announced safety inspection of the licensee's chemistry program. Areas reviewed included: licensee action on previous inspection findings; chemistry management and organization; technician selection, training, and qualification; radioactive capability tests samples; effluent release records and reports; effluent sampling and analysis; 00CM implementation; water chemistry control program; measurement control evaluation; analytical procedures evaluation; and PASS analysis capability.
Results: Of the areas reviewed, no deviations or violations were identified.
8609150070 860905 PDR ADOCK 05000322 G
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DETAILS 1.
Individuals Contacted
- M. Herlihy, Radiochemistry Task Force Manager
- M. Case, Operations
- R. Grunseich, Compliance
- S. Daniel, Radiochemistry Engineer
- R. Glazier, QC Section Supervisor
- E. Youngling, Nuclear Engineering Department Manager
- C. Seaman, QC Division Manager
- D. Smith, Compliance
- J. Wynne, Training
- G. Gisonda, Licensing
- W. Steiger, Jr., Plant Manager
- J. Scalise, Operations / Assistant Plant Manager
- J. Schmitt, Radiation Controls Division Manager
- J. Notaro, QA Manager
- J. Smith, Director of Training M. Ma, Radiochemistry Task Force
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K. Taylor, Radiochemistry Task Force A. Hogevoll, Radiochemistry Task Force R. Petricek, Radiochemistry Support Supervisor M. Waterman, Foreman Advisor A. Feldman, Radiochemistry Support Staff J. Pyo, Chemical Engineer P. Lynch, Chemist G. Romeo, Radiochemistry Support Staff N. Marcos,, Training Instructor J. McCue, Technical Training Supervisor
- Denotes those present at the exit interview.
The inspectors also talked with and interviewed other licensee personnel including members of the chemistry and operations staffs.
i 2.
Licensee Action on Previous Inspection Findings (Closed) Follow-up Item (302/85-40-01): Preparation and use of independent measurement and calibration control standards.
The licensee has implemented the use of independent calibration and measurement control standards.
See Section 10.
(Closed) Follow-up Item (322/85-40-02): Initiate a measurement control program with analyzed standards plotted on control charts.
The inspector verified that the licensee is using control charts for the appropriate chemical parameter analyses.
See Section 10.
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(Closed) Follow-up Item (322/85-40-03): Comparison of water sample analytical results. Because of personnel turnover the licensee could not locate the split sample results. Samples will be split again during a subsequent inspection.
(Closed) Unresolved Item (322/86-03-01): Qualifications of radiochemistry foreman. The radiochemistry foreman whose qualifications were in question is no longer in a radiochemistry foreman position.
(Closed) 25-00-13 TI: This inspection completed review of the licensee's water chemistry control program.
(Closed) Unresolved Item (322/86-03-05): Failure to use control charts for chloride analyses. The licensee is now implementing the chloride analysis procedure and using control charts as required.
(Closed) Follow-up Item (322/86-03-06): Laboratory QA/QC program. The licensee is following accepted laboratory practices in implementing laboratory QA/QC practices such as curve fitting of instrument calibration data.
See Section 10.
(0 pen) Unresolved Item (322/86-03-07): Performance of radiation monitoring system (RMS) maintenance by personnel without electronics experience.
The Computer Engineering Section is now performing electronic maintenance on the RMS. However, the computer group has yet to assume full responsibilities in the area from chemistry.
(Closed) Follow-up Item (322/86-03-02): Staffing of radiochemistry management and support positions. The licensee has changed the organizational structure to eliminate one position (radiochemistry supervisor) and is staffing other positions with licensee personnel. See Section 3.
(Closed) Follow-up Item (322/86-03-03): Selection criteria for radio-chemistry supervisor. The position of radiochemistry supervisor has been eliminated from the licensee's organization.
(Closed) Follow-up Item (322/86-03-04): Technicians qualifted on RMS
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procedures without the use of task evaluation guidelines. The licensee is now implementing the technician qualification procedure as required.
See Section 4.
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3.
Management and Organization of the Radiochemistry Section The inspector reviewed the licensee's radiochemistry organization with respect to structure and staffing. The inspector also reviewed the qualifications of the supervisory and professional personnel in the licensee's radiochemistry organization. These reviews were conducted with respect to Section 6.2, Organization; and Section 6.3, Unit Staff Quali-fication, of the Technical Specifications (TS) and ANSI Standard N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel".
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The licensee's radiochemistry organization remains essentially the same as documented in Inspection Report No. 50-322/86-03 (January 27 -
February 14,1986) with the exception of the Radiochemistry Supervisor position. This position has been eliminated in order to provide direct communication between the Radiochemistry Engineer and the Foremen. Also, the positions of Chemist and Chemical Engineer have been staffed with licensee personnel instead of contractor personnel. The position of Radiochemistry Engineer is currently staffed by a contractor. The licensee's radiochemistry organization is detailed in Procedure SP71.002.01, Rev. 6, dated April 16, 1986.
The licensee currently has a draft revision to this procedure which eliminates one position, Radio-chemist. Of the eight remaining supervisory and professional positions in the draft organization, seven are staffed by licensee personnel, the exception being the Radiochemistry Engineer. This indicates a significant change from the previously reviewed staffing situation (Inspection Report ilo. 50-322/86-03) where over approximately 40% of the individuals in the organization were contractor personnel or were acting in a specific posi-tion. The licensee is continuing to use contractor personnel as support staff. All individuals in the current organization meet or exceed the licensee's selection criteria contained in Procedure SP 71.002.01. The selection criteria in this procedure are the criteria in FSAR Section 13.1.3 and ANSI /ANS-3.1-1979 which meet or exceed the criteria of ANSI N18.1-1971.
The licensee has also formed a Radiochemistry Improvement Task Force to provide intensive assistance on technician training and qualification and improvement of the laboratory QA/QC program.
The Task Force manager reports directly to the plant manager.
Except for the Task Force manager, the majority of other task force members are contractor personnel whose qualifications exceed ANSI N18.1-1971 requirements for professional level chemistry staff.
4.
Technician Selection, Training, and Qualification The inspector reviewed the licensee's program for the selection, training, and qualification of Radiochemistry Technicians.
The review was performed using the criteria contained in Section 6.4, Training, of the TS and ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel".
The licensee's technician selection and training program is detailed in Procedure SP 71.0006.01, " Radiochemistry Technician Selection, Training and Qualification Program".
This procedure meets the requirements of the licensee's TS. The previous inspection in this area (Inspection Report No. 50-322/86-03, performed January 27 - February 14,1986) indicated apparent problems in the area of technician qualification.
The licensee is requalifying all the radiochemistry technicians in response to the identified apparent problems.
This requalification effort was first focused on the area of backshift qualification in order to permit around the clock technician coverage without direct chemistry supervision on the back shifts. The requalification effort is being administered by the Radiochemistry Improvement Task Force.
The licensee currently has nine of the 14 technicians qualified for backshift work. Task evaluation
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guides are used to qualify the technicians.
Task evaluation guides are written by task force members and are reviewed by the task force manager.
Schedules for tracking qualifications and projections of qualification completion are maintained by the Radiochemistry Improvement Task Force.
The task force is effectively and aggressively implementing Procedure SP 71.006.01 with respect to technician qualification. Work not performed by qualified technicians is performed under the direct control of laboratory supervisory personnel.
Radiochemistry technician training is provided to technicians by the training department.
Ten newly hired technicians are undergoing this training.
The training program is based on a technician task evaluation matrix following guidelines recommended by the Institute of Nuclear Power Operations (INPO). The formal training program consists of classroom, laboratory, on the job training, and technician qualification; technician qualification is performed by the radiochemistry department. A contractor is administering the licensee's training program.
Currently the formal classroom training is underway. The inspector reviewed the formal class-room curriculum and noted the content, nature and length of the training program.
Individual technician selection, training, and qualification records are now being mair.tained by the training department.
In addition, the inspector noted the communication between the training and radiochemistry personnel; radiochemistry memos were sent to training to confirm the need to include laboratory QA in the chemistry training curriculum, and training personnel are attempting to coordinate the on the job training given to the technicians with the technician qualification requirements.
5.
Radioactive Capability Test Samples Test samples were submitted to the licensee in order to evaluate the licensee's capability to measure radioactivity in effluents.
The test samples duplicated the types of samples a1d nuclides that the licensee would encounter during operation. The test samples were analyzed by the licensee using the licensee's normal methods and equipment.
The results of the test sanples measurement comparison indicated that all of the measurements were in agreement under the criteria used for intercomparison of results.
(See Attachment 1) The intercomparison data is listed in Table 1.
6.
Effluent Release Records and Reports The inspector reviewed selected radioactive liquid discharge permits and the licensee's control system for continuous gaseous releases, as well as associated procedures, analysis records and calculations for 1985 through July 31, 1986.
The inspector also reviewed the licensee's Semi-Annual Effluent Reports issued for 1985. The inspector determined that no
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Technical Specification limits for planned or unplanned radioactive effluents had been exceeded for 1985 and 1986 to date.
The inspector also verified that the radioactive waste treatment systems were used for all releases during that same period, if applicable.
The licensee reported for 1985 that there were no gaseous batch discharges; no detectable radioactivity in the continuous mode gaseous and liquid effluents; and insignificant radioactive quantities in the liquid batch discharges for the latter half of 1985.
The inspector verified these statements through a review of the sampling analysis records and data-base from the on-line Radiation Monitoring System (RMS).
7.
Effluent Sampling and Analysis Program The inspector reviewed licensee documentation and verified sampling locations and sample storage to determine if liquid and gaseous effluent sampling and analysis were being conducted as required by Technical Specification Sections 3/4 11.1 and 3/4 11.2.
Selected chemistry procedures and surveillance records were reviewed including the following:
SP 73.631.01, Revision 0, Station Ventilation Exhaust Radiation Monitor Operation.
- SP 73.631.31, Revision 3, Liquid Process Radiation Monitor Operation.
- SP 74.020.02, Revision 13, Liquid Waste Release Analyses and Discharge Authorization.
- SP 74.020.04, Revision 7, Containment Drywell Exhaust and Air Removal Pump Exhaust Analysis and Discharge Authori-zation.
- SP 74.020.10, Revision 11, Continuous Liquid Releases - General Sampling, Analysis and Data Storage.
- SP 74.020,20, Revision 11, Airborne Releases - General Sampling, Analysis and Data Storage.
Discussion with Chemistry Department Control Technicians and Foreman were also conducted, i
Within the scope of this review, no violatiens were identified. The i
inspector noted that the prescribed frequencies and type of sampling and
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analysis were being performed.
Sample locations appeared to be adequate.
The inspector noted that a review of sample line flush times was being
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performed as a result of a self-identified audit finding. The results of this study will be reviewed when completed.
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Offsite Dose Calculation Manual Implementation
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The inspectors reviewed the licensee implementation of the Shoreham j
Offsite Dose Calculation Manual (00CM), Revision 8, dated February, 1986. The calculations to determine dose contributions from plant
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radioactive effluents to unrestricted areas using the methodology l
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specified in the ODCM was also reviewed.
In addition, the inspectors evaluated the alarm / trip setpoints for the liquid and gaseous effluent pathways and related calibration procedures to cetermine compliance with Technical Specifications 3.3.7.10/4.3.7.10 and 3.3.7.11/4.3.7.11.
Within the scope of this review, no violations were identified. The inspector determined the statior ventilation exhaust monitor, liquid radwaste effluent line monitor, RHR heat exchanger service water outlet monitors, and Reactor Building salt water drain tank outlet monitors were calibrated in accordance with surveillance procedures:
SP 74.631.02, Station Ventilation Exhaust Rad Monitor Calibration, Revision 6, and
SP 74.631.32, Liquid Release Rad Monitor Calibration, Revision 7.
A noted strength of the licensee's surveillance program was the use of an administrative program that automatically scheduled all Technical Specification surveillances and related activities.
With regard to maintaining the monitor alarm / trip setpoints, all release monitor setpoints were in accordance with the ODCM bases and initial calibration data.
However, the inspector noted there was a discrepancy between the ODCM referenced detector efficiency curve and the efficiency factors listed in SP 74.020.02, Revision 13 " Liquid Waste Release Analysis and Discharge Authorization." The inspector stated that the validity of the generic efficiency factors at lower energies should be determined with the use of radioactive sources.
The licensee stated an evaluation of the efficiency curve had been undertaken. The inspector recommended the licensee complete their evaluation of the efficiency curves for detector RE-13, using either mock-up gel sources or solid transfer' sources of low energy, review the efficiency factors used in SP 74.020.02, and revise the setpoint master file, if required. The inspec-tor also noted the capabilities of the RMSS were being upgraded. This included software changes.
Verification of the computer codes used to perform the required offsite dose calculations would be reviewed when the modification was completed.
These items will be reviewed during a subsequent inspection (50-322/
86-11-01).
9.0 Water Chemistry Control program 9.1 Requirements The licensee's water chemistry control program was reviewed relative to criteria, commitments, recommendations and consensus industry standards provided in:
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- Technical Specification 3/4.3.7.8, " Chloride Intrusion Monitors;"
Technical Specification 3/4.4.4, " Chemistry;"
NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," Revision 2 (February,1918);
NRC Regulatory Guide 1.56, " Maintenance Of Water Purity In'
Boiling Water Reactors," Revision (July, 1978);
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Electric Power Research Institute (EPRI)/ Boiling Water Reactors Owners Group (BWROG), "BWR Water Chemistry Guidelines,"
(April 1, 1984); and
American Society For Testing And Materials (ASTM), Section 11,
" Water Standards."
Descriptions in the licensee's Final Safety Analysis Report (FSAR)
were also used in the review.
9.2 Scope Of The Review The following areas of the licensee's water chemistry control program were reviewed:
Organization;
Plant Water Chemistry Systems;
Sampling and Measurement; and
Implementation of the Water Chemistry Control Program.
The licensee's performance in each area was determined by interviews and discussions with the Radiochemistry and Operations staffs, review of procedures and records, and observations of plant facilities and equipment during tours of the Reactor, Radwaste and Turbine buildings.
9.3 Organization l
Program organization was reviewed with regard to policies, goals / objectives, bases, assignment of responsibilities and authorities, resources to implement the program, and procedures for maintaining high purity water in the steam cycle.
The licensee did not appear to have a clear docurrented policy providing the goals / objectives of, management commitment to, support for and control of the water chemistry control program. General Electric Company's Fuel Warranty requirements provided the basis for the chemical parameters sampled and their controlling values.
The licensee indicated that the EPRI/BWROG guidelines would be tested during power ascension tests, (i.e. STP #1, " Chemical and Radiochemical Tests," Revision 3, June 20, 1986), to determine if the EPRI/BWROG Guidelines were compatible with plant operations.
The inspector discussed development of a plant-specific water chemistry control program (including water chemistry specifications, corrective
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actions in the event of water impurities exceeding specifications, sampling and analysis schedules, in-line instrumentation controls and data / records management and trending programs) with the licersee.
Responsibilities for sampling / analysis of chemical parameters and operation of plant systems to control those chemical parameters were split among Radiochemistry, Radwaste and Operations within the plant organization.
Radiochemistry personnel provided sampling / analysis of radiochemical and chemical parameters and reported their results to plant management. Operations had responsibility for the operation of the Reactor Water Cleanup System (RWCU) including filter demineralizer replacement.
Radwaste had responsibility for operation of the Condensate Demineralizers including regeneration of mixed ion beds (although this activity was controlled by the Operations Engineer).
Station procedures were selectively reviewed to determine if:
Critical chemical variables and limit / action levels for control of those variables had been developed relative to the Fuel Warranty requirements;
Sampling locations, schedules and methods had been provided;
Surveillance requirements under Technical Specifications 3/4.3.7.8 and 3/4.4.4 were identified;
Analytical methods and their basis had been provided;
Methods for recording, trending and reporting chemical data were established; and
Investigative and corrective actions to be taken when chemical parameters exceeded action levels were identified.
Controlled station procedures and draft procedures were included in the review to determine current practices and cnanges undergoing review. Within the scope of this review, the licensee appeared to be developing station procedures covering water chemistry specifica-tions, corrective actions in the event of water impurities exceeding specifications, sampling and analysis, in-line instrumentation and data / records management to implement a plant-specific water chemistry control program following completion of startup testing. The chenical and radiochemical startup tests, (i.e. STP #1) addressed chemical parameters sufficient to evaluate the EPRI/BWROG Guidelfr,es.
9.4 Plant Water Chemistry Systems The licensee's Condensate, Condensate Domineralizer and RWCU Systems were reviewed for familiarization and conformance to their descriptions in the licensee's FSAR.
The as-built design was reviewed for potential pathways of impurity ingress into the steam cycle. The inspectors noted that the design was a conventional
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s General Electric BWR design with sea water as condenser circulating
water and titanium condenser tubes. The following potential pathways of impurity ingress were reviewed:
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failure of condenser tubes;
exposure to air during plant outajes;
accidental loss of resin fines from the Condensate Demineralizer or RWCU systems; j
leaching of regenerative chemicals from demineralizer beds; and
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organic intrusions via the plant drains and radwaste system i
recycle of water to the Condensate Storage Tank.
In each instance, the licensee's sampling / monitoring design appeared adequate to identify the source of the contaminant.
9.5 Sampling And Measurement
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The licensee's process sampling and in-line monitoring system was reviewed.
The system provides liquid and gaseous samples for
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analysis of the water chemistry of the reactor coolant system. The following sample panels and associated in-line instrumentation were observed:
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Turbine Building Sample Panel (PNL-055);
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Reactor Building Sample Panel (PNL-049);
Radwaste Building Sample Panel (PNL-054A);
Radwaste Building Indicator Panel (PNL-0548); and
RWCU Sample Rack (PNL-23)
Each sample panel was reviewed for conformance with industry l
consensus standards, (e.g. ASTM D 3370-82, " Practices for Sampling i
W.Ler, " ASTH D 1066-82, " Practices for Sampling Steam," and ASTM 0
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3864-79, " Guide for Continual On-line Monitoring Systems for Water
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Analysis"). Maintenance and calibration activities relative to the j
following in-line instrumentation were reviewed:
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conductivity instrumentation including main condenser, pump I
discharges, resin bed influent and effluent, feedwater, main
steam line, radwaste and seal waters;
constant temperature baths for the sampling panels;
pH instrumentation;
domineralizer influent and effluent sodium analysers*
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domineralizer turbidimeter; and l
l domineralizer silica monitors.
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Grab sampling at the sample panels was reviewed and discussed with i
the Radiochemistry staff. Within the scope of this review, the l
following item was noted:
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Sampling lines must be purged to remove materials that may have deposited or settled in the sampling line to ensure acquisition i
of a representative sample. ASTM D 3370-80 recommends purging sampling lines with 3 - 4 times the sampling line volume and provides approximate purging periods for sampling lines equivalent to Schedule 40 pipe of various diameters. The licensee's general sampling procedure reproduced the ASTM
approximate purging times. However, the ASTM purging times are in units of seconds per foot of sampling line.
In order to properly purge a sample line, a user must determine the length of sampling line, multiply the length by the purge time per foot and flush the sampling line for the number of seconds provided by that multipitcation.
The licensee had not determined the lengths of the various sampling lines in the sample panels. Guidance for minimum flush times for the sample lines was not provided to technicians taking the samples. The inspe: tors noted that a QC audit had also identified this weakness in the sampling procedure.
9.6 Implementation The licensee's implementation of a water chemistry control program during low power testing and post-criticality layups was reviewed.
Licensee sampling / analysis schedules and records were reviewed for technical specification related surveillance.
The plant experience with impurity ingress since initial criticality was also reviewed.
Regeneration and replacement of mixed deionizer resins in the Condensate Demineralizer and RWCU Systems were reviewed. The licensee's development of a trending program for chemical parameters was discussed with Radiochemistry staff members.
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Within the scope of this review, no items were noted.
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10. Measurement Control Evaluation The adequacy and effectiveness of the licensee's nonradiological chemistry quality control program was reviewed against the requirements of Section 6.8 of the Technical Specifications, licensee's Procedure 71.018.01, Revision 6, " General Laboratory Operation," drafts of
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Procedures 78.002.01, 71.012.11, 71.018.01, 72.002.01 and 78.018.02 and standard industrial practices. The Itcensee's performance relative to these requirements and standards was determined by review of records, discussions with licensee personnel and observations by the inspectors.
The laboratory's quality assurance program reviewed by the inspectors showed weaknesses during the 85-40 and 86-03 inspections.
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f The Itcensee had prepared and was using two independent standard solutions for calibration and measurement control.
This affords the licensee a means of cross checking and verifying the integrity of the standard solutions.
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The inspectors reviewed the draft procedures for quality control in the
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- l radiological and nonradiological laboratories. The procedures contain
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preparation and control of lab chemicals, standard and reagent I
solutions; i
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control of radiochemistry laboratory instrumentation
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general laboratory and quality control
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general sampling techniques
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calibration and operation of Eppendorf pipets l
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cht-square test and control chart
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The licensee is in the process of revising the appropriate analytical
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procedures to include a statistical curve fitting method for the i
l calibration curve.
The preparation of the calibration curve is described
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The inspectors reviewed the measurement control charts. Control charts l
were prepared for the following analysis and instruments:
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i Boron - Mannitol Titration i
I Baron - Spectrophotometric i
Chloride - Spectrophotometric l
Chloride - Specific Ion Electrode i
Phosphate - Spectrophotometric
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Silica - Spectrophotemetric (
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Metals (Cr, Fe, Cu, N1) - Atomic Absorption Spectrophotometry i
TOC Analyzer
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Liquid Scintillation Counter
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Gamma Well. Counter Alpha and Beta Proportional Counter G.an. Spectroenvler (PASS)
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The control charts were generated with an acceptance criteria of
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sigma and an unacceptable parameter of 23 sigma. At the last
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i nonradiological chemistry inspection, only one control chart was j
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generated, i
j 11. Analytical Procedures Evaluation i
During the inspection, standard chemical solutions were submitted by the
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I inspector to the Itcensee for analysis.
The standard solutions were
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analyzed by the Itcensee using normal methods and equipment.
The analysis
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l of standards is used to verify the licensee's capability to monitor i
chemical parameters in various plant systems with respect to Technical
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Specifications and other regulatory requirements.
In addition, the
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analysis of standards is used to evaluate the Itcensee's analytical
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The results of the standard measurements comparison indicated that with the exception of one chromium measurement and three chloride measurements using the old meter, all of the results were in agreement under the criteria used for comparing results (see Attachment 2).
The comparison data is listed in Table 2.
The chromium disagreement was due to sampling. During inspection 86-03, the NRC inspector discussed with the licensee his concern with the i
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effectiveness of the voltmeter used with the specific ton electrode for
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the chloride analysis. This analytical procedure is very important because it is the primary measurement in the Technical Specification requirement for determining chloride and is the backup measurement for the in-line chloride measurement for the Post Accident Sampling System
(PASS).
The voltmeter could not determine tenths of millivolts, only i
whole millivolts.
The NRC standards showed that the voltmeter did not have the sensitivity to determine the chloride ion accurately. The licensee had purchased a new voltmeter that was subdivided into tenths of millivolts, but hadn't put it into service.
During the inspection, the licensee calibrated the new voltmeter and analyzed the NRC standards for l
The analytical comparisons were in agreement.
12.
post Accident Sampling Capability - NUREG - 0737: !!.B.3 The adequacy and effectiveness of the licensee's nonradiological post accident sampling and analytical program was reviewed against Section 6.8 of the Technical Specifications, NUREG - 0737:11.B.3, and licensee's post accident procedures.
The inspector submitted standard chemical solutions to the Itcensee for the analysis of boron and chloride using their on-line analyzers and their backup measurement systems for the grab sample, a)
Chloride The system provides for the on-line analysis of chlorides by a Otonex Ion Chromatograph.
The instrument was inoperable at the start of the inspection on July 28. On July 31, the instrument was operable. The licensee calibrated the ton chromatograph with a single point calibration and didn't run a control standard.
The analytical comparisons of the NRC standard solutions were in agreement (see Table 2).
The backup chloride measurement for a grab sample was a specific ton electrode.
The licensee was using a voltmeter that was insensitive and proved inadequate in analyzing the NRC standards.
The meter could not read tenths of millivolts.
The Itcensee calibrated a new meter that proved adequate (see Table 2).
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Boron The system provides for the on-line analysis of boron by an Orion Model 1610 Baron /pH analyzer. At the time of the inspection, the baron analysis, to be performed on the NRC standards, could not be
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demonstrated due to equipment failure. The backup boron measurement ior a grab sample was a fluoroborate selective ton electrode which was also inoperative.
The chloride and boron in-line analyzers are undependable due to the high preventative maintenance necessary.
The primary measurement systems and the backup measurement systems for the PASS will be evaluated using NRC standards at a subsequent inspection (Inspector Follow-up Item 86-11-02).
13.
Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on August 1, 1986.
The inspector summarized the purpose, scope and findings of the inspectio.
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TABLE 1 SHOREHAM CAPABILITY TEST RESULTS SAMPLE IS0TCPE NRC VALUE LtCENSEE VALUE COMPAR1$04 RESULT?. 84 TOTAL MICFOCURIES Simulated Charcoal (Face loaded)
Detector A Cd-109 (2.3720.11)
(2.6520.02)
Ag reement Ce-139 (7.920.4)E-2 (8.620.2)E-2 Ag reement Co-57 (4.020.2)E-2 (4.4010.06)E-2 Ag reement Co-60 (1.0620.05)E-1 (1.1120.01)E-1 Ag reement Cs-137 (1.02tO.04)E-1 (1.0810.0110-1 Ag reement Sn-113 (1.7220.0S)E-1 (1.9120.07)E-1 Ag reement Y-88 (2.6610.12)E-1 (2.72tO.13)E-1 Ag reement Simulated Charcoat (Face loaded)
Detector B Cd-109 (2.3720.11)
(1.9910.01)
Ag reement Ce-139 (7.910.4)E-2 (6.910.2)E-2 Ag reement Co-57 (4.020.2]E-2 (3.6010.05]E-2 Ag reement Co-60 (1.0610.05)E-1 (9.4510.09)E-2 Ag reement Cs-137 (1.0220.04)E-1 (9.18to.09)E-2 Ag reement Sn-113 (1.72to.08)E-1 (1.46to.05]E-1 Ag reement Y-88 (2.6610.12)E-1 (2.3010.07)E-1 Ag reement
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l-TABLE 1 SHCRENAM CAPABILITV TEST RESULTS SAMPLE ISOTCPE NRC VALUE LICENSEE VALUE COMPARISON l
PESULTS IM TOTAL MICROCURIES Simula ted Cha rcoa l (uniformly loaded)
Detector A Cd-109 (2.2920.11)
(2.1520.02)
Ag reement Ce-139 (7.620.4)E-2 (7.210.2)E-2 Ag reement Co-57 (3.9to.2)E-2 (3.6910.05]E-2 Ag reement Co-60 (1.0210.05)E-1 (9.7210.09)E-2 Ag reement Cs-137 (9.820.5)E-1 (9.0920.09)E-2 Ag reement Sn-113 (1.6610.08)E-1 (1.6520.06)E-1 Ag reement Y-83 (2.57tO.13]E-1 (2.3810.09)E-1 Ag reement
I Simulated Charcoat
'
(uniforasy soaced)
Detector B Cd-109 (2.2J10.11)
(2.5410.01)
Ag reement Ce-139 (7.610.4)E-2 (7.210.2)E-2 Ag reement Co-57 (3.920.2)E-2 (4.2010.05)E-2 Ag reement Co-60 (1.0220.05)E-1 (1.0510.01)E-1 Agreement l
Cs-137 (9.820.5)E-1 (1.03to.01)E-1 Ag reement
l Sn-113 (1.6610.08)E-1 (1.7910.05)E-1 Ag reement
!
l Y-88 (2.57to.13)E-1 (2.6910.08)E-1 Ag reement
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I
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-, _ _.
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. =. _ _.
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TABLE 1 SHCREHAM CAPA8tttTY TEST RESULTS SAMPLE ISOTCPE NRC VALUE LICENSEE VALUE COMPARISON PESULTf. IN TOTAL MICROCURIES Simulated Particulate Fi tter Detector A Ce-144 (3.4610.02)E-2 (3.310.2)E-2 Ag reement Co-60 (2.6810.02)E-2 (2.56t0.04)E-2 Ag reement l
Cs-137 (1.5020.02)E-2 (1.3810.02)
Ag reement Mn-54 (1.4710.02)E-2 (1.56to.09)E-2 Ag reement l
Simulated Particulate Filter l
Detector B Ce-144 (3.4610.02)E-2 (3.2520.14)E-2 Ag reement i
l Co-60 (2.6810.02)E-2 (2.3920.03)E-2 Ag reement Cs-137 (1.5010.02)E-2 (1.37to.02]E-2 Ag reement Hn-54 (1.47 0.02)E-2 (1.3520.06)E-2 Agreement l
l l
!
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--,
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TABLE 1 SHOREHAM CAPABILITY TEST RESULTS SAMPtf Efkev)
NRC VALUE LICENSEE VALUE COMPARISON RESULTS IN MICROCURIES CAPHAS PER SECOND Simulated oergas via:
Detector A 186 (160116)
(20523.9%)
Ag reement 242 (340120)
(41212.1%)
Ag reement l
295 (850150)
(97011.3%)
Ag reement I
352 (1640190)
(1890 1.0%)
Ag reement
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!
l l
20TE: At the t.se of this inspection Detector B was not calibrated for the offgas vial geometry.
l l
l l
i ai
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TABLE 2 CAPABILITY TEST RESULTS SHOREHAM Chemical Parameter NRC Value License Value Ratio (Lic./NRC)
Comparison Results in parts per billion (ppb)
Chloride 20.6tl.4 34.4tl.6 1.6710.14 Disagreement (old meter)
69.7t3.0 79.812.3 1.1410.06 Disagreement 27.722.8 42.514.3 1.53t0.22 Disagreement Chloride 20.611.4 22.711.4 1.1010.10 Agreement (new meter)
69.713.0 68.610.4 0.9810.04 Agreement 27.722.8 29.710.2 1.0710.11 Agreement Resultsinpartspermillion(ppm)
Silica 6.5311.03 6.8510.10 1.0510.02 Agreement 11.7010.10 11.3510 0.9710.01 Agreement 11.5020.10 11.2510 0.9810.01 Agreement 0.038 0.045
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-
0.018 0.021
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-
l 0.023 0.020
-
-
l Boron 1014115 99516.0 0.9810.02 Agreement
.
l 50401130 4955127 0.9810.03 Agreement in47 26 2953i22 0.97i0.01 Agrcc=cnt i
i Iron 0.8510.06 0.8010.08 0.9410.12 Agreement 1.5910.07 1.6810.01 1.0610.05 Agreement 2.2910.14 2.5010.03 1.0910.07 Agreement Copper 0.8910.01 0.8610.01 0.97t0.02 Agreement 1.7310.03 1.7710.01 1.0210.02 Agreement 2.5610.03 2.5820.02 1.0110.01 Agreement Nickel 0.8810.11 0.8510 0.9710.12 Ag eement 1.7210.09 1.6910.01 0.9810.05 Ageeement 2.5310.05 2.4410.02 0.96 0.02 Agreement Chromium 0.8010.07 0.7510.01 0.94t0.08 Agreement 1.7910.03 1.5410.03 0.8610.02 Disagreement
'
2.4910.19 2.4310 0.9810.07 Agreement Chloride 1.0310.07 1.0410.14 1.0 Agreement l
(In-line IC 6.9710.30 8.0610.60 1.16t0.10 Agreement ForPASS)
2.7710.28 2.2410.35 0.81i0.15 Agreement
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l ATTACHMENT 1 i
l CRITERIA FOR COMPARING ANALYTICAL MEASUREMENT
!
This attachment provides criteria for comparing results of capability tests and i
verification measurements.
The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.
In these criteria, the judgement limits are variable in relation to the
!
comparison of the NRC Reference Laboratory's value to its associated uncertainty. As that ratio, referred to in this program as " Resolution",
'
increases the acceptability of a licensee's measurement should be more
~
,
selective. Conversely, poorer agreement must be considered acceptable as the
,
resolution decreases.
,
!
]
Resolution 8 Ratio For Agreement 8
!
<3 0.4 - 2.5
4-7 0.5 - 2.0 i
8 - 15 0.6 - 1.66
!
16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25
'
,
>200 0.85 - 1.18 l
8 Resolution = (NRC Reference Value/ Reference Value Uncertainty)
l 8 Ratio = (License Value/NRC Reference Value)
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l
{
t i
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--
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ATTACHEMENT 2 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 Licensee Value (ratio = NRC Value
);
(2) the uncertainty of the ratio is propagated.5 If the absolute value of one minus the ratio is less than or equal to twice the ratio uncertainty, the results are in agreement.
(l1-ratio l s 2 uncertainty)
8 + Sx2 + Sy*
Z= x, then Sz
~F x=
y=
8(From: Bevington, P. R., Data Reduction and Error Analysis for the Physical Sciences, McGraw-Hill, New York, 1969)