IR 05000341/1987047
| ML20237C199 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/11/1987 |
| From: | Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20237C195 | List: |
| References | |
| 50-341-87-47, NUDOCS 8712210126 | |
| Download: ML20237C199 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-341/87047(DRSS)
Docket No. 50-341 License No. NPF-43 Licensee:
The Detroit Edison Company 6400 North Dixie Highway Newport, MI 48166 Facility Name:
Fermi 2 Inspection At: Fermi Site, Newport, Michigan Inspection Conducted:
November 16-20, 1987
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Inspectors:
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Date
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.Sc}h{umacher, Chief
/ M,,/( 7 Approved By:
Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on November 16-20, 1987 (Report No. 50-341/87047(DRSS))
Areas Inspected:
Routine announced inspection of:
(1) the chemistry program, including procedures, organization, and training; (2) water quality control prog (rams; (3) quality assurance / quality control program in the laboratory; and 4) nonradiolgical confirmatory measurements.
Results:
No violations or deviations were identified.
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DETAILS l.
1.
Persons Contacted j
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- W. S. Orser, Vice President Nuclear Operations
- W. M.' Tucker, Superintendent of Operations
- M. E. Prystupa, General Supervisor, Chemistry
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- R. Eberhandt, Radiation Protection l
- W. Terrasi, Principal Engineer, Nuclear Engineering
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- T. Dong, Plant Safety
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- G. Shulka, Senior Engineer, Licensing
- K. M. Shields, Chemist J. Kepus, Environmental Programs Coordinator r
S. Bartman, Senior Engineer, Rad Engineering R. Pospiech, Chemistry Specialist R. Nearhoff, Instrument Specialist D. Farmer, GE Chemist Contractor W. Weisberg, Senior Chemistry Technician
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- W. Rogers, Senior Resident Inspector, NRC The inspectors also interviewed other licensee personnel.in various departments in the course of the inspection.
- Denotes those present at the plant exit interview on November 20, 1987.
2.
Licensee Action on Previous Inspection Findings a.
(0 pen)OpenItem 50-341/86027-01:
Licensee to reconsider position on the adoption of the BWR Owners Guidelines after six months to a ear of (commercial) operational experience at greater than 90%
y(The plant is presently licensed to operate at a maxim but
" Water they are effectively followed through Plant Order EFP-1094,is Chemistry Guidelines," Revision 2, November 11, 1987, that consistent with the Guidelines for most plant systems.
At the inspectors' request licensee representatives agreed to consider a more formal commitment to the Guidelines, although not until further operating experience has been acquired.
b.
(Closed)OpenItem 50-341/86027-02:
Licensee to upgrade in-line monitoring equipment in chemistry.
An engineering study has been initiated to estimate the costs of an upgrade to state-of-the-art instrumentation and improved sampling sites.
While this project will improve maintenance and data collection, it appears that the the present system is suitable.
This item is considered closed and
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progress will be followed in the routine chemistry inspections.
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c.
(Closed) Open Item 50-341/86027-03:
Licensee to plot control charts for nonradiological chemistry standards and samples.
The licensee has upgraded and implemented the laboratory QA/QC program and implemented control charts for most analyses, including high level boron by titration; chloride, sulfate and sodium by lon chromatography (IC); silica by UV/ visible spectrophotometry; and chromium, copper, iron and nickel by inductively-coupled plasma (ICP).
This program, still under development, is discussed further in Section 7.
d.
(Closed) Open Item 50-341/86027-05:
Licensee to respond to three chemistry audit findin audit to close out findings.gs (A-QS-P/TS-86-23) and a following The inspectors' review of the findings showed that they had been closed by reclassifying a group of procedures from NS (not safety-related) to SR (safety-related),
adding filtering septa to the demineralizers to reduce resin ingress to the reactor, and improving the use of layup procedures.
3.
Management Controls, Organization and Training The management structure of the Chemistry Group is essentially unchanged since the previous inspection in this area.1 The licensee's chemistry technician training program has been certified by INP0 as of May 28, 1987.
No violations or deviations were identified.
4.
Water Chemistry Control Program The inspectors reviewed the water chemistry control program based on EFP 1094, " Water Chemistry Guidelines," Revision 2, November 11, 1987, and P0M 71.000.03, " Sampling and Analysis," Revision 7, February 26, 1987.
The punt has in-line monitors for measuring conductivity, dissolved oxygen, silica, turbidity, d, the licensee is renting ansodium and tota In addition, during the startup perio in-line ion chromatographic system from GE for the continuous determination of various parameters including chloride and other anions, metals and organic acids.
These monitors are supported with grab samples by the chemistry laboratory.
Water system parameters trended by the laboratory include condensate demineralized influent and effluent conductivity, feedwater conductivity, and reactor water conductivity, chloride and sulfate.
Demineralized resin ingress has been largely responsible for difficulties encountered in staying within technical specification cumulative limits for conductivity and administrative limits for w
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sulfate.
Recent improvements involving reduction in pore size of the septa in the precoat filter demineralizers appears to have prevented resin escape and resulted in improved water quality during the last few weeks of operations.
The licensee is tracking " hours out-of-specification" as a performance indicator.
A review of recent operating data indicated that plant water was currently being maintained at or below Action Level 1 limits.
These trend charts provide valuable information on the performance of the water purification system and should enable the plant to operate within the BWR Owners Group Guidelines to which licensee representatives stated their commitment.
The water quality control program appears to be satisfactory.
No violations or deviations were identified.
5.
Implementation of the Chemistry Program The inspectors reviewed the chemistry programs including physical facilities and laboratory operations.
Housekeeping was good and space appeared to be adequate for the existing workload.
The laboratory was located in the radiologically controlled area of the plant.
Laboratory equipment includes a D1 onex Model 2020i Ion Chromatograph, a Photochem Organic Carbon Analyzer, a Bausch & Lomb UV/ visible spectrophotometer, a Perkin-Elmer Gas Chromatograph and a Leeman Labs Inductively-Coupled i
l-Plasma Spectrophotometer.
Laboratory instrument calibration is described in POM 71.000.10 (SQ),
" Calibration of Chemistry Equipment," Revision 5, September 3, 1987.
Calibration stickers are used on instruments to certify date of calibration and indicate the next calibration date.
A file is maintained for instrument calibration and maintenance.
Reagent preparation is covered under POM 74.000.11, " Reagent Preparation,"
Revision 2, Feburary 6, 1987.
Reagents were pro 3erly labeled with expiration dates and no outdated reagents were o) served.
The inspectors observed a technician analyze the BNL silica samples
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on the UV/ visible spectrometer, and two Specialists analyze other BNL samples by ion chromatography, ICP, and titration (boron).
They
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appeared to be knowledgeable about the work and followed the procedures.
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Overall, the laboratory appeared to be adequate for the proper operation
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of the plant and to be operating satisfactorily.
No violations or deviations were identified.
6.
Nonradiological Confirmatory Measurements The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to various Technical Specification and other regulatory and
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I administrative requirements.
These samples had been prepared, standardized, and periodically reanalyzed (to check for stability) for the NRC by the Safety and Environmental Protec tion Division of Brookhaven l
National Laboratory (BNL).
The samples were analyzed by the licensee using routine methods and equipment.
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The sumples were diluted by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate in a manner similar to that of routine samples.
The results are presented in Table 1 and the criteria for agreement in Attachment 1.
These criteria for agreement are based on comparisons of the mean values and estimates of the standard deviations (s.d.) of the measurements.
Consideration was given to the fact that the uncertainties (s.d.) of the licensee's results were not necessarily representative of the laboratory's because they were obtained by one analyst over a short
]eriod of time.
Consequently if the licensee s.d. was less than that of 3NL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the s.d. of the ratio Z (S in Attachment 1).
z The licensee also prepared two samples to be split with BNL.
To these were added analytes supplied by the inspectors.
Reactor water was spiked with the anions, chloride and sulfate, and samples of feedwater were spiked with copper, iron, nickel, and chromium ions.
The licensee will determine the concentrations of the analytes in each and the results will be sent to Region III for comparison with the values determined by BNL.
This will be followed under the Open Item No. 50-341/87047-01.
The licensee obtained 25 agreements in 27 sets of samales analyzed.
The disagreements were in the intermediate chromium and tie high level silica, which, when the analyst redid them with additional care, were in agreement.
The low-level chloride is a borderline agreement, due to the high variability of the BNL results.
Although the sulfate, sodium, and low-level silica results are in agreement, they showed biases greater than 5%, which, if not corrected, could cause difficulties in subsequent intercomparisons.
The inspectors noted, that while the the boron results were very good, the Specialist took extra care in the analysis and obtained these values only after a second set of analyses.
(After doing some tests with the performance / calibration samples, he decided that the initial results were not reliable, and did not submit them.) The boron analysis is particularly critical because the T/S requirement allows only very narrow limits for the sodium pentaborate concentrations in the Standby Liquid Control Tank, from about 13.0 to 13.8%.
This represents a maximum relative variability of only 93% in the analysis.
Licensee representatives agreed to improve the cred'bility and reliability of the procedure, as demonstrated by control ctart data obtained I;y the regular analysts (Chemistry Technician).
The two-sigma control limits should be substantially less than 'the above 3%, e.g., about 1%, to provide a margin of safety for concentrations near a T/S limit.
Development of this procedure will be followed in subsequent inspections under Open Item No. 314/87047-02.
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Although some weaknesses were noted and further development of procedures and the QA/QC program is needed, the results of this program showed the i
laboratory to be operating well overall.
No violations'or deviations were identified.
7.
Implementation of the QA/QC Program in the Chemistry Laboratory The inspectors reviewed the nonradiological QA/QC program in the laboratory, as noted in Section 2c.
The laboratory had control charts with three-sigma control limits on most analyses, some of which had limited data because they were only recently initiated.
The inspectors discussed some possible improvements with laboratory personnel, including the use of two-sigma warning or control limits to better observe statistical behavior of the control standard analyses, more frequent calculation of variabilities, and the more careful assessment of the charts.
As an example, one chart had several points near the upper (three-sigma) control limit, which indicated a substantial drift in the analysis, i.e., the purely statistical probability of one point being at the limit is a very small 0.004.
The licensee representatives agreed to add the two-sigma lines to the charts, to possibly use them as control limits, and to consider implementing the other suggestions.
Progress in i
this will be followed in subsequent routine chemistry inspections.
The inspectors reviewed the licensee's interlaboratory comparison program controlled by procedure P0M 71.000.04, " Chemistry Quality Verification Program," Revision 3, September 30, 1987.
Vendor-supplied samples (Analytics, Inc.) are analyzed on a quarterly basis.
A review of selected data indicated that the licensee performed well on some analyses, but a number of analytes showed large biases.
Sodium analyses have a bias of 30-60%, low-level boron 110% and copper 82%.
This program is ongoing and the results of more recent analyses have shown improvement.
Performance in this program will be followed in subsequent routine chemistry inspections.
P0M 71.000.04 also covers the technician testing program which is performed quarterly.
Unknowns are prepared in-house and distributed to
the technicians for analysis.
The licensee is developing acceptance
criteria for the technicians' analytical results.
The inspectors
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suggested that a method similar to that used in the measurements program could be used (Attachment 1).
This will be followed in subsequent inspections under Open Item No. 341/87047-03.
The licensee utilized multiple point calibration curves where possible
and incorporated independent controls in all calibration procedures.
Instruments having single point calibrations were tested for linearity within the analysis range.
The licensee's QA/QC program has progressed satisfactorily since the previous inspection and it appears that it will be a good program.
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No violations or deviations were identified.
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l 8.
Audits and Appraisals The inspectors reviewed the most recent internal audit, A-QS-P/TS-87-07, of the Chemistry and Radiochemistry Program conducted during March 10-20, 1987 and April 6-10, 1987.
The auditors appeared to address in adequate detail overall plant water systems and the chemistry program utilized to y$,
maintain water parameters within Technical Specifications and Owners
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Group Guidelines.
Although no findings were made, a number of observations and recommendations were presented in the audit.
Items
pertaining to the Chemistry Laboratory appear to have been addressed in a timely manner.
The audit report indicates that the licensee's mechanisms for responding to audit findings are adequate.
No violations or deviations were identified.
9.
Environmental Monitoring:
TLD Collocated The inspectors reviewed the location of 21 collocated TLD's and determined by physical inspection that all but two were located on the same structure e the licensee's.
The remaining two TLD's were observed to be located a short distance away from the licensee's. Two of the NRC TLD's were missing and will be replaced.
The remaining 19 were oriented toward the plant and appeared to be in good condition.
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Several discrepancies in azimuth and distance between the NRC and the licensee will be resolved by the NRC using updated maps provided by the
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No violations or deviations were identified.
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10.
Open 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 6 and 7.
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11.
Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on November 20, 1987.
The inspectors discussed the Open Items in Section 2 and observations on the quality control program and the confirmatory measurements.
Licensee representatives agreed to modify the QC charts and to consider other modifications of the program, as discussed in Section 7.
The inspectors noted the great progress in the QA/QC program since the previous inspection.
The inspectors indicated that the licensee's commitment to the BWR Owners Guidelines for chemistry should t
l be acknowledged in corporate policy directives.
Licensee representatives
l agreed to consider such a document, although they were reluctant to do so until they haa had experience with the plant in commercial operation.
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During the exit interview, 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 representatives did not identify any such documents or processes as proprietary.
i Attachments:
1.
Table 1, Nonradiological Interlaboratory Test Results, November 16-20, 1987 2.
Attachment 1, Criteria for Comparing i
Analytical Measurements (Nonradiological)
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c, TABLE 1
_N, radiological Interlaboratory Test Results Fermi 2 November 16-20, 1987
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c Analyte AnalysfsDilution NRC Licensee Ratio Comparison Method 1:x Y
s.d.(n) X s.d.(n) Z s.d.
2 s.d.
Concentration, ppb Chloride IC 2000 12.0 1.6 9.63 i O.15 0.799 0.107 A+
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2000 18.7 0.6 19.4 0.35 1.037 0.038 A 3000 26.8 0.73 26.3 0.15 0.981 0.027 A Sulfate IC 2000 10.0 1 0.5 10.7 i 0.2 1.070 i 0.057 A 2000 20.5 i 1.2 22.0 0.3 1.073 1 0.064 A 3000 26.9 1.0 29.4 1 0.25 1.093 0.055 A*
Silica Spec 2000 27.2 1 2.8 7 24.3 0.6 0.893 0.095 A 2000 54.5 1 3.5 7 52.7 0.6 0.967 1 0.063 A 2000 80.0 2.5(7 73.0 0. 0 0.912 0.040 D*
(Repeat)
2000 80.0 1 2.5 (7) 79.7 0. 6 0.996 1 0.032 A
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Fe ICP
489
508
1.039 0.088 A
955 1 34 1005
1.052 1 0.043 A
1470
1473
1.002 0.029 A Cu ICP
468 24 (12) 488 1 5 1.043 0.054 A
966 49 (14)1007
1.042 0.058 A
1450 60 (12)1518
1.047 1 0.044 A Ni ICP
509
495
0.973 0.051 A,
1020
979
0.960 1 0.029 A
1530
1510
0.987 i 0.027 A Cr ICP
510 30 (7)
514
1.007 0.061 A
941 30 (7) 1061
1.128 0.048 0*
1430 80 (7) 1526
1.067 0.061 A-(Repeat)
941 30 (7)
931 1 14 0.989 0.035 A Na IC 1000 4.58 0. 5 6) 5.40 1 0.20 1.179 0.136 A 1000 9.23 0.8 6) 10.4 0.5 1.127 0.117 A 1000 14.4 0.8 6) 15.4 1 0.15 1.069 0.060 A
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k Concentration, ppm Boron Titr
1000 1 10 1002.5 1 2.2 1.002 0.010 A
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3035
1.004 0.016 A
4947 61 7)4928 1 10 0.996 0.012 A l-l a.
Value standard deviation (s.d.); n is number of BNL analyses.
The number of licensee analyses is 3.
b.
Analytical methods:
IC - Ion chromatography ICP - Inductively-coupled plasma Spec - Spectrophotometric Titr - titration c.
A = Agreement A = Disagreement D
= Borderline Agreement
- Substituted the BNL uncertainty for licensee's uncertainty.
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ATTACHMENU Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing resuits of the capabilit The acceptance limits are based on the uncertainty (standard deviation) y tests.
of the I
ratio of the licensee's mean value (X) to the NRC mean value (Y), where (1) Z = X/Y'is the ratio, and (2) S is the uncertainty of the ratio determined from the pfopagationoftheuncertaintiesoflicensee'smeanvalue, S, and of the NRC's mean value, S.1 Thus, x
y S2
32 Z2- ~ Y2- + 1, so that z _ x p
= Z *.(S*2S2f
+1 S
{X2 y2)
I The results are considered to be in agreement when the bias in the ratio (absolute value of difference between unity and the ratio) is less than or equal to twice the uncertainty in the ratio, i.e.
I 1-Z l 1 2*S7 1.
National Council on Radiation Protection and Measurements, A Handbook of Radioactivity Measurements Procedures, NCRP
- Report No. 58, Second Edition, 1985, Pages 322-326 (see Page 324).
4/6/87
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