IR 05000341/1989023

Insp Rept 50-341/89-23 on 890818-22 & 0901-06.No Violations Noted.Major Areas Inspected:Radwaste Transportation & Chemistry Programs,Including Organization & Mgt Controls, Gaseous & Solid Radwaste,Shipping & QC Programs

ML20248D524
Person / Time
Site:	Fermi
Issue date:	09/25/1989
From:	House J, Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248D523	List: IR 05000341/1989023 ML20248D518
References
50-341-89-23, NUDOCS 8910040304
Download: ML20248D524 (14)

Text

, , s, -

e .

>.

U. S. NUCLEAR REGULATORY COMMISSION.

g1 REGION IIIL

> Report No. 50-341/89023/(DRSS)

Docket No. 50-341! License No. NPF-43 l, Lic'ensee: The Detroit' Edison Company

~6400 North Dixie Highway Newport, MI 48166 Facility Name: Fermi 2-

-Inspection At: Fermi ~ Site, Newport, Michigan-

. 1 Inspection Conducted: August 18-22, 1989 (0nsite)

-September 1-6, 1989 (Telephone Discussions)

T p2

~

. .

Inspectors: .- . aul Dat /AK/87 Date

'

Approved.By: M h r ef 7[ f Radiological Controls and Date Chemistry Section Inspection Summary-Inspection on August 18-22, 1989 (Report No.50-341/89023(DRSS))

Areas Inspected: Routine, unannounced inspection of the licensee's radwaste/

transportation and chemistry programs including: ' organization and management controls (IP 83750, 84750, 84850), gaseous radwaste (IP 84750,84724), liquid-radwaste (IP 84750,84723) solid radwaste-(IP 84750,84850,84722), shipping and transportation-(IP 83750, 84850), audits and apptaisals (IP 83750, 84750,

~84850), effluent reports ~(IP 84750,84723,84724), process and effluent control

instrumentation (IP 84750), primary coolant radiochemistry (IP 84750), reacto systems water' quality control programs (IP 84750), quality assurance / quality control. programs in the laboratory (IP 84750), review of past open items -

(IP 92702) and circumstances surrounding a hot particle even Results: The organizational structure, management controls, staffing levels, and upper management support for the radwaste/ transportation program appeared generally good. The licensee's 10 CFR 61 waste generation, classification,

-and characterization program appears to be good. The plant is co.nlited to 8920040304 890925 PDR

,

'

O ADDCK 05000341 PNU

.

_ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _

n- , . - _

.

Ly 4

.

i a water quality program and monitors chemistry parameters with trend chart . Water chemistry parameters generally have been less than the Owners Group

-. Guidelines during the first part of 1989 and especially during the. current run perio The Chemistry Quality Assurance program appeared to be good.

l'

__ _ __ ._

_-_- _. - _ - _ _ - - - - _ . - . _ .__ .

,,

., R .

DETAILS

~

l'. Person s'Contacte *R.;Andersen, Radiation Protection Manager

• S. Bartman, Supervisor, Radiological Effluents

< *R.~ Baum, Sr.L Radiological Engineer, ALARA

'~

• R..Eberhardt, Superintendent, Radiation Protection'

'*D. Gipson,' Plant Manager-

.

'*L' Goodman, Director, Nuclear Licensing

.

'*E. Kokosky,. Supervisor, Radiation Protection

• J. Pendergast, Licensing Engineer

• T.'Riley, Supervisor,. Compliance

• P.- Schmelzer, Radiological Engineer

• K. Shields, Supervisor, Chemistry

• R.=Smerigan,. Environmental Technician

• Stafford, Director, Nuclear Quality Assurance

• T. VanderMey, Radiological Engineer

~

S. Stasek, NRC Resident Inspector

'The Inspectors also interviewed other licensee personnel in various departments in the course of the inspectio * Denotes those present at the plant exit interview on August.18,198 . Licensee Action on Previous Inspection Findings (IP 92701) (Closed) 0 pen Item (50-341/87047-02): Improve reliability and precision of sodium pentaborate analysis. The licensee acquired a Boron Autotitrator and. achieved agreements.in the three Boron unknowns prepared by Brookhaven National Laborator ' (Closed) Unresolved Item (50-341/88009-5): Evaluation of reactor building noble gas release See section (Closed) Open Item (50-341/88009-04): Elevated background levels

,

on the liquid radwaste discharge monitor. The licensee has revised the post-discharge flushing procedure (POM 23.718.05) to require thorough post-discharge flushes of the entire line. Since the implementation of this requirement, discharge monitor background levels have been reduced significantl (Closed) Open Item (50-341/88020-01): Review of radiological analysis to determine the scaling factor used to meet 10 CFR 61 requirements. The analysis consisted of selected waste streams from the facility and the analysis methodology appears adequat . - _ _ _ _ - - . _ _ _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ - -____ - _ -

_ .

_ _ - _ _ _ _ _ __

.; .

N

. . Management Controls'and Organization (IP 83750, 84750, 84850):

Organization of the Chemistry Section is similar to that observed in

'the_last inspection-report 2 The Chemistry Supervisor had returned to-

-

the laboratory having exchanged positions with-the Project Engineer:for a period of-time for _ cross training. The chemistry group _ had two

'~

engineers who manage the plant. water. chemistry. A chemical. engineer is responsible for plant water treatment, in-line monitors and sampling systems. A project engineer who.had recently completed cross trainin in the laboratory is responsible for a. variety of areas including fuel failure prevention, Lay-up preparation.for the upcoming outage, and lubrication material compatibility with mechanical equipment. The Environmental.Prograr. Coordinator position had recently been. fille This individual-is mpnsible for hazardous. waste compliance, NPDES permit and other ci ciemistry environmental issues. This manegement

structure with Chemi c y a part of the Operations group appears to function well. Assignment of laboratory quality assurance responsibility to a senior technician should improve management in that are Licensee representatives stated that INP0 accreditation of the training program is good for four years. The two year interim report had been-submitted to INP0 for review but a response had not been receive The inspectors reviewed the licensee's organization and management controls for the radwaste and shipping transportation programs, including: organizational structure; staffing; delineation of authority; effectiveness of procedures and other management techniques used to imolement the prograa; and experience concerning.self-identification and. correction of_ program implementation weaknesse .The overall administration of the solid, liquid and gaseous radwaste and radwaste transportation programs are the responsibility of the Radiation Protection Manager (RPM), who reports directly to the Station Manager. Direct implementation of these programs is the responsibility of the Supervisor-Radiation Effluents, who is supported by 4 technical staff members' responsible for shipping / documentation coordination and operational aspects of the liquid and solid radwaste control program .The health physics and chemistry staff provide waste classification, sampling and analysis assistance, as needed. The radwaste systems are operated by the operations department. The overall responsibility for the process and effluent monitoring systems is shared with radiation protection. Calibration and related surveillance for effluent monitoring and control instruments are the responsibility of the health physics staf Management of the Chemistry and Radwaste Groups appeared to be adequat No violations or deviations were identifie Region III Inspection Report No. 50-341/88036

__ -_______-_ _ _- _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ - - _ - . _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ - _ _ _ _ _ _ _ _ --___ _ --_ -

_ - - ._

!s l

.. , Gaseou_s Radioactive Waste (IP 84750, 84724)

The inspectors reviewed the licensee's gaseous radwaste management program, including: changes in equipment and procedures; gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesse Gaseous effluents are exhausted via the reactor and turbine building and SGTS stacks; containment vents and purges are exhausted via the reactor building stack. With the exception of the reactor building (see below), gaseous releases are quantified for noble gas and weekly particulate filter and charcoal samples. Stack tritium releases are measured using a gas bubbler which takes samples from the noble gas port of the stack monitors (SPING-4). Prior to drywell purges, grab samples of noble gas and tritium are collected and analyzed from both the vent stack and containment to verify releases will not exceed the ODCM criteri The Nuclear Data computer program for dose updates and projections is run weekly and before containment purges (more than meeting the 31 day maximum interval for dose projection determination). Releases of each nuclide for the period are computed for determining the gamma air dose, beta air dose, total body dose, skin dose and most. restrictive organ dose for the current period, the current calendar quarter to date and the calendar year to date. For 1989 to date, the total. effluent releases and dose to tne public were computed and are considerably below regulatory limit During a previous inspection (Inspection Report No. 88005) it was noted that the reported reactor building noble gas releases were based on monthly stack grab samples which continuously indicated LLD although the reactor building gaseous effluent monitoring system (SPING) indicated small amounts of gas were being released. As a result, the licensee was requested to perform a review of their program for evaluating, quantifying, analyzing, and reporting of gaseous effluen The licensee's evaluation confirmed that low-level noble gases were being released from the reactor building stack mainly from the off gas system and gland seal condenser exhaust. As a result, the licensee changed the grab sample point to the off gas vent pipe which carries the off gas and gland seal exhausts before their dilution by the reactor

'

building ventilation. Reactor building effluents are now based on the grab samples from that location and reflected in the semi-annual effluent report. The licensee will continue to use those results unless the reactor building stack SPING or monthly grab samples indicate higher noble gas releases. The reactor building gaseous effluent results reported in the last 6 month semi-annual report for 1988 will be revised based on the results gathered from the new sampling poin This matter was discussed at the exit meetin No violations or deviations were identified

--_ _ _ _ _ _ _ _ _

- -_-_-__ -- _ _ - -- _ _-

fi ., * ,

b ' Liquid Radioactive Waste (IP 84750, 84723)

The inspectors reviewed the' licensee's liquid radwaste management program,-

including: changes in equipment and procedures; liquid radioactive waste effluents;for compliance with regulatory requirements; adequacy.of required records, reports and notifications; process and effluent monitors for compliance with' maintenance,, calibration, and operational requirements; and experience concerning identification'and correction of programmatic weaknesse Liquid effluents are batch' released to a monitored release line that

>

. leads-to the circulating water decant line which discharges to Lake Eri The ' decant line provide:: . dilution to assure.that the effluent reaching

.the lake is below MPC for the nuclides released. Most plant liquids, including chemical waste liquids are processed and reclaimed by use o filters, radwaste evaporators, and resin beds. There were seven lake discharge batch releases in 1988 and 3 batch releases during the first six months of 1989 releasing about 45 millicuries (excluding tritium)

r in 1988 and about sixteen millicuries in 1989. No instances of a release exceeding technical specification limits were identified. Licensee'

representatives stated that decreases in liquid effluent releases i and 1989 to date resulted from improved water inventory managemen A larger. inventory than needed was maintained during 1986-87 and excess water was pumped through the radwaste system and discharged into the lake. A plant water balance study and reduction of leaks have contributed to the decrease'in liquid radwaste release Analyses of batch liquid releases include counting a representative sample of the liquid using a Nuclear Data intrinsic germanium system

.to identify and determine the concentration of gamma emitting nuclides specified in Technical Specification Table 4.11.1-1. For' pure beta emitters including strontium-89 and 90, and iron-55, their concentrations are assumed to be identical to the concentrations analyzed in the latest monthly ~ composite samples of batch releases; the composite samples are sent to a contractor for beta analysis. A computer program provides the MPC fraction for each nuclide, the sum of the MPC fractions, the allowable radwaste discharge flow rate, and the setpoint (above background) of the discharge monitor. The maximum dilution flow used for the lake blowdown in the calculation is 20,000 gpm. The maximum release rate from the effluent line is 50 gpm. Selective review of recent release records identified no problems with setpoint determinations and setting To meet Technical Specification 4.11.1.2 surveillance requirements for each liquid batch release, the activity of each nuclide is entered into a computer program which determines the cumulative dose contributions (in accordance with the ODCM) for the total body and any organ for that batch release. The inspectors reviewed discharge records for three batch releases from a waste sample tank and the licensee's methodology for determining the MPC fraction for each nuclide and discharge monitor setpoints. The inspectors independently selected several isotopes listed on one of the discharge batch releases and applied the ODCM methodology to determine dose; no problems were note _ _ ____ _ - -___ - _ _ - _ _ - _

.

.. .

The inspectors reviewed a licensee evaluation which compared the liquid effluent monitor sensitivity values. derived from primary calibration data to values calculated from recent liquid release packages. The results of the evaluation indicated good correlation between monitor response expected from the primary calibration data and that which was observed during actual release. The evaluation also showed the nuclide mix in actual releases was. different from the nuclides used in the primary calibration. As a result, it was recommended that different sensitivity factors in setpoint calculations be used. The recommendations were accepte No violations or deviations were identified Calibrations and Functional Tests of Gaseous, Liquid Effluent Monitors and Area Radiation Monitors (ARMS) (IP 84750)

The inspectors selectively reviewed calibration and channel functional test records for effluent radiation monitors on the liquid system (including the radwaste discharge and circulating water reservoir decant line) and gaseous system (off gas, reactor, turbine, service, radwaste and onsite storage building (OSSF) monitors) and the technical specification area radiation monitors (ARMS). Calibration methods appeared appropriate and met technical specification requirement The liquid monitors were initially calibrated using a single concentration of Cesium-137, Cobalt-57 and Cobalt-60 liquid sources, and response to several different isotopic sources to determine linearity of response and for use in subsequent calibration checks. Subsequent calibrations are performed to verify that response to decay corrected solid sources have remained within an established error ban The initial calibration of the normal and accident range gaseous effluent monitors used several concentrations of different noble gases to establish efficiencies and to demonstrate linearity. At the same time, several solid sources with differing beta energies were counted and efficiencies determined. During subsequent calibrations these solid sources are counted to show that the counting efficiency has not significantly changed over a broad range of energies. Linearity is also verified by counting several sources of a single nuclide with a broad range of activitie Technical specification required ARMS are calibrated pursuant to procedures (NPP 64.080.302-304) using a nominal 100 uCi Cesium-137 sealed source at delivered dose rates of 5 and 25 mR/hr; alarm / trip setpoints are set in accordance with T/S requirements. The output of the source is verified using a Victoreen R-chamber calibrated by the manufacturer annually. Other ARMS are located throughout the reactor facility and have control room readout and annunciator alarm capabilitie The inspector noted the current procedure allows a plus or minus 50 percent tolerance between the "as read" exposure rate and the actual exposure rate. ANSI /ANS 6.8.1-1981 " Location and design criteria for area radiation monitoring systems for light water nuclear reactors"

. - _ _ - _ _ - _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - - _ _ _ _ - - _ _ - _ - _ - _ _ . --___-___-_____-________-_a

_ _ .- - _ - _ - _ . -- -- - -._ _ _ _ - -

.. _ -_ _

.

M . .; .

a (h "

states that the. actual response should be plus or minus 20 percent'of a the actual exposure rate. It was also noted that the non-T/S ARMS had

'

not been calibrated since their original calibration in 1986,,nor were

,

there procedures requiring calibration ~ ANSI /ANS 6.8.1-1981 recommends

'

that annual.or refueling calibrations are desirabl Licensee representatives stated-these calibrations would be reviewed and-tighter standards for replication could be implemente No violations or' deviations were identified Solid Radwaste and 10CFR 61 (IP 84750, 84850, 84722)

The'. inspectors reviewed the licensee's solid radwaste management program,

,

'

including: changes to equipment and procedures, processing, control, and

. storage of solid wastes;ladequacs of required records, reports, and

'

notifications; performance of the process control and quality assurance programs; compliance with' waste generator requirements in 10 CFR 20.311 and 61' including implementation of procedures .to properly classify and characterize waste, prepare manifests, and mark packages; and experience concerning identification and correction of programmatic weaknesse Solid radioactive waste consists primarily of spent resin, filter sludge and-dry active waste (DAW). " Wet" solid wastes are dewatered on site and shipped in high integrity containers (HICs). Dewatering operations are performed pursuant to NRC-approved Topical Reports and a process control program (PCP) which incorporates vendor procedures approved by the license The station initially segregates contaminated and potentially clean dry solid wastes by designating separate waste receptacles throughout the station._ DAW is collected, sorted, and ccmpacted onsite by the licensee and transferred to a vendor for supercompaction. Non-compacted DAW is packaged and shipped directly to the burial site. For waste classifications that cannot be readily measured by gamma spectral analysis (primarily transuranic), vendor derived scaling factors are used. The licensee coll _ects. waste stream samples from RWCU, demineralized and condensate resins, samples of DAW and plant smears for vendor isotopic analysis and scaling factor determination. Liquid waste straam and area smear samples analyzed by the licensee are compared with the latest vendor analyses to determine any significant change. Results of the latest vendor analyses were reviewed by the inspectors; no problems were foun Waste' manifests for radwaste shipments made in 1989 were selectively reviewed and appear to meet 10 CFR 20.311 requirement DAW-curie content is determined using appropriate calculational methods based on surveys performed on the surface of each barrel. Curie content of cask liners is based on batch samples from each effluent stream. No problems were found with curie content determinations The licensee's program for waste classification, form and -characterization appears to be well developed, consistent with regulatory guidance and is being properly implemented. Waste manifest and shipment tracking programs also appear properly developed / implemented and meet applicable regulatory

. - _ . - - _ _ _ ._ . _ _ _ _ - _ _ _ - _ _ _ _ - _ - _ _ _ -

___

.

... .

.

requirements. According to the licensee, no significant problems have been identified with their shipments by the waste burial site-inspector The licensee's waste generator /10CFR 61 classification and characterization program appears.to be goo No violations or deviations were identifie . Effluent Reports (IP 84750)

The inspectors selectively reviewed radiological effluent analysis results to determine accuracy of data-reported in the Semi-annual Radiological Effluent Release Reports for 1988 and 1989 to date. The reports include information required by T/S and Appendix B of Regulatory Guide 1.21, June 1974. As noted in Section 4 of this report, the gaseous effluent dose values reported in the last six month semi-annual effluent report for 1988 will be adjuste No violations or deviations were identified Transportation of Radioactive Material ano Radwaste (IP 83750)

The inspectors reviewed transportation of radioactive materials, including: determination whether written implementing procedures are adequate and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesse Between July 1988 and June 1989, the licensee made about 25 solid waste shipments. The radwaste consisted mostly of dewatered resins transferred to waste burial sites as Class A unstable waste. No problems have reportedly been identified at burial sites with the licensee's radwaste shipment The radiation protection / health physics staff coordinates all radioactive material and radwaste shipments, performs package and vehicle surveys, verifies curie content calculations, determines adequacy of shipping papers and package marking / labeling. Station QA/QC reviews all outgoing shipments for compliance with selected procedures and DDT requirement No violations or deviations were identified 1 " Hot" Particle Event On August 31, the licensee reported an incident involving discovery of a hot particle under the toe of a contract worker's right tennis sho ,

The particle was discovered at about 9:00 AM on August 31, 1989, when I a whole body frisker alarmed as the employee was leaving the RCA. No other hot particles were found during subsequent surveys made of the individual and of the entire Radiation Control Area (RCA).

_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _

- - - ._- - - - _ _ -

.

7 .. ' . . .

l The particle.was analyzed as 0.3' microcurie'ofz cobalt-60 with no other-radioactivity. The calculated dose-(500 millirads) to the small toe l '

assumed 2.75 hour8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> exposure and was consistent with the workers statement that the shoes had not previously.been worn-into the RCA at the Fermi plant. This statement and the absence of any previous cobalt-60 hot particles at Fermi leads licensee representatives to believe that-this particle most likely came from another nuclear

,

statio In discussions with'the licensee and with the inspector, the worker

~

stated that she regularly wore the shoes 1nto the Indian Point 2 plant (but not into the RCA) while employed-there between July 1988 and j February 198 Fermi personnel surveyed the worker's automobile, l' living quarters and contents finding only a slightly contaminated j jacket which had never been worn inside Fermi 2.

l The licensee's RPM also examined the worker's toe and observed no reddening or other_ apparent radiation effect. The worker stated the same thing in discussions with the' licensee and with the inspecto Nevertheless, the licensee arranged for a medical consultant to examine the worker's toe. A licensee representative informed Region III that the' medical consultant's examination conducted on September 12, 1989,

, revealed nothing abnorma The information developed in this review was given to the NRC's Region I office by telephon ' 11. Water Chemistry Control Program (84750)

,-

The inspectors reviewed the water chemistry control program which is based on NPP-CH1-01, Administrative Control of Chemistry Specifications, Revision 0, December 12, 1988, and is consistent with the BWR Owners Group Guidelines (0GG). Trend charts are maintained for a number of l chemistry parameters including those required by the OGG. The plant had been on line for over 150 days and during that time plant water

'

quality appeared to be within the EPRI Guidelines. During discussions, the licensee indicated that maintaining good water quality was a high priority item and the organizational structure and responsibilities of the Chemistry Group reflect _this. The in-line monitoring system is scheduled to be upgraded during the Fall 1989 refueling outage. Water chemistry parameters should continue to improve and will be followed in subsequent inspection The licensee was experiencing high differential pressure problems with the condensate filter-demineralizers. Those units employ porus septa onto which a slurry of ion exchange resin is coated. The problem has  ;

been identified as iron oxide buildup on the septa whicn reduces water flow through the demineralized and increases the differe.ntial pressur A relief valve opens as the pressure drop increases causing water (condensate) to bypass the demineralizers and to be recycled into the l reactor without cleanup. Service life of the precoated filter l demineralized is only a few days as compared with an expected cycle l

- _ _____ __-_ _-_

_ _ _ _ _ .

_

___ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

.. %

time of 20 or more days. Condensate demineralizers are being backflushed and recoated with fresh resin before the pressure drop is sufficient to activate the bypass valv The licensee is investigating this problem. The-source of the iron oxide was not known; however, during the upcoming refueling outage the condenser will be inspected '

for rus The short cycle time of the condensate demineralizers resulted in an increased volume of partially spent resin which must be shipped to a low level storage site and additional resin must be purchase The inspectors discussed several concerns with the licensee including increased solid radwaste volume, possible increased dose from frequent resin changeout and possible increased activation products in the reactor water. Licensee representatives agreed to keep the inspectors informed of progress in this are No violations nr deviations were identifie . Implementation of the QA/QC Program in the Chemistry Laboratory 84750)

The inspectors reviewed the nonradiological chemistry QA/QC progra The licensee maintains statistically derived control charts on which are plotted the mean and standard deviations (12 and 13 S.D.). From a review of selected charts, most analyses appeared to be in statistical control. The chloride assay (Ion Chromatography) appeared to have a low bias and a licensee representative agreed to review the data. These charts are required by POM 71.000.10 (SQ), Calibration of Chemistry Equipment, Revision 5, September 1, 1987. The procedure requires action to be taken at 13 s.d.; however, the licensee is more conservative and repeats the control when it falls outside 12 The inspector noted that these actions should be documented in the procedure listed abov While reviewing the control charts, the inspectors noted that the controls used by the licensee were not independent of the calibration solutions. Although the controls were prepared separately from the calibrators and at different concentrations, their origin was still the same material used in preparation of the calibration solution A licensee representative stated that control material from different manufacturers was being purchased. Implementation of this material will be followed in subsequent inspection The licensee's interlaboratory and intralaboratory comparison programs are defined in NPP-CH1-02, Chemistry Quality Verification, Revision 0, i November 1, 1988. Acceptance criteria for the Intralaboratory i comparison was based on the NRC nonradiological chemistry confirmatory measurements progra NPP-CH-1-02 defines the chemistry parameters that are utilized for technician testing and requires that technicians be tested on a semiannual basis. A review of selected data indicates that this was done. The licensee's interlaboratory comparison program is vendor supplied and has been previously described 2 A licensee representative stated that the laboratory is evaluating a different vendor supplied interlaboratory comparison program that may be better suited to their need Ibid

L-___--____________ -_- ___

. _

_----

, ,

.?; ; ~* / ' p }

hy EA review of selected. data from'the currentfprogram indicated that while'

& _some variability existed between_paralle11 samples of: chloride and~ sulfate-(two different c' concentrations) the results were reasonably good. The

,

.. variability.could be due to minor calibration errors which are common in-f: the Ion Chromatograph. Implementation of: the independent' controls'should .

.

assist in? preventing calibration errors. Also, the vendor fails to supplyLstatistical' data or results-from other plants that participate in the progra This makes. comparisons difficul '

The' inspectors reviewed boron concentration, volume and temperature o 'the Standby Liquid Control'(SLC) Tank. -Technical-Specification 4. requires that the concentration of. boron in the SLC tank be analyzed on a monthly basis.' Data for the first six months of 1989. indicated that the boron / volume parameters were-within T/S limit ~

g '

The licensee has i acquired an autotitrator for boron analyse Three boron unknowns from- !

Brookhaven-National Laboratory (BNL)'were . submitted to the licensee for analysis and_all.were agreements. -.The accuracy and precision of this -l assay is important because T/S limits for the volume-concentration - ,

window in the'SLC tank are narro l No violations'or' deviations were identified.

'

13. Audits and Appraisals' 1 The inspectors reviewed the most recent internal audits; Number 89-0095, Quality Assurance Audit of Chemistry, conducted during March 13-23,-1989, and Number 89-0145, Quality Assurance Audit of the' Radioactive Effluents and Radiological' Material Transfer & Disposal, conducted du' ring May 15-through June 9, 1989. The auditors appeared to address in adequate detail overall plant water systems and the chemistry program utilized to maintain water parameters within Technical Specifications and Owners ;

' Group Guidelines. Audit 89-0095 resulted in eleven observations and one '

deviation event report. The items applicable to the Chemistry Group

-

,

. appear to have been addressed in a timely manner. Audit 89-0145 identified H-12 observations. The audit team appeared to adequately review radiological areas. The licensee' appeared to address identified items in a timely manne No violations or deviations were identifie '

14. 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 are discussed in Section a 1 Exit Interview

The scope and findings of the inspection were reviewed with licensee representatives at the conclusion of the inspection on August 18, 198 The inspectors discussed the Open Items in Section 2, observations on the quality control program, plant water chemistry, SLC tank

' -

-

- __m

. - - . .- ..

.

. .

i parameters and. Boron assay Reporting of revised gaseous effluent releases in the 1988 semi-annual effluent report and the calibration of non-T/S ARMS were also discussed. During the exit interview, the inspectors discussed the-likely informational content of the inspection

.

report with regard to documents or processes. reviewed by the inspecto Licensee representatives did not identify any such documents or processes as proprietar Attachments: Table 1, Nonradiological Interlaboratory Test Results, August 14-18, 1989 Attachment 1, Criteria for Comparing Analytical Measurements (Nonradiological)

!

l 13

=_ ._

_ . _ - -

L' .

.. . .

TABLE 1 Nonradiological Interlaboratory Test Results Fermi 2 Nuclear Generating Plant August 14-18, 1989

'

Analyte a a c Analyticgl NRC Licensee Ratio Comparison Method Y SD X 1 SD Z i SD 12-SD Concentration, ppm d

Boron Titr 1000 1 17 992 i 9 0.992 1 0.019 A 2960 1 40 2919 23 0.986 1 0.015 A 4902 1 76 4912 1 39 1.002 1 0.017 A Value i standard deviation (50); number of BNL analyses is 6 to The number of licensee analyses is Analytical methods: Titr - titration A = Agreement D = Disagreement NRC (BNL) values replaced by mean values of plants in Region II _ _ _ _ _ - _ _ - ._