IR 05000344/1989007
| ML20244B283 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/23/1989 |
| From: | Garcia E, Hooker C, North H, Russell J, Tenbrook W, Witt F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20244B271 | List: |
| References | |
| 50-344-89-07, 50-344-89-7, IEIN-87-020, IEIN-87-20, IEIN-89-044, IEIN-89-44, NUDOCS 8906130053 | |
| Download: ML20244B283 (30) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-344/89-07
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Docket No. 50-344
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License No. NPF-1 Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 l'
I Facility Name:
Trojan Nuclear Plant
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Inspection at:
Rainier, Oregon.
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Inspection Conducted:
April 17-21, 1989 M////
Inspectors:
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H.'S'.
North, Senior Radiation Specialist Dat6 Signed-Team Leader, Region V~
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F. J. Witt, Chemical Engineer,.ECEB, NRR Date Signed Mk s% m C. A. Hooker, Radiation Specialist, Date Signed
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$*-/1 ' O gJ^Russei'1, Radiction Specialist.
Date Signed Region V
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W. K. TenBrook, Radiation Specialist.
Date Signed hegion V Appioved by:
./F eme fi/2f/8f
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E. M. Garcia, Acting Chief Date Signed Facilities Radiological Protection Section Summary:
Inspection on April 17-21, 1989 (Report No. 50-344/89-07)
Areas Inspected:
Special unannounced team inspection of plant chemistry related areas, including organization and management, quality assurance, training and qualifications, water chemistry control and analysis, facilities, systems affecting plant chemistry, confirmatory measurements of radioactive kk
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-2-l and nonradioactive species, and post accident sampling.
Inspection procedures 30703,'79501, 83722, 83723, 83727, 84750 were addressed.
Results:
The licensee's programs were capable of meeting their safety
.. objectives.
Particular strengths that were noted included a capable and dedicated chemistry staff, an effective radiochemical measurements program supported by a good ouality control and assurance program, and an excellent erosion / corrosion control program. Weaknesses identified includod, surveillance activities in the chemistry area; the absence of a quality control program consistent with industry standards for the nonradioactive measurements program; the control of chemicals for plant use; and the storage of high pressure hydrogen and nitrogen on the roof of the control building.
No deviations were identified.
In the eight areas addressed, one unresolved item related to the storage of hydrogen gas was identified (Report Section 8).
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DETAILS 1.
Persons Contacted
- D. W. Cockfield, Vice President, Nuclear
- C. P. Yundt, General Manager, Trojan Plant S. Anderson, Hazardous Materials. Specialist
- S. A. Bauer, Manager, Nuclear' Regulation Branch G. M. Crowley, Chemistry. Technician G. Davis, Chemistry Technician
- N. C. Dyer, Health Physics Supervisor
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F. E. Dyson, Chemistry Technician A. Friberg, Manager, Procurement Engineering Branch M. D. Gatlin, Materials Supervisor
- J. D. Guberski, Compliance Engineer
- M. W. Hoffmann, Manager, Mechanical Engineering Branch K. Hukari, Systems Engineer G. J. Kent, Supervising Engineer,' Surveillance and. Test Engineering G. C. Kernion, Laboratory Supervisor
- J. W. Lentsch, Manager, Personnel Protection
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K. ' L. Neese, Secondary Chemist
- S.~B. Nichols, Manager, Training Branch
- D. L. Nordstrom, Manager, Quality Assurance J. N. Puckett, Unit Supervisor, Support' Group (Training)
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- J.'D.'Reid, Manager, Plant Services R..Reinhardt, Fire Protection Supervisor.
- A. D. Rice, Laboratory Supervisor-
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- ~G. L. Rich, Manager, Radiation Protection Branch (Trainee)
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, * J.lA. Russell. Supervisor, Quality Audits
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- R.lP. Schmitt, Manager, Operations and Maintenance
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- M.'H. Schwartz, Manager, Surveillance and Test Engineering Branch D. S. Seely, PSE Supervising Engineer
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M. Snook, Minager, Quality,$upport Services Branch
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L. D. Sojka, Surveillance and Test Erigineering
- C. Sprain, Manager, Chemistry Branch
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- D. T/. Swan, Manager, Technical Services T.1Tidymann, Chemistry Technician
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L. Timme, Chemistry Technician ~
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W. VanDusen, Chemistry Technicien
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- * T. D. Walt, General Manager, Technical Functions
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P. L. Wilson, Procurement Clark G. Zielinsky, Effluent Analyst (*) Denotes persons attending the exit. interview.
In addition to the individuals identified above, the inspectors met and held discussions with other members of the licensee's staff.
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NRC Personnel Attending the Exit Interview G. P. Yuhas, Chief, Emergency Preparedness and Radiological Protection Branch, Region.V
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~ R. C. Barr, Se,'or Resident Inspector, Trojan H. S. North, Senior Radiation Specialist, Region V, Team Leader F..J. Witt, Chemical Engineer, ECEB, NRR C. A. Hooker, Radiation. Specialist, Region V
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J. E. Russell, Radiation Specialist,' Region V L
W. K. TenBrook, Radiation Specialist, Region,V
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_NRC Contractor Personnel g
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j 3 Sujit Banerjee; Ph.D., Group Leader, Analytical and Environmental Chemistry,.Brookhaven National Laboratory 2.
Organization"and Management (8372'2) ~
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The licensee organization and staffing, with respect to the chemistry staff, was consistent with Technical Specifications (TS) Sections 6.2 l
ORGANIZATIONAL REQUIREMENTS.
The' Branch Manager, Chemistry reports to the Manager, Person'el Protection, who in turn reports to the General n
L Manager.
The staff includes two ' Laboratory Supervisors with an authorized staff of 14 Chemistry Technicians (CT), with one vacant position. The staff also includes a Project Engineer, an Effluent Analyst, a Hazardous Waste Coordinator, and supporting clerical staff.
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The position of Chemist, Nuclear Plant, was' vacant at the time of the inspection.
The'two vacant positions had resulted from internal
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promotions.
All personnel were permanent staff.
The level. of staffing appeared appropriate for the existing work load.
i It was noted however, that the licensee's staff commitment to an internal quality' control program was minimal.
However, the recently created position for a second Laboratory Supervisor was in support of a Chemistry Quality Control Program.
The quality control program.is discussed in a later section of the ra90rt. When the licensee inplements a quality control program, it may be necessary to augmeat the staff.
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Discussiun with the staff established that the licensee had not prot 6ulgated a formal statemeat of policy with respact to, a commitent to chemistry contrcl.
A memor andum, dated liay 17., 1985, Orser to Lentsch, Subject: "PGE Response to NRC Staff Recommended Actions Stemming From Tt.e l
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. Integrated Program For The Resolution of L'nresolved Safety Issues
tl Regarding Steam Generator Tube Integrity (Generic Letter 65-02),"
addresses the secondary water themistry program in memoranoum paragraph j
3. A.
The memorandum notes that Trojan implemented the steam generator owners' group PWR Secondary Water Chemistry guidelines shortly after
publication in October 1982, with one exception.
Power is not reduced to j
30% if dissolved oxygen exceeds 10 ppb for 7 days due to the resulting difficulty in identification of condenser air in leakage.
The licensee has established Annual Objectives for the Personnel Protection organization including chemistry.
These goals included:
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Zeroi startup holdsMor' power reductions attributable to' chemistry?
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controls;
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- Reduceisteam generator sludge and integrated contaminant levels to?
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less;than 1988 levels;.
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y, Reduce reactor coolant source term a measurable amount by Li/ Boron
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occordination and new filtration technology;-
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blind standards outsidel acceptable' ranges; Improve laboratory l quality, control, with fewer than ten percent 'of
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f t-s No outage delays'due to'high radiation ~1evels in refueling water;<
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Maintain.an average condensate oxygen level at less than 3 ppb; and
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' Maintain effluent releases at less than 450 Ci of noble gas, less
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F than 0.004 Ci of gaseous iodine and particulate, and less than 0.25
- Ci of liquids.
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Ba' sed on.a review of the " Quarterly Review 'of 1989 Annual Objectives,"
the^1icensee was apparently effectively. addressing the annual objectives.
- Monthly Chemistry Reports appeared to be an effective tool for maintaining awareness of current status by the on-site and corporate management, including theLVice President, Nuclear, of problems and
" < qcorrective actions taken during the month, and achievement of established q goals for the Chemistry and Radiochemistry Control Programs.
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..The licensee had a program in place'for and was tracking' response to.the
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October 1988 INPO Evaluation.
The. areas addressed included: increased
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! monitoring'of routine chemistry by management and supervisory personnel
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,.and layup chemistry control.
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LThe111,censee]s organ'ization and managuent controls appearec to be t
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"i adequate to*r:eet their safety objectives.
No vioutions or deviation g[]. - F'[#
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Trainingar#Requalification(83723)
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- 4 Th[ licensee's training program was accredited by INP0 in December 198h g
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,sAs'a part7pf the accreditation process a job-task-analysis was performed.
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When ttie program was initially implemented, the qualifications of all
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f technicians' we,re evaluated by their supervisors and they were placed in
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the program at~ the'. point where remedial training was appropriate.
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basic chemistry technician training program was specified by Training
y (AdministrativefProcedure (TAP), TAP-401,' Chemistry Technician Replacement f Training Program.
Completion of the entire program requires from 3 to 6 months.
Due to the small size of the technician staff and the stability of the technician work force, training is^ accomplished largely through supervised self study.
The training includes General Employee Training
. (GET), fundamentals and specific duty area training.
Certain portions of the fundamentals training can'be bypassed through the use of a pretest on che subject matter.
Pretesting is not used to waive training that is t
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plant specific in nature.
The. laboratory and ' job performance aspects of-training were accomplished through on-the-job training"in plant.
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Performance on the classroom /self study portions,of the training is evaluated by means of examinations, 70% passing, on-the-job training is r-evaluated by oral examination and practical demonstration.
4.
The retraining program was described in TAP-403,' Chemistry Technician Retraining Program.
Trie retraining program requires three days of
participation per quarter except in the quarter including the annual
refueling outage, or a total of nine days.
The content of the retraining
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program is determined by a retraining committee consisting of a laboratory supervisor, a training specialist and representatives from the technician work force.
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i Technical Staff / Technical Manager Training Program, TAP-603, makes provisions for training-in reactor plant chemistry, at the discretion of
the individuals supervisor..The generally applicable curriculum includes
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GET, administrative, systems, systems engineering and a classroom lecture i
series.
The licensee had included MORT training for managers,
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supervisors, system engineers and certain corporate staff members.
l A new training facility had recently been completed on site.
The facility provided space for a chemistry laboratory training facility.
At j
the time of the inspection this facility was incomplete.
The licensee's training staff stated that completion of this portion of the facility could be significantly delayed due to the high cost of completing and equipping a chemistry laboratory.
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.The licensee's training program appeared to provide the support to the chemistry program necessary to meet.the programmatic safety requirements.
No violations or deviations were identified.
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4.
Quality Assurance (DA) (83722, 83723 and 84750)
The licensee's Nuclear Quality Assurance Department staff had been relocated from the corporate office to the site. Within the Quality l
Operations grtup, the Quality Audit group with a staff of six, had l
resporsibilit.,, for quality audits, performance and corepliance.
Audit j
frequency was specified in NQA?-117.
n matrix in the hQAP identffied
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those portions of the QA prograta possibly applicable to an audit of
chemi t,try.
Tht: audit frequency specified. for chemistry was once every 24
months.
In addition, Technical Specification (TS) audits were conducted
at 6 month intervals.
The NQAP snecifi u that TS audits ere to hs
conducted at 12 month intervals. The TS audits may or m0y not aoJress chemistry specific items in any particular audit.
The most recent audit of chemistry was conducted June 29 through July 6, 1987.
This audit included a chemical engineer from the PGE staff as a i
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specialist auditor.
This individual did not have responsibilities in the area or organization being audited. The Quality Audit Supervisor stated that special arrangements for the use of specialists from other utilities was being explored for some audit activities. The advantages of
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including such specialists in the next audit of chemistry were discussed.
The 1987 audit, PGE QA Audit of Trojan Chemistry Activities, RCJ-319-87,
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dated August' 4,1987, was' reviewed, as well as the Audit Checklist-Q Review, AP No. 497..The audit resulted in the issuance of 2 Nonconforming Activity. Reports (NCARs) and'nine recommendations. The 2
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'NCARs addressed the use of a chemical beyond it's designated expiration date, and control of industrial chemicals and materials for use onsite...
-The audit report commented, under the topic Labcratory Quality Control.,
"It was determined that Trojan Chemistry performs-some spiked sample
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analyses but does not have an established program which identifies-frequencies, sample types, etc.
It may be in Trojan's. interest to establish such a pregram as recommended in INPO Good Practice CY-702."
The QA organization performs surveillance which are less formal than the audits.
Documents recording these surveillance, '.'1988 Surveillance -
Reports P 176 (June 1988) to current," and-" Logs,"'were examined.
No surveillance in the area of chemistry were identified..The advantages
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of frequent, short, spot check type surveillance activities were discussed with the Quality Audit Supervisor and at the exit interview.
QA Evaluation of Contractors'/ Suppliers' QA Capabilities dated July 20, 1988, and attached QA Audit Report No. QSD-87-2162; supplied and performed by the Northeast Utilities Service Co.(NUSCO); were reviewed.
The evaluation was performed by the PGE QA Department to verify that a vendor had established and had effectively implemented a QA program to control-the manufacturing and suppling of nuclear grade resins purchased by the licensee. The PGE QA evaluation included a review of the vendor's QA Manual and the NUSCO QA Audit Report in accordance with licensee procedure NDP 300-2, Selection of Procurement Sources.
The NUSCO QA audit was conducted on October 21, 1987, and included the review of the vendors QA manual, quality and analytical procedures, and inspection of manufacturing and laboratory facilities.
Particular emphasis was placed on product traceability by the auditor.
No findings were issued as a result of the audit. The auditor determined that the vendor had established and implemented an adequate QA Program to control the manufacture and supply of nuclear grade resin.
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The licensee's QA audit program met the req 11rements of the quality
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assurance plan however the program lacked the strengths provided by an effective surveillance program in the area of chemistry.
5.
Review of Analytical Capability (79501 and 84750)
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perfor: nance with regard to standards provided by the NRC, the adequacy of
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procedures and instrumentation, the proficiency of the technical staff,
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.the extent of management support, and the level of the Quality Control
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l (QC) and.the Quality Assurance (QA) program.
Performance was evaluated based-~on generally accepted standards in the nuclear power industry, and A
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on guidelines established by the National Institute of Standards and
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Technology'(NIST), formerly the National Bureau of Standards, and other i
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A.
Measurement Control Evaluation Discussion with Chemistry Department Management revealed that a a
procedure for measurement control-was not in place.
As a result, the licensee.had no means of verifying that results were within a defined range of analytical uncertainty.
Most of the instrumentation was calibrated monthly with a functional check performed weekly.
This frequency was well below industry standards.
In addition, one point calibrations were used, this practice transfers errors associated with that one point to subsequent analyses based on that calibration.
Specific procedures for each laboratory operation were in place, however,.the detail did not appear sufficient for operation of the ion chromatograph (IC) and the inductively coupled plasma spectrometer (ICPS).
For example, sample chromatogram were not included in the IC operating procedure.
Also, the calibration procedures for the ICPS were complex but were not discussed and illustrated,
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in general, the training received by the analysts appeared to be Edequate. The analysts were observed to conduct the analyses required of them in a proficient manner in accordance with procedures.
The licensee ~ appeared to normally assign one individual to a piece of equipment'when it was first received.
The individual then familiarized himself with the equipment and wrote a procedure which was independently verified.
The first; individual then trained others in the, use of the ' equipment.
However, no formal " checkout" sequence,'which included the determination of detection limits, precision and accuracy, was conducted.
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B.
[hemistry Quality Assurance (QA) and Quality Control (QC) Program The QC 'rogram consisted of vendor The QA/QC program was, reviewed.
p supplied blind samples which were analyzed approximately once per quarter and supervisor prepared blind standards which were analyzed eight times per year.
The QA program consisted of a biennial audit of Chemistry Department activities by the OA organization.
The last audit; #RCJ-319-87, dated August 4, 1987, was reviewed.
Personnel performing the audit appeared to be qualified in accordance with the requirements of f.NSI/ASME N45.2.23-1978, qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants.
This audit is addressed in report section 4.
The results of vendor supplied blind sample analyses were reviewed
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for the last three calendar quarters.
Numerous examples of a lack
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of agreement between Trojan analyses and vendor values were noted.
These and other problems, as noted in this report section, indicated the need for a more circumspect QA/QC program for water chemistry.
It was noted that a program along the lines of that detailed in Quality Assurance of Chemical Measurements, by John K. Taylor, l:
Ph.D., and as employed by gther nuclear utilities would be effective in alleviating the performance problems identi.
.d herein.
This was
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brought to licensee management attention during the course of the
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fnspection and at the exit interview.
The Personnel Protection
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l Manager and the Chemistry Manager stated that they had.been
considering and planned development and implementation of such a l-program.
It..was noted however that the implementation of such a program would take a considerable time, perhaps greater than a year.
This matter is considered an Open Item (50-344/89-07-01).
The licensee's non-radiological QA/QC program appeared weak to the
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point that the defensibility of data generated by the laboratory was questionable. The licensee's QA office did not involve itself in
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chemistry QA, beyond the biennial audits which were conducted.
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Procedures were not QA approved and record keeping appeared to be i
inadequate.
For example, the parar9eters used to calibrate the ICPS were.not retsined after the analyses, and it'was, therefore, t
E impossible for an' auditor (or even the supervisor) to' judge the l
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manner in which the' procedure was conducted.
Chromatogram
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generated by the ICs were not retained and were not inspected.
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routinely by.the supervisor.
As a result, the supervisors were not
in a position to comprehensively review the results.
i C.
Laboratory Capability Test.
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. Certified standards, prepared by Brookhaven National Laboratory (BNL), were provided to the licensee for analysis in accordance with standard licensee procedures.
Each analyte was provided at three.
concentrations, and it was requested that each determination be made
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three times.
A ratio was calculated for the licensee's value to l
that of BNL, and the two values were considered to be in agreement if the ratio equalled one within the uncertainty of the ratio.
This
uncertainty was obtained as
+ [BNL 2[(o c
!O" Lic where "Lic" and "BNL" are the licensee and BNL values respectively,
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and o is the associated standard deviation.
i The results of the evaluation are provided in Table 1.
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Disagreements were noted for fluoride and ammonia and for the chloride analysis in the PASS matrix.
The PASS matrix censisted of l
a mixture of various ions designed to simulate a possible post accident primary sample in chemical composition, which in addition I
contained standard samples of chloride and boron.
The PASS matrix was described in Appendix 2 to the paper entitled, Requirements for Post-Accident Sampling and Analysis, presented at the 1983
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winter meeting of the American Nuclear Society; San Francisco,
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When the licensee first analyzed the fluorides, the results were 26-33% higher than the certified values.
The inspector pointed out l
that the disagreement probably originated from a deteriorated standard.
The licensee conducted a rerun with a fresh standard, and I
the results were low by 13-17%.
These large changes (of 40-50%)
appeared to reflect the use of a single point calibration.
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s The ammonia results were systematically biased from -8% to +21%.
The inspector pointed out that the. systematic bias was symptomatic of an altered electrode response.
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The chloride determination in'the PASS matrik was low by 42%.
The inspector pointed out that the' deviation could have originated from an altered electrode, response.
The. licensee reran the analysis-using'a. standards-addition method recommended by the inspector which was not in accordance with the approved procedure,.and was able to obtain an acceptable ~ result' using this'. revised, technigue.
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TABLE 1
- iANALYTICAL' CHEMISTRY $RESULTS w
AGREE /
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ANALYTE 8NL value a
LIC.value o RATIO DISAGREE hydrazine P 19.9 0.3'
1.011.04 A
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Q 49.9 0.5
1.001.03 A
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R 100
101 1.011.03 A
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lithium J
.19.7 0.4 21.1 1.071.03 A
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K 30.0 0.7 31.1 0.4 1.041.03 A
L 41.3
39.9 0.971.04 A
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ammonia M
0.52 0.03 0.48 0.02 0.921.14 A
H 1.51 0.02 1.56 0.04 1.031.06 A
2.46 0.12 2.97 0.06 1.211.11 D
silica S
52.8 2.8 48.3 2.1 0.911.14 A
T 104
94.3 2.1 0.911.09 A3 U
157
145 2.1 0.921.04 A
fluorida A 22.5
30.0 0.5 1.331,18 D
B 42.3 0.4 54.2 2.6 7.281.10 D
C 82.8 1.7 104 2.2 1.261.06 D
chloride A 22.5
19.9 0. 9 0.881.20 A
42.3 0.4 40.7 0.0 0.96?.04 A
C 82.8 1.7 86.2 0.65 1.041.04 A
sulfete A
19.6 1.4 19.7 0.4 1.011.15 A
F 38.3 2. 7 39.3 1.5 1.031.16 A
C
2.3 81.3 0.7 1,041.06 A
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iron G
186
198
1.061.05 A
l H
398
401
1.011.03 A
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I 585
591
1.011.05 A
copper G
200
193
0.971.04 A
H 403
385
0.961.07 A3-I 600
566
0.941.05 A
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boron D'
l'040.
985
0.951.02 A
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3089'
' 41 2930
0.951.03 A
g/
F, 5000.
.4839
0.971.04 A
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sodium J
24.2 2.8 19.3 0.6 0.791.24 A
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. 42.4 2.4
1 1.011.12 A
K
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L; ' 63.2 3.6
1.01.11 A
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fluoride A 22.5 2'
18.8 0.841.28 A
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B-42.3
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0.871.03 D
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C 82.8 1.7
-
0.831.06 '
D I
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PASS B
2040'
1952-
0.961.09 A
L
.C1 56.4 1.3
.32.9 5.2 0.581.32 D
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C1 (rerun)
56.7 5. 8 1.011.21 A
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Values are in ppb except for silica, boron and. PASS / chloride whi,ch are in ppm.
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BNL's uncertainty was assigned to the licensee value since the licensee only made one determination.
'3 These are technically disagreements; however, in the inspector's opinion the disagreement was too small to be of concern.
The above noted differences appeared symptomatic of the weakness of the QC program.
Standard practices, generally accepted throughout the nuclear industry, are to: perform multi point calibrations vice one point calibrations; run independent standards daily or prior to each application of a procedure; prepare and utilize control charts with 2a warning and 3o action levels; recognize and expeditiously address trends and biases; and calibrate analytical balances more frequently, functionally checking them prior to each analytical standard preparation.
It is also standard practice to maintain records of instrumental traces, calibration curves.and all other parameters necessary for reconstruction of measurements and for supervisory uview on a day-to-day basis.
Additionally, new procedures and equipment customarily undergo extensive review to develop arid document sensitivity, precision and accuracy data prior to the implementation of their routine use.
The resul's of this portion of the inspection were discussed with the chemistry staff during the inspection and at the exit interview.
It appeared that, in spite of the concerns identified, the licensee's program we capable of meeting it's safety objective.
No violations or deviations were identified.
D.
Analytical Procedures (79501)
~
Current copies of various chemistry procedures were reviewed.
Written procedures appeared to have been established, implemented and maintained in accordance with the requirements of TS 6.8,
.
,
,
Proceduros and Programs, and prepared, reviewed and approved in
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7.
accordance.with the requirements of TS 6.5.3, Technical Review and
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Control... It'was noted 'that Chemistry Procedures no longer require a i
review by the QA organization and the-Chemistry Manager _ stated ~ that" W
such' reviews had been discontinued in about 1982 as there was no one-i
- in the QA organization with the expertisetto perform an adequate review; The inspector noted that, although not required by the TS,
<
the procedures would clearly benefit from an _ independent review and
' approval, and that, had such a review been in place, some of the-QA rand QC problems, identified in-this report section may have'been identified and corrected.
.
The' analytical procedures and instrumentation appeared to be-
adequate to;the performance of chemical analyses at a level of sensitivity and with sufficient, although questionable, accuracy in
..
accordance with the recommendations of the Electric Power Research
" Institute (EPRI) in PWR Primary Water Chemistry Guidelines, Revision 1. and PWR Secondary Water Chemistry Guidelines,. Revision 2.
Also, it was noted during the-review of the vendor manuals for the ICs'and ICPS, and verified during discussions with-the chemistry supervisors, that the software ' associated with these complex devices.
had not been validated and verified.
The use of computer codes which have not been validated and verified can lead to the-
,
introduction.of significant errors into safety related analyses.
,This was brought to licensee management attention-during the i
'
inspection and at the exit interview.
'
E.
Facilities and Equipment (83727 & 79501)
The facilities and equipment of the primary and secondary chemistry c
laboratories were reviewed.
Adequate work space appeared to have been provided in the laboratories.
Fume hoods in each appeared to provide sufficient work space.
Ventilation rates.in the hoods were measured monthly and recorded on logs attached to the hood.
The laboratories had state-of-the-art equipment including three Dionex ICs; a 2000 series in the bot 1sb; a new 4000 series in the cold lab'
~
and a new 8000 series in the cold lab,-which had not been put into servicec ~ and a new Lemman ICP3, Laboratory safety appeared good.
analysts ware observed wearing protective clothing and equipment
~
during procedures.
Contaminated sinks.were posted; dose rates were
at a background ' level and. shielding materials were available to reduce dosi rates from hot samples.
I
Laboratory' chemical' stocks were reviewed. 'All appeared to be of reagentigrade and appropriately rarked with expiration dates. When
~
questioned, the laboratory supervisors stated that no receipt analyses or quality' checks were performed on the reagent grade chemicals used'as standards in the' laboratories.
Select Standard Preparation Records were reviewed forlthe period 1988 to date and appeared complete and correct. The Chemistry Manager stated that all reagents were'given a shelf life of 5~ years unless known to be
-
more unstable.
During a tour of the secondary laboratory, it was noted that'a prepared standard of 0.2 N sulfuric acid, in a flask with an attached burette, had an expiration date of January 1992, 5 years from the date of preparation.
It appeared questionable whether a standard solution of sulfuric acid could be expected to j
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hygroscopicity. This was brought to the Chemistry Manager's'
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attention,"and he stated that he would. review the matter.
Other h-than this particular. item, all other reagents and standard preparations appeared to be properly stored and protected from contamination.
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Select' calibrations of laboratory balances'were reviewed for the l'
period 1988-to.date.. It was-noted that'the balances'are' calibrated.
L by a vendor once a year andfare functionally checked quarterly in L
accordance with licensee procedure CL-100, Mettler Balance Calibration Procedure.
Standard industry practice would require.
.,'
- that,the balances be functionally checked prior to each weighing
'
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with a certified weight. This was brought to the Chemistry, Manager's. attention and he stated that he would reexamine'the
'
e matter.
"
The hazardous material control program was discussed with the site-Hazardous Materials Specialist.
He stated that the site program.for control of hazardous' materials is not implemented for the chemistry.
- laboratories as the analysts are considered capable of controlling these hazards within the laboratories.
The analysts' participate in the. yearly General Employee Training which contains some material.
twith regard to the hazardous material program and they occasionally.
& o./
receive a presentation onihazardous materials during their quarterly retraining.
~
No changes in facilities'or equipmentLwere noted which would t
necessitate a review in accordance with the requirements of 10 CFR 50.59.
.
,
.
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The licensee's; program appeared adequate to meet their safety objectives.
No violations or; deviations were: identified. A 6.
Plant Systemd Adfectihg Plant Cheniistry 79501, 84750-
.
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At'the time of3 this inspection the Trojan Nuclear Plant was shut down for maintenance and refueling. 'In general,'the chemistry program has been effective in preventing degradation' of the. primary coolant pressure
"
boundary from both the-reactor; coolant and' secondary coolant sides. The
,
licensee is implementing the latest EPRI initiatives to optimize chemistry control to ininimize corrosion and the buildup of radioactive corrosion products., Materials have.been replaced, long term inspection o
' programs have been' instituted, and chemical treatment programs have been
.
implemented to minimize corrosion and its effect on performance of safety-related equipment.
A.
~At the beginning of each shutdown, the licensee adds about 1 ppm hydrogen peroxide to the reactor coolant to promote a forced
,
i oxidation of the deposited crud.
When the peroxide is injected, the purification system flow is maximized at 90-110 gpm to clean up the
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resulting crud burst.
The forced oxidation step is completed when
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L the Co-58 is reduced to 0.05 pCi/gm (goal).
Forced oxidation prevents a crud burst that leads to high radiation levels' when the reactor' head is removed-for refueling. When the head is off,
_
reactor coolant purification is not normally performed.
.
This. operation has apparently been effective in keeping the
,
p radiation levels'in the primary system ALARA.
During the last fuel; cycle (117, the licensee'had revised the
"
chemistry control' program to operate with an elevated pH in the z
This was accomplished by maintaining a coordinated e
.
lithium-boron concentration.
Recent industry experience and
.research has shown,that4 increasing the' reactor pHslevel will reduce radiation levels in the primary systems.. Operating plants with increased pH levels lhave shown less crud deposition.on fuel.and subsequent transport 'of activated corrosion products to out-of-core regions.
The EPRI recommended c'oordinated lithium-boron control is used in
" maintaining a pH of 7.4 with a maximum of 2.2 ppm-lithium.
Shutdown
'
'
radiation levels had not been reviewed to determine a decreasing trend in radiation buildup.
It is' expected to take about"three fuel cycles before the effect of higher pH is discernible.
.The 11censee's response to Generic Letter 88-05, " Boric Acid-l
, yN Corrosion of. Carbon Steel Reactor Pressure Boundary Components in
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' PWR Plants;'Lincludes plant procedures' to visually inspect reactor.
.
coolant system components for leakage and the effects of boric acid
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I *g corrosion. ' A visual inspection is performed prior to
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. return-to power from a refueling outage, modification, or repair i
>when the system has beenLopened.
A visual-inspection is also E
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performed during Modes.4, 5 and 6 f911owing a shutdown from Mode 1,
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ile which the time elapsed from the previous inspection is more thani
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30 days', and the shutdown duration is greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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'3 Appropriate action'is taken'to clean.up boric acid deposits and-l i
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, repair leakage.
These measures are consistent with the
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recommendations of the generic letter.
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St'am Generators (SG)
'
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4, During the last fuel' cycle, the' licensee-converted to morpholine p
treatment of the SGs, a higher pH treatment, which should reduce SG L
corrosion problems.
Replacement of the Admiralty Brats condenser E
I
,
-tubes and copper feedwater and moisture separator reheaters with
]
titanium have allowed higher pH operation.
Morpholine, in K
conjunction with hydrazine reduces' erosion / corrosion in two phase regions, since it is less volatile than ammonia and provides a i
l higher pH in the wet steam regions.
On startup after each outage,.
l the licensee performs a boric acid soak for a few days at about 10 i
L ppm boric acid.
Boric acid is not maintained in the SGs during the operating cycle.
Boric acid soaks are utilized to mitigate denting.
Because of condenser leakage problems during the last cycle, the condensate polishers were placed in operation for cleanup.
Since l
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the hydrogen form, cation resin.in the_ condensate polishers exhaust:
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.'more'quickly with morpholine than' ammonia, morpholine treatment was
'
' discontinued during condensate polisher. operation.. A pH of. 9.3-9.6.
'was-maintained in the feedwater by ammonia-hydrazine treatment when p j
'the morpholine treatment was discontinued.
.jDuringthelicensee's1988refuelingoutage.atotal'of2361bs.of:
'
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,*4 sludge wasl removed from the-fourf SGs with only about 60% of: the
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' i. } " i material lbeing residual copper.
The' licensee had removed and
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Feplaced.al_1' components;contai.ning copper bearing alloys.
The
_
. licensee completed the-sludge lancing operations for 1989 during
,
,
.4
.
'this. inspection, and had' removed a; total of 502llbs. of sludgecfrom
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,the fobr SGs. "The licensee attributed the11ncrease to additional.
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t crud' removed from the system due the~use of morpholine and operating'
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MM
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P with a higher;pH level in the secondary system. -The EPRI PWR,
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Secondary Water Chemistry Guidelines, Revision 2,^ dated December'-
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'.1988, describes the use of' morpholine.1 Compared to'other PWR plants b
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' "be*at a minimum and was a reflection of-the maintenance of a good.
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. of,sim1,lar size,tthe amount of sludge' buildup.at Trojan appeared to
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chemistry control ' program.
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Modifications to the SG blowdown system during the 1988 refueling-4 ;j L ; [; y ; H, ' outage \\ increased the ' blowdown rate from 30 gpm per SG to 100 gpm
..
SG. ;The licensee observed a significant decrease in the 30 % power
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. hold for'ch'emistry stabilization.
The licensee expects the added f
. blowdown" rate to reduce the amount of corrosion damage caused by
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f buildup of contaminants--in the SGs, and improved chemistry control.
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' Tubes' plugged in the SGs total 127,-95', 113, and 135 for the A, B, C~
and;D units respectively.
About 80 percent.of the plugged tubes.
were in' row 1'which were' preventively plugged because of high "U bend" stresses.
The remaining tubes were plugged due mainly to primary side stress corrosion cracking. The' Trojan SGs have fewer plugged-tubes than comparable, steam' generators at other plants, which is indicative of good secondary water chemistry.
x After sludge lancing the,SG tube sheet and tubes'were inspected by boroscope.
Video indicated that most of the sludge was removed from the tube sheet and the tubes did not have an excessive' crud deposit.
A small. loose.part (metal" turning) was'found and will'be removed from one of-the tube sheets.
During this outage, a 100 percent-eddy current' inspection was to be performed.
The defective Westinghouse plugs:were to be capped by' robotic procedures.
Th'e licensee is reviewing Revision 2'of the EPRI PWR Secondary Water
'
<
Chemistry Guidelines to update plant procedures.
In-line Dionex ion chromatography. units will be placed into operation on each steam
'
generator during the next cycle.
Steam generator blowdown is now
,
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continuously monitored for pH, conductivity and oxygen.
"
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L The original Admiralty. Brass condenser tubes had been replaced with titanium tubes during the 1987 outage.
Copper alloys have also been l
. _ _ - _
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removed fromlthe feedwater heaters and moisture separator reheaters.
Some condentier leakage was experienced during the last operating cycle. The leakage has been~ identified to be from the water box, through the water box-condenser flange bolts, and into the condenser shell side.t During this' outage, thei eakage path will be sealed l
with an elastomer.
Sulfur hexafluoride is injected into the water box during condenser operation to detect leakage (in off gas) into the. condensate.
Helium ^ leak testing.is used to pinpoint.the location of.the leakage.
During this outage, the condensers are in wet layup with recirculation through the' condensate polishers.
The licensee is studying design changes necessary'to permit draining the E
condensers for dry layup with a nitrogen olanket.
Dry layup with a nitrogen blanket should minimize corrosion during outages.
D.
Makeup Water Systems
,
Dissolved air is minimized in the following makeup water systems:
demineralized water storage tank - can be cycled through
degasifier condensate storage tank - recirculated through degasifier
primary water storage tank - floating roof and can be pumped to
degasifier E.
Condensate Cleanup System The full flow condensate polishing system consists of eight Powdex type filter demineralizers.
Demineralized vessels not in service can be maintained in standby by using individual vessel holding pumps which maintain the demineralized precoat. The entire system can be bypassed by motor control valves on the two parallel condensate pump discharge streams.
The licensee is evaluating other resins to improve condensate polisher performance.
F.
Service Water System The service water system was chlorinated twice a week.
Sodium bisulfite is used to neutralize the chlorine prior to discharge to the river.
During this outage, a Betz CT-1 treatment system was installed for improved Asiatic Clam control.
Prior to discharge to the river, the Betz CT-1 is deactivated with a clay material. The licensee has a permit for the use of this treatment system.
Chlorination has controlled Asiatic Clams during the past cycle.
In addition, lube oil coolers in each service water train are disassembled for removal of clam shells every two weeks.
A vertical section of service water piping downstream of an orifice developed through wall leakage'due to cavitation erosion.
The carbon steel pipe section was replaced with stainless steel.
Although, still cavitating, the stainless steel is surviving the erosion.
Some of the small service water valves had to be replaced due to erosion from river water silt.
The erosion / corrosion
.
_ - _. _ _ _ _. _ _ _ _ _ _. _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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surveillance program for high energy carbon steel systems is being
,
extended to the service water system.
'G
. Erosion / Corrosion
.
The licensee had implemented a long term inspection and surveillance
program to monitor high-energy carbon steel pipe wall-thinning due
.
to erosion / corrosion. A computer program is used to keep track of.
thel numerous components inspected and the resulting wall thinning data.
Based on wall-thinning rates and trending information, the licensee optimizes the selection of components to be inspected by Ultrasonic Testing during each outage. Where components are approaching code allowables'or will reach'this value befor3 the end of the next cycle, they are replaced.
Components have been replaced with stainlets steel and chrom-moly carbon steel to minimize wall-thinning rates.
H.
Conclusions The licensee has kept abreast with recent industry and EPRI developments on improved chemistry treatment and corrosion control, including the following:
(1) Forced oxidation by hydrogen peroxide additions to the reactor coolant to release and cleanup Co-58 with the letdown purification demineralized prior to head removal for refueling.
(2) Replaced copper alloys in main condensers, feedwater heaters, and moisture separator reheaters; also, replaced low chrome carbon steel piping to a more erosion / corrosion resistant material.
(3) Initiated high pH with lithium hydroxide additions, coordinated with boron, in the reactor coolant to reduce corrosion rates and to reduce the buildup of radiation fields from primary systems.
(4) Steam generator boric acid soaks are utilized on startup to mitigate tube denting.
(5) Morpholine, in conjunction with hydrazine, secondary water
, chemistry pH control was initiated the last cycle to reduce
' erosion / corrosion in two phase regions.
, (6) Sludge lancing of steam generator tube sheets is employed each refueling outage to control sludge accumulation.
,
(7) Condenser" leakage is being addressed this outage by sealing i
leakage paths; thus, minimizing impurity ingress into the
condensate / feed system.
'
(8) On-line system for' injection of sulfur hexafluoride and helium into the condenser and detection in off gas for early detection
>
L and location of cooling water inleakage.
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degasifier,during startup, hot standby, cold shutdown and layup to minimize' steam generator corrosion.
(10) Visual inspection of reactor coolant system components for.-
leakage and the effects of boric acid corrosion-following a shutdown.from_ Mode 1.
Appropriate action isitaken to_ clean up boric acid deposits and repair leakage.
- (11) A 100 percent eddy-current inspection of all steam generator tubes will be performed this outage.
-
(12) ' Biocide. treatment of service water is utilized to control-Asian Clam infestations.
(13) Long term inspection and surveillance program had been
-
instituted to monitor high-energy carbon steel -pipe wall thinning due to erosion / corrosion.. This program is-being extended to the service water system.
7.
Control of Bulk' Chemicals (79501)
'
'
The controls for procurement, receipt and storage for nuclear grade resins, granular boric acid, hydrazine and lithium hydroxide were reviewed. ' Purchase orders provided a complete description of the
- material.being purchased including:sthe chemical composition and purity requirements; the requirements for packaging and shipping; and requests for a Certification of Analysis identifying results, test methods, lot / batch number, and the PGE Purchase Order and Release numbers.
Procurement appeared to be consistent with licensee procedure A0-12-1, Procurement Document Control:and NRC R.G. 1.123, 1977, Quality Assurance Requirements for Control of Procurement o'f Items and Services for Nuclear Power Plants.
Receipt' inspections of materials _ purchased appeared to be consistent with procedure A0-12-3, Material Receipt Inspections and QCP-17, Receipt Inspections of Quality Related Materials.
With respect to storage of warehousAd bul[ chemicals, oli April 19, 1989,
~
,
the following observations were made during'a tour'of,the Material
Control Warehouse and the WSH Warehouse:
,
y Although items were noted to be properly labeled, there appeared to
- -
be no organized method for storage, protection,-or separation to prevent contamination by other materials in the event of leakage.
In the WSH Warehouse, the inspector observed _that a_ pallet of bags containing granular silica had leaked a considerable amount of silica onto the bags of granular boric acid stored below.
<.
The boric acid is used in the reactor coolant system (RCS) as a soluble poison to aid in reactivity control.
Silica in the RCS causes scaling and fouling of heat transfer surfaces and is L
maintained below 0.2 ppm.
The licensee has experienced elevated silica in the primary system with the source unknown.
.
_.._.-.__.m.___
___. _ - _ _ _ _ _ _
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...
.
17.
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In. the Material Control Warehouse, the' inspector observed laboratory l
liquid reagents including acetic acid, stored on shelves near l
quality related parts. Although no leakage was observed, it would seem prudent to store the reagents in a more isolated area,'further from quality related parts.
The inspector discussed the above-observations with the Materials Supervisor (MS) shortly after the tour.
The MS informed the inspector that there was an ongoing project to improve the efficiency of warehousing operations that also included a recent evaluation of their operations by a contract firm.
In regard to the spilling of silica on the boric acid, the MS took immediate action to correct the problem.
The above observations were also discussed at the exit interview. The inspector's observations were acknowledged by the licensee.
8.
Hydrogen Storage on the Roof of the Control Room During the inspection, the inspectors identified a potential safety problem concerning the location of the hydrogen storage facility.
Hydrogen is used on pressurized water. reactor (PWR) plants for providing a cover _ gas in the volume control tank, and for cooling the main turbine-generator.
At boiling water reactor (BWR) plants, hydrogen is also used for cooling the main turbine generator and for injection into the feed system for plants which have implemented. hydrogen water chemistry.
The Trojan hydrogen storage facility is located on the control room roof which is 30-inch-thick reinforced concrete.
The air intakes for the control room ventilation and emergency pressurization system ars located within approximately 25 feet of the hydrogen gas storage facility.. Hydrogen gas leakage from the storage facility or associated piping.could possibly introduce a flammable or explosive gas mixture into the control room.
Because the hydrogen storage facility, containing four 8,000 scf hydrogen tanks at up to 2450 psig, is Seismic CategoryfII, a seismic ~ event may result in a hydrogen leak.
Furthermore, the pressure relief valves in the hydrogen facility exhaust downward to within 6 inches of the control room roof in the vicinity of the control room ventilation system air intakes.
It was also noted that six 8,000 scf nitrogen tanks were located in the vicinity of the control room air intakes.
Nitrogen leakage and dispersion into the air intakes may lead to incapacitation of the control room operators.
A detonation of a hydrogen storage tank (energy equivalent to 217 pounds of TNT) may structurally damage the roof of the control room and affect performance of safety-related equipment on the. control room roof such as the ventilation system intake and exhaust structure, the emergency pressurization system, and equipment in the control room itself.
The hydrogen supply is replenished through a fill line located on the exterior wall of the auxiliary building at ground level.
An explosion of the hydrogen delivery truck may structurally damage safety-related component cooling water pumps and radwaste storage tanks
,
located inside the auxiliary building in the vicinity of the hydrogen
fill line.
_ _ - _ _ _ _ _ _ - _ _ _ _ -
_ _ _ - -
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.The topical report Guidelines for' Permanent BWR Hydrogen Water-Chemistry-
'
Installations,- 1987 Revision, EPRI NP-5283-SR-A, was. reviewed and accepted by NRC. -NRC's approval letter, dated July 13, 1987, states that this topical-report may be useful in providing industry guidance for the (..-
' design,- operation, maintenance, surveillance, and testing of hydrogen
systems..for (1) providing a cover gas'in the PWR volume control tank and L,
(2) for cooling the main turbine' generator...In addition, NRC Information
. Notice No. 87-20, Hydrogen Leak In Auxiliary Building, dated April 20, g
'1987, indicated that the NRC was then reviewing the EPRI/BWROG topical report (EPRI NP-5283-SR-A)..The' Trojan plant hydrogen facility does not.
.
meet these guidelines from the standpoint of (1) the separation distance F'
eN needed between a hydrogen, pipe break and the control room ventilation
[
intake to prevent buildup of a flammable or explosive gas ~ mixture inside
. s the control room, and (2) the separation distance needed to prevent
,
' damagelto' safety-related structures resulting from the explosion of an
<
8,000.scf hydrogen tank.
,* C Thejlicensee! recognized that hydrogen can leak.from the storage. facility land, enter the control room via the air. intakes in at least:two' documents,
- -
j-In aJ11censee letter to NRC, dated March 2, 1988, concerning Control-Room.
- 4.M; f j
'
," Habitability m Ammonia Detectors, it was stated that ammonia detectors do
,
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inot discriminate.again'st background gases at Trojan which leads to
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- spurious alarms) :These background gases. include hydrogen which is loaded j'
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Q b0 hydrogen venting from1the main generator.
The licensee's initial Oper-W a
f ational Asse'ssment: Review (OAR) No. 87-29 screening responding to the
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4 des'ign tie (1987,.NRC Information Notice 87-20, recommended that the T
<1 April'20
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g Contre 1/, Auxiliary / Fuel Building complex.
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verified to preclude excess hydrogen accumulation in the
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Sectio'nIII,' Evaluation,of0AR-87-29,reducedthescopeofthereviewof
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A the potential problem, limiting it specifically to the subject of the s*
,
NRC's Information Notice No. 87-20, Hydrogen Leak in Auxiliary Building.
"*
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The initial evaluation of 0AR-87-29, dated May 5, 1987, had established-
.I
an= evaluation priority target date; of July 3,1987.
The evaluation / corrective action portion of CAR-87-29 was completed and signed on April 4, 1989.
The corrective actions were to provide for installation of a new excess flow valve, prepare a procedure and perform pressure decay tests on hydrogen piping system, and revise PGE-1012, Fire Protection Plan Program Description.
At the. exit interview on April 21, 1989, the licensee informed NRC team members that they had been unable to find any design documents which addressed the potential safety problems concerning the storage of hydrogen on the roof of the control room.
The licensee has taken the following action on a high priority basis:
1.
Closed hydrogen storage tank isolation valves.
2.
Installed an oxygen monitor in the control room to prevent incapacitation of the control room operators.
3.
Prepared an action plan to resolve the problem including relocation of the hydrogen storage system.
,
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In response to' possible generic issues raised by these findings' an
.
information notice (IN No. 89-44, dated April-27,~.1989) was issued.
!:l'
This matter is considered to be-unresolved and will be addressed at a
'
H future time (89-07-04).
J
,9.
Chemistry Safety'and ALARA Practices (79501, 83727 and 84750)
.
,
k The primary and's'econdary; sampling systems and the location of the laboratories appeared to be designed to maintain radiation exposures
'
'ALARA.
Principal secondary sampling,[ including SG blowdown sampling, was conducted ~from samp1e lines. piped into the cold chemistry lab.
l located outside of the radiologically controlled area (RC).
Principal-L, primary system sampling was conducted from<a ventilated hood that was
. conveniently located (near the hotilab in theiRCA.
The primary
~
'
sampling station.was also adequately separated and-shielded from-
- '
general work areas toflimit. unnecessary eiposure'to plant personnel not involved with sampling operations (
'
i
'
' Chemical addition stationsin the~ plant'were appropriately provided_with
_
eye wash fountains and safety showers that,were conveniently located and
<
identified.
Signs controlling' eating, and smoking.and warnings of high noise areas' and other personnel hazards were appropriately located.
The Chemistry Department had responsibility for the control andfuse of hazardous. chemicals used at the plant. Administrative Order A0-10-6,
_
,
s Chemical Safety Program, adequately delineated the responsibilities and'
guidance for implementation of State and Federal requirements. The Chemistry Department had assigned an individual the responsibility for
,
implementing the program outlined in A0-10-6, that include'd the review and approval of Chemical Purchase Requests and Chemical Work Permits.
10.
Confirmatory Measurements - Radioactive Species-(84750)
T!m licensee's records of certification of sources used to calibrate lattratory radioanalytical instruments were examined.
Sources.used
. for calibration of gross alpha / beta counters,- gamma spectrometers, and liquid scintillation counters, were each purchased from firms participating in measurement verification programs with the NIST. The certified dates for the sources were consistent with the time of use for
instrument calibration.
Records of radioanalytical instrument calibrations were reviewed.
The licensee had recalibrates all gamma spectrometers on,an annual basis, and calibrated gross alpha / beta internal detectors on a quarterly basis.
The
-
,
calibration frequencies and methods were consistent with the guidance of Regulatory Guide 4.15 and ANSI N42.14-1978.
,
The licensee's program for measurement control of radioanalytical instruments was evaluated.
The licensee employed a computer-based quality assurance routine for all radioanalytical instruments.
Measurement control checks were performed daily for each instrument, and entered into the quality assurance software file.
Measurement control charts'were generated for each instrument parameter, with warning and i
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action'levelsestablihedattwoahdth'reeDstandarddeviationsfrom'the
'
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mean, as calculated fromjstatisticalfanalysis,of all data to date. The-
_ precision.of the. data'was obtained from the standard deviation of the
~
daily: quality checks,. printed on the control chart as percent deviation
.
"
from'the mean. The frequency and nature of the~ measurement-checks, and the management of the data, were consistent with guidance.for performance checks provided in RG 4.15 and ANSI'N42.14-1978.
The performance of the instruments pursuant to the measurement control checks demonstrated
satisfactory maintenance of_ accuracy, precision and resolution for required' measurements.
,
,
~To' assess effluent measurement ~ sensitivity, the inspector requested that the licensee acquire a gamma background spectrum for 30 minutes, the c
licensee's _ default. counting time, using the gamma detector with lowest counting efficiency. The inspector also requested that the background spectrum be analyzed using the three least-efficient geometries employed
-
for radiological effluents; the 33 milliliter gas sphere, 2 liter liquid Marinelli-beaker,'and standard charcoal cartridge.
Lower limits of Detection.(LLD) were calculated ~and compared to those required by radiological. effluent TS.. In each case, the calculated detection limits were..approximately one o_rder of_ magnitude lower than those required.-
The licensee's management of radiological samples was evaluated to determine.if. radioactive decay prior to_ analysis would potentially_
. increase the calculated detection limit, particularly.for _short-lived noble gases'..The typical time between sample collection and sample analysis, as reflected in gamma spectrometer data, for effluent samples-collected the week prior to the inspection was. reviewed.
Effluent samples were typically analyzed within. ten minutes of' collection, which
~
would.have precluded significant impairment of' measurement sensitivity by
- sample decay.
Filters' and cartridges removed from effluent pathways after weekly sample collection possessed a decay time of up to 3.5 days between midpoint of.
sampling ~and the time of, analysis.
However, since TS 4.11.2.1.2-Surveillance Requirements specifies analyses for I-131 and particulate with half-lives greater than eight days, decay did not significantly degrade measurement sensitivity for the specified radionuclides above the TS LLDs.
_
'
'
Although the TS provide for LLD^ decay cor'rections from midpoint of sample
~
collection to the. time of analysis, no specific provision is provided in the TS for decay corrections of identified radionuclides activity.
The licensee had implemented more sophisticated decayfcorrections for activity identified on-continuous release sampling media.
Two computer codes, CCOMP and.BCOMP, had been developed for continuous and batch
~
releases through continuous sampling' media, respectively.
The CCOMP program performed a correction for equilibrium of short-lived radionuclides on sampl.ing media,,assumihg that the effluent concentration had remained constant during the samp1e' collection period.
When the
~
i
~
effluent concentration varied in. response to batch' releases, the BCOMP routine estimated released-activity with equilibrium corrections.for each batch volume and duration' entered into the. code.
BCOMP did not perform equilibrium corrections for radionuclides with half-lives less than one
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from near-term released activity.
The licensee's methods for effluent
[ '"
' activity calculations were satisfactory.
?
The licensee's procedure for reactor coolant' system specific activity
,,
,
surveillance,' CMP-39, Rev.14,-Specific Activity, was examined for
,
consistency with TS 4.4.8.
The procedure specified that the gross
' X
. activity determination was to be used to identify trends and excursions y
in RCS activity meriting further sampling, and that the gross activity
~
['
measurement was not limited to'the TS 3.4.84 100/E-Bar Limiting Condition
'
for Operation.(LCO).
,The inspector and the Laboratory Supervisor _ discussed the' provisions of CMP-39 'The inspector stated that the' procedure specified appropriate analyses for RCS activity surveillance,' but 'did not contain instructions'
. -for formal: comparisons between 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> surveillance and the TS 3.4.8'
t'
specific activity limit.
The Laboratory Supervisor agreed that the-i acceptance criteria,were:not clearly.specified, and stated.that the
'
'
procedure would be changed to include provisions.for comparing the result
'of.the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> gross activity determination to the TS 3.4.8 LCO.
The.
inspector will evaluate the' procedure change during,a subsequent
'
inspection (50-344/89-07-02).
s
,
The regional mobile laboratory was bro'ught'onsite t'oLperform' gamma
. isotopic measurement intercomparisons with the licensee's counting
'
,'
laboratory.
Severall sample types routinely obtained by the. licensee for t.
.-m~
technical specification radiological surveillance were analyzed by both
'
'
1 laboratories 'and rintercompared i: sing the NRC verification criteria (see enclosure).
The.first sample obtained was a 47 mm filter of suspended solids from 1 liter.of reactor coolant.
The filter was obtained two weeks. prior to the m inspection, during hydrogen peroxide addition to the reactor coolant
- 'fsystem.
The hydrogen peroxide' injection had brought large amounts of.
activated' corrosion products into solution.
Therefore,-the suspended
solids activity presented in Table 2 was not representative'of normal operations.
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l Table 2 Suspended Solids from 1000 ml Reactor Coo'lant h
L uCi/mi uCi/ml
. NRC Licensee NRC Random Ratio:
Agreement Analyte Result Result Uncertainty Licensee /NRC Range'
,
E
- D1 Cr-51 2.20E-04 2.27E-04 9.20E-06 0.97 0.75-1.33 D1 Mn-54 1.00E-05 8.84E-06 6.17E-07 1.13 0.6-1.66 D1 Co-58 1.14E-03 1.03E-03 8.00E-07 1.11 0.85-1.18
'D1 Co-60 8.00E-06 0.66E-06 1.03E-06 0.92 0.6-1.66 D1 Sn-113-8.30E-06 4.73E-06 9.62E-07 1.76 0.5-2.00 D1 Sn-117m 0.00E+00 3.75E-06 6.14E-07
0.5-2.00 D1 Cs-134 7.08E-05 6.59E-05 1.29E-10'
1.08 0.85-1.18 D1 Nb-95 2.28E-05 2.78E-05 9.60E-07 0.82 0.75-1.33-D1 Zr-95 2.29E-05 2.11E-05-1.22E-06 1.08 0.75-1.33; D1-Mo-99 1.86E-04 1.67E-04 8.00E-06 1.11 0.75-1.33 D1'Tc-99m 1.89E-04 1.88E-04 8.20E-06 1.01 0.75-1.33 D1 Ru-103 5.23E-05 5.04E-05 1.46E-06.
1.04 0.75-1.33 D1 1-131 2.40E-04 2. 30E-04' 3.10E-06'
1.04 0.80-1.25 D1 Te-132 5.92E-05'5.51E-05 6.16E-06
1.07 0.6-1.66 D1 Cs-136 0.00E+00 1.04E-05'1.37E-06"
0.5-2.00
~
DI Cs-137
- 4.90E-05"4.46E-05L1.19E-06; 1.10 0.75-1.33 D1 Ba-140 n 8.04E-04 6.00E-04 8.50E-06~
1.34 0.80-1.25
"
D1 La-140 5.'10E-02' 5.03E-02 3. 60E-04 1.01 0.80-1.25 s
D1 Ce-141 13.97E-06 4;04E-06.7.21E-07 0.98 0.5-2.00
-
+
- D2 Cr-51 2i41E-04 2.27E-04.20Es06 1.06 0.75-1.33
'
D2 Mn-54 1.07E-05 8.84E-06 6.17E-07 1.21 0.6-1.66 D2 Co-58 F 1.13E-03 1.03E-03 8'.00E-07 1.10 0.85-1.18 D2 Co-60 8.81E-06 8.66E-06 1.03E-06 1.02 0.6-1.66 D2 Sn-113 6.06E-06 4.73E-06 9.62E-07-1.28 0.5-2.00 D2 Sn-117m 0.00E+00 3.75E-06 6.14E-07 s
0.5-2.00 D2 Cs-134 7.11E-05 6.59E-05 1.29E-10 l'
1.08 0.85-1.18 D2 Nb-95 2.77E-05 2.78E-05 9.60E-07 1.00 0.75-1,33 D2 Zr-95 2.06E-05 2.11E-05 1.22E-06'
O.97 0.75-1.33 D2 Mo-99 1.88E-04 1.67E-04 8.00E-06 1.12 0.75-1.33 D2 Tc-99m 1.91E-04 1.88E-04 8.20E-06 1.02 0.75-1.33 D2 Ru-103 5.43E-05 5.04E-05 1.46E-06 1.08 0.75-1.33 D2 I-131 2.48E-04 2.30E-04 3.10E-06 1.08 0.80-1.25 D2 Te-132 7.35E-05 5.51E-05 6.16E-06-1.33 0.6-1.66 D2 Cs-136 1.68E-05 1.04E-05 1.37E-06 1.61 0.5-2.00 D2 Cs-137 5.17E-05 4.46E-05 1.19E-06 1.16 0.75-1.33.
02 Ba-140 7.89E-04 6.00E-04 8.50E-06 1.31 0.80-1.25 D2 La-140 4.92E-02 5.03E-02 3.60E-04 0.98 0.80-1.25 D2 Ce-141 6.04E-06 4.04E-06 7.21E-07 1.50 0.5-2.00 Indicates germanium detector serial 1096
- Indicates germanium detector serial 2155 Measurements for Sn-117m and Ba-140 did not agree.
The licensee detected the 158.6 kev gamma ray from Sn-117m, but the spectrometry software did
- _ _ -
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,
._
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-
.
.
not identify Sn-117m. The licensee and the inspector evaluated the nuclide library and discovered that Sn-117m was not included. -The.
inspector verified that the licensee had entered appropriate nuclide information for Sn-117m into the software library prior to the end of the inspection.
The licensee's inability to identify _Sn-117m was of minor safety significance, given the smal.1 portion of Sn-117m in the isotopic mix.
However, the failure to identify the absence.of Sn-117m suggests that the licensee's software. verification and validation practices-for the spectrometry library were not thorough.
o The disagreement for Ba-140 activity was caused by different gamma abundance factors (gamma emissions ~per disintegration) used by the NRC and licensee laboratories.
The NRC laboratory used a factor of 0.25 as reported byiKocher, where the licensee used 0.19 as reported by Erdtmann and Soyka.' ;Both abundance. factors were drawn from acceptable scientific referenc'es,'so the inconsistency was regarded as an acceptable scientific disagreement.
Th' 'se'cond. sample' arIalyzed was approximately. ten ml of reactor coolant e
.i obtained from the. residual heat removal system.
The results of the
'
- i,4; intercomparisoil ave pr'esented in Table 3.
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, uCi/ml uCi/mi NRC
-
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sLicensee NRC Random Ratio:
Agreement y
-Analyte Result Result Uncertainty Licensee /NRC Range-
'
s 01 Mn-54 7.00E-04 6.28E-04 4. 22E-05 1.11 0.6-1.66 D1 Co-58 9.30E-02 7.93E-02 3.00E-04
'1.17 0.85-1.18 D1 Co-60 3.08E-03 2.62E-03 7.40E-05 1.17 0.75-1.33 D1 Cs-134 9.04E-04 7.85E-04 7.98E-05 1.15 0.6-1.6; D1 Np-239-1.65E-03 1.33E-03 9.30E-05 1.23 0.6-1.66 D1 Mo-99 8.71E-04 8.22E-04 3.83E-05 1.06 0.75-1.33 D1 Tc-99m 8.86E-04 9.23E-04 4.30E-05 0.96 0.75-1.33 D1 1-131 6.95E-04 6.51E-04 7.53E-05 1.07 0.6-1.66 D1 I-132 4.84E-03 3.90E-03 1.18E-04 1.24 0.75-1.33
'D1 Te-132 3.47E-04 3.04E-04 4.05E-05 1.14 0.5-2.00 01 Cs-137 7.79E-04 6.51E-04 8.43E-05 1.20 0.5-2.00 D1 Ba-140 1.95E-03 1.89E-03 3.79E-04 1.03 0.5-2.00 D2 Mn-54 7.26E-04 6.28E-04 4.22E-05 1.16 0.6-1.66 D2 Co-58 9.13E-02 7.93E-02 3.00E-04 1.15 0.85-1.18 D2 Co-60 3.10E-03 2.62E-03 7.40E-05 1.18 0.75-1.33 D2 Cs-134 1.13E-03 7.85E-04 7.98E-05 1.44 0.6-1.66 D7 Np-239 1.63E-03 1.33E-03 9.30E-05 1.23 0.6-1.66 P' M' 99 1.14E-03 8.22E-04 3.83E-05 1.39 0.75-1.33 D2 Tc-99m 1.16E-03 9.23E-04 4.30E-05 1.26 0.75-1.33 D2 I-131 7.10E-04 6.51E-04 7.53E-05 1.09 0.6-1.66 02 I-132 4.72E-03 3.90E-03 1.18E-04 1.21 0.75-1.33 D2 Te-132 4.18E-04 3. 04E-04 4. 05E-05 1.37 0.5-2.00 D2 Cs-137 7.21E-04 6.51E-04 8.43E-05 1.11 0.5-2.00 D2 Ba-140 2.66E-03 1.89E-03 3.79E-04 1.41 0.5-2.00
- - -_-_
._--_-_ _ -
_ _ _ _ _ _ -
...
- -
~
While the results of the reactor coolant'intercomparison were generally within the agreement range, the overall mean of the data demonstrated a consistent bias between the licensee and NRC analyses.,The inspector visually examined the sample provided for'the NRC analysis and observed that the reactor coolant aliquot had been overdiluted past the designated 50 ml capacity of the container.
Subsequent gamma self-absorption and the inverse square law had decreased the gamma flux with' respect to the efficiency calibration, biasing the NRC result low.
s The inspector requested that a second reactor' coolant sample'be obtained, and
/
a 50 ml dilution mark wastestablished.on the NRC container.. The second coolant sample analysis was.intercompared with licensee detector serial 2155, which had exhibited marginal disagreement for Mo-99 in the initial intercomparison.
The results of the second coolant sample intercomparison are given in Table 4.
,
Th 4 Reactor Coolant, Second Sample'
uCi/ml uCi/ml NRC Licensee NRC Random Ratio:
Agreement Detector Analyte Result Result Uncertainty Licensee /NRC Range
Mn-54 1.28E-04 1.33E-04 2.05E-05 0.96 0.5-2.00
Co-58 1.76E-02 1.74E-02 1.30E-04 1.01 0.80-1.25
Co-60 5.84E-04 6.10E-04 3.41E-05 0.96 0.75-1.33
Cs-134 1.97E-04 1.28E-04 3.20E-05 1.54 0.5-2.00
Np-239 9.30E-04 9.16E-04 5.03E-05 1.01 0.75-1.33
Mo-99 2.71E-04 2.19E-04 1.68E-05 1.24 0.6-1.66
Tc-99m 2.7CE-04 2.46E-04 1.89E-05 1.12 0.6-1.66
I-131 2.42E-04 2.17E-04 3.77E-05 1.12 0.5-2.00
?
I-132 2.41E-03 2.43E-03 4.50E-05 0.99 0.80-1.25
Te-132 3.15E-04 2. 66E-04 2.87E-05 1.19 0.6-1.66
Ba-140 1.42E-03 1.11E-03 1.64E-04 1.28 0.5-2.00 The results of the second coolant intercomparison were superior to the initial
,
comparison, with less tendency toward positive bias, supporting the conclusion l
that sample overdilution was the cause of the previous bias.
The inspector and the licensee independently derived reactor coolant dose l
equivalent iodine-131 activity and average beta gamma energy per
' disintegration (E-8ar) of principal gamma emitters from their respective measurements of the second reactor coolant sample.
The calculational methods of licensee procedures CMP-24, Rev. 2, Determination of Dose Equivalent I,31, and CMP-49, Rev. 1, Determination of E-Bar, and the requirements of TS 3/4.4.8 i
were followed within the limits of the analysis performed.
The derived values
!
were intercompared to determine if biases in measurement data could cause derived quantities to disagree after dose conversion factors and energy per decay factors were applied.
The licensee and NRC dose equivalent I-131 values were 3.29E-4 uCi/ml and 3.05E-4 uCi/ml, respectively, for a ratio of 1.08.
This ratio was m_
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respectively for an) excellent ratio of 0.99.
Only~ soluble liquid gamma
?
The..
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The; fourth sample obtained was an air filter of containment atmosphere for.
_
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comparisonwith}theradiationprotectiongammaspectrometer. This detector y
was, employed for radiation protection air sample measurements.
The RCS.
L
,
l suspended solids filter was not used ascit would have yielded unacceptable
. detector. system dead time losses at the'short sample-to-detector distances for
. hich the radiation protection detector had been calibrated. The w
intercomparison data for the' air filter measurements'are presentedsin' Table 5.
Table.5
'
.ConjainmentAtmosphereA1.rFilter uCi/ea uCi/ea NRC Licensee
.NRC
' Random ~
Ratio:
Agreement Analyte Result Result. Uncertainty Licensee /NRC-Range'
..
D1 Mn-54 1.35E-04 1.33E-04 1266E-05 1.02 0.6-1.66 D1 Co-58 7.97E-05 9.94E-05 2.18E-05 0.80 0.5-2.00 D1 Co-60 1.92E-03 2.06E-03 4.80E-05 0.93 0.75-1.33 D1 Cs-134 1.73E-04.1.75E-04 1.90E-05 0.98 0.6-1.66.
D1 Cs-137 6. 96E-04 7.20E-04 2. 74E-05 0.97 0.75-1.33 The filter measurements.were in agreement.
'
The final. sample was-obtained from a dirty waste drain tank, from which-subsamples were taken for gamma isotopic intercomparison and other radiochemical analyses. The results of the gamma isotopic intercompsrison
..
with licensee detector serial 2155 are presented in Table 6.
Table 6 ll;
'.
Dirty Waste Drain Tank Liquid l
uCi/ml uCi/mi NRC Licensee NRC Random Ratio:
Agreement
. Analyte Result Result Uncertainty Licensee /NRC Range
..a
.
f.Mn-54'
8.49E-06 8.90E-06 3.10E-07 0.95 0.75-1.33
Co-57 7.68E-07 5.84E-07 1.21E-07 1.32 0.5-2.00 J LCo-58; 3.62E-04 3.50E-04 9.00E-07 1.04 0.85-1.'18 Co-60
- 8.47E-05 8.30E-05 5.40E-07 1.02 0.80-1.25
'
m.
-
Ag-110m '2.84E-06 3.13E-06 3.64E-07 0.91 0.6-1.66
'
Cs-134, 4.01E-05 3.93E-05 4.60E-07 1.02 0.80-1.25 f
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Nb-95 4.21E-06 4.49E-06 2.92E-07 0.94 0.6-1.66 Zr-95 1.59E-06 1.73E-06 3.63E-07 0.92 0.5-2.00 Mo-99 1.50E-06 1.08E-06 1.18E-07 1.38 0.6-1.66 Tc-99m 1.53E-06 1.22E-06 1.33E-07 1.25 0.6-1.66 RuRh-106 1.40E-05 1.12E-05 2.08E-06 1.24 0.5-2.00 Sb-125 5.68E-06 5.58E-06 7.07E-07 1.02 0.5-2.00 1-131 8.89E-06 8.96E-06 2.92E-07 0.99 0.75-1.33 Cs-137-5.64E-05 5.36E-05 4.10E-07 1.05 0.80-1.25 La-140 4.32E-06 3.22E-06 1.65E-07 1.34 0.75-1.33 The results of the intercomparison were very good.
Slight measurement bias was caused by settling of solids in the respective samples.
The inspector and the licensee retained preserved drain tank samples for the measurement of beta end x ray emitters, tritium, radiostrontium and Fe-55. The inspector requested it.at the licensee perform analyses for these radionuclides for intercomparison to NRC reference laboratory analyses.
The inspector will review the measurement data for beta and x-ray emitters upon receipt of the both the licensee and NRC laboratory data (50-344/89-07-03).
The results of the licensee's interlaboratory comparison program for radiochemical analysis for the second through fourth quarter of 1988 were reviewed. The licensee participated in two intercomparison programs, one
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- through a private, NIST-traceable vendor, and a second program employing
'NIST prepared samples,'thus providing direct measurement assurance by NIST.
The:results of the intercomparisons showed an isolated tritium analysis disagreement, which was' attributed to cross-contamination from laboratory glassware that had not been fully cleaned prior to use.
Two of the five strontium-89 measurements marginally disagreed with certified values.
The
' licensee was evaluating the use of liquid scintillation counting to assay
- radi.ostrontium rather than a proportional counter in order to avoid
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, measurement errors caused by inaccurate sample sel.f-absorption corrections.
The _ licensee's program for interlaboratory radiochemical comparisons was
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-excellent.
The licensee's program fo'r radiochemical analysis was superior.
Strengths included accurate measurements, as verified by NRC confirmatory measurements and the licensee's measurement verification programs, good measurement control practices and effective methods for quantifying continuous releases.
Weaknesses' included lack of acceptance criteria for RCS activity determinations and the absence of Sn-117m in the gamma spectrometry library.
No violations or deviations were identified.
11.
Post Accident Sampling System (PASS) (84750)
The PASS was evaluated for compliance with the criteria of NUREG-0737, paragraph II.B.3, Postaccident Sampling Capability.
Current copies of the PASS procedures were reviewed.
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'The licensee performed a demonstration of the PASS procedures at the
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request of the inspectors to demonstrate their ability to meet the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> i
sample collection and analysis criteria.
Valve manipulations were i
simulated due to maintenance at the time of the inspection.
The licensee l'
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successfully' demonstrated their ability to. meet the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> criteria for
radionuclides in reactor coolant, hydrogen levels, dissolved gases',
chloride and boron in liquids.
There was no capability for inline
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monitoring.
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.The ability to' perform PASS without having to place in service an isolated auxi'fiary system was verified by examination of PAS and associated. system diagrams.
The PASS procedure for chloride analysis was dnne by a select ion electrode method although-the licensee also hasLthe capability of.
performing 1 routine chloride analyses with their.IC.
The' licensee
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A demonstrated that they could easily meet the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> analysis criteria for chloride.
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The licensee's Summary of Time / Motion / Dose survey for PASS Operation calculation number TM-100, revision 0, dated December 21, 1983, was reviewed and appeared adequate to demonstrate their ability to perform-reactor' coolant and containment atmosphere sampling and analysis without c
radiation exposures exceeding the 10 CFR 50, Appendix A, General. Design Criteria 19, dose limits for the whole body and extremities.
The licensee's supporting calculations, which identify and quantify the-radionuclides source terms exnected in the-worst case post accident-situation, were, reviewed..The specified source terms appeared c. conservative ~and consistent with the guidance provided in Regulatory.
~ Guides 1.4 and 1.7. eThe licensee's' PASS dilutes the reactor coolant sample with demineralized water to 1:1000..This dilution minimizes the dose rates'to which analysts are exposed.
The sensitivity of the licensee's radioanalytic instrumentation appeared sufficient to. quantify these diluted samples.
Calculations of the post accident background exposure r'ates.at.the sampling stations and'in the laboratories were also reviewed..These appeared sufficiently low so as to both minimize personnel doses and to introduce insignificant error into the analyses.
The accuracy; range and sensitivity 'of the;licEn'see's measurement
~ capability appeared adequath to' pro' vide pertinent' data to the. operator in
~
order to describe the radiological status of the reactor coolant-system within the factor of 2 specified in NUREG-0737, II.B.3.
A review of the design of the PASS indicated that significant provisions appeared to have been taken for purging sample lines, for reducing plateout, for minimizing sample loss, for preventing blockage of sample L
lines, for appropriate disposal of the samples, and for flow restriction l
to limit coolant loss from a rupture of the sample line.
Provisions to assure that samples are representative appeared to be adequate and sample lines seemed of the minimum length.
Sample residues could be returned to a closed system.
The licensee program appeared adequate to meet its safety objectives.
No violations or deviations were identified.
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Exit Inte'rview
Th'e scope and findings of the inspection were. discussed with individuals'
, denoted.in. report section.1.
It was noted that on the basis of~the.
material condition of the plant,_ Portland General Electric Company, had
.,
demonstrated a strong commitment to good chemistry control..Particular-
' strengths that were noted included a capable and dedicated chemistry m
staff,'an effective radiochemical measurements program supported by a good quality control.and assurance programc and an excellent erosion / corrosion control program.
.With these strengths, however, certain. weaknesses were identified.
In
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the area of: quality assurance, an absence of frequent,; limited scope, surveillance activitiestin the chemistry area was.noted..Second, the'
examination of the nonradioactive chemistry measurements program
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disclosed the absence of a quality control program consistent with'
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industry standards and characteristic of good performers in this area.
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The' third area of concern was related to the control of chemicals fors, plant use.
In this case, it was observed that granular silica had
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spilled onto, bagged boric acid.
An additional matter in thisfarea was the storage of high pressure hydrogen and nitrogen on'the' roof.of.the
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control _ building'above the control room in close proximity-to the' control room air' intakes. 'The' apparent failure of Portland General' Electric'
Company. to vigorously pursue NRC Information Notice ~ No. ~ 87-20 and the Operational Assessment Review (OAR-87-29)'which' addressed the'Information
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Notice and the potential unevaluated safety hazard was of.significant
. concern.
The individual team members presented brief summaries of their findings.
The licensee commented in response to the specific items identified that.
the implementation of a surveillance program was in the early phases of-implementation.
With respect to.the absence of. a chemistry quality :
control program the licensee stated that such a program was in the early planning stage and would be implemented'as,soon as possible.
.
With respect to the concerns related to the storage of chemicals, specifically with respect to the hydrogen" storage, the licensee stated that prompt action'was being taken toimiriimize.the hazard until the:
b condition had been evaluated and corrective actions could be taken.
Documents Reviewed.
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- Trojanorganizationandsstaffing; chart
- Memorandum, O'rser to Lentsch,'May 17, 1985~,TWSO-364-85, PGE response to Generic Letter;85-02
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- Memorandum, Lentsch' to Vundt, April 11,1989, JWL-035-89, Personnel Protection-Quarterly Review of 1989 Annual Objectives
- Memorandum, Lentsch to Yundt, March 30, 1989, JWL-029-89,--INPD Action Plans
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w Review of Information Notice 87-20, Hydrogen Leak in Auxiliary 8uilding
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- Chemistry Department Reports for last 12 months
- PGE.QA' Audit of Trojan Chemistry Activities, RCJ-319-87, dated August
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4, 1987
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" Audit Checklist Review, AP No. 497, dates 6/29/87--7/6/87
' Procedures Reviewed-
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" A0-1-1, Management Organization
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0-1-2, Plant l Organization.
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- A0-1-3, General Managers Responsibilities's
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"~A0-1-7, Personnel Protection Responsibilities
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- A0-3-1,: Shif t Complement and Work Time
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- A0-3-19, Approved Chemicals and Cleaning Agents for Primary and Related
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Systems i
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- AO-10-6, Chemical Safety Program
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' TAP-401, Training Administrative Procedure, Revision 3, Chemistry Technician Replacement Training Program TAP-403, Training Administrative Procedure, Revision 3, Chemistry Technician Retraining Program
- TAP-603, Training Administrate:ve Procedure, Revision 5, Technical Staff / Technical Manager Training Prograat
- Plant Operating Manual, Volume ll, Chapter VI, Laboratory Quality Control Plant Operating Manual, Volume 11, Chapter VII, Laboratory Measuring and Test Equipment Calibration Program
- Plant Operating Manual, Volume 11, Chapter XII, Miscellaneous Information
- CMP-14, Dissolved Oxygen (Chemet Kit Method)
- CMP-16, Chloride (Select Ion Probe Method)
- CMP-21, Fluoride (Select Ion Probe Method)
- CMP-61, Anions-Ion Chromatograph Method CL-100, Mettler Balance Calibration Procedure f
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A CL-180, Leem'en Plasma-Spectrometer Protocol and Instrument Calibration
- GC-6, Boron: Potentiometric Method - Low Level Boron Concentration
- GC-26, Lithium - Ion Chromatograph
- LI-28, Ion Chromatograph
- CMP-40, PAS and Analysis of Reactor Coolant and Containment Atmosphere CFIP-41, Reactor Coolant Liquid Post-Accident Sampling System Operating Procedure CMP-43, Post Accident Reactor Coolant Sample Transfer, Lab Setup, Isotopic and Chemical Analysis
- CMP-44, Analysis of Percent Hydrogen on Post Accident Containment Atmosphere
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