IR 05000373/1986045

Insp Repts 50-373/86-45 & 50-374/86-45 on 861209-12,15 & 870105.Violation Noted:Failure to Use Collodion Solution That Was Current in Preparation of Planchets for Isotopic Beta Analysis of Reactor Coolant

ML20212R493
Person / Time
Site:	LaSalle
Issue date:	01/22/1987
From:	Holtzman R, Hueter L, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212R457	List: IR 05000373/1986045 ML20212R454 ML20212R465
References
50-373-86-45, 50-374-86-45, NUDOCS 8702020681
Download: ML20212R493 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

! Reports No. 50-373/86045(DRSS);50-374/86045(DRSS)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18

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Licensee: Commonwealth Edison Company Post Office Box 767

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Chicago, IL 60690 Facility Name: LaSalle County Station, Units 1 and 2 Inspection Conducted: December 9-12, 1986 (onsite)

December 15, 1986 (by telephone)

January 5, 1987 (by telephone)

Inspectors: $ o an VJt.1./77

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fhMxert 'O M. J. Destman Date

Date Approved By:

}{f M4 V M. C. Schumacher, Chief 2- 7 Radiological Effluents and Date Chemistry Section

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Inspection Summary Inspection on December 9-15, 1986 and January 5, 1987 (Reports

No. 50-373/86045(DR55); No. 50-374/86045(DR55)) .

Areas Inspected: Routine announced inspection of: (1) chemistry and radiochemistry, including water chemistry control, quality assurance /

quality control of sampling and analysis in the laboratory, observations of technicians' performance in the laboratory, and sampling facilities; (2) training and qualifications of chemistry staff; (3) licensee internal audits; and (4) review of previously identified open items.

Results: No violations or deviations were identified in four of the five a areas inspected. One apparent violation was identified in the area of

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chemistry / radiochemistry laboratory operation for failure to use a collodion

solution that was current in the preparation of planchets for isotopic beta

, analysis of reactor coolant, as required by Technical Specification 6.2.A.

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(Severity Level V, Supplement I)

8702020681 870123 ~

PDR ADOCK 05000373 Q PDR

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DETAILS Persons Contacted

1G. J. Diederich, Station Manager, LaSalle County Station (LSCS)

1R. D. Bishop, Services Superintendent, LSCS

, IF. R. Lawless, LSCS 1,3L. R. Aldrich, Rad / Chem Supervisor, LSCS

_ 1J. A. Schuster, Chemist, LSCS

1D. A. Winchester, QA Acting Supervisor, QA Department 1M. H. Richter, Technical Staff, LSCS Lead Chemist, LSCS 3 T. Nottingham, L. Blunk, Lead Rad / Chem Training I st Training Department, n ructor, '

LSCS R. Cozzi, QA Lead Auditor, QA De

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R. Klotz, GSEP Coordinator, Rad Chem/partment, Department,LSCS LSCS

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W. R. Hunnington, Assistant Superintendent, Operations, LSCS 3C. Wiesniewski, Chemist, LSCS 2M. Burgess, Analytical Chemistry Services, Ceco

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S. Hopewell, Chemistry Services Supervisor, CECO M. Henry, Rad / Chem Technician (RCT), LSCS

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R. Wingate, RCT, LSCS R. Kohlmann, Chemist, LSCS The inspectors also interviewed other licensee personnel in the course of the inspection, including those in chemistry and health physics.

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2 Denotes those present at the plant exit interview on December 12, 198 Telephone conversation on December 15, 198 Telephone conversation on January 5, 198 . Licensee Action on Previous Inspection Findings

, (Closed) Open Item (50-373/85003-01; 50-374/85003-01): Licensee

to inspect and repair radiological environmental monitoring program i (REMP) air samplers. During this inspection, the inspector checked

! air sampler L-02 and found no air in-leakage problems. This item is close (Closed) Open Item (50-373/86008-03; 50-374/86009-03): Calibrate gamma spectroscopy detectors for gas within two weeks after receipt of standard (March 11,1986). The licensee calibrated the detectors

l- as noted for the gas supplied vialgeometry,ics, Analyt Inc.)previously

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, usingthe However, because thedimensions 14-ml vendor-ofthisviald(ifferedsomewhatfromthoseofthelicensee'svial,

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the licensee determined their relative detection efficiencies by

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4 Inspection Reports No. 50-373/86008; No. 50-374/86009

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using each of these containers filled with the vendor's solid mixed

. gamma standar These efficiencies were identical within about 1%

over the energy ranges of 122 to 662 kev. This item is close (0 pen)OpenItem(50-373/86008-04;50-374/86009-04): Review licensee participation in radiological intercomparison programs. The licensee currently has no interlaboratory radiological comparison program, but a corporate program is being develo)ed, as discussed previously6 .

Licensee representatives expected t1e program would be implemented in January 198 This item will remain open until the inspectors can

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review the results.

i i (Closed) Open Item (50-373/86026-01; 50-374/86027-01): Licensee to thoroughly review 1985 semiannual effluent reports to identify and correct errors and establish an adequate review -)rocess for future reported data. The licensee completed a thorougl review of the 1985 semiannual radioactive effluent reports as well as the effluent i

data used to compile these reports. Errors in the reports were identified and corrected by an errata report dated October 31, 198 The larger errors identified appeared to have been in the conservative direction and no regulatory limits were approached as a result of correcting the data. To preclude recurrence and to provide an adequate review process for future reported data, additional training orts and two inde was reviews provided were established to the preparers (one by the of the Radrep / Chem Supervisor) pendent for future reports before publication. This item is close (Closed)OpenItem(50-373/85017-01;50-374/85017-01): Review licensee monitoring program for the Unit 2 condensate storage tank (CY-2) HPCS return line break of May 27, 1985, and for the subsequently determined Unit 1 CY-1 HPCS return line analogous but smaller leak, and the disposition of associated contaminated soi As noted in Inspection Reports No. 50-373/86026; No. 50-374/86027, the licensee had been in contact with NRR and planned to make a submittal to them pursuant to 10 CFR 20.203 for dis)osal by onsite burial of contaminated material associated with bot 1 the Unit 1 and Unit 2 condensate storage tank HPCS return line breaks. A licensee representative from the Technical Center in Maywood who has responsibility for the submittal stated that most of the submittal has been drafted except for the dose assessment portion and the ground water assessment portion. A contractor will be hired to provide needed input for the dose assessment and possibly the ground water assessment. The licensee representative estimated the contract would be awarded in February and the package would be

, completed about mid year 1987. This open item is considered close !

Further under newfollowups Open ItemsofN licensee 50-373 p/86045-01; No. 50-374/86045-01.rogress on bIbid

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_ . _ . . _ _ , _ , _ _ _ . _ . _ , _ . . . . _ _ . . . _ _ _ . _ . _ , _ , _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ , _ - _ _ _ _ _ _ . _ . . ~ ~ _ - _ , _ ~ _ _ _ _ . . . . _ . _ . _ _ (Closed) Open Item (50-373/86028-01; 50-374/86029-01): Determine the activities of Sr-89, Sr-90, Fe-55 and gross beta in a spiked liquid sample from RESL and send the results to Region III. The results of comparisons made on these four analyses are presented in Table 1. The comparison criteria are described in Attachment The results all are in agreement, although the licensee values are biased on the low side with respect to RES (0 pen) Open Item (50-373/86028-02; 50-374/86029-02): Examine progress of plant modifications affecting water quality contro During this inspection, the inspectors discussed with licensee representatives the status of ten plant modifications being considered by the licensee to implement the licensee's water chemistry control program. The licensee performed a study on detecting condenser tube leaks (item a) and determined that the existing on-line conductivity monitor is sufficient to detect tube leakage rather than install a new sodium anal A licensee vendor (NWT) also completed a study (item g) yze to determine the effectiveness of the condenser as a deaerator and found that no changes to the condenser were necessary to be made to remove dissolved oxygen. All the other modifications described in the previous report6are to be made in 1987. This item will remain open, pending completion of plant modifications to improve water qualit (Closed) Open Item (50-373/86028-03; 50-374/86029-03): Licensee to maintain the counting room at reasonable temperatures. During the previous inspection the inspectors found the counting room temperatures to be elevated (90 F and above) much of the tim This apparently affected the gamma saectrometers and the alpha-beta counters. The inspectors reviewed tie temperature records of this room since June 1986 and found the temperatures to be generally satisfactory, at about 72 This item is close (0 pen) Open Item (50-373/86028-05; 50-374/86029-05): Progress of the QA/QC program will be reviewed in subsequent inspection. The developments of this program are examined in Section (Closed) Open Item (50-373/86028-04; 50-374/86029-04): Review licensee followup on inspector observed RCT problems in water sampling. During a tour of the plant during this inspection, the inspections observed that the handles on the valve stems to sample radwaste tanks that were missing in the last inspection had been installed. In addition the plastic hose on the conductivity flow cell had been repaired so no air in leakage occurred to cause faulty conductivity measurements. This item is close (Closed)OpenItem(50-373/86028-06;50-374/86029-06): Review of the nonradiological interlaboratory crosscheck program. The licensee has a crosscheck program in which the corporate Technical Center 6 Inspection Reports No. 50-373/86028; No. 50-374/86029

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supplies blind samples to the nuclear plant laboratories. The results of the various laboratories are then compared with each other and with the known concentrations. The results of the third round(September 1986)overallappearedtobeaboutthesameas those in the previous one in June 1986. The metals and silica had less than a 9% bias, while those of fluoride and sulfate were 34 and 16%, respectively. Although the chloride results disagreed substantially with those of the reference laboratory, they were in good agreement among the laboratories with a relative standard deviation of 12% (apparently there were some errors in the reference laboratory results). These variabilities were similar to those in the previous set of samples in June 1986. At that time the results for chloride, fluoride biases, and the silicon, and some of the metals had slightly lowerand sulfat This program is valuable in demonstrating some of the laboratories'

analytical strengths and weaknesses. This item is closed and the

program will be followed as part of the QA/QC inspections (Section 6). Management Controls, Organization, Training and Qualification O

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Th'e inspectors reviewed the organization and staffing of the Chemistry

! Group and the changes that have occurred since the last inspection'

4 Two of the five chemists reporting to the Lead Chemist have left the Group and one new chemist has recently been hired. The licensee is

interviewing possible candidates for the one vacant position. Each chemist has a Bachelor of Science Degree in chemistry and is assigned specific responsibilities. Laboratory assignments of the Radiation Chemistry Technicians (RCTs) are made by the laboratory forema Because of the rotation of the RCTs between Health Physics and Chemistry resulting in a lengthy interval between assignments of the RCTs to the Chemistry Group, the chemists and laboratory foreman must provide close supervision of the RCTs to assure credible analytical results are obtaine The licensee has under consideration the recommendation to permanently assign the RCTs to one or the other Group but no firm decision has been mad Training for the seven new RCTs was comaleted in Septembe This brings the number of RCTs who have completed t1eir training to 3 The inspector reviewed the qualification cards involving performance of over 300 tasks,

' tor the new RCis and found they had been satisfactorily completed. An annual two-week retraining program involving discussion of revised and new procedures, operation of new laboratory instruments, and quality

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control will be presented starting in 1987.

I No violations or deviations were identifie . Water Chemistry Control Program The inspectors reviewed Revision 1 to the licensee's BWR Water Chemistry Control Program presented in NSD Directive NSDD-S17 dated August 25, 1986, and noted several changes to the revision (Revision 0) discussed in a

1. Ibid

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previous inspection8. They added sulfate as a key chemical parameter with limiting concentrations during different plant operating modes, which are consistent with the BWR Owners Group Guidelines, and they clarified action level definitions. A Variance Request Raport reguirement for corporate management permission to operate outside the administrative limits in the Directive has also been adde Some of the administrative limits are more restrictive than in Revision 0, such as the achievable value for dissolved oxygen in reactor feedwater/ condensate at power operation of 10 rather than 20 ppb. The licensee has set March 1, 1987 as the date when each BWR station is required to incorporate these requirements into its procedure. This item will be reviewed in a subsequent inspectio Open Items No. 50-373/86045-02; No. 50-374/86045-0 The inspectors confirmed that the station is implementing the licensee's Directive through procedure LAP 1800-4 " Rad / Chemistry Surveillarce,"

Revision 6, dated June 4, 1986, and LAP 1800-7, "BWR Chemistry Control Program," Revision 1, dated March 19, 1986. The licensee has established action levels for off-normal conditions and satisfactorily plots trends of key chemical parameters during, plant operation. The trended data for 1985 and 1986 reviewed during this inspection indicated that the station has been generally successful in operating within the guidelines and improvement in water quality over time was noted. Off normal levels of key chemical parameters were recognized, mitigated, and corrected in a timely manner. Implementation of the recommendations of the licensee's BWR Working Group to modify plant equipment and monitors discussed in the previous inspection" and in Section 2 should also further improve the water chemistry of the station. The licensee has also issued a manual onthissubject(datedNovember 17,1986) detailing saecifications for operation of each plant system to assure good water caemistry of each system. A review of this document revealed no problem No violations or deviations were identifie . Chemistry and Radiochemistry Laboratory The inspectors observed RCTs collect samples and perform various chemical and radiochemical analyses. They appeared generally knowledgeable and well versed in procedures and laboratory practices. However, one problem was note During pre)aration of the planchets for isotopic beta analysis of reactor coolant on )ecember 10, 1986, the RCT used a collodion solution to cover the sample on the planchet in which the bottle had a label dated November 28, 1986 as the date of expiration. Licensee Procedure LCP 110-2,

" Preparation or Reagents " Revision 8, December 3, 1986, prohibits the use ofpreparedreagentshavInganexpiredshelflif This is a violation of Technical Specification 6.2.A which requires adherence to procedure (Violation 50-373/86045-03;50-374/86045-03).

One violation was identifie " Ibid WIbid

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6. Implementation of the QA/QC Program in the Chemistry Laboratory The Chemistry QA/QC Program The inspector reviewed the non radiological chemistry QA/QC program described in the procedures and implemented in the laboratory. The program is based on the following Procedures:

LCP 810-19, " Analyses of Quality Control Samples in the Chemistry Laboratory," Revision 0, May 16, 1986, and LCP 810-20, " Rad-Chem Technician Semi-Annual Proficiency Check," Revision 0, May 15,198 Instrument )erformance is monitored regularly with check samples, usually witi concentrations near the upper and lower limits of the analytical ranges, for analyses including pH, high-level boron, turbidity, silica, chloride, and anions and gases using ion and gas chromatograph Technician and procedure precision performances are also monitored with blind sam with each set of determinations. ples and samples These duplicateare analyses done standards from ERA, and chemistry supervisio various sources, To demonstrate including procedure EPA,ility, the differences between the variab values from the duplicate measurements are plotted, along with control limits based on standard deviations. The inspectors discussed the possibility of using control charts based on actual control sample data to better maintain and demonstrate the stability of the procedure The results of the duplicate and blind sample tests are also used to assess RCT proficiency semiannually, as required by Procedure LCP 810-20. For these the QC Chemist tabulates the results of one set of the blind samples for chloride, pH and silica analyzed during the proper time interval. This is satisfactory but, as the inspectors discussed with licensee representatives, the licensee has a large amount of RCT proficiency data, not only on these, but also on other analytical procedures. However, much of it is apparently not used in the assessment of the RCTs. The inspectors suggested that the data from each RCT be collected and tabulated separately for each individual to allow for better assessment of each RCT by the chemists and to improve the credibility of the results, Interlaboratory Comparisons The licensee aarticipates in an interlaboratory comparison program operated by tie corporate Technical Center. The results are presented in Section 2 Non-radiological Confirmatory Measurements The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor chemical parameters in various plant

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systems relating to various Technical Specifications and other regulatory and administrative requirements. These samples had been prepared and standardized for the NRC by the Safety and Environmental Protection Division of Brookhaven National Laboratory (BNL). The samples were analyzed by the licensee using mostly routine methods and equi) ment, although some of the methods were still being evaluated by tie license The samples were diluted as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate along with routine samples. The results are presented in Table 2 and the criteria for agreement in Attachment 2. These agreement criteria are based on comparisons of the mean values and estimates of the standard deviations of the measurements. The licensee achieved nine agreements in 17 comparisons. Plasma spectrometer (DCP) analyses of metals gave three disagreements in nine comparison with licensee values low by 2 to 81 The bias was consistent with low values observed with the licensee's 1 ppm standard run afterwar Ion chromatograph (IC) analyses for anions showed five disagreements in six comparisons with licensee values high by 30 to 70% except fluoride which was not detected owing apparently to elution problems and the loss of its peak in the water pea These problems were discussed with licensee representatives at the exit interview and by telephone on December 15, 1986 and January 5, 1987. Licensee representatives could not explain the disagreement They indicated confidence in their calibration of the DCP and are investigating the possibility of a systematic error in sample preparation which they believe caused the disagreements in the metals analyses. They stated that the IC fluoride problem was first observed about a week before the inspection and was being investigated to determine if elution schedule changes were neede The possibility of a defective column was also beinc considere NRC representatives noted that use of a single stancard stock solution for both calibrations and performance checks was a poor QC 3ractice as it could cause failure to distinguish between pro)lems with the standards and with the instrument Overall,thelaboratoryQA/QCprogramshowsimprovementwithbetter accumulation of performance data on analytical measurements and RCT proficiency. However, assessment of this data is weak and needs considerable improvement, including better use of control charts. The licensee's chemistry staff would probably benefit considerably from additional training in Quality Control and statistic Nonradiological confirmatory measurements comparisons during this inspection indicated significant problems in licensee use of the IC, which and lesser is scheduled problems to become in use the primary of the DC Similarmethod forwere problems anionindicated analyses,in the

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stations performance in the interlaboratory comparison program. Licensee efforts to improve the laboratory QA/QC program will continue to be followed under Open Items No. 50-373/86028-05; No. 50-374/86029-0 No violations or deviations were identifie . Licensee Internal Audits and Surveillances The inspectors reviewed one onsite audit (QAA-01-86-25, September 16-19, one offsite audit (QA 01-86-I1 9-12,1986); and seven 1986);llances(QAS 01-86-107,131,145, survei September 186, 235, 253 and 266) relating to chemistry performed by the onsite and offsite QA Department personnel during 1986. The inspector reviewed the responses by the licensee to ,

each finding and observation and determined that the licensee has taken appropriate actions to close all findings and observations in a timely manne The inspector noted that the licensee adequately responded to the inspector's concerns regarding one open item from the offsite audit concerning missing supporting documentation on chemical samples referenced in Procedure No. LAP 500-14 and a deficiency regarding clarification of Procedure No. LCP 150-3 pertaining to instrument calibration. These items were properly closed ou No violations or deviations were identifie . Open Item Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or both. Open Items disclosed during the inspection are discussed in Sections 2, 4, and . Exit Meeting The inspection scope and findings were reviewed with licensee representatives (Section 1) at the close of the inspection on December 12, 1986 and in followup telephone discussions on December 15, 1986 and January,5, 198 Licensee representatives acknowledged inspector concerns regarding confirmatory measurements disagreements and committed to work on resolution of the problems. They also ac(nowledged inspector concerns regarding the need for further QA program improvements and the desirability of additional staff training in quality control and statistics.

i During the inspection, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee representatives did not identify such documents or procedures as proprietary.

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Attachments: Table 1, Confirmatory Measurements Attachment 1, Criteria for Comparing Radiological Analytical Measurements Table 2, Non-Radiological Interlaboratory Test Results Attachment 2, Criteria for Comparing Non-Radiological Analytical Measurements

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I TABLE 1 U S NUCLEAR REGULATORY COMMISSION I

OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM FACILITY: LASALLE CNGS FOR THE 4 OLIARTER OF 1986

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NRC------- ----LICENSEE---- ---LICENSEE NRC----

i SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T (

L SPIKED SR-89 1.1E-04 3.0E-06 8.8E-05 0.0E-01 7.7E-01 3.8E 01 A SR-90 1.1E-05 4.0E-07 9.4E-06 0.0E-01 0.8E-01 2.7E 01 A FE-55 6.7E-05 1.3E-06 5.6E-05 0.0E-01 8.3E-01 5.1E 01 A

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G BETA S G BETA 1.8E-05 9.0E-07 t.4E-05 0.0E-01 7.8E-01 2.0E 01 A T TEST RESULTSt ,

, AoAGREEMENT D= DISAGREEMENT

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o= CRITERIA RELAXED N=NO COMPARISON (

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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra .

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In these criteria, the judgment limits are variable in relation to the comparison of the NRC's value to its associated one sigma uncertainty. As that ratio, referred to in this program as " Resolution", increases, the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement should be considered acceptable as the resolution decreases. The values in the ratio criteria may be rounded to fewer significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE

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Agreement

<4 0.4 - .5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 200 - 0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides. These may be factored into the acceptance criteria and identified on the data sheet.

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TABLE 2 Non-Radiological Interlaboratory Test Results LaSalle County Station, Units 1 and 2 December 9-12, 1986 Chemical NRC Licensee Ratio Parameter Method YiSy(m)a XiSx iSz Comparison b Concentration, ppb Chloride IC 12.0 1 .50 1 0.26 A 20.1 1 0.55 37 1 1 1.84 1 0.06 0 Fluoride IC 11.6i0.25(7) <5 D 21.8 1 0.95(8) <5 0 Sulfate IC 10.0 1 .7 i .27 1 0.09 D 20.5 1 .0 1 2 1.56 1 0.11 D Silica Color- 54.3 1 5.6 (7) 58 1 .068 i 0.110 A metric 320 110(7) 315 i 1 0.984 1 0.031 A l Concentration, ppm Boron Mannitol 985i10(7) 1003.7 1 .019 i .010 A l titration

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Copper DCP 0.48610.024(12) 0.451 1 0.02 0.928 1 0.072 A 1.45 10.06(13) 1.420 1 0.049 0.979 1 0.053 A

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Iron DCP 0.489 1 0.035 6) 0.433 1 0.033 0.886 1 0.093 A 1.47 1 0.042 13) 1.331 1 0.040 0.905 1 0.038 0 Chromium DCP 0.51 1 0.03 6 0.469 1 0.0072 0.920 1 0.056 A 1.43 1 0.08 6 1.357 1 0.0067 0.950 0.053 A Nickel DCP 0.50910.026(6) 0.458 1 0.006 0.900 1 0.047 D 1,53 10.04(6) 1.402 1 0.020 0.916 i 0.027 0 i

' Number of replicate analyses done by BNL; licensee did three

replicate analyses, except for the boron which was done in

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ATTACHMENT 2 Criteria For Comparing Analytical Measurements This attachment provides criteria for comparing results of capability test In these criteria the ratioofthelicensee'judgmentlimitsarebasedontheuncertaintyofthe s value to the NRC value. The following steps are performed:

(1) the ratio, Z, of the licensee's value, X, to the NRC value, Y, is computed Licensee Value (ratio = NRC Value )

(2) the uncertainty of the ratio is propagate If the absolute value of one minus the ratio is less than or equal to twice the ratio uncertainty, the results are in agreement. (ll-ratial < 2 -

uncertainty)

X Sz2 = Sx2 + sy2 Z = Y, then Z2- F yr-(From: 2Bevington, P.R., Data Reduction and Error Analysis for the Physical Sciences, McGraw-Hill, New York, 1969)

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