IR 05000373/1988005
| ML20151P038 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/19/1988 |
| From: | House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151P024 | List: |
| References | |
| 50-373-88-05, 50-373-88-5, 50-374-88-05, 50-374-88-5, NUDOCS 8804260071 | |
| Download: ML20151P038 (10) | |
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U.S. NUCLEAR REGULATORY COMISSION
REGION III
Reports No.
50-373/88005(DRSS); 50-374/88005(DRSS)
Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee:
Commonwealth Edison Company
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Post Office Box-767 Chicago, IL 60690 Facility Name:
LaSalle County Station, Units 1 and 2 Inspection At:
LaSalle County Station Site, Marseilles, Illinois Inspection Conducted:
March 2-10, 1988 (On-site)
March 18, 1988 (Telephone)
March 24, 1988'(Telephone)
Inspectors:
Nac
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Date
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E House M/Ap Date N/
Approved By:
M. C. Schumacher, Chief
/?MP Radiological Effluents and Date I
Chemistry Section
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Inspection Summary
. inspection on March 2-10, 18, 24, 1988 (Reports No. 50-373/88005(DRSS);
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No. 50-374/88004(DRSS))
Areas Inspected:
Routine, announced inspection of:
(1) the chemistry i
program, including procedures, organization, and training; (2) reactor systems water quality control programs; (3) quality assurance /quallt.y t
control program in the laboratory; and (4) nonradiolgical confirmatory
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measurements.
Results:
No violations or deviations were identified.
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8804260071 880419 PDR ADOCK 05000373 i
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OETAILS 1.
Persons Contacted
- G. J. Diederich, Station Manager, LaSalle County Station
- P. F. Manning, Assistant Superintendent, Technical Services LSCS
+*P. T. Nottingham, Lead Chemist, LSCS
- L. R. Aldrich, Rad / Chem Supervisor LSCS
- M. R. Huntington, Services Superintendent LSCS
- M. E. Burgess, Analytical Services Group, CECO
- A. C. Settles, Regulatory Assurance, LSCS
- 0. A. Winchester, Senior Quality Asurance Inspector, LSCS
- H. J. Harper, Quality Assurance Inspector, LSCS S. Wilkinson, Chemist, LSCS C. A. Wisniewski, Chemist, LSCS J. P. Terrones, Engineering Assistant LSCS L. Blunk, Training Instructor, LSCS The inspectors also interviewed other licensee personnel in various departments in the course of the inspection.
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- Denotes those present at the plant exit interview on Mat'ch 10, 1988.
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+ Denotes those present during the telephone conversations held March 18 and March 24, 1988,
2.
Licensee Action on Previous Inspection Findi,n_Es (Closed) Open Item (373/86028-02; 374/86029-02):
Examine progress of plant modifications affecting water quality control.
The licensee completed evaluation of ten items considered for modification to improve chemistry controls.
Seven (Items a.,
c.,
f.,
g.,
h.,
i., and j.) were
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judged unnecessary or not cost effective and are no longer being considered.
Item b., concerning valve replacements to reduce RWCU demineralizer trips,
is completed.
Item d, upgrading of chemistry process monitors is largely done; final work involving a microprocessor based conductivity monitor and
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l sample temperature control capability (Item e.) are to be completed during the third refueling outages for each unit.
(0 pen) Open Item (373/86028-05; 374/86029-05):
Review progress of QA/QC i
program.
Some improvement is evident (Section 6) in overall laboratory L
QA/QC which is reflected in improved performance in the station's performance in nonradiological confirmatory measurements (Section 5).
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I However, weaknesses persist in the program for periodic testing of
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individual technician (RCT) performance.
Corporate audit QAA 01-88-02, conducted in January 1988, noted that 14 of 38 RCT's had not received the i
annual proficiency check specified in Nuclear Stations Division Directive NSDD-525, "Nuclear Stations Chemistry Quality Control Program Manual."
In response to this audit, the station is to complete the proficiency
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checks by Merch 28, 1988.
During the current inspection, the NRC inspector j
confirmed that LaSalle Chemistry Procedure LCP 810-20 which 1.iplements
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this aspect of NSDD-S25 was not being completely implemented; the inspector further noted that the RCT's not checked were, in general, those working the back shift and that the training was not correlated with rotation of the RCT's into the laboratory after assigne.ents elsewhere.
This item will remain open pending resolution of this matter.
3.
Management Controls, Organization a_n_d,Trainino d
The inspectors reviewed the organization and staffing of the chemistry group.
At present, four chemists, a laboratory foreman, and an engineering assistant report to the Lead Chemist who reports to the Rad / Chem Supervisor.
Approximately 30 RCTs are supervised by the 1)boratory foreman.
Current staff, including RCTs, meet technical specification qualification requirements.
The chemists are not assigned to specific units but instead are assigned to oversee specific functional aspects of the chemistry program.
There are no formal backup assignments.
Without the redundancy provided by unit assignments, this is a weakness.
The licensee is looking to hire additional chemists and indicated that with additional staffing, unit assignments may be made.
The inspector's review of selected training records indicated good RCT attendance at continuing training sessions given throughout 1987.
The station's training program has received INPO certification.
The rad / chem foremen began attending these sessions in mid-1987, and the laboratory foreman began to do so at the beginning of 1988.
The records indicated that the foremen receive little refresher training on the newer chemistry instruments and procedures.
This is a weakness because it limits the ability of the foremen to supervise the backshift RCTs who are usually those with the least amount of plant experience.
During day shift, a chemist is normally present to provide guidance if needed.
RCTs rotation between health physics and chemistry continues to be a weakness.
Specialization is still contemplated and is expected to occur in the near future.
It should provide for better trained personnel.
No violations or deviations were identified.
4.
Water Chemistry Control Program The inspectors reviewed tne water chemistry control program which is based on N00-517, BWR Water Chemistry Control Program, July 25, 1987, Revision 2, and LAP 1800-7 January 18, 1988, Revision 3.
NOD-S17 is a
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i corporate directive that defines plant water chemistry control programs for the three BWR Stations.
The operational chemistry limits and action
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levels appeared generally consistent with the EPRI Water Chemistry
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Guidelines.
LAP 1800-7 contains instructions for implementing NOD-S17.
The licensee monitors water quality with in-line monitors for conductivity
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and dissolved oxygen.
Other parameters such as chloride, sulfate, and silica are monitored from grab samples by the chemistry laboratory.
The
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laboratory is generally well equipped with a Dionex Model 2020i Ion Chromatograph with a Hewlett Packard 3390 Integrator, a Beckman Spectra Span VI Direct Coupled Plasma Spectrometer, a Tracor Gas Chromatograph, an Orion 701 A lonalyzer, and an 0.I. Model 700 Total Organic Carben Analyzer.
An assigned chemist tracks systen chemistry with tabulated data front the chemistry laboratory.
The same data are entered into an offsite computer system from which trend charts can be generated.
However, the charts are not immediately available onsite and their use appears to be limited.
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The engineering assistant alco prepares trend plots of selected parameters using the data tabulated by the chemist, but again, the plots are not timely enough to be useful except in retrospect.
The licensee stated that equipment for continuous data recording from the in-line monitors has been acquired and will be installed during the next outage.
A review of selected data indicated that Units 1 and 2 have operated below actica Level 1 except for excursions during power changes or during startup/ shutdown conditions.
No violations or deviations were identified.
5.
Nonradiological Confirmatory Measurements The inspector submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to various Technical Specification and other regulatory and administrative requirements.
These samples had been prepared, standardized, and periodically reanalyzed (to check for stability) for the NRC by the Safety and Environmental Prote(. tion Division of Brookhaven National Laboratory (BNL),
The samples were analyzed by the licensee using routine methods and equipment.
The samples ware diluted by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate in a manner similar to that of routine samples.
Tr.e results are presented in Table 1 and the criteria for agreement in Attachment 1.
These criteria for agreement are based on comparisons of the mean values and estimates of the standard deviations (s.d.) of the measurements.
Consideration was given to the fact that the uncertainties (s.d.) of the licensee's results were not necessarily representative of the laboratory's because they were obtained by one analyst over a short period of time.
Consequently, when the licensee s.d. was less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the s.d. of the ratio Z (S, in Attachment 2).
The licensee also prepared two samples to be split with BNL.
To these were added analytes supplied by the inspector.
Reactor water was spiked with the anions, chloride, fluoride, and sulfate, and samples of condensate were spiked with the cations copper, iron, nickel, and chromium.
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licensee will determine the concentrations of the analytes in each and the results will be sent.to Region III for comparison with the values
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determined by BNL.
This will be followed under the Open Item No.
50-373/88005-01 and No. 50-374/88005-01.
The licensee analyzed 9 materials at three concentrations each.
Of the 27 analyses, 19 or 70% were in agreement with the BNL values.
Three analysis performed on the ion Chromatograph (high fluoride and low and high chloride) were in disagreement with BNL results.
The high
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biases exhibited in the disagreements may be due to inaccurate calibration
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curves or to the procedure used to load the sample on the column.
Two milliliters of saeple (or calibrator) are loaded by injection from a
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plastic syringe ento the column.
Yhese syringes do not provide quantitative delivery as do pumps or injection loops.
Moreover, the volume loaded is much less than is normally used, thereby magnifying errors in volume delivered.
The licensee is investigating calibration of the IC system and alt 1rnative sample injection systems.
Subsequent I
reanalyzes of those analytes in disagreement (ion chromatography)
resulted in some improvement in bias and were in agreement.
However,
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the standard deviations of the reanaly=es were considerably higher than on the initial run, and it appears that problems still exist with the IC.
The licensee's efforts to improve the system will be followed under Open Items C0-373/88005-02; 50-374/83005-02.
The boroa analyses resulted in one disagreement on the low standard.
The licensee attempted to modify the mannitol titration procedure normally used for higher concentrations samples from the Standby Liquid Control Tank.
Normally, a low level boron assay is only used to qualitatively screen the water in the system used for testing the SLC Tank.
Although
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in disagreement, the licensee's results obtained by ad hoc modification
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of the mannitol precedures differed by only 4% from the NRC values.
M tal analyses by Direct Coupled Plasma Spectroscopy resulted in four disagreements.
These were Copper (low, medium standards), Nickel
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(medium standard), and Chrome (low standard).
All disagreements showed a low bias which may have resulted from faulty calibration.
Subsequent reanalyzes of those metals in disagreement after recalibration showed agreements for all except for mid level nickel which was in disagreement by about 5%.
The inspectors observed petticipation of several day shift RCTs in the analyses of the confirmatory measurements samples.
The RCTs followed written procedures with.;a apparert difficulties.
No violations or deviations were identified.
i 6.
Implementation of the QA/QC Program in the Chemistry Laboratory
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l The inspectors reviewed the non radiologi u' QA/QC program in the
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laboratory which is defined by NSD Directivi NSDD-525, "Nuclear Stations Chemistry Quality control Program Manual," Revision 0, January 1987.
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Laboratory QA/QC appears to be improving.
The use of multiple point
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calibration curves for some analyses, controls, and improved control i
charts are improvements.
The licensee calibrates the ion chromatograph
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(HP 3390A integrator) daily using a 30 ppb standard followed by 5
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and 10 ppb performance check standards with acceptance limits of i 1 ppb.
i A 20 ppb control is then analyzed before and after the run with an
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acceptance criterion of i two standard deviations about the mean.
Including the controls before and after the run provides some indication of intrarun precision and instrument drift during the analysis.
However,
j there is a weakness in that all calibrators and controls are prepared i
from the same starting material.
The control should be prepared from o different manufacturer or, if from the same manufacturer, a different lot
number in order to provide an independent check.
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The licensee has an Interlaboratory Comparison Program based on and i
required by NS00-S25 Section 9.1.
A review of selected data from 1987, indicates that the licenste is in reasonably close agreement with SMAD
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samples.
The bias ranges from 0-36%, but 26 out of 30 samples are within 10%, 20 out of 30 are within 5%, and 4 analyses have a bias greater than 10%.
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l The licensee is also participating in a comparison program through a i
private vendor.
Two sets of unknowns have been analyzed and the results exhibited considerable biases, especially for chlor ice and
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l sulfate (fon chromatography).
Metals had much lower biases, 3-8%.
The vendor reports include data for all participants in the program.
The licensee's performance is representative of the overall variability for ali participants.
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The inspectors reviewed laboratory reagents and fot.nd them to be properly
labeled with no expired materials in use.
Instrument calibration logs j
are maintained with the instruments.
A maintenance record system is being developed.
No violationr or deviations were identified.
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8.
Open Items
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i Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee, or both.
Open items disclosed during the inspection are discussed in Section 5.
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9.
Exit Interview
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i The scope and findings of the inspection were reviewed with licensee
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representatives (Section 1) at the conclusion of the inspection on l
March 10, 1988.
The discussion focused on the Open Items of Section 5, laboratory QA/QC, and confirmatory measurements comparisons.
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Ouring the exit interview, the inspector discussed the likely inforraational
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content of the inspection report with regard to documents or processes
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reviewed by the inspector during the inspection.
Licensee representatives
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did not'. identify any such documents or processes as proprietary.
Attachments:
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Table 1, Nonradiological Interlaboratory
. Test ~Results, March 2-10, 1988 2.
Attachment l',-Criteria.for Comparing
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' Analytical Measurements (Nonradiological)
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TABLE 1 Nonradiological Interlaboratory Test Results LaSalle County Nuclear Generating Station Units 1 and 2 March 2-10, 1988 C
Analyte Analysfs Dilution NRC Licensee Ratio Comparison Method 1:x Y i s.d.(n)
X i s.d.(n)
Z t s.d.
1 2 s.d.
Concentration, ppb Floride IC 2000 11.25 i 1.0 (7) 10.33 1 0.29 0.918 1 0.086 A
2000 22.15 1 0.2 (7) 21.83 1 0.76 0.986 1 0.035 A
2000 41.4 1 0.85 (7) 44.33 1 0.29 1.071 1 0.030 D
Repeat 2000 41.4 1 0.85 (7) 39.5 i 1.0 0.954 1 0.031 A
Chloride IC 2000 9.25 1 0.05 (7) 11.43 1 0.6 1.236 1 0.065
2000 18.65 1 0.15 (7) 20.00 1 1 1.072 1 0.054 A
2000 38.25 1 0.6 (8) 41.00 1 0 1.072 1 0.023 D
(Repeat)
2000 9.25 1 0.05 (7) 11.0 1 1.5 1.189 1 0.162 A
(Repeat)
2000 38.25 1 0.6 (8) 41.0 11.9 1.072 1 0.052 A
Sulfate IC 2000 9.75 1 0.7 (7) 10.0
1.026 1 0.074 A
2000 19.15 i 1.35 (7) 19.5 1 0.5 1.018 1 0.076 A
2000 39.0 1 1.2 (9) 37.0 1 0.5 0.949 i 0.032 A
Silica Spec 1000 52.8 1 2.3 (7) 55.0 1 8.0 1.042 1 0.161 A
1000 104 1 4.0 (7) 100.0 1 0 0.962 t 0.037 A
1000 157 1 2.0 (7) 158.0 1 6 1.006 1 0.040 A
Iron DCP 100 0.186 1 0.005(7) 0.186 1 0.007 1.000 1 0.046 A
100 0.398 1 0.005(6) 0.372 1 0.021 0.935 1 0.054 A
100 0.585 1 0.015(7) 0.611 1 0.065 1.044 1 0.114 A
Copper DCP 100 0.200 1 0.003(7) 0.177 1 0.007 0.885 1 0.037
100 0.403 1 0.015(7) 0.359 1 0.009 0.891 1 0.049
100 0.60 1 0.015(7) 0.580 1 0.056 0.967 i 0.096 A
(Repeat)
0. 4 1 0.006(7) 0.395 1 0.003 0.988 1 0.017 A
(Repeat)
0.81 1 0.03 (7) 0.788 1 0.002 0.973 1 0.036 A
Nickel DCP 100 0.203 1 0.006(7) 0.185 1 0.013 0.911 1 0.069 A
100 0.417 1 0.007(7) 0.376 1 0.003 0.902 1 0.023
100 0.605 i U.025(7) 0.587 1 0.064 0.970 1 0.113 A
(Repeat)
0.834 1 0.014(7) 0.791 1 0.008 0.948 1 0.023 D
Chromium DCP 100 0.198 1 0.005(7) 0.181 1 0.002 0.914 1 0.034
100 0.385 1 0.005(7) 0.373 1 0.004 0.969 1 0.016 A
100 0.580 1 0.01 (7) 0.579 1 0.034 0.998 1 0.061 A
(Repeat)
0.396 1 0.01 (7) 0.398 1 0.005 1.005 1 0.028 A
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, Concentration, ppm Boron.
- Titr 1-1040 1 10:-(7)
997 * 6.5 0.959 1 0.013-D'
-1 3100 1 100 (7)
-2949 i 7
- 0.951 1 0.031 A
5000 i 90 (7)
4865 i 19 0.973 1 0.018-A (Repeat)
1040 1 10 (7)
985 i 3.5 0.947 1 0.013
a.
Value i-standard. deviation (s'.d.); n is number of BNI. analyses.
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The number of licensee analyses is threo unless otherwise noted.
A'alytical methods: Titr - titration b.
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- Ion thromatography Spec - Spectrophotometry SIP - Specific Ion Probe DCP - Direct Coupled Plasma Spectroscopy c.
A = Agreement D = Disagreement
- = Substitution of BNL uncertainty for licensee's uncertainty.
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ATTACHMENT 1 Criteria for Comparing Analyticai Measurements
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This attachment provides criteria for comparing results of the capabilit
/ he acceptance limits are based on the uncertainty (standard deviation) y tests.
T of the i ratio of the licensee's mean value (X) to the NRC mean value (Y), where (1) Z = X/Y is the ratio, and (2) S is the uncertainty of the ratio determined from the pfopagationoftheuncertaintiesoflicensee'smeanvalue, S, and of the NRC's mean value, S.1 Thus, x
y S2 s2 s2 F ~ V, V_, so that z _ x y
[S21 + s 2D Y
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S =Z*1 z
(X2 y2)
The results are considered to be in agreement when the bias in the ratio
' '(absolute value of difference between unity and the ratio) is less than or equal to twice the uncertainty in the ratio, i.e.
~ 1.1-Z l < 2*Sz'
1.
National Council on Radiation Protection and Measurements, A Handbook of Radioactivity Measure.1ents Procedures, NCRP Report No. 58, Second Edition, 1985, Pages 322-326 (see Page 324).
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4/6/87
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