IR 05000373/1989009

Insp Repts 50-373/89-09 & 50-374/89-09 on 890403-06 & 11.No Violations Noted.Major Areas Inspected:Chemistry Program, Including Procedures,Organization & Training,Reactor Sys Water Quality Control Programs & Qa/Qc Program in Lab

ML20246C738
Person / Time
Site:	LaSalle
Issue date:	05/01/1989
From:	Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246C735	List: IR 05000373/1989009 ML20246C731
References
50-373-89-09, 50-373-89-9, 50-374-89-09, 50-374-89-9, NUDOCS 8905100023
Download: ML20246C738 (11)

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U.S. NUCLEAR. REGULATORY COMMISSION

REGION III

Reports No'. 50-373/89009(DRSS); 50-374/89009(DRSS)

Docket.Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18 Licensee: Commonwealth Edi. son Company

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Post Office Box 7.67 *

Chicago, IL 60690 Facility Name: LaSalle County Station, Units 1 and 2-Inspection At: LaSalle County Station Site, Marseilles, Illinois Inspection Conducted: April 3-6 and 11, 1989 (Onsite)

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' Inspectors: R Date '

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J. E. House [ ~ 4 ~~ f 7 Date h. b am.a. oho ,

M.C.d.humacher(Aril11,only) 0 -t - os Date 0. M A- _

Approved By: M. humacher, Chief 3-/-86 Radiological Controls and Date Chemistry Section Inspection Summary Inspection on April 3-6 and 11, 1989 (Reports No. 50-373/89009(DRSS);

No. 50-374/89009(DRSS))

Areas Inspected: Routine announced inspection of: (1) the chemistry program

' including procedures, organization and t aining (IP 84750); (2) reactor system 5 water quality control programs (IP 84750); (3) quality assurance / quality control program in'the laboratory (IP 84750),(4) nonradiolgical confirmatory measurements-(IP 79701); and (5) the Radiological Environmental Monitoring Program (REMP) (IP 84750). .

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Results: The licensee has separated the technicians into chemistry and

. radiation protection group The water quality control program conforms to the EPRI Steam Generator Owners Group Guidelines. Overall water quality appeared to be adequate. Performance in nonradiological confirmatory measurements comparisons was good. Laboratory QA/QC was generally improved but weaknesses in the boron assay exist. The licensee was in the process of correcting these problems. The REMP appeared to be working satisfactoril No violations or deviations were identifie \

8905100023 890501 PDR ADOCK 05000373 {

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DETAILS Persons Contacted

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

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• P.F. Manning, Asst. Superintendent, Technical Services, LSCS

• L.R. Aldrich, Rad / Chem Supervisor, LSCS

• W.R. Huntington, Services Superintendent, LSCS

.*J.C. Renwick, Production Superintendent, LSCS

• J. Walkington,- Services Director, LSCS

• J.A. Schuster, Chemist, LSCS ,

• C. A. Wisniewski, Chemist, LSCS

• S.R. Hopewell, Nuclear Chemistry Supervisor, CEC 0

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• R.C.-Supple, Chemist, CECO

• T.J. Benoit, Quality. Assurance, CECO

• T.A. Hammerich, Regulatory Assurance Supervisor, LSCS 5.-Wilkenson, Chemist, LSCS  :

D. Rhoades, Chemist, LSCS i K. Klotz, GSEP Coordinator, LSCS D. 0 sterling, Chemistry Technician (CT), LSCS K. Lyons, CT, LSCS

• R. Kopriva, Resident Inspector, NRC  !

• M.C. Schumacher, Chief, RCC Section, Region III, NRC The inspectors also interviewed other licensee personnel in various departments in the course of the inspectio l

• Denotes those present at the plant exit interview on April 11, 198 ] Licensee Action on Previous Inspection Findings (IP 92701) (Closed) Open Item (50-373/86028-05; 50-374/86029-05): Review QA/QC Program including precision, bias and RCT performance testing. The j licensee's overall quality assurance program has improved since the i previous inspection. Control charts have statistical bases, the technician testing program reflects the corporate QA guidelines and'

laboratory analyses have generally. improve (Closed) Open Item (50-373/88005-01; 50-374/88005-01): Licensee to spike reactor water with anions, feedwater with metals, split samples with BNL, analyze and send results to Region III. The licensee has completed the sample splits with BNL (Table 1) and all six analyses were in agreement by the criteria of Attachment 1 (Section 5). (Closed) Open Item (50-373/88005-02; 50-374/88005-02): Licensee to improve the operation of and QA procedures for the Ion Chromatograp (IC). Additional equipment has been acquired and integrated into the IC, including pump injection and multiple point calibration curve Analytical results for the BNL unknowns (Section 5, Table 2) indicate improved performance of the IC syste __ _ - -_ _ .

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2 Management Controls, Organization and Training (IP 84750)

The inspectors reviewed the organization'and.' staffing of the chemistry group. The laboratory management is.similar to that observed in the previous inspection.1 The Rad / Chem technicians have been formally divided into two groups with 13 technicians permanently assigned as Chemistry Technicians (cts). This appears to have improved stability in the laboratory and should reduce the work load of the chemists in training and. retraining the cts. Licensee representatives stated that the 13 cts are qualified under the ANSI N18.1-1971 Standard and that a technician not meeting this qualification would always be working under the guidance of a qualified technicia The licensee has made some progress in providing backup capabilities

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within the chemistry organization. A chemist has been assigned responsibility for each unit. Backup for chemists having responsibility in functional areas is improving. Progress in this area will be followed in subsequent inspection No violations or deviations were identifie . Water Chemistry Control Program (IP 84750)

The inspectors reviewed the water chemistry control program which is similar to that from the previous inspection in this area.2 The operational chemistry limits and action levels appeared to be generally consistent with the EPRI BWR Owners Guideline The licensee monitors water quality with inline monitors for conductivity and dissolved oxygen. Other parameters such as chloride, sulfate and silica are monitored from grab samples by the chemistry laboratory. New digital monitoring instrumentation to replace the older analogue monitors has been acquired and will be installed at upcoming outages. Real ' time information.from these devices will also be available in the control room and'for computer storage and analysi A chemist reviews the collected and tabulated laboratory data dail Extensive trend charts, which also include reactor power levels, are available for the assessment of plant water quality in various systems, including reactor coolant specific conductivity, silica, dissolved oxygen, sulfate, and radioactivity parameters; similar charts are maintained for condensate and polisher effluents and feedwater. The timeliness of the charts has improved 3 as they are now produced weekly in the plan A review of selected data indicated that Units 1 and 2 have operated below Action Level 1, except for excursions during power changes or 1 Region III Inspection Reports No. (50-373/88005; 50-374/88005)

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during startup/ shutdown' conditions. . One problem noted was that silica concentrations in Unit I reactor coolant increase steadily from 10-250_ ,

ppb cver several. days and decreases after polisher bed' regeneratio Another problem was that the dissolved oxygen levels in reactor fee'dwater-were about 20% above the EPRI-recommended range of 20-50 ppb. The licensee is investigating this to determine the source of the excess oxygen, and its'

significance, as'shown by possible increases in corrosion product E No violations or deviations were identifie . Nonradiological Confirmatory Measurements (IP 79701)

The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities _ to monitor nonradiological chemistry parameters in various plant systems with .

t- 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 Radiological Sciences Division of Brookhaven National Laboratory (BNL). The samples were analyzed by the licensee using routine methods and equipmen The. samples were diluted by licensee personnel as necessary to bring the-concentrations within the ranges normally analyzed by the laboratory, and-run in triplicate in a manner similar to that of-routine sample The-results are presented in Table 2 and the criteria for agreement in Attachment These criteria are based on comparisons of.the mean values and estimates of the standard deviations (SD) of the measurement Consideration was given to the fact that the uncertainties-(SD) of the licensee's results are not necessarily representative of the laboratory's when they are obtained by one analyst over a short period of tim Consequently whun the licensee SD was less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the SD of the ratio Z (S in Attachment 1).

Further,whentheBNLSDappearedtobeexcessivIlylowforagiven analytical method, a value of 3%-relative SD (RSD) was. substituted for l- the SD The licensee also prepared a spiked sample of reactor water to be analyzed and split with BNL. Reactor water was spiked with the anions chloride, fluoride and sulfat The licensee will determine the concentrations of the analytes and report the results to Region III for comparison with the values determined by BNL. This will be followed under Open Item Nos. (50-373/89009-01; 50-374/89009-01).

The licensee determined nine' analytes at three concentrations each, and achieved agreement in 21 of 25 analyses (84%). The two lower-level boron results were excluded from this asse;sment (see below). The low and middle level silica results were in disagreement and the_high level, although an agreement, showed a substantial negative bias. These came into agreement after rerunning at a lower dilution, although a bias persisted. The middle level chloride was also in disagreemen Following reanalysis of the silica and chloride samples and reassessment of the boron data the licensee had all agreements-(100%).

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Analyses of the two lower-level boron samples showed biases of about 5%.

• This bias is substantial.when consideration is given to the inherently high precision of the mannitol-boron titration method and that this analysis is a Technical Specification requirement with a relatively narrow range of allowed boron concentration However, since the values reported by this licensee are similar to those from the other laboratories in Region III these are considered to be agreements, as shown in Table While the boron results were in agreement with those of the other laboratories by the criteria of this program, they still had a persistent negative bias of about 1.5%. Further, this bias is consistent with that derived from some 78 licensee quality control measurements used 'n the determination of the sodium pentaborate concentrations in the SBL These measurements on the nominal 1000 ppm boron performance check standard had a mean value of 987 1 0.8 (standard error, n=78),

which by Student's t-Test is statistically below 1000 ppm (p<0.005).

The source of the difficulty appears to be a lack of proper assessment of

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the QA/QC data (performance check results), a lack of control charts, and to deficiencies in the analytical procedure LCP-110-9, " Determination of High Range Boron (Sodium Pentaborate)," Revision 10, December 12, 198 During the inspection the licensee initiated an investigation of this problem by conducting laboratory measurements of boron concentratio Licensee representatives noted that they will revise the procedure, iuplement control charts and assess the QC data more carefull Progress in this area will be followed under Open Item Nos. (50-373/89009-02; 50-374/89009-02).

No violations or deviations were identifie . Implementation of the QA/QC Program in the Chemistry Laboratory (IP 84750)

The inspectors reviewed the nonradiological chemistry QA/QC program which is defined by " Nuclear Operations Chemistry Quality Control Program",

Revision 3, January 16,1989. Elements of the QA/QC program are in place and overall laboratory QA/QC appears to be improvin Multiple point calibration curves, independent controls and improved control charting of assays (except boron-Section 5) have contributed to the progra Selected data from the licensee's Interlaboratory Comparison Program (required by the corporate Q/A program) were reviewed and the analytical results showed reasonable agreement with those of the corporate Technical Center (TC) in that approximately 85% of the analyses were within 10%

of those of the TC. The licensee also participated in a comparison program through a private vendor (NWT). A review of selected data showed a somewhat poorer comparison with only 60% of the results within $ 10% of those of the vendor. Licensee data represent values for single analyses and might have been more representative of the unknown if multiple runs were reported. The licensee's performance is comparable to that of other participants in the vendor's program. This program is useful and should assist the licensee in monitoring the overall QA program and provide a means of comparison with the performance of other licensee _ _ - - _ _ _ _ - _ . . _ . A

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The licensee is required by the corporate QA/QC program to maintain a CT performance testing program. A review of selected records indicated that the cts are being tested in accordance with program guidelines. The l acceptance criterion currently used is i 20L A licensee representative

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stated that this criterion will be converted to't 2 standard deviations when sufficient data have been collected. The separation of technicians

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into two groups, radiation protection and chemistry technicians, has i facilitated the technician testing program and provided a more stable laboratory environmen ..

Ion Chromatography instrumentation has been upgraded to include three Dionex systems with computer interfaces. The inspectors noted that the laboratory still ~uses an obsolete photocolorimeter for the silica analysis. This instrument lacks the sensitivity'available with modern spectrophotometers and may have been partly responsible.for two silica disagreements (Section 5). A recent corporate assessment of the chemistry area (Section 8) suggests that this instrumentation should be upgrade During the inspection, licensee representatives stated that a' prop'osal had been made to the corporate Laboratory QA Committee to recalibrates certain instruments only when performance checks were outside the control limits of i 2 standard deviations. The inspectors noted to the licensee representatives that this would be a poor QA practice and could lead to a deterioration of analytical performance. As this proposal could result in degradation of the laboratory QA/QC program it will be followed under Open Item Nos. (50-373/89009-03; 50-374/89009-03).

The inspectors observed several chemistry technicians analyze the confirmatory measurements samples without apparent difficultie During the analyses the technicians.followed written procedure Laboratory reagents were properly labeled and no expired materials were observed. Calibration logs are maintained with the instrument Overall, the nonradiological QA/CA program for the laboratory appeared to be developing well and, the laboratory appeared to.be adequate for the proper operation of the plant and to be operating satisfactoril No violations or deviations were identifie . Radiological Environmental Monitoring Program (REMP) (IP 84750)

The inspectors reviewed the REMP, including the 1987 Annual Environmental Report, the January-December 1988 monthly environmental progress report and-the air sampling station The Annual Environmental Report appeared to comply with the REMP requirements. All of the required samples were collected and analyzed, except as noted in the report, and a perusal of the results showed them to be reasonable. This report and the cumulative 1988 Progress Report appeared to be acceptabl !

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The inspectors toured the air sampling stations around the plant'and

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observed a licensee representative demonstrate the testing of the air samplers,'and-check the systems for operability and leakage of the sampling-train. The pump and filter train on the air samplers on'the seven observed stations appeared to be operating satisfactorily, both with respect to vacuum and flowrate. Each had the latest calibration record attached. The licensee representative agree to check with the corporate REMP supervisor on corporate policy on.the test procedur This will be followed in. subsequent routine REMP inspections. The REMP appeared to be operating satisfactoril No violations or deviations were identifie . . Audits and Appraisals (IP 84750)

The inspectors reviewed the most recent corporate assessment of chemistry,- l PMZ-88-003, September 12-16,-1988. The evaluation appeared to be thorough and a number of deficiency items were described which did not require a-written. response. However, the inspectors noted to the licensee that the item regarding upgraded instrumentation for silica analyses (Sections 5 and 6), due to inadequate sensitivity, should have required a written respons No violations or deviations were identifie . Open Items 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 5 and . Exit Interview (IP 30703)

The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on April 11, 1989. The inspectors discussed the Open Items in Sections 2, 5 and 6 plus observations on the quality control program, confirmatory-measurements, and in particular, the problem and corrective measures in the boron analysi During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee representatives did not identify any such documents or processes as proprietar Attachments: Table 1, Nonradiological Interlaboratory Split Sample Results, August 1988 2. ' Attachment 1, Criteria for Comparing Analytical Measurements (Nonradiological) j 3. Table 2, Nonradiological Interlaboratory Test Results, LaSalle County Station, April 3-11, 1989 l

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TABLE 1 Interlaboratory Split Sample Results LaSalle County Station

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Analyte Analytjcal NRC Licensee Ratio Comparison Method Y i SD X i SD Z i SD i 2 SD Concentration, ppb f Reactor Coolant Water Chloride IC 51.5 1 .0 i .049 0.033 A Sulfate IC 48.3 1 .0 2.6 1.035 0.054 A i Feedwater Iron DCP 229 10 231 2 1.009 0.009 A Copper DCP 228 i6 243 2 1.066 1 0.038 A*

Nickel DCP 247 10 247 12 1.000 1 0.008 A Chromium DCP 259 i1 244 2 0.942 1 0.040 A+ Analytical method:

IC Ion chromatography DCP Direct current plama spectrophotometry Comparison:

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• Uses BNL value for S +Uses 3% RSD for S l I

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ATTACHMENT 1 j

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Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing results of_ the capability test .

i The acceptance limits are based on the uncertainty (standard deviation) of the 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, Sy .1 Thus,  ;

x 52 S2 z _ x S2 y_, so that Y ~ Y * _Y'

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=Z*l[S*2- + Y (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, .

l 1-Z l 1 2*S 7 National Council on Radiation Protection and Measurements, t

A Handbook of Radioactivity Measurements Procedures, NCRP Report No. 58, Second Ldition, 1985, Pages 322-326 (see Page324).

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TABLE 2 Nonradiological Interlaboratory Test Results LaSalle County Station April 3-11,'1989 c

Analyte- Analytigal NRC' Licensee Ratio Comparison Method Y i SD .X11 SD 2 1.SD i 2 SD '

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Concentration, ppb Chloride' IC '3.70 1 0.02' 4.20 1 0.26 1.135 i 0.071 A- ,

7.46 i 0.12 8.37'i 0.15 1.122 1 0.027 D l

'. .15.30 i 0.24 16.00 1. 0.60 1.046 i 0.043 A ,

.(rcrun). 7.46 1 0.12' 7.63 1 0.15 1.023 0.026 !

Fluoride IC 4.50 1 0.40 4.23 i 0.06 0.940 1 0.085 A

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8.46 1 0.16 8.33- 0.75 0.985 i 0.091 A 16.56 1 0.34 16.50 1 0.40 0.996 0.032 A

. Sulfate I .90 1 0.28 4.30 i' O.30 1.103 1 0.110 A 7.66 1 0.54 8.77 1 0.32 1 145.1 0.091

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15.60 1 0.46 16.70 1 0.25 1.071'i 0.035 A  !

Fe DCP 372 1 10 405 14 1.089 1 0.048 A 796 1 10 791 1 16 0.994 1 0.024 A 1170 1 30 1170- 't 13 1.000- 0.028 A Cu DCP 400 i 6 390 1 5 0.975 1 0.019 A  !

806 1 30 783 i 8 0.971 0.037 A

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1200 i 30 1155 1 3 0.963 1 0.024 A N DCP 406 t'12 391' i 6 0.963 1 0.032 A 834 i 14 776 i 9 0.930 1 0.039 A+

1210, t 50 1166 1 15 0.964 i 0.042 A C DCP 396 .i 10 392 1 3 0.990 1 0.026 A 770 1 10 765 1 4 0.994 i 0.014 A 1160 20 1144 1 3 0.986 0.017 A I Silica' Colr 26.4 i .0 0 0.833 i 0.062 D* l 52 -

2 46 1 1 0.885 1 0.048' D* I 78.5 i .3 2.2 0.921 1 0.040 A+

(rerun)- 52.8 1 2. 8 . 49 i 0 0.928.1 0.056 A

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104 1 4 100 1 0 0.962 1 0.040 A

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