IR 05000382/1983010
| ML20024C249 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/11/1983 |
| From: | Crossman W, Murray B, Nicholas J, Wise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20024C243 | List: |
| References | |
| 50-382-83-10, NUDOCS 8307120447 | |
| Download: ML20024C249 (50) | |
Text
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APPENDIX U. S. NUCLEAR REGULATORY COMISSIGH
REGION IV
NRC Inspection Report:
50-382/83-10 License /CP:
CPPR-103 Docket:
50-382 Licensee:
Louisiana Power and Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Facility Name: Waterford 3 Inspection At:
Taft, Louisiana Inspection Conducted:
February 28-March 3, 1983
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Inspectors:
6 9/P3
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Blair Nicholas, Radiation Specialist Date wu
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Russell Wise, Radiation Specialist Date kk3 Approved:
42 4 /
~Date Blaine Murray, Chief,/ Facilities Radiation.
Protection Section
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Reviewed:
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W. A. Crossman, Chief, Reactor Project Section 8 Date Inspection Summary Inspection conducted February 28-March 3, 1983 (Report 50-382/83-10)
Areas Inspected:
Routine, announced preoperational inspection of the licensee's chemistry / radiochemistry program including organization, staffing and staff qualifications, training program, radiochemistry program, secondary chemistry program, chemical inventory program, primary chemistry sampling system, secondary chemistry sampling system, postaccident sampling system, effluent releases, facilities and equipment, laboratory instrument calibration and quality control, audits and review of chemistry / radiochemistry activities, administrative and F307120447 830523 PDR ADOCK 05000382 Q
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4 analytical procedures, and independent confirmatory measurements using the Region IV mobile countir.g laboratory for onsite comparisons of standards and sample results.
The inspection involved a total of'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> onsite by two NRC inspectors.
Results:.Within the 15 areas inspected, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted Louisiana P,pwer and Light Company (LP&L)
- S.
A. Alleman, Assistant Plant Manager D. E. Adams, Nuclear Project Support Group, Technical Services, Chemistry / Radiochemistry S. Sradford, Technical Specialist
- G.
L. Dolese, Radiochemistry Supervisor J. Ellis, Radiochemistry Technician M. Llewellyn, Acting Secondary Chemistry Supervisor
- J. R. McGaha, Technical Support Superintendcnt
- W. M. Morgan, Quality. Assurance Engineer
- W.
N. Perry, Chemistry Engineer C. J. Toth, Training Manager - Nuclear Others Contacted W. He11ums, Acting Training Supervisor, HP/ Chemistry Training, Nuclear Support Services,'Inc.
M. O'Neal, Training Instructor, Chemistry, Engineering Data Systems -
Nuclear
- Denotes those present during the exit briefing on March 3, 1983.
The NRC inspectors also interviewed several other Waterford 3 (WF 3)
station personnel during the inspection.
2.
Scope cf Inspection The purpose of this inspection was to review the licensee's progress in the chemistry / radiochemistry program for the period May 15, 1982, through Fcbruary 28, 1983.
Areas reviewed included staff organization and qualifications, training, radiochemistry and secondary chemistry programs, sampling systems, effluent releases, facilities and equipment, laboratory instrument calibration and quality control, licensee ~ audits program of chemistry / radiochemistry activities, administrative and analytical proce-dures, and the-performance of confirmatory measurements on sclected counting geometries used in technical specification compliance measure-ments.
The previous chensistry/ radiochemistry program preoperational inspection was' performed during May 3-7, 1982.
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3.
Licensee Action on Previous Inspection Findings (0 pen) Open Item (382/8212-01): Corporate Chemistry / Radiochemistry Oraanization - This item was discussed in NRC. Inspection Report 50-382/82-12 and involved the lack of a corporate chemistry / radiochemistry program,
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position qualifications and job descriptions, defined responsibilities and interfaces with the onsite chemistry / radiochemistry department, procedures-governing activities, and complete staffing of the corporate chemistry /
radiochemistry technical support group. At the time of this inspection, the licensee had developed a corporate chemistry / radiochemistry program, had developed position qualifications and job descriptions, had defined responsibilities and interfaces with the onsite chemistry / radiochemistry department, and had developed procedures governing activities within the chemistry / radiochemistry section. _The licensee has yet to complete the staffing of the chemistry / radiochemistry section of the nuclear project support group.
See Section 5.a for additional details.
(0 pen) Open Item (382/8212-02): Onsite Chemistry / Radiochemistry Organization - This item was discussed in NRC Inspection Report 50-382/82-12 and involved the lack of approved position qualifications and job descrip-tions, defined responsibilities and interfaces with the corporate organization, procedures' governing functional areas of activity, and complete staffing of the onsite chemistry / radiochemistry department. At the time of this inspection, the licensee had developed position qualifica-tions and job descriptions and the necessary procedures to cover the remaining items listed.
The licensee had not completed the staffing of the onsite chemistry / radiochemistry department with qualified, experienced personnel.
See Section 5.b for additional details.
(0 pen) Open Item (382/8212-03):
Chemistry / Radiochemistry Organization Qualifications - This item was discussed in NRC Inspection Report 50-382/82-12 and involved the lack of selection and qualification criteria for corporate and onsite chemistry / radiochemistry personnel. The licensee had not developed a procedure for selection and qualification criteria of onsite chemistry / radiochemistry personnel in order to meet ANSI N18.1-1971 qualifications.
The licensee had not completely staffed their corporate or onsite chemistry / radiochemistry staffs with ANSI-qualified personnel as committed to in the FSAR.
See Section 6.b for additional details.
(0 pen) Open Item (382/8212-04):
Chemistry / Radiochemistry Training Program -
This item was discussed in NRC Inspection Report 50-382/82-12 and involved the lack of an official training program ~ for chemistry / radiochemistry personnel, completed qualification training of chemistry / radiochemistry personnel, and a qualified chemistry training coordinator and chemistry instructor.
At the time of this inspection, the licensee had contracted for the development of a training program for chemistry / radiochemistry personnel and was starting to implement that training.
The licensee's
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. chemistry / radiochemistry staff were not completely qualified on all plant chemistry systems and analytical. procedures.
The licensee was recruiting for a chemistry training coordinator.
See Section 7 for additional detai l s.-
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(0 pen) Open_ Item (382/8212-05):
Primary Chemistry (Radiochemistry)
i Program - This item was discussed.in NRC Inspection Report l50-382/82-12 and involved the-lack of completed and. proven procedures to implement a
. radiochemistry program as committed tolin the FSAR.
At the time of this
inspection, the licensee'had completed many of the required procedures, but was still lacking detailed methodology for analysis and sampling in the primary chemistry systems.
See Section 8 for details.
(0 pen) Open Item (382/8212-06):
Secondary Chemistry Program - This item was discussed in NRC Inspection Report 50-382/82-12_and involved the_ lack of
_ completed and. proven procedures.to implement a secondary chemistry program as committed to in the FSAR.
At the time of this inspection, the licensee-had completed many of the required procedures, but was still lacking
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t completion of' instrument calibration and detailed methodology for shmpling
.the secondary chemistry systems.
See Section 9 for details.
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(0 pen) Open Item (382/8212-07):
Chemical Inventory Program - This item
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was discussed in NRC Inspection Report 50-382/82-12 and involved the implementation of a chemical procurement and inventory program for the station laboratories. -At the time of_this inspection, the licensee had implemented an approved chemical inventory program and completed procurement of chemicals and reagents necessary to support operation of the plant.
The licensee still needs to provide better storage facilities for bulk and flammable chemicals.
See Section 10 for details.
(0 pen) Open Item (382/8212-08):
Primary Chemistry Samplina System - This
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- item was discussed in NRC Inspection Report 50-382/82-12 and involved the lack of detailed sampling procedures for primary chemistry samples, installation and calibration of the primary chemistry sample panel, and the calibration of the automatic gas analyzer system and primary system prccess instrumentation. At the time of this inspection, the licensee had installed the primary chemistry sample panel, automatic gas analyzer system, and primaty system process instrumentation.
The licensee still needs to complete final checkout of the primary chemistry sample panel, complete the calibration of.the primary system process analyzers, and provide specific sampling procedures for all routine primary chemistry samples.
See Section 11 for additional details.
(0 pen) Open Item (382/8212-09):
Secondary Chemistry Samplina System -
This item was discussed in NRC Inspection Report 50-382/82-12 and involved the lack of detailed sampling procedures for secondary chemistry samples, installation and calibration of the secondary chemistry sample panel, and the. calibration of the secondary chemistry process instrumentation.
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the time of this inspection, the licensee had completed the installation of the_ secondary chemistry sample panel 'and process instrumentation.
The calibration of the secondary chemistry process instrumentation was nearly completed. -The licensee stili needs to complete final checkout of all secondary chemistry sample points, complete the calibration of all the
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secondary chemistry process analyzers, and provide specific sampling procedures for all routine secondary chemistry samples.
See S9ction 12 for details.
(0 pen) Open Item (382/8212-10):
Postaccident Sampling System - This item
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was discussed in NRC Inspection Report 50-382/82-12 and involved the con-struction and installation of a postaccident sampling system. At the time of this inspection, the licensee had made very little physical progress in the construction and installation of the postac.cident sampling system since the last inspection.
Procedures were still in draft form and not available for review.
See Section 13'for details.
(0 pen) Open Item (382/8212-11):
Controls for Effluent Releases - This item was discussed in NRC Inspection Report 50-362/82-12 and involved the lack of a developed program for controlling the release of gaseous and liquid effluents in accordance with Regulatory Guide 1.21.
This item was not reviewed during this inspection and remains open pending completion of all effluent release procedures.
(0 pen) 0 pen Item (382/8212-12):
Facilities - This item was discussed in
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NRC Inspection Report 50-382/82-12 and involved the completion of construc-tion and occupancy of the chemistry / radiochemistry laboratories and work
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areas. Occupancy of the secondary chemistry laboratory, radiochemistry laboratory, and counting ~ room had been completed at the time of this inspection even though construction was not 100 percent completed._ The primary sample room' and sample line modificaitons were not completed.
The chemistry supervisor's and' radiochemistry supervisor's office was not equipped or occupied.
See Section 15 for additional details.
(0 pen) Open Item (382/8212-13):
Chemistry / Radiochemistry Analytical
Instrumentation - This item was discussed in NRC Inspection Report 50-382/82-12.and involved procurement of laboratory instrumenta-tion; occupancy of laboratory areas; the lack of operating, calibration, and calibration check procedures; and the implementation of an instrument calibration check program.
At the time of this inspection, the licensee had procured the necessary laboratory instrumentation to establish a satisfactory chemistry / radiochemistry program and had occupied and made functional the laboratory areas.
The licensee has yet to complete and implement the instrument quality control program.
See Section 16 for additional details.
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(0 pen) Open Item (382/8212-14): ' Audits and Review - This' item was discussed in NRC Inspection Report 50-382/82-12 and involved the lack of an estab-
lished audit and review program for chemistry / radiochemistry department j -
activities.
At the time of this inspection, the licensee had increased
- their QA-staff with qualified personnel and had drafted an initial audit checklist for primary chemistry, secondary chemistry, and chemical inventory programs.
The licensee has yet to complete and implement a QA inspection program for the chemistry / radiochemistry department.
See Section 17 for details.
.(0 pen)'Open Item (392/8212-15):
Procedures --This item was discussed in
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- NRC Inspection Report 50-382/82-12 and involved the lack of the necessary procedures to implement a complete and satisfactory chemistry / radiochemistry program. The licensee had completed and' approved approximately 92 percent
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- of-the planned chemistry / radiochemistry procedures at the time of the inspection.
The' licensee needs to complete the remaining nina planned
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. procedures and' evaluate the necessity for procedures in areas not presently
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addressed.
See Section 18 for-additional details.
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4.
Open Items Identified During This Inspection.
No..new open items were identified during this' inspection.
5.
Chemistry / Radiochemistry Organization i
t The NRC inspectors reviewed the lice'see's corporate'and onsite n
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organizations regarding chemistry / radiochemistry activities to determine
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Documents Reviewed
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FSAR Section 13.1, " Organizational Structure of Applicant"
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CE-01-000, " Organization of the Chemical and Environmental Department,"
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Revision 0, April 22, 1981
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DL-81-164-1, " Position Description for. Engineering Supervisor -
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Nuclear," Revision 0, November.30, 1981
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DL-81-164-8, " Position Description for Chemistry / Radiochemistry
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- Engineer-Nuclear," Revision 0,-November 30, 1981
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DL-81-164-26, " Position Description for Chemistry / Radiochemistry
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Utility Engineer - Nuclear," Revision' O,' November 30, 1981
.DL-81-164-77, " Position Description for Technical Support
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Superintendent - Nuclear," Revision 0, October 7, 1982 F
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DL-82-164-80, " Position Description for Chemistry Department' Head -
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Engineer. ; Nuclear," Revision 0,' October 7,-1982 DL-82-164-104, " Position Description for Radiochemist Utility
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Engineer - Radiochemistry," Revision 0, October.7, 1982 i
DL-82-164-106,. " Position Description for Radiochemistry Supervisor
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1 Chemical Supervisor - Nuclear," Revision 0, October 7,1982
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DL-82-164-103, " Position Description for Chemist Utility Engineer -
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- Nuclear,"-Revision 0,= October 7, 1982
. DL-82-164-105, " Position Description for ' Secondary Chemistry Supervisor i.
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Chemical Supervisor - Nuclear," Revision 0, October 7, 1982 0L-82-164-109, " Position Description for Chemistry Technical
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Specialist - Nuclear," Revision 0, October 7,1982 DL-82-164-102, " Position Description for Chemistry Technician -
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Nuclear," Revision 0, October 7, 1982 NAP-280, " Chemistry / Radiochemistry Organization and Responsibilities,"
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Revision 0, January 5, 1983
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NAP-281, " Chemistry / Radiochemistry Technical Support," Revision 0,
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January 5,.1983 NAP-282, " Chemistry / Radiochemistry Monitoring," Revision 0, January 5,
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1983
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NAP-283, " Chemistry / Radiochemistry Records rnd Reports," Revision 0, j.
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January 5, 1983 L
NAP-284, " Chemistry / Radiochemistry Personnel Training," (Draft)
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NAP-285, " Chemistry / Radiochemistry Personnel Selection and
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Qualifications," (Draft)
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NAF-286, " Chemistry / Radiochemistry Review of Other Plant Experience
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and Technology Transfer," (Draft)
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Corporate Chemistry / Radiochemistry Organization
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-The following chart diagrams the present Louisiana Power and Light (LP&L) corporate technical services chemistry / radiochemistry
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-organizational structure and. assigned individuals:
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L. V. Maurin Vice President - Nuclear Operations F.-
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-Nuclear: Project Support'
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- Project Support Manager - Nuclear
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K. R. Iyangar
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Technical Services Engineering Supervisor - Nuclear D. E. Adams Chemistry / Radiochemistry Engineer - Nuclear VACANT Chemistry / Radiochemistry Utility Engineer - Nuclear.
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The management of chemistry / radiochemistry activities within the Louisiana Power and Light (LP&L) corporate organization has been
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I assigned to the Waterford 3 nuclear project support group (NPSG)
personnel.in the chemistry / radiochemistry section (C/RS).' The responsibilities Land. interface with the onsite chemistry / radiochemistry department has been defined in Nuclear Administrative Procedure (NAP)-280 and is further delineated in NAP-281, NAP-282, and NAP-283.
The chemistry / radiochemistry section has been assigned interface duties in the areas of liaison between plant' staff and outside organizations, ensuring dissemination of pertinent chemistry informa-tion, providing chemistry diagnostic and analytical support, performing
- annual reviews of the chemistry / radiochemistry department, performing monitoring of chemistry program activities, and assisting in chemistry /
radiochemistry personnel training.
The NRC inspectors reviewed the position descriptions, personnel selection and qualification criteria, and present staffing of the C/RS.
Position descriptions and qualification criteria for the C/RS
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personnel were found to be acceptable. The, corporate chemistry /
radiochemistry engineer-nuclear meets ANSI N18.1-1971 qualifications.
The chemistry /rediochemistry utility engineer-nuclear position remains vacant. The position was being recruited actively at the time of the inspection.
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Open Item (382/8212-01), Corporate Chemistry / Radiochemistry Organization, will remain open pending the completion of the C/RS staff with qualified personnel and. final approval of program procedures.
b.
Onsite Chemistry / Radiochemistry Organization
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The NRC inspectors reviewed the Waterford 3 staff assignments in regard to chemistry / radiochemistry responsibilities.' The following chart shows the present station organizational structure and assigned individuals:
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R. P. Barkhurst Plant-Manager - Nuclear
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S. A. Alleman Assistant Plant Manager - Nuclear J. R. McGaha Technical Support Superintendent
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W. N. Perry Chemistry Engineer - Nuclear I
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C. B. Hawkins C. R. Booth Radiochemist Chemist Utility Engineer - Nuclear Utility Engineer - Nuclear G. L. Dolese M. D. Llewellyn Radiochemistry Supervisor Act. Sec. Chemistry Supervisor Chemical Supervisor - Nuclear Chemical Supervisor - Nuclear i
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I Techn cal Specialist - Nuclear Chemistry Technician - Nuclear
[6]
[4]
The numbers in brackets denote the staffing authorized.
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The responsibility for coordination of all plant chemistry department activities had been assigned to the chemistry engineer - nuclear.
That position also was assigned the responsibility for the supervision and management of all chemistry department personnel.
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The NRC inspectors reviewed the approved position descriptions and
'found them acceptable..However, it was noted that the experience requirements.for the radiochemist, radiochemistry supervisor, and'
chemistry supervisor were in accordance with present staff experience, but exceeded the requirements of ANSI N18.1-1971.
It.is a concern of the NRC inspectors that if the'present staff should need to be-replaced the licensee would have a difficult' job finding personnel i
having experience:as described in the present position descriptions.
The licensee was implementing procedures governing activities within
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the assigned areas of responsibility.
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The chemistry ~ engineer - nuclear, radiochemist utility engineer -'
nuclear, chemist utility engineer - nuclear, radiochemistry supervisor, and secondary chemistry supervisor positions were filled in the organizational structure with. qualified personnel. At the time of-the inspection,'seven of the-ten onsite chemistry / radiochemistry technician positions had been filled.
The chemistry engineer was
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actively recruiting to fill the remaining positions with qualified personnel.
The chemistry / radiochemistry department was supplementing its staff during startup with seven qualified and experienced contract personnel.
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Open Item (382/8212-02), Onsite Chemistry / Radiochemistry Organization, l
will remain open pending the complete staffing of the chemistry /
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radiochemistry department with qualified personnel.
No violations or deviations were identified.
6.
Chemistrv/ Radiochemistry Personnel Qualifications The NRC inspectors reviewed.the qualifications of the chemistry /.
radiochemistry personnel including corporate and onsite to determine agreement with commitments in the FSAR and the-recommendations of Regulatory Guide 1.8, ANSI'N18.1-1971, and NUREG-0731.
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Documents Reviewed
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Chemistry / Radiochemistry Department personnel training records and
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experience resumes Corporate Chemistry / Radiochemistry Engineer. training and experience
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resume FSAR, Section 13.1, " Organizational Structure of Applicant"
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- DL-81-164-8, " Position Description for Chemistry / Radiochemistry
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' Engineer - Nuclear,"' Revision 0, November 30, 1981
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' DL-91-164-26, " Position Description for Chemistry / Radiochemistry
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Utility Engineer -l Nuclear," Revision 0, November 30, 1981 NAP-285, " Chemistry / Radiochemistry Personnel Selection and
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Qualifications," (Draft)
DL'-82-164-80, " Position Description for Chemistry Department Head
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- Engineer - Nuclear," Revision 0, October. 7,1982
.DL-82-164-104, " Position Description for Radiochemist Utility
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Engineer - Radiochemistry," Revision 0,' October 7,1982 DL-82-164-106, " Position Description for Radiochemistry Supervisor
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Chemical Supervisor - Nuclear," Revision 0, October'7, 1982 DL-82-164-103, " Position Description for Chemist Utility Engineer,"
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Revision 0, October 7, 1982
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DL-82-164-105, " Position Description for Secondary Chemistry Supervisor
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Chemical Supervisor - Nuclear," Revision 0, October 7, 1982 DL-82-164-109, " Position Description fo'r Chemistry Technical
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Specialist - Nuclear," Revision 0, October 7, 1982 DL-82-164-102,." Position Description for Chemistry' Technician -
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- Nuclear," Revision 0, October 7,1982 a.
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The licensee had established'in Procedure NAP-285 and position descriptions minimum qualifications ahd selection criteria for the staff positions in the corporate chemistry / radiochemistry section which provide guidance on evaluation of persornel" training and
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experience.
The corporate ~ chemistry / radiochemistry engineer (corporate-
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radiochemist) meets the FSAR' commitments, which follow the recommenda-tions of NUREG-0731 and ANSI N18.1-1971.
The licensee had not filled the corporate position of~ chemistry / radiochemistry utility engineer-nuclear at the time of the inspection.
b.
Onsite The licensee h'ad committed to, in the FSAR, the qualification requirements recommended in ANSI /ANS 3.1-1978 (not currently adopted by the NRC), which are more stringent than those contained in (and endorsed by the NRC) ANSI N18.1-1971. The NRC inspectors reviewed O
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the resumes of selected staff parsonnel to determine if.the members of the chemistry / radiochemistry staff met the experience qualifica-tion recommendations for chemistry / radiochemistry personnel as outlined in Sections 4.3 and 4.4 of ANSI N18.1-1971.
The NRC inspectors noted that all supervisory positions in the chemistry /
radiochemistry department met the ANSI N18.1-1971 qualifications.
However, only three out of_the seven technicians hired to fill ten positions appeared to meet the experience qualification recommenda-tions of ANSI N18.1-1971.
The licensee had not developed a procedure which would provide guidance for the hiring of qualified chemistry /
radiochemistry personnel other than which had been incorporated into--
the respective position descriptions.
Open Item (382/8212-03), Chemistry / Radiochemistry Oraanization, Qualifications, will remain open pending review of all resumes of the corporate and onsite chemistry / radiochemistry personnel and the davelopment of selection and qualification criteria for onsite
chemistry / radiochemistry personnel to meet, as a minimum, ANSI N18.1-1971 qualifications.
No violations or deviations were identified.
7.
Chemistry / Radiochemistry Training Program The NRC inspectors reviewed the licensee's chemistry / radiochemistry training program to determine compliance with FSAR commitments, 10 CFR 19.12 requirements, and the recommendations of ANSI N18.1-1971, and Regulatory Guide 1.8.
Documents Reviewed FSAR-Section 13.2, " Training"
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PMD-TR-002, " Program Description for General Employee Training,"
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Revision 0, January 15, 1982
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l PMD-TR-009, " Program Description for_ Nuclear Training Group
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Organization," Revision 0, January 12, 1982
PMD-TR-028, " Program Oescription for Chemistry Training," Revision 0,
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l June 11, 1982
_CE-01-001, " Training and Qualification of Chemistry Department
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Personnel," Revision 0, June 15, 1982
. Chemistry Technician Training Program Outline by Engineering Data
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Systems (EDS), Inc., (Draft), not dated l
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Individual training record for each chemistry / radiochemistry staff
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l member Qualification card for each chemistry / radiochemistry staff member
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The NRC inspectors discussed the training program for' chemistry /~
radiochemistry personnel with the traininc managerf-nuclear, the acting training supervisor for HP/ chemistry training, and a contract training instructor.for chemistry.
A training program for chemistry / radiochemistry personnel was being developed by an offsite contractor.
The course was i
being designed to last 11 weeks with 4-hours per-day classes.
The course j
is to'be of modular concept and oriented toward site-specific system
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descriptions and practical factors.
The course is to include sections on mathematics, chemistry and radiochemistry,' atomic and nuclear physics, reactor physics, PWR fundamentals, plant systems, corrosion control,
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nuclear plant environment, monitoring and analysis, radioactive waste
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management, and calibration and quality control.
Personnel were being scheduled for. training beginning April 4, 1983, which was to be conducted by contract personnel.
At the time of the inspection, the nuclear training division'had not hired a chemistry instructor or chemistry training coordinator.
The NRC inspectors reviewed the chemistry / radiochemistry staff individual training records maintained by the acting chemistry. training coordinator.
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The records indicated that most of the chemistry / radiochemistry staff had completed the three levels of general employee training, respirator
training, first-aid 1st responder training, fire fighting training, and emergency plan training.
The various staff members had_ completed different levels of system qualification and analytical procedures training as required by their job assignments during startup..The respective indi-vidual's qualification card illustrated what systemt and procedures that person was qualified'to use.
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Open Item (382/8212-04), Chemistry / Radiochemistry Training Program, will remain open pending:
Hiring of a chemistry training coordinator and/or chemistry instructor.
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Implementation of an official training program for chemistry /
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radiochemistry personnel Completed qualification training of.all chemistry / radiochemistry
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personnel
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Final review of chemistry / radiochemistry individual personnel training
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records, including written exams and qualification ~ records No violations or deviations were identified.
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fPrimary Chemistry (Radiochemistry) Program
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The NRC' inspectors reviewed the licensea's primary chemistry program to determine compliance with FSAR commitments, proposed Technical Specifica-tions,:and recommendations contained.in'CENPD-28, " Combustion Engineering Chemistry Manual."
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Documents Reviewed V
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'FSAR, Chapter 16, proposed Technical 2 Specifications
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FSAR, Table 9.3-7, " Reactor Coolant and Reactor Makeup Water"
.
FSAR, Chemistry Section 9.3.4, " Chemical and Volume Control System"
.
CENPD-28, " Combustion Engineering Chemistry Manual"
.
.
PMD-CE-02, " Program Description for Primary Chemistry," Revision 0, May.17, 1982 CE-01-002, " Log Keeping, Filing, and Record Storage," Revision 1,
.
January 22,11982 CE-01-003, " Reporting Chemistry Data to Operations Group," Revision 0,
.
February 5, 1982 CE-01-005, " Test Stand Calibration Scheduling Program," Revision 0,
.
August 31, 1982 CE-01-006, " Analytical and Process Equipment Calibration Scheduling
.
Program," Revision 0,: August 31, 1982 CE-01-008, " Inventory and Control of Chemicals and Reagents,"
.
Revision 0, December 9, 1981 CE-02-006, " Maintaining Reactor Ccolant Chemistry," Revision 0,
.
September.17,.1982 CE-02-007, " Maintaining Camponent Cooling Water Chemistry," Revision 0,
.
January 7, 1982 CE-02-009, " Maintaining Baron Management System Chemistry," Revision 0,
.
August 19, 1982 CE-02-010. " Maintaining f afety Injection Tank Chemistry," Revision 0,
.
10ctober 14, 1982
.-.. -.. -. - -. -... -.. -
.
. -
- -. -... -. -. -
.
.
.
.
16-CE-02-011, " Maintaining Spent Fuel Pool Chemistry," Revision 0,
.
February 5, 1982 CE-02-012, " Maintaining Boron Concentration During Refueling,"
.
Revision 0, November 1, 1982 CE-02-016, " Monitoring Gaseous Waste Management," Revision 0,
.
October 14, 1982 CE-02-018, " Monitoring Liquid Waste Management," Revision 0,
.
November 1, 1982 CE-02-020, " Maintaining Primary Water Storage Tank Chemistry,"
.
Revision 1, January 26, 1983 CE-02-025, " Maintaining Refueling Water Storage Pool Chemistry,"
.
Revision 0, July 19, 1982 CE-02-026, " Boron Concentration Prior To and During Initial Core
.
Load," Revision _0, July 19, 1982 CE-03-006, "Use of the On-Line Hydrogen /0xygen Analyzer," Revision 0,
.
July 29, 1982 CE-03-007, " Operation of the Process pH Monitors," Revision 1,
.
June 30, 1982 CE-03-008, "Use of the Process Conductivity Monitors," Revision 0,
.
August 24, 1981 CE-03-009, "Use of the Process Dissolved Oxygen Monitors," Revision 0,
.
August 12, 1981 CE-03-101, " Determination of Chlorides - Mercuric Nitrate Method,"
.
Revision 1, January 26, 1983 CE-03-103, " Determination of Chlorides - Specific Ion Electrode
.
Method," Revision 1, December 15, 1982 CE-03-104, " Determination of Chlorides
- Colorimetric Method,"
.
Revision 0, September 10, 1981 CE-03-105,. " Determination of pH," Revision 1, December 15, 1982
.
CE-03-106, " Determination of Conductivity," Revision 2, December 15,
.
1982 L
-
.
..
U CE-03-107, " Determination of Fluorides," Revision 1, December 15,
.
1982-CE-03-108, " Determination of Hydrazine (0-80 ppb)," Revision 0,
'
.
August 27, 1981 CE-03-109, " Determination of Hydrazine," Revision 2, December 15,
.
1982 CE-03-111, " Determination of Ammonia," Revision 1, October 27, 1981
.
CE-03-112 " Determination of Ammonia in the Presence of Hydrazine
.
>200 ppb - Distillation Method," Revision 1, December 15, 1982
,
CE-03-118, " Determination of Dissolved Oxygen >0.05 ppm - Winkler
.
Method," Revision 0, August 27, 1981 CE-03-119, Determination of Dissolved Oxygen - Indigo Carmine
.
Method," Revision 0, August 27, 1981
-
CE-03-120, " Determination of Dissolved Oxygen - Meter," Revision 0, i
.
t August 27, 1981 CE-03-121, " Determination of Boron," Revision.1, August 27, 1981
.
i CE-03-122, " Determination of Boron - Titration Method,". Revision 1,
.
August 12, 1981
'
CE-03-123, " Determination of Boron - Curcumin Method," Revision-1,
.
August 12, 1981
<
l CE-03-127, " Determination o'f Suspended Solids," Revision 0, August 12,
.
l 1981 CE-03-300, " Preparation of Liquid Samples for Radiological Chemical
.
Analysis," Revision 0, June 4,1982 CE-03-301, " Determination of Gross Beta Radioactivity," Revision 0,
.
August 4, 1982 CE-03-302, " Determination of Gross Gamma Radioactivity," Revision 0,
.
August 4, 1982
,
l
'
CE-03-303, " Gross Alpha Measurement," Revision 0, November 9, 1981
.
CE-03-305, " Sampling of Ventilation and Gaseous Waste Management l
.
Systems'for Radioactive Effluents," Revision 0, January 26, 1983 l
i
!
-
.
..
..
.
-
-
.
-.
.-
...
-.
.
CE-03-306, " Determination of the Average Beta-Gamma Energy of Reactor
.
Coolant," Revision 0, September 17, 1982 CE-03-313, " Tritium Analysis," Revision 0, July 21,1982
.
CE-03-320, " Gamma Spectroscopy Analysis," Revision 0, July 29, 1982
.
CE-03-324, "Compositing Samples for Weekly, Monthly, and Quarterly
.
Composites," Revision 0, August 4, 1982 CE-03-325, " Determination of Nitrogen, Hydrogen, Oxygen, and Gaseous
.
Activities," Revision 0, October 5, 1982 CE-03-400, "Use of the Plasma Emission Spectrometer," Revision 0,
.
October 5, 1982
' CE-03-700, " General Grab Sampling Techniques," Revision 0, January 7,
.
1982 CE-03-800, " Operation of the Ion Chromatograph," Revision 0, January 9,
.
1983 CE-03-902, "Postaccident Baron Analysis," Revision 0, November 1,
.
1982 CE-03-903, "Postaccident Gamma Spectroscopic Analysis," Revision 0,
.
December 15, 1982 CE-03-904, "Postaccident Analysis of Dissolved Hydrogen in the
.
Reactor Coolant," Revision 0, September 21, 1982 Planned Procedures Not Available for Review CE-01-004, " Periodic Analysis Scheduling Program" (Draft), in PORC
.
review CE-01-016, " Control of Measuring and Test Equipment" (Draft),-in PORC
.
review CE-01-020, " Chemistry / Radiochemistry Quality Control" (Draft), in
.
PORC review
'
CE-01-901, " Testing and Maintenance of Postaccident Sampling Systems"
.
(Draft), in PORC review CE-02-100, " Chemistry Technical Specifications Surveillance Performance
.
Coordination" (Draft), in POPC review
. - -
.
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.
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-
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.,
,
~
19
-
-
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,
'
.CE-03-311, " Radiostrontium Analysis" (Draft), in PORC review
-
.
CE-03-900, " Operation of the Postaccident Sampling System" (Draft),
.
in PORC review
{CE-03-901, "Postaccident' Sampling of Containment Atmosphere" (Draft),
.
in PORC~ review
!
The NRC inspectorsTreviewed'the primary chemistry program and found the licensee's program improved from the previous inspection.
The program
!
implementation appeared to be 9n schedule and nearly 100 percent of the implementing and analytical procedures had been completed and approved.
L
. The licensee had. developed a procedure for the operation and calibration
[
of the plasma emission spectrometer.
The operation section of the proce-dure contained methodology for. qualitative analysis of fon concentrations L
.in.a sample; however, quantitative analysis methods were not defined.
At l-the time of the inspection,' initial calibration of the plasma emission spectrometer was underway and the instrument had been calibrated for several -fons common to power-plant concerns and analysis.
!
The licensee had developed a procedure for the operation and calibration
of-the ion chromatograph. The procedure. contained methodology for cal-
,
ibrationfof 5 anions and 1 cation and a method of quantitative analysis of these ions.
At the time of the inspection, initial calibration curves had l
been established for fluoride, chloride, and sulfate ions.
l lat the time of-the inspection, the' licensee'had not developed detailed procedures for the preparation, accountability, and quality. control of all
'
nuclear instre.nent radioactive calibration standards as recommended by ANSI N323-1978.
The licensee had developed procedures for the operation, calibration, and calibration check of the nuclear analytical instrumentation including the Beckman LS 7000 liquid scintillation system, Nuclear Data 6620 gamma spectrometerfsystem, and the NMC Model PCC-11T/DS-3 proportional alpha / beta counting system. The procedures were found to be lacking in sufficient detail for a technician to perform each function of instrument operation
' independently as required.~
The licensee had not completed calibration of all process and laboratory analytical-instrumentation which was used to. support the primary chemistry l
program.
!
The licensee had not developed detailed sampling procedures for all systems sampled 'to meet primary ~ chemistry analysis requirements as required by Regulatory Guide 1.21 and ANSI N13.1-1969.
Sample points had not been identified for all primary chemistry systems l or tanks.
l
L I
~
l
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-
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.
, ' '
.
4 At the time of the inspection, the licensee had verified tank volumes for
-
tanks which would contain potentially contaminated material.
During hot functional testing, the licensee is to verify recirculation times required to produce representative samples from these tanks as required by Regulatory Guide 1.21.
'
~
Open Item (382/8212-05), Primary Chemistry (Radfochemistry)~ Program, will remain open pending:
Completionofprimarychemistrysystemiprocedures',~ surveillance
.
procedures, radiochemistry analytical procedures, instrument cal-
-ibration procedures, instrument calibration check procedures, and postaccident primary chemistry procedures.
Completion of instrumentation calibrations.
.
.
Development of detailed preparation procedures for all nuclear
.
instrument radioactive calibration standards.
Development and implementation of detail'ed sampling procedures for
.
every primacy system to be sampled including sampling times for each primary sample point to produce a representative sample.
Verification of tank recirculation times to produce representative
.
samples.
Verification of all analytical-procedures using known standards.
.
No violations or deviations were identified.
9.
Secondary Chemistry Program The NRC inspectors reviewed the licensee's secondary chemistry program to determine'ecmpliance with FSAR commitmeats, proposed Technical Specifica-tions, and recommendations contained in CENPD-28, " Combustion Engineering Chemistry Manual."
Documents Reviewed
~FSAR, Chapter 16, proposed Technical Specifications
.
FSAR, Section 10.3.5, " Secondary Water Chemistry Monitoring Program"
.
CENPD-28, " Combustion Engineering Chemistry Manual"
.
PMD-CE-003, " Program Description for Secondary Chemistry," Revision 0,
.
February 17, 1982
.
.
.
CE-01-002, " Log Keeping, Filing, and Record Storage," Revisinn 1,
.
January 22, 1982 CE-01-003, " Reporting Chemistry Data to Operations Group," Revision 0,
.
February 5,1982 CE-01-005, " Test Stand Calibration Scheduling Program," Revision 0,
.
August 31, 1982 CE-01-006, " Analytical and Process Equipment Calibration Scheduling
.
Program," Revision 0, August 31, 1982 CE-01-008, " Inventory and Control of Chemicals and Reagents,"
.
Revision 0, December 9, 1981 CE-01-009, "Corbicula Infestation Evaluation of Safety Related
.
Systems," Revision 0, July 29, 1982 CE-02-000 " Maintaining Auxiliary Boiler Chemistry," Revision 0,
.
February 5, 1982 CE-02-001, " Maintaining Steam Generator Chemistry," Revision 0,
-
.
July 29, 1982 CE-02-002, " Maintaining _Condensuce and Feedwater Chemistry,"
>
.
Revision 0, August 13, 1982 CE-02-004, " Maintaining Boze Filter Chemistry," Revision 0, October 27,
.
1981 CE-02-005, " Maintaining Makeup Demineralizer Chemistry," Revision 0,
.
January 22, 1982 CE-02-007, " Maintaining Component Cooling Water Chemistry," Revision 0,
.
January 7, 1982 CE-02-008, " Maintaining Condensate Storage' Pool Chemistry," Revision 0,
.
September 17, 1982 CE-02-013, " Maintaining Chill Water Chemistry," Revision 0, July 21,
.
1982 CE-02-014, " Maintaining Supplementary Chill Water Chemistry,"
.
Revision 0, August 27, 1981 CE-02-015, " Maintaining Turbine Building Cooling Water Chemistry,"
.
Revision 0, April 12, 1982
-
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-
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.
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.CE-02-017, " Maintaining Package Cooling Tower Chemistry," Revision 0,
<
.
January '22, 1982 CE-02-019, " Maintaining Diese14 Generator Jacket Cooling Water
.
. Chemistry," Revision 0, April 5, 1982 CE-02-021, " Systems Layup During the Construction Phase," Revision 0,
.
December 9, 1981 CE-02-22, " Feed, Condensate, and Heater Drains Systems Chemistry
.
Prior to Normal Operation," Revision 0, October 27, 1981 CE-02-023, " Reactor Coolant and Auxiliary Systems Chemistry Prior to
.
Fuel Load," Revision 0, November 11, 1981'
CE-02-024, " Steam Generator Chemistry Prior to Normal Operation,"
.
Revision 0, November 9, 1981 LCE-02-027, " Maintaining Condensate Storage Tank Chemistry," Revision 0,
.
July 21, 1982 CE-02-028, " Maintaining Stator Coil Water Chemistry," Revision 0,.
.
,'
January 22, 1982 CE-03-007, " Operation of the Process pH-Monitors,"-Revision 1,
.
June 30, 1982 CE-03-008, "Use of the Process Conductivity Monitors," Revision 0,
.
' August 24,'1981 CE-03-009, "Use of the Process Dissolved Oxygen Monitors," Revision 0,
.
August 12,'1981
.
. CE-03-010, "Use of Process Silica Monitors," Revision 0, October 1, 1981 i
CE-03-011, "Use of Process Sodium Monitors," Revision 0, June 30,
.
1982
CE-03-012, "Use of the Hach Surface Scatter 4 Turbidimeter,"
.
Revision 0,1 August 24, 1981 CE-03-013, "Use of the Hach Process Hardness Monitor," Revision 0,
.
- October 6, 1981
.CE-03-014, "Use of Process Hydrazine Monitor," Revision 0, August 27,
,
.
.
1981
i
.
,
,
w-.r--,
---..
.-.m.
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-
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w-e
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_
_
-_
-
.
.-...
.
1
.
..
,
CE-03-101, " Determination of Chlorides <10 ppm - Mercuric Nitrate
.
Method," Revision 1, January 26, 1983
_
CE-03-103, " Determination of Chlordies - Specific Ion Electrode
.
.'
Method," Revision 1, December 15, 1982 s
CE-03-104, " Determination of Chlorides <10 ppm - Colorimetric Method,"
.
Revision 0, September 10, 1981
CE-03-105, " Determination of pH - Meter," Revision 1, December 15,
.
1982-
,
"
CE-03-106. " Determination of Conductivity," Revision 2, December 15,
.
1982
.
CE-03-107, " Determination of Fluorides," Revision 1, December 15,
.
i 1982 CE-03-108, " Determination of Hydrazine (0-80 ppb)," Revision 0,
.
August 27, 1981 CE-03-109, " Determination of Hydrazine," Revision 2, December 15,
'
.
1982 CE-03-111, " Determination of Ammonia," Revision 1, October 27, 1981
.
CE-03-112, " Determination of Ammonia in the Presence of Hydrazine
.
>200 ppb - Distillation Method," Revision 1, December 15, 1982 CE-03-113, " Determination of Dissolved Silica," Revision 1, i
.
l-December 15, 1982 CE-03-115, " Determination of Hardness (0-2 ppm)," Revision 0,
.
-September 28, 1981 l
CE-03-116, " Determination of Total Hardness >2 ppm," Revision 1,
.
!
October 6, 1981
'
CE-03-118, " Determination of Dissolved Oxygen >0.05 ppm - Winkler
.
Metnod," Revision 0, August 27, 1981-CE-03-119 " Determination of Dissolved Oxygen - Indigo Caraine
.
l Method," Revision 0, August 27, 1981 l.
CE-03-120, " Determination of Dissolved Oxygen - Meter," Revision 0,
.
l August 27, 1981 l
l l
-
.
I l
I
-,
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._, -
_,
.
.
..
.
.
.
.. - -
-
..
..
.
.
-
.. - -
-.
-
.
.
,
'
.
.
3 h
CE-03-125, " Determination of Fluoride and Chloride Contamination --
~
.
' Patch Test-Method 'A',"-Revisica 1, August 20, 1981
'CE-03-126, " Determination of Surface Chlorides.and Fluorides - Patch
.
/ Test Method 'B'"," Revision 1, August 12,.1981
!
., CE-03-127, " Determination of Suspended Solids," Revision 0, August 12, 1981 CE-03-128,"" Determination of' Suspended Nonfilterable' Solids,"
.
.
Revision 0, August 12, 1981; CE-03-129, " Determination of Surfactants - Methylene Blue Method,"'
.
.
Revision 0, October 1, 1981 ~
CE-03-130, " Determination of Solids - Membrane Comparison Chart,"
.
Revision 0, August 12, 1981 CE-03-131, Determination of Particulate Contamination in Liquids -
,
.
-Particle Count Method," Revision ':L, August 12, 1981
.
CE-03-132, " Determination of Total-Phosphates - Amino Acid,"
.
Revision 0, August 27, 1981
'
.
.
CE-03-138, " Determination of Turbidity --Turbidimeter Method,"
.
i.
Revision 0, August 12, 1981 l
CE-03-139, " Determination of Acidity
. Titration Method," Revision 0,
.
August 27, 1981 CE-03-140, " Determination of Total ~ Alkalinity - Phenolphthalein and
.
Methyl Orange," Revision 0, August 20,'1981
.CE-03-141, " Determination of Baume and Percent Concentration of
.
,
Aqueous Solution," Revision 0, August ~20, 1981
,
I.
CE-03-146, " Determination of Nitrite - Titration Method," Revision 1,
.
September 17, 1982.
'CE-03-149, " Determination of Hydroxide Ion in Water," Revision 0,
.
August 12, 1981
-
CE-03-400, "Use of the Plasma Emi sion Spectrometer," Revision 0,
.
October 5, 1982 CE-03-500, " Determination of Free CO," Revision 0, October 6, 1981
.
i i
I.
--,
-.__,_.__ _
.,..
., _... _._ _._.. _ __. _,_..,_..... -,_..... ~.___.._.
_ _. _ _.._,.
-
..
_.
. _.
.
__
.
__
..
,
.
.
'CE-03-501, " Determination of Chlorine - Starch-Ioaide Titration,"
.
Revision G, October 27, 1981
.CE-03-503, " Determination of Total Free Chlorine - Comparator Method,"
.
> Revision 0, October 27, 1981'
,
'
CE-03-505, " Determination of Biological;0xygen Demand," Revision 1,
.
April 5,1982.
,
CE-03-600, " Determination of 011 and Grease in Liquid Solvent
.
Extraction," Revision 1,.0ctoberL27,>1981
,
i
.
CE-03-601, " Determination of Kinematic Viscosity of Liquid Petroleum Products," Revision 0, October 27, 1981~
+
^
U CE-03-602, " Determination of Water and Sediment in Oil ~- Centrifuge,"
.
Revision 1, October 27, 1981-CE-03-603, " Determination of Water Content in Electro-Hydraulic
.
,
Fluid," Revision 1, October 6, 1981-CE-03-604, " Determination of Mineral Oil in EH Fluid," Revision 1,
.
October 6, 1981 CE-03-605, " Determination of Neutralization Number - Titration
,
.
Method," Revision 0, October 6, 1981 CE-03-700, " General Grab Sampling Techniques," Revision 0, January 7,
.
1981 CE-03-800, " Operation of the Ion Chromatograph," Revision 0, January 9,
[.
.
!
1983
!
I
'
Planned Procedures Not Available for Review CE-01-004, " Periodic Analysis Scheduling Program" (Draft),-in PORC
.
review CE-01-016, " Control of Measuring and Test Equipment" (Draft), in PORC
.
review h
CE-01-020, " Chemistry / Radiochemistry Quality Control" (Draf t), in
.
l PORC review (
CE-02-003, " Maintaining Wet Cooling Tower Chemistry" (Draft), in
.
progress i
--
_
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.
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.
. -.. -.
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.
- -. - - -. - ~..
-
. _._
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.
.
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,
._._ _
.
__
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,
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The'NRC : inspectors reviewed the secondary chemistry program and found the
.
' licensee's. program near completion.
The program implementation appeared to be on schedule.and only four planned procedures had not been completed and approved.
,
The licensee had not developed detailed sampling rocedures for all systems sampled to meet secondary chemistry analysis requirements as
. required by Regulatory Guide 1.21.
Sample points had not been identified for all secondary chemistry systems or tanks.
At the time of the inspection, the licensee had verified secondary tank volumes, but had not determined tank recirculation times or sample line
!
iflush times required to produce representative samples as required by Regulatory Guide 1.21.
~
~
The licensee had not developed proceaures 'specifically for the use of the analytical balance, B&L Spectronic 88, and laboratory centrifuge.
LThe licensee had not completed calibration of all process and laboratory
analytical instrumentation which was used to support the secondary chemistry program.
-
Open Item (382/8312-06),' Secondary Chemistry Program, will remain open pending:
.
' Completion of secondary chemistry procedures, -surveillance procedures,
.
,
'
secondary-chemical control and analytical procedures, instrument calibration procedures, and instrament calibration check procedures.
Development and implementation of detailed sampling procedures for
.
every secondary system to be sampled including sampling times for each secondary = sample point to produce a representative sample.
' Verification of tank recirculation times to produce representative
.
,
samples.
I
' Completion of instrumentation calibrations.
.
l'
. Verification of all analytical procedures using known st'andards.
.
No violations or deviations'were identifie'.
d r;
l-10.
Chemical Inventory Program-The NRC _ inspectors reviewed the licensee's chemical inventory and
-
l~
accountability. program to determine compliance and support for FSAR i
commitments, proposed Technical Specifications. and recommendations l
contained in CENPD-28, " Combustion Engineering Chemistry Manual."
l n
-
.
.
Documents Reviewed PMD-CE-006, " Program Description for Chemical Inventory," Revision 0,
.
April 22, 1982 CENPD-28, " Combustion Engineering Chemistry Manual"
.
CE-01-008, " Inventory and Control of Chemicals and Reagents,"
.
Revision 0, December 9, 1981 The NRC inspectors reviewed the present status of the chemical inventory program and found the laboratory staff implementing the program in the laboratories as described by procedure.
The licensee'had completed procurement of chemicals and reagents necessary to support the primary 'and secondary chemistry programs.
These chemicals and reagents were stored in the respective laboratories and storage area on the -4 foot elevation in the Reactor Access Building.
The licensee presently stores flammables in specially-designed cabinets in the respective laboratories.
Storage area.for large quantities of flammable solvents had not been provided.
Storage for bulk quantities of resins and boric acid had been provided in-a separate storage building on the licensee's property.
Open Item (382/8212-07), Chemical Inventory Program, will remdin open pending:
Complate implementation of.the proposed program.
.
Establishment of a safe area for storage of flammable chemicals other
.
than laboratory amounts stored in the respective laboratories.
Consideration of establishment of a computer program to handle
.
inventory and accountability of chemicals.
No violations or deviations were identified.
11.
Primary Chemistry Sampling System The HRC inspectors reviewed the licensee's primary chemistry sampling system to determine compliance with FSAR commitments, proposed Technical Specifications, and recommendations contained in CENPD-28, " Combustion Engineering Chemistry Manual."
.
.-
,. -, -
. _..
-
.--
.-
.
._
-
.
.
-
. - ~.
.
'
s.
..
/,
'
Documents Reviewed
,
FSAR,- Chapte.r IS~, proposed Technical Specifications'
.
.
,
FSAR, Section 9.3.2.2.1, " Primary Sampling System"~
-
.
.
CENPD-28, "Combbstion Engineering Chemistry Manual"
.
,
.
y
_
_
.
=
,
_CE-03-305, " Sampling of Ventilation-and Gassous Waste Management
_
.
Systems for Radioactive Effluents," Revisi6n: 0, January 26, 1903
.
.
CE-03-700,J! General Grab Sampling Technique.3," Revision 0, January 7,
.
'
1982
'
-
-
g q.
,
The NRC inspectors _ visited the primary chemistry samplirig area !to be used by.the radiochemistry etaff in performing their variouRradicchemistry responsibilities.
The:pr mary sampling system bririgs} samples from the i
reactor coolant syste.ii and auxiliary systems to a" common location in the
,
primary sample roo'n on, the primary sampling papel located on the -4 foot elbvation in theI.eactor Access Building.. Grab. sample provisiorn are F
pr'ovided.
At the tied. of 'the inspection,'the'new primary, sample' panel was a
-
installed and.prelimi. nary check-out of' system instrumentation and valves
- was in prograss. _ The pressurizer surge ~1the[joressurizer steam space, and reactor coolant hot leg sample pointslhwileh:\\ tested.
Sample lines which
~
had been located in dicontrolled areas (and ahes of high occupancy' within
,
,
the radiation controlled area were being eqaiigef and routed throug Ktje
'
-
-35 foot elevation. to ' reduce potentially hikh radiation areas for. inany E
workers ~andreducehigh'oackgroundreadingsrintnehealth~physicscoun
' area.
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)
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The automatic gas;. analyzer was installed in the roggi adjacent to the i [/
primary sample room.. Gas samples from various systems are to be autos /
,
matica11y analyzed.for' hazardous concentration mixtv{es47 oxygen arly (, [
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Grab samples may be collected and taken-Lpc.he radiochemistry (
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laboratory for further analysis..The1 automatic gas anab3tr was not (,
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completely operational nor completely: galibrated at the time sof the '],
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inspection.
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sample panel and obtain grab samples as r,equired by Regulatory Guide 1l.21,
,
The NRC inspectors reviewed the existing sampling procedures to determine +
,
'
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if they provided guidance in the proper techniques for collection of
!
specific grab samples.
The existing procedurea were adequate;for sampling j
of ventilatjon and gaseous waste effluents and general grab sampling '
techniques.
However, specific sampling procedures had not been 9ritten to
provide step-by-step guidance fot collectibn of all. primary chEnistry!
samples which would include Auch informatiod as sampling frequency, sample h
point valve identification, sample point l location, sampling vaive lineups, specific tank recirculation times, sample Q ne flu e times totprovide a
,
representative sample, sample quantity, andtsample(contaiper labeling.
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Open Item (382/8212-08), Primary Chemistry Sampling System, will remain open pending:
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Complete' checkout of the primary-sampling panel.
.
Completion of sampling procedures and valve lineups for use of the
.
sampling panel.
Complete calibration and checkout of the automatic gas analyzer
.
panel.
No violations or deviations were identified.
12.
Secondary Chemistry Sampling System The NRC inspectors reviewed the licensee's secondary chemistry sampling
. system to determine compliance with FSAR commitments, proposed Technical Specifications, and recommendations contained in CENPD-28, " Combustion Engineering Chemistry Manual."
Documents Reviewed FSAR, Chapter 16, proposed Technical Specifications
.
FSAR,-Section 9.3.2.2.2, " Secondary Sampling System"
.
CENPD-28,." Combustion Engineering Chemistry Manual"
.
t>
l CE-03-700, " General Grab Sampling Techniques,". Revision 0, January 7,
.
1982
- -
The NRC inspectors visited the secondary chemistry sampling area to be used by the chemistry staff in performing' their various chemistry respons-ibilities.
The secondary sampling system takes water and steam samples from the secondary cycle, makeup demineralizer, and condensate transfer
. pump discharge and brings them to a common location in the secondary
~
chemistry laboratory located on the -4 foot elevation in the Reactor Access Building.
Grab sample provisions are provided.
At the time of the inspection, the secondary. sampling panel and process t
b analyzers were installed.
The sodium silica, oxygen,-hydrazine, and pH ii i
analyzers had been checked and calibrated.
The conduct v ty mon tors were
'
p not functional and had been removed for repair.
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The licer.see had not developed detailed step-by-step sampling procedures to provide guidance in the proper techniques for collection of specific representative grab samples from tanks and the secondary chemistry sample panel.
Open Item (382/8312-09), Secondary Chemistry Samplina System, will remain open pending:
Complete checkout of the secondary sampling panel.
.
Completion of sampling procedures and valve lineups for use of the
.
sampling panel.
Complete calibration and checkout of the process analyzers.
.
No violations or deviations were ' identified.
13.
Postaccident Samplina System The NRC inspectors reviewed the licensee's postaccident sampling system to determine compliance with FSAR commitments and the recommendations of NUREG-0660 and NUREG-0737.
Documents Reviewed FSAR, Section 9.3.8, "Postaccident Sampling System"
.
CE-03-902, "Postaccident Boron Analysis;" Revision 0, November 1,
.
1982 CE-03-S03, "Postaccident Gamma Spectroscopy Analysis," Revision 0,
.
December 15, 1982 CE-03-904, "Postaccident Analysis of Dissolved Hydrogen in the
.
Reactor Coolant," Revision 0, September 21, 1982 Planned Procedures Not Available for Review CE-01-901, " Testing and Maintenance of Postaccident Sampling Systems"
.
(Draft), in PORC review CE-03-900, " Operation of the Postaccident Sampling System" (Draft),
.
in PORC review CE-03-901, "Postaccident Sampling of Containment Atmosphere" (Draft),
.
in PORC review
._
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The NRC inspectors toured the area in the plant where the postaccident sampling system is to be installed.
The hardware was not installed at the time of the inspection.
Procedures to test and operate the system were proposed but not available for review. A detailed review of the completed system will be conducted prior to plant operation.
Open Iten (382/8212-10), Postaccident Samplina System, will remain open pending installation completion, checkout, and calibration of the proposed system.
t No violations or deviations were identified.
14.
Controls for Effluent Releases The NRC inspectors did not review the licensee's controls for effluent releases during this inspection.
This area was discussed and progress updated in NRC Inspection Report 50-382/83-07.
Based on the findings as discussed in that repot t, open item (382/8212-11), Controls for Effluent Releases, will remain open pending completion of all effluent release procedures.
15.
Facilities
The NRC inspectors toured and inspected the facilities to be used by the chemistry / radiochemistry staff in performing their various chemistry support responsibilities.
The inspection findings updates the current status of availability of the chemistry staf f laboratory and office areas.
The following facilities were inspected:
Area Location Status Water plant laboratory Makeup Water Temporary, incomplete Domineralizer Building Chemistry and Radiu-
-4 ft elevation RAB*
Completed, not equipped chemistry Supervisors'-
or occupied
office Chemistry /Radiochem-
-4 ft elevation RAB Completed, equipped, istry storage area and in use l'
i Secondary Chemistry-4 ft. elevation RAB Completed, equipped, l
Laboratory and operational Primary Chemistry-4 ft. elevation RAB Completed, equipped, l
Laboratory and operational l
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Radiochemistry Counting-4 ft. elevation RAB Completed, equipped, Room and operational Primary Sample Room-4 ft. elevation RAB Incomplete, new sample panel installed, but not operational Gas Analyzer Room-4 ft. elevation RAB Completed, gas analyzer installed, but not operational or completely calibrated
- Reactor Access Building The ifcensee had nearly completed construction of the designated space for chemistry / radiochemistry activities.
The chemistry / radiochemistry labora-tories were equipped and operational.
The laboratories were supplied with chemicals, labware, and analytical instrumentation to perform the required analytical procedures.
The gas test board had not been installed in the-radiochemistry laboratory.
The water plant laboratory was yet a temporary facility.
It was equipped with a turbidimeter, pH meter, conductivity bridge, and water hardness test stand.
Plans were in place to locate a trailer unit next to the makeup water demineralizer building on March 7, 1983, and equip it for use as a water plant laboratory.
The trailer was to have fume hoods and utilities so it could be used as an emergency laboratory.
The trailer will have two gasoline electrical generators fnr emergency power. The Nuclear Data ND-66 analyzer will be installed for use as an emergency backup counting facility.
The counting room was supplied with stabilized electrical power, appropriate ventilation, and air conditioning to protect the operation of the sensitive instrumentation located in the counting room.
The counting room was equipped with two horizontal gamma scintillation detectors and respective lead and steel sheilds connected to a Nuclear Data ND-6620 system, a Nuclear Data ND-66 dual floppy disk system, a Beckman LS-7000 liquid scintillation spectrometer Fystem, and a Nuclear Measurements Corporation DS-3 decade scaler and PCC-11T detector gas proportional counter system.
The equipment was installed and the counting room was occupied for instrument calibration purposes.
The primary sample room and gas analyzer rooms were not operational.
Final construction and piping modifications were not completed.
The construction of the chemistry supervisor's and radiochemistry supervisor's office was completed.
At the time of the inspection, the office was not equipped or occupied.
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Open Item (382/8212-12), Facilities, will remain open pending completion of construction and occupancy of the chemistry / radiochemistry facilities.
No violations or deviations were identified.
16.
Chemistry / Radiochemistry Analytical Instrumentation, Calibration, and Quality Control
The NRC inspectors reviewed the licensee's inventory of analytical equipment and supplies to be used in the counting room and laboratories.
The inventory of laboratory and counting equipment avilable during this inspection was as follows:
fauipment Model Status
'
Drying Oven Blue M Two, onsite Large Centrifuge IEC Centra-7 One, onsite Electronic Analytical Mettler AK-160 One, onsite Balance Mechanical Analytical Mettler H-35AR One, onsite Balance Top Loading Balance Mettler PC-400 Two, onsite Triple Beam Balance Ohaus One, onsite Conductivity Bridge Leeds and Northrup Two, onsite; l
Two, on order Conductivity Bridge Beckman RC-20'
Two, onsite l
~
l pH Meter Orion 701A Two, onsite; j
One, on order i
pH Meter Corning 125 Two, onsite;
'One, on order l
pH Meter Orion 399A Two, onsite Specific Ion Meter Orion 407A.
Three, onsite; One, on order
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Turbidimeter Hach 2100A-Three, onsite; One, on order Auto-titrator Mettler DL-40 One, onsite
'
Plasma Emission Spectrometer Beckman/ Spectra Span 5 One, onsite UV/VIS Spectrometer Perkin-Elmer Lambda-3 Two, onsite
?
Spectrometer Baush & Lomb One, onsite Spectronic 88 Gas Chromatograph Carle AGC-111 One, onsite Ion Chromatograph Dionex One, onsite Gamma Isntopic Spectrometer Nuclear Data ND-6620 One, onsite Nuclear Data ND-66 Dual Floppy Disks One, onsite Gamma Detectors High Purity Ge - 8.9%<
One, onsite
.GeLi - 22.4%
One, onsite Liquid Scintillation Spectrometer Beckman LS-7000 One, onsite
, Gas Proportional Counter NMC PCC-11T/DS-3 One, onsite The NRC inspectors found the type and quantity of analytical instrumentation adequate to perform the analytical requirements of the respective labora-tories and counting room.
As indicated by the above status list, most of the laboratory instruments had been received onsite.
Those instruments still on order were duplicates or backups to existing inservice equipment.
Laboratory and instrument supplies and spare parts had been procured and stored in the respective laboratories or chemistry / radiochemistry storage area.
The' analytical instruments were located in their respective work areas and subject to relocation for work efficiency reasons after a trial period.
Verification of operability and calibration of analytical instruments in the two laboratories was in progress. The analytical balances, conductiv-ity bridges, pH' meters, and turbidimeters had been initially calibrated.
The plasma emission spectrometer was calibrated for iron, copper, and lithium.
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l The_.UV/VIS spectrometers were calibrated for ammonia, silica, hydrazine,
'
and phosphate..The auto-titrator was calibrated for boron analysis.
The
' gas chromatograph was calibrated for hydrogen, oxygen, and nitrogen
analyses.
The ion chromotograph was calibrated for chloride,, fluoride,
'_and sulfate ions.
Implementation of the calibration check' program was started on selected
instruments, but not totally implemented at;the time of-the inspection.
The NRC inspectors visited thehradiochemistry counting room'ahd reviewed
,
the status of. counting instrument calibrations and' quality control to determine compliance with the recommendations of Regulatory Guide 4.15.
,
i The liquid scintillation spectrometer was not calibrated prior to the inspection.
During the inspection, a laboratory. technician used the NRC's g
quenched certified tritium standards to establish an initial quench curve calibration. Thealpha/betagag4groportionalcounterhadbeencalibrated for alpha measurements using a As certified source, but no beta calibra-j tion had been performed prior to the inspection.
The gamma spectrometer
system and high purity germanium detector had been calibrated f.or the i
principal counting geometries and at various shelf distances from the detector.
The following calibrations performed in February 1983 were reviewed:
face loaded charcoal cartridge, shelves 1, 2, and 3; homogenous loaded charcoal cartridge, shelves 1, 2, and 3; one liter square bottle, shelves 1 and 2; 20 ml. scintillation vial, shelves 1 and 2; 47 mm.
particulate filter, shelves 1 and 2; one liter gas Marinelli beaker; and
{'
33 cc. gas bulb sphere, shelves 1-8.
Calibration check data for the gamma
'
spectrceeter system for the period September 14, 1982 through March'3, l'
1983, were reviewed.
The licensee's records were found in order and according to procedure.
Open Item (382/8212-13), Chemistry / Radiochemistry Analytical Instrumentation, will remain open pending:
i Receipt of remaining instrumentation and supplies.
.
Completion of-quality control procedures for analytical instruments.
.
Verification of operability and calibration of all analytical.
.
instrumentation.
Implementation of the instrument calibration check program.
.
l
.
No violations or deviations were identified.
"
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- 17.
Audits and Review f
The NRC inspectors reviewed the licensee's internal audit / review program regarding chemistry / radiochemistry activities to determine compliance with
,
I
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FSAR, mitments, the requirements of 10 CFR Part 50, Appendix B, and the recommen itions of ANSI N18.7-1976, Regulatory Guides 1.33, 1.144, 1.146, and 4.15.
Documents Reviewed FSAR, Chapter 17
.
Safety Evaluation Report (NUREG 0787) Waterford Unit No. 3
.
LPAL Quality Assurance Manual
.
Quality Assurance Staff Organization Chart
.
Audit Checklist for Primary Chemistry, Secondary Chemistry, and
.
Chemical Inventory, (Draft)
The NRC inspectors were specifically interested in the existence of an audit / review program and the scope of that program as it relates to the chemistry / radiochemistry department and what progress had been made in the development and implementation of such a program since the previous inspection.
The licensee's quality assurance department in the area of nuclear operations had hired qualified staff to fill positions as inspectors in the sections of audits, support engineering, and surveillance.
These inspecto.s will be responsible for the development and implementation of the quality control program as it relates to nuclear operations, The licensee was in the process of revising Chapter 17.2 of the FSAR, the Quality Assurance Manual, and developing audit procedures and audit checklists. A review of the audit checklist for primary chemistry, secondary chemistry, and chemical inventory frdicated that the quality assurance department was becoming more knowledgeable in the activities of the chemistry / radiochemistry department.
The NRC inspectors have concerns that the audit / review program include the following areas in its scope:
Reviews performed by supervision within the chemistry / radiochemistry
.
department of such activities as staff effectiveness, work practices, adequacy of staff training, and procedural compliance.
Reviews performed by the onsite quality assurance (QA) department in
.
the area of water plant water quality and secondary chemistry control of feedwater and steam generator water quality.
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Reviews. performed by the onsite QA department in the area of
.
environmental impact. monitoring and NPDES chemical discharges to the
,
environment.
!
Reviews performed by the onsite QA department in the areas of
.
' controlling and reporting of liquid and~ gaseous effluent releases.
Reviews performed b'y the onsite QA department in the area of Technical
.
Specification requirements related to primary chemistry of the reactor coolant system.
!
Reviews performed by the onsite QA department in the areas of
.
laboratory instrument operation, calibration, and calibration checks.
-Reviews performed by the onsite.QA department in the area of instrument
.
radioactive calibration sources validity and their control,
i i
Reviews performed by the onsite QA department in the area of chemistry
.
and radiochemistry procedural accuracy.
Corporate audits performed to ensure compliance with Technical
.
Specifications, Code of Federal Regulations, and stated objectives.
,
Audit / review format, including the existence of audit procedures and-
.
!
checklists, to provide an insight regarding the adequacy and scope of '
I
.the proposed audit / review activities.
Composition of audit / review teams.to enstre that the team members
.
possess the necessary expertise to properly evaluate the assigned
!
areas.
Corrective action program to provide timely resolution of identified
.
.
deficiencies.
[
These concerns were previously identified in open item (382/8212-14) and are emphasized again.
The progress shown by the quality assurance depart-
,
ment showed that-it was headed in the appropriate direction to accomplish a program which will eliminate the above listed concerns.
,
Open Item (382/8212-14), Audits and Review, will remain open pending icplementation of a comprehensive audit / review program for chemistry /
radiochemistry activities.
No violations or deviations were identified.
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-18.
Procedures The NRC inspectors. reviewed the licensee's chemistry / radiochemistry
.
_ department procedures to determine compliance with 10 CFR Part 20 require-
!-
- ments, FSAR commitments, and-recommendations contained in Rcgulatory
,
Guides 1.21, 1.33,.4.15; and ANSI N13.1-1969, N18.7-1976 N323-1978; and
'
Combustion Engineering Chemistry. Manual CENPD-28.
'
-For documentation purposes, in this report, the licensee's procedures have been classified as:
(1) Station Approved Procedures,_(2) Procedures to be-
' Completed, and (3) Procedures not Identified Which Need to be Written.
The NRC inspectors noted that_.the licensee had approved approximately
92 percent (103 procedures) of.a11' planned chemistry / radiochemistry f
procedures, with approximately 9 procedures remaining to be approved.
a.
Station Approvea Procedures
'!
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4.
CE-01-000, " Organization'of the Chemistry Department," Revision 0,
.
.
April'22,'1981
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t CE-01-001, " Training and Qualification ~of the Chemistry Department
.
Personnel,": Revision 0, June.15,1982 CE-01-002, " Log Keeping, Filing,' and Record Storage," Revision 1,
,.
.
January'22, 1982 i
CE-01-003,;" Reporting Chemistry Data to the Operations Group,"
.
Revision 0; February 5, 1982
'
CE-01-004, " Periodic Analysis, Scheduling Program," Revision 0,
.
September. 21,~ 1982 CE-01-005, " Test Stand Calibration Scheduling Program,"
.
Revision 0, August 31,.1982 CE-01-006, " Analytical and Process Equipment Calibration
.
Scheduling Program," Revision 0, August 31, 1982 CE-01-008, " Inventory and Control of Chemicals and Reagents,"
.
Revision 0, December 9, 1981
CE-01-009, "Corbicula Infestation Evaluation of~ Safety Related
.
.
Systers,". Revi siot: 0, July 29, 1982 CE-02-000, " Maintaining Auxiliary Boiler Chemistry," Revision 0,
.
l February 5, 1982
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CE-02-001 " Maintaining Steam Generato Chemistry," Revision 0,
.
July 29, 1982 CE-02-002, " Maintaining Condensate and Feedwater Chemistry,"
.
Revision 0, August 13, 1982 CE-02-004, " Maintaining Boze Filter Chemistry," Revision 0,
.
October 27, 1931 CE-02-005, " Maintaining Makeup Demineralizer Chemistry,"
.
Revision 0, January 22, 1982 CE-02-006, " Maintaining Reactor Coolant Chemistry," Revision 0,
.
September 17, 1982 CE-02-007, " Maintaining Component Cooling Water Chemistry,"
.
Revision 0, January 7, 1982 CE-02-008, " Maintaining Condensate Storage Pool Chemistry,"
.
Revision 0, September 17, 1982 CE-02-009, " Maintaining Boron Mar,agement System Chemistry,"
.
Revision 0, August 19, 1982 CE-02-010 " Maintaining Safety Injection Tank Chemistry,"
.
Revision 0, October 14, 1982 CE-02-011. " Maintaining Spent Fuel Pool Chemistry," Revision 0,
.
February 5, 1982 CE-02-012. " Maintaining Boron Concentration During Refueling,"
.
Revision 0, November 1, 1982 CE-02-013, "Maintainir.g Chill Water Chemistry," Revision 0,
.
July 21, 1982 CE-02-014, " Maintaining Supplementary Chill Water Chemistry,"
.
Revision 0, August 27, 1981 CE-02-015, " Maintaining Turbine Building Cooling Water Chemistry,"
.
Revision 0, April 1, 1982 CE-02-016, " Monitoring Gaseous Waste Management," Revision 0,
.
October 14, 1982 CE-02-017, " Maintaining Package Cooling Tower Chemistry,"
.
'
Revision 0, January 22, 1982
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CE-02-018, " Monitoring Liquid Waste Management," Revision 0,
.
November 1, 1982 CE-02-019 " Maintaining Diesel Generator Jacket Cooling Water
.
Chemistry," Revision 0, April 5 1982 CE-02-020, " Maintaining Primary Water. Storage Tank Chemistry,"
.
Revision 1, January 26, 1983 CE-02-021, " Systems Layup During the Construction Phase,"
.
Revision 0, December 9, 1981 CE-02-022, " Feed, Condensate, and Heater Drains Systems Chemistry
.
Prior to Normal Operations," Revision 0, October 27, 1981 CE-02-023,." Reactor Coolant and Auxiliary Systems Chemistry,"
.
Revision 0, November 11, 1981 CE-02-024, " Steam Generator Chemistry Prior to Normal Operation,"
.
Revision 0, November 9, 1981 CE-02-025, " Maintaining Refueling Water Storage Pool Chemistry,"
l
.
Revision 0, July 19, 1982
,
CE-02-026, " Boron Concentration Prior to and During Initial Core
.
Load," Revision 0, July 29, 1982 CE-02-027, " Maintaining Condensate Storage Tank Chemistry,"
.
l Revision 0, July 21, 1982 CE-02-028, " Maintaining Stator Coil. Water Chemistry," Revision 0,
.
[
January 22, 1982 CE-03-006," Use of the On-Line Hydrogen /0xygen Analyzer,"
.
l Revision 0, July 29, 1982 l
!
CE-03-007, " Operation of the Process pH Monitors," Revision 1,
.
(
June 30, 1982 l
l CE-03-008, "Use of the Process Conductivity Monitors," Revision 0,
.
'
August 24, 1981 CE-03-009, "Use of the Process Dissolved Oxygen Monitors,"
.
Revision 0, August 12, 1981 CE-03-010, "Use of Process Silica Monitors," Revision 0,
.
October 1, 1981
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-CE-03-011, "Use of Process Sodium Monitors," Revision 0, June 30, 1982 CE-03-012,."Use of the Hach Surface Scatter 4 Turbidimeter,"
.
Revision 0, August 24, 1981
.
- CE-03-013 "Use of Hach Process Hardness Monitor," Revision 0, October 6, 1981 CE-03-014. "Use of the Process Hydrazine Monitor," Revision 0,
.
August 27, 1981 CE-03-101, " Determination of Chlorides - Mercuric Nitrate
.
Method," Revision 1 January 26, 1983 CE-03-103, " Determination of Chloride - Specific Ion Electrode
.
Method," Revision 1, December 15, 1982 CE-03-104, " Determination of Chlorides <10 ppm - Colorimetric
.
Method," Revision 0, September 10, 1981 CE-03-105, " Determination of pH - Meter, " Revision 1, December 15,
.
- 1982 CE-03-106, " Determination of Conductivity," Revision 2,
.
December 15, 1982 CE-03-107, " Determination of Fluoride," Revision 1, December _15,
.
1982'
CE-03-108, " Determination of Hydrazine (0-80 ppb)," Revision 0,
.
-
August 27, 1981 CE-03-109, " Determination of Hydrazine," Revision 2, December 15,
.
1982
[:
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CE-03-111,~ " Determination of Ammonia," Revision 1, October 27,
.
[
1981
..
CE-03-112, " Determination of Ammonia in the Presence.of.Hydrazine
.
.
f
>200 ppb - Distillation Method," Revision 1, December 15, 1982 l
.
-
CE-03-113,-" Determination of Silica," Revision 1, December 15,
'
.
1982
~
CE-03-115, " Determination of Total Hardness 0-2 ppm," Revision 0,
.
,
L September 28, 1981 l
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CE-03-116, '" Determination of Total Hardness >2 ppe," Revisica 1,
.
October 6, 1981 CE-03-118, " Determination of Dissolved Oxygen >0.05 ppa -
.
Winkler Method," Revision 0, August 27, 1981 CE-03-119, " Determination of Dissolved Oxygen - Indigo Carmine
.
Method," Revision 0, August 27, 1981 CE-03-120, " Determination of Dissolved Oxygen - Meter,"
.
Revision 0, August 27, 1981 CE-03-121, "D'etermination of Boron," Revision 1, August 27, 1981
.
CE-03-122, " Determination of Boron - Titration Method,"
.
Revision 1, August 12, 1981 CE-03-123, " Determination of Boron - Curcumin Method," Revision 1,
.
August 12, 1981
.
CE-03-125, " Determination of Fluoride'and Chloride Contamination -
.
Patch Test Method.'A'," Revision 1, August 20, 1981 CE-03-126, " Determination of Surface Chlorides and Fluorides -
.
Patch Test Method
'B'," Revision 1, August 12, 1981 CE-03-127, " Determination of Suspended Solids," Revision 0,
.
August 12, 1981
~
CE-03-129, " Determination of Surfactants - Methylene Blue
.
Method," Revision 0, October 1, 1981'
CE-03-130, " Determination of Solids - Membrane Comparison
.
Chart," Revision 0, August 12, 1981 CE-03-131, " Determination of Particulate! Contamination in
.
Liquids - Particulate Count Method,". Revision'1, August 12, 1981
-
.CE-03-132, " Determination of Total Phosphates - Amino Acid,"
.
Revision 0, August 27, 1981 CE-03-138, " Determination of Turbidity - Turbidimeter Method,"
.
Revision 0, August 12, 1981 CE-03-139, " Determination of Acidity - Titration Method,"
.
Revision 0, August 27, 1981
!'
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CE-03-140, " Determination of Total Alkalinity - Phenolphthalein
.
and Methyl Orange," Revision 0, August 20, 1981 CE-03-141, " Determination of Baume and Percent Concentration of
.
Aqueous Solution," Revision 0, August 20, 1981 CE-03-146, " Determination of Nitrite - Titration Method,"
.
Revision 1, September 17, 1982 CE-03-149, " Determination of Hydroxide Ion in Water," Revision 0,
.
August 12, 1981 CE-03-300, " Preparation of Liquid Samples for Radiological
.
Chemical Analyses," Rovision 0, June 4, 1982 CE-03-301, " Determination of Gross Beta Radioactivity,"
.
Revision 0, August 4, 1982 CE-03-302, " Determination of Gross Gamma Radioactivity,"
.
Revision 0, August 4, 1987 CE-03-303, " Gross Alpha Measurement," Revision 0, November 9,
.
1981 CE-03-305, " Sampling of Ventilation and Gaseous Waste Management
.
Systems for Radioactive Effluents," Revision 0, January 26, 1983 CE-03-306, " Determination of the Average Beta-Gamma Energy of
.
Reactor Ccolant," Revision 0, September 17, 1982 CE-03-313, " Tritium Analysis," Revision 0, July 21, 1982
.
l CE-03-320, " Gamma Spectroscopy Analysis," Revision 0, July 29,
.
1982 CE-03-324. "Compositing Samples for Weekly, Monthly, and Quarterly
.
Composites," Revision 0, August 4, 1982 CE-03-325, " Determination of Nitrogen, Hydrogen, and Oxygen and
.
Gaseous Activities," Revision 0, October 5, 1982 CE-03-400, "Use of the Plasma Emission Spectrometer," Revision 0,
.
October 5, 1992 CE-03-500, " Determination of Free CO," Revision 0, October 6,
.
1981
-
-
_
,
-
_,,
_
. _
.
_.
.
.
'
,
.
44-CE-03-501, " Determination of Chlorine - Starch-Iodide Titration,"
-
.
Revision 0, October 27,.1981 CE-03-503, " Determination of Total Free Chlorine - Comparator
.
Method," Revision 0, October 27, 1981 CE-03-600, " Determination of 011 and Grease in Liquid Solvent
.
Extraction," Revision 1, October 27, 1981 CE-03-601, " Determination of Kinematic Viscosity of Liquid
.
Petroleum Products," Revision 0, October 27, 1981 CE-03-602, " Determination of Water and Sediment in Oil -
.
Centrifuge," Revision 1, September 25, 1979 CE-03-603, " Determination of Water Content in Electro-Hydraulic
.
Fluid," Revision 1, October 6, 1981 CE-03-604, " Determination of Mineral Oil in EH Fluid," Revision 1,
.
October 6, 1981 CE-03-605, " Determination of Neutralization Number - Titration
.
Method," Revision 0, October 6, 1981 CE-03-700, " General Grab Sampling Techniques," Revision 0,
.
January 7,1982 CE-03-800, " Operation of the Ion Chromatograph," Revision 0,
.
January 9, 1983
,..
CE-03-902, "Postaccident Boron Analysis," Revision 0, November 1,
.
1982 CE-03-903, "Postaccident Gamma Spectroscopic Analysis,"
.
Revision 0, December 15, 1982 CE-03-904, "Postaccident Hydrogen Analysis," Revision 0,
.
September 21, 1982 l
b.
Procedures to be Comp 7eted CE-01-016. " Control of Measuring and Test Equipment"
.
CE-01-020, " Chemistry / Radiochemistry Quality Control" t
.
l i
CE-01-901, " Testing and Maintenance of Postaccident Sampling
.
!
Systems" s
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,
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.
,
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,
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.
.
'45 CE-02-003, " Maintaining Wet Cooling Tower Chemistry"
.
CE-02-100, " Chemistry Technical Specifications Surveillance
.
Performance Coordination"
-
CE-03-311, " Radiostrontium Analysis"~
.
CE-03-330, " Determination of Iron-56"
.
CE-03-900, " Operation'of the Postaccident Sampling System"
.
CE-03-901, "Postaccident Sampling of Containment Atmosphere"
.
'
^
c.
Procedures not Identiffed Which Need to be Written The NRC inspectors noted that' procedures for.the following areas had
,
'
not been identified by the licensee to be written:
Tank Sampling Recirculation Times
.
Specific detailed sampling procedures for all' manually taken
.
samples which include valve lineups, labeling, handling pre-cautions, safety considerations, and flush times to provide representative samples.
Preparation of instrument radioactive calibration standards
.
Determination of Lithium
.
Determination of Sodium
.
Determination of Radioiodine in the Reactor Coolant System
.
(Extraction Method)
Determination of Iodine Equivalence in the Reactor Coolant.
.
System Determination of Radiocesium in the Reactor Coolant System
.
(Extraction Method)
The NRC inspectors were informed by the licensee that in the near future many of the procedures listed above will no longer be a part of the Plant Operating Manual (POM) and become depart-mental procedures not requiring Plant Operations Review Committee (PORC) approval.
.
-
-
,
._.
-
..
F
.
.
Open Item (382/8212-15), Procedures, will remain open pending:
Completion and approval of procedures referenced in Section 18.b of
.
this report.
Licensee evaluation of procedures addressed in Section 18.c of this
.
report.
No violations or deviations were identified.
19.
Analytical Measurements a.
Confirmatory Measurements Confirmatory measurements were performed on the following standards-in the Region IV mobile laboratory at Waterford 3 Nuclear Station during the inspection:
(1) NRC Face Loaded Charcoal Cartridge Standard (SRS-13161-109)
(2) LP&L Face Loaded Charcoal Cartridge Standard (SRS-13125-92)
(3) RESL Fece Loaded Charcoal Cartridge Standard (80-6)
(4) NRC Particulate Filter Standard (SRS-13162-109)
(5) RESL Particulate Filter Standard (80-8)
(6) LP&L 1 liter Gas Marinelli Beaker Standard (SRS-13084-92)
(7) LP&L 30 cc Gas Bulb Standard (SRS-13083-92)
(8) NRC 20 ml Liquid Scintillation Vial-Standard (SRS-13156-109)
(9) Laboratory Liquid Waste (10) NRC Liquid Scintillation Tritium Standard (H329054)
(11) NRC Gross Alpha Thorium-230 Standard (S-2331)
(12) NRC Gross Beta Cesium-137 Standard (SRS-13154-109)
The confirmatory measurements test consists of comparing measurements made by the. licensee and the NRC Region IV mobile laboratory.
The NRC's mobile laboratory measurements are referenced to the National Bureau of Standards by laboratory intercomparisons.
Confirmatory measurements are made only for those nuclides identified by the mobile laboratory as being present in concentrations greater than 10 percent of the respective isotopic values for liquid and gas concentrations as stated in 10 CFR Part 20, Appendix B, Table II.
Attachment No. 1 contains the criteria used to compare results.
-
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b.
Results The licensee maintains two detectors, a high purity intrinsic germanium (HPG) and a germanium-lithium (Geli), connected to a Nuclear Data 6620 gamma spectrometer system.
Either and/or both detectors will be used for routine isotopic analysis of radioactive samples to demonstrate compliance with Technical Specifications and regulatory requirements.
The high purity germanium detector was the only detector operable at the time of the inspection, so it was the only detector cross-checked during this inspection.
The following tables show the various sample comparison results:
(1) NRC Face Loaded Charcoal Cartridge Standard (SRS-13161-109)
(Standardized 11:00 CST, January 1,'1983)
LP&L Result NRC Result LP&L/NRC Nuclide (uCi/ Sample)
(uCi/ Sample)
Ratio Decision b Co 2.82 1 0.01 E-02 2.83 1 0.01 E-02 1.00 Agreement 60Co 3.60 1 0.03 E-02 3.89 1 0.02 E-02 0.93 Agreement 83Y 8.18 1 0.05 E-02 9.23 1 0.04 E-02 0.89 Agreement 109Cd 8.99 i 0.02 E-01 8.95 1 0.02 E-01
.1.01 Agreement 113Sn 4.64 1 0.03 E-02 4.98'i 0.02 E-02
'0.93 Agreement 17 Cs 4.17 1 0.03 E-02 4.55 1 0.02 E-02
.0.92 Agreement ce 2.31 1 0.01 E-02 2.39 1 0.01 E-02 0.97 Agreement
!.
Hg 5.68 1 0.03 E-02 7.24 1 0.03 E-02 0.'92 Agreement (2) LP&L Face loaded Charcoal Cartridge Standard (SRS-13125-92)
(Standardized 11:00 CST, January 1, 1983)
LP&L Result NRC Result LP&L/NRC Nuclide (uCi/ Sample)
(uCi/ Sample)
Ratio Decision l
Co 2.26 1 0.01 E-02 2.21 1 0.01 E-02 1.02 Agreement
OCo 2.97 1 0.03 E-02 3.13 1 0.02 E-02 0.95 Agreement 88Y 6.69 1 0.04 E-02 7.33 1 0.04 E-02 0.91 Agreement 109Cd 7.04 1 0.02 E-01 6.95 i 0.02 E-01 1.01 Agreement l
.
m
.
.
i 13Sn 3.71 1 0.02 E-02 3.97 i 0.02 E-02 0.94 Agreement 137Cs 3.41 1 0.02 E-02 3.65 1 0.02 E-02 0.93 Agreement 139Ce 1.89 i 0.01 E-02 1.87 i 0.01 E-02 1.01 Agreement 03Hg 5.37 i 0.03 E-02 5.68 1 0.02 E-02 0.95 Agreement (3) RESL Face Loaded Charcoal Cartridae Standard (80-6)
(Standardized 9:00 CST, March 19, 1980)
LP&L Result NRC Result LP&L/NRC Nuclide (uCi/ Sample)
(uCi/ Sample)
Ratio Decision 57Co 8.95 1 0.30 E-03 8.48 1 0.30 E-03 1.06 Agreement 60Co 6.30 1 0.04 E-02 5.99 1 0.04 E-02 1.05 Agreement 137Cs 4.52 1 0.02 E-02 4.42 1 0.02 E-02 1.02 Agreement (4) NRC Particulate Filter Standard (SRS-13162-109)
(Standardized -11:00 CST, January 1,1983)
LP&L Result NRC Result LP&L/NRC Nuclide (uCi/ Sample)
(uCi/ Sample)
Ratio Decision 57Co 2.08 1 0.01 E-02 2.21 1 0.01 E-02 0.94 Agreement 60Co 2.64 1 0.02 E-02 2.96 i 0.03 E-02 0.89 Agreement 88Y 6.50 1 0.04 E-02 7.09 1 0.05 E-02 0.91 Agreement 109Cd 6.51 1 0.02 E-01 6.89 i 0.03 E-01 0.94
. Agreement 113Sn 3.31 * 0.02 E-02 4.22 1 0.04 E-02 0.78 Poss. Agreement 13 Cs 3.01 1 0.02 E-02 3.55 1 0.03 E-02 0.85 Agreement 139Ce 1.74 1 0.01 E-02 2.00 1 0.01 E-02 0.87 Agreement 203:Ig 3.52 x 0.02 E-02 3.75 1 0.03 E-02 0.94 Agreement
.
-
.
-
..
.
.
(5) RESL Particulate Filter' Standard (80-8)
(Standardized 9:00 CST, March 19, 1980)
i LP&L Result NRC Result LP&L/NRC Nuclide (uC1/ Sample)
(uCi/ Sample)
Ratio Decision 57Co 1.32 1 0.05.E-02 1.13 1 0.0G E-02 1.17 Agreement 60Co 1.02 i 0.01 E-01 8.83 1 0.06 E-02 1.16 Agreement 137Cs 7.72 1 0.04 E-02 6.68 0.04 E-02 1.16 Agreement (6) LP&L 1 liter Gas Marinelli Beaker Standard (SRS-13084-92)
(Standardized 11:00 CST, January 1, 1983)
1-LP&L Result'
NRC Result LP&L/NRC Nuclide (uC1/ Sample)
(uCi/ Sample)
Ratio Decision 85Kr 1.580 1 0.006 E+02 1.577 1 0.003 E+02 1.00 Agreement 127Xe 6.388 1 0.008 E+00 3.681 1 0.003 E+00 1.74 Disagreement (7) LP&L 30 cc Gas Bulb Standard (SRS-13083-92)
(Standardized 11:00 C$T, January 17, 1983)
LP&L Result NRC Result LP&L/NRC Nuclide (uCi/ Sample)
(uCi/ Sample)
Ratio Decision 85Kr 1.857 i 0.006 E+02 1.609 1 0.005 E+02 1.15 Agreement 127,.
7.148 1 0.009 E+00 6.287 i 0.003 E+00 1.14 Agreement
(8) NRC 20ml Liquid Scintillation Vial Standard (SRS-13159-109)
(Standardized 11:00 CST, January 1,1983)
LP&L Result NRC Result LP&L/NRC Nuclide (uCi/ Sample)
(uCi/ Sample)
Ratio Decision Co 2.65 1 0.01 E-02 2.72 1 0.01 E-02 0.98 Agreement 60Co 3.56 1 0.03 E-02 3.64 1 0.03 E-02 0.98 Agreement 88Y 8.67 i 0.05 E-02 8.88 1 0.06 E-02 0.98 Agreement 109Cd 8.42 0.02 E-01 8.53't 0.03 E-01.
0.99 Agreement 113Sn 4.48 1 0.03 E-02
- 4.41 1 0.03_E-02'
1, 02 Agreement 137Cs 3.96 1 0.02 E-02 4.06 1 0.0'3 E-02~
0.98 '
Agreement
,
,
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.
-
139
'
2.24 1 0.02 E-02 1.00 Agreement Ce 2.24 i O.01 E-02
203Hg 6.24 i 0.03 E 02 6.28 i 0.04 E-02 0.99 Agreement
(9) -Laboratory Liquid Waste
_(Sampled 15:00 CST, March 2, 1983)
'
LP&L Result NRC Result.
LP&L/NRC Nuclide (uCf/ Sample)
(uC1/ Sample)
Ratio Decision
' Agreement l
Mn 2.48 i 0.02 E-04 2.52 1 0.02 E-04 0.98 ~
-
'
7.12't 0.03 E-04
'1.04
' Agreement Co 7.42 i 0.03 E-04
-
Se 6.04 1 0.02 E-04.
5.72 1 0.02 E-04 1.06 Agreement
~
Y 1.17.1 0.10 E-05 1.05 i 0.10 E-05 1.12 Agreement
l Zr 1.75 1 0.15 E-05 1.60 1 0.14 E-05
'1.09 Agreement 125Sb 1.03 t'O.03 E-04
- 1.00 0.03 E-04 1.'03 Agreement 133Ba 8.53 1 0.02 E-04 8.17 i 0.03 E-04 1.04 Agreement 137Cs 9.62 1 0.03 E-04 9.47 i 0.03 E-04 1.02 Agreement (10) NRC Liquid Scintillation Tritium Standard (H329054)
(Standardized September 1, 1982)
LP&L Result-NRC Result 1/
'P&L/NRC
.
.
Nuclida (dom)
'(dpe)
Ratio Decision
>
H 86,641 2 380 87,589 1 2627 0.99 Agreement
-
1/ NRC result was taken from the standard certificate supplied with the standard as prepared by Beckman Instruments and traceable to the National Bureau of Standards.
,
'
,
i (11) NRC Gross Alpha Thorium-230 Standard (S-2331)
,
(Standardized September 23, 1980)
,
!
.LP&L Result
- NRC Result 1/
LP&L/NRC
!
Analysis (dpm)
.
(dpm)
Ratio Decision
<
i Gross i'
Alpha 9558 i 77 8250 1 160 1.16 Agreement 1/. NRC result was taken from the standard certificate supplied with the
'
-standard as prepared by Eberline Instrument Corporation and traceable to the National Bureau of Standards.
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-
(Standardized August 29, 1982)
LP&L Rasult NRC Result 1/.
Analysis (dpe)
(dom) -
LP&L/NRC Ratio Decision Gross
,
'
Beta 47,179 i 159 37,271 i 1714 1.26 Agreement 1/'
NRC result was taken from the standard certificate supplied with the standard as prepared by Analytics, Inc. and traceable to the National Bureau of Standards.
i No violations or deviations were identified.
,
20.
Exit Briefina The NRC inspectors met with the Itcensee representatives identified in
Section 1 of.this report at the conclusion of the inspection on March 3,
.
1983.
The lead NRC inspector discussed the scope and findings of the
,
inspection and informed the 1(censee of.the results of the confirmatory i
measurements performed on various intercomparison samples.
The lead NRC
inspector stated that all open items must be resolved before Region IV l
will recommend issuance of an operating license.
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ATTACHMENT NO. 1
.
..
Criteria for Comparing Analytical Measurements The following are the criteria used in comparing the results of capability tests and verification measurements. The criteria are based on an empirical relationship established through prior experience and this program's analytical requirements.
In these criteria, the judgment limits vary in relation to the comparison of the resolution.
Resolution = NRC Value NRC Uncertainty Ratio = Licensee Value NRC Value Comparisons are made by first determining the resolution and then reading
..
across the same line to the corresponding ratio. The following table shows
,
the acceptance values.
.
RESOLUTION RATIO Possible Possible
~~
Agreement Agreement A Agreement B
-
0.4 - 2.5 0.3 - 3.0 No Comparison ~
4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 l
8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5 16 - 50 0.75 - 1.33 0.6 - 1.66 0.5 - 2.0
51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.66
-
> 200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33
.
"A" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification is
-
greater than 250 kev.
Tritium analyses of liquid samples.
Iodine on adsorbers.
"B" criteria are applied to the following analyses:
l Gamma Spectrometry where principal gamma energy used for identification is less than 250 kev.
,
,
90 Sr and Sr determinations.
Gross Beta where samples are counted on the same date using the same reference nuclide.
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