IR 05000397/1995022
| ML17291A955 | |
| Person / Time | |
|---|---|
| Site: | Columbia |
| Issue date: | 08/10/1995 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17291A954 | List: |
| References | |
| 50-397-95-22, NUDOCS 9508170009 | |
| Download: ML17291A955 (37) | |
Text
ENCLOSURE U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-397/95-22 License: 'PF-21 Licensee:
Washington Public Power Supply System 3000 George Washington Way P.O.
Box 968, MD 1023 Richland, Washington Facility Name:
Washington Nuclear Project-2 (WNP-2)
Inspection At:
Richland, Washington.
Inspection Conducted; July 17-20, 1995 Inspector:
J.
B. Nicholas, Ph.D.,
Senior Radiation Specialist Facilities Inspection Programs Branch Approved:
B.
u ay, C ie
,
aci i ies nspection Programs Branch ate
.
Ins ection Summar d:
R f, d
f p
f f
P chemistry and radiochemistry programs i,ncluding water chemistry and radiochemistry confirmatory measurements.
Results:
~
The organizational structure and staffing of the chemistry department met commitments and requirements.
During the past
/> years, the chemistry department had experienced some organizational changes and a
low turnover of personnel.
The chemistry department was fully staffed with qualified personnel (Section 1. 1).
A good chemistry department training program had been implemented.
All chemistry technicians were properly qualified (Section 2. 1).
A review of Chemistry Technical Specification requirements were included in the 1994 Unit operation audit.
The licensee's quality assurance audit pro'gram did not include a specific audit frequency for the chemistry program, but good performance based quality assurance 9508i70009 9508i4 PDR AOQCK 05000397
surveillances were performed and provided good program evaluation and management oversight and were considered a strength (Section 3. 1).
A good water chemistry program was being implemented.
An improved consumable chemical material control program was developed and implemented.
Plant water chemistry controls were included in the planned source term reduction program.
Performance in the water chemistry confirmatory measurements program were above average (Section 4.1).
A good radiological analytical measurement program was implemented.
The licensee had properly calibrated and maintained state-of-the-art radiological counting instrumentation.
Performance in the radiological confirmatory measurements area was good and consistent with the previous performance (Section 5. 1).
Attachments:
Attachment
Persons Contacted and Exit Meeting Attachment 2 - Water Chemistry Confirmatory Measurements Results (Primary Chemistry Laboratory)
Attachment 3 Attachment 4 Criteria for Comparing Water Chemistry Analytical Measurements Radiological Confirmatory Measurement Results Attachment 5 - Criteria for Comparing Radiological Analytical Measurements
DETAILS
ORGANIZATION AND MANAGEMENT CONTROLS (84750)
The inspector reviewed the organization and staffing of the chemistry department to determine agreement with commitments in the Updated Safety Analysis Report and compliance with the requirements in Technical Specification 6.2.
1.1 Discussion The inspector reviewed the organizational structure and staffing changes in the chemistry department since the previous NRC inspection of this area conducted in November 1993.
There had been several organizational changes in the chemistry department over the past
'/~ years.
During the past
/~
years, there had been only three chemistry technician personnel changes.
This represented a low turnover of chemistry staff.
These personnel changes had no negative effect on the performance of the chemistry program.
The chemistry department personnel were directly responsible-for performing their assigned duties which involved the monitoring and controlling of chemistry parameters in station water systems, effluent systems, and the environmental monitoring program by collecting and analyzing<samples in accordance with the Technical Specifications and Offsite Dose Calculation Manual requirements.
The inspector interviewed several chemistry personnel and determined that they were familiar with. the requirements of the station's chemistry program and maintained a high level of responsibility.
Staffing of the chemistry department was in accordance with the Updated Safety Analysis Report and Technical Specifications..
Station administrative and chemistry departmental procedures were reviewed for the assignment of responsibilities for the management and implementation of the chemistry program.
The inspector determined that the duties and responsibilities specified in the station procedures were being implemented, and the chemistry department activities were well managed.
The inspector attended the daily morning meetings held by the chemistry manager with the chemistry supervisors and lead technical specialists who were responsible for the five functional areas within the chemistry department.
During these daily meetings, the chemistry supervisory staff briefed the chemistry manager on plant chemistry activities from the previous day and night and discussed the chemistry department activities for the remainder of the day'.
It was noted that the chemistry supervisors, lead technical specialists, and chemistry manager made frequent entries into the radiological controlled area in the plant and chemistry laboratory area.
The inspector determined that chemistry department management was providing adequate supervisory oversight of the chemistry daily activitie.2 Conclusions The organizational structure and staffing of the chemistry department met the commitments in the Updated Safety Analysis Report and the requirements in the Technical Specifications.
During the past
~/u years, the chemistry department had experienced some organizational changes and a low turnover of personnel*.
The chemistry department was fully staffed with qualified personnel.
Chemistry department management controls were being implemented in accordance with station procedures.
TRAINING AND QUALIFICATIONS (84750)
The inspector reviewed the training and qualification program for chemistry department personnel to determine agreement with commitments in the Updated Safety Analysis Report and compliance with the requirements in Technical Specifications 6.3 and 6.4.
2.1 Discussion The inspector reviewed the qualifications of the present chemistry, department staff.
It was determined that all of the chemistry staff met the qualification requirements of ANSI/ANS 18. 1-1971 and that all of the 15 chemistry journeyman technicians were shift qualified and had completed all of the routine training program requirements in accordance with station training procedures.
It was determined that the chemistry department had an
'dequate qualified staff to meet the shift staffing requirements.
The inspector reviewed the training program for chemistry department personnel including a review of the chemistry technician -training course catalog and training task matrix, the 1995 chemistry training schedule, selected chemistry training lesson plans, the chemistry training instructor's qualifications, and selected individual chemistry technician training records.
The chemistry training program was being implemented and documented in accordance with station procedures.
The licensee had developed a good chemistry training program which was being effectively implemented by an experienced training instructor.
During the review of individual chemistry technician training records to verify completion of semiannual post-accident system training, it was noted that one semiannual training record for two shift chemistry technicians had not been entered into the training record data base.
This observation was brought to the attention of the chemistry training manager and chemistry training specialist.
Documentation was provided to the inspector which indicated that the two shift chemistry technicians had completed their on-the-job training during the 6-month period in question, but the attendance information for the on-the-job training session had not been transmitted to the training record data base.
The licensee immediately corrected the training record data base for the two chemistry technicians based on the on-the-job attendance roste.2 Conclusions The licensee had implemented a good chemistry department training program.
All of the 15 chemistry technicians were fully qualified to perform routine independent chemistry sampling and analyses.
EQUALITY ASSURANCE PROGRAM (79502, 84750)
The inspector reviewed the quality assurance audit and surveillance programs regarding the chemistry program activities to determine agreement with the commitments in the Updated Safety Analysis Report and compliance with the requirements in Technical Specification 6.5.2.8.
3.1 Discussion The inspector reviewed the quality assurance audit schedules for 1994 and 1995.
The audit schedules were in compliance with the Technical Specifications required audits and audit frequency requirements.
However, the inspector noted that the schedules indicated no periodically scheduled audit of the chemistry program.
The Technical Specifications did not require a
specific audit of the chemistry program at a required frequency.
The inspector reviewed the 1994 annual quality assurance audit report for unit operation which contained a review of the chemistry program activities.
The audit report indicated that no problems were noted with the implementation of the chemistry program Technical Specification requirements.
The audit was performed by qualified personnel who were knowledgeable in nuclear chemistry program activities.
The inspector discussed with the licensee the frequency that the chemistry program would be audited using the annually required audit to review Technical Specification programs.
The licensee indicated that there was no requirement or commitment to perForm an audit of the chemistry program on a regular periodic frequency.
During the inspection, the inspector discussed the performance of a periodic audit of the chemistry program with the licensee.
The inspector also discussed the performance of a periodic audit of the chemistry program with the licensee during the exit meeting.
The quality assurance manager stated that the audit frequency of the chemistry program would be evaluated.
The inspector reviewed 10 performance based quality assurance sbrveillances and assessments which were performed periodically to monitor selected chemistry department activities during the time period November 1993 through Hay 1995.
The inspector reviewed the quality assurance surveillance and assessment reports of the chemistry program for scope, thoroughness of program evaluation, and timely followup of identified deficiencies and recommendations for program improvement.
The inspector determined that the operational quality assurance surveillances and assessments of the chemistry program were thorough and technically comprehensive and were conducted in sufficient depth to provide good evaluation of the chemistry department's performance.
The licensee's quality assurance surveillance and assessment program was considered a strength.
The inspector reviewed the qualifications of the
quality assurance personnel and technical specialist who performed the surveillances and assessments of the chemistry program.
The quality assurance auditors and technical specialist were well qualified and knowledgeable of chemistry program activities conducted at nuclear power generating facilities.
3.2 Conclusions One quality assurance audit of the chemistry program had been performed.
Good performance based quality assurance surveillances and assessments, which periodically'onitored chemistry program activities, were'performed.
The quality assurance surveillances and assessments were technically comprehensive and provided good program evaluation and management oversight and were considered a strength.
WATER CHEMISTRY CONTROL, CHEMICAL ANALYSIS, AND CONFIRMATORY NEASURENENTS (79502, 84750)
The inspector reviewed the water chemistry analysis program including facilities and equipment; implementation of the quality. control program..for chemical measurements, selected analytical procedures, and water chemistry confirmatory measurements to determine agreement with commitments in the Updated Safety Analysis Report and compliance with the requirements in Technical Specifications 3/4.4.4 and 6.8. 1.
4.1 Discussion Water Chemistr Controls The inspector's review of the water chemistry program determined that the licensee had approved administrative procedures, surveillance procedures, chemical control procedures, sampling procedures, analytical instrument calibration and quality control procedures, and analytical procedures.
A review of selected water chemistry procedures indicated that the licensee had established and implemented good water chemistry programmatic procedures to meet the commitments in the Updated Safety Analysis Report and the requirements in the Technical Specifications.
The inspector inspected the chemistry laboratory, laboratory analytical instrumentation, chemistry sample room, and in-line process instrumentation used by the chemistry staff for water chemistry analytical measurements and control.
The chemistry laboratory was equipped with the necessary chemicals, reagents, and state-of-the-art analytical instrumentation to perform the required analyses to monitor. the various water system chemical parameters.
The inspector verified that analytical instrument quality control and calibration standards were prepared from independent standard stock solutions, which were specifically labeled with color coded labels and stored separately.
It was noted that the licensee was operating a properly calibrated in-line ion chromatograph for routine analysis of anions and cations to help in monitoring chemical parameters in many of the plant water systems.
The inspector reviewed selected chemistry analytical procedures and procedures for the operation, calibration, and quality control of the analytical
instrumentation used for the analyses of the NRC water chemistry standards.
It was verified, by direct observation, that the chemistry laboratories analytical instruments were properly calibrated, and an excellent instrument quality control program was being implemented in accordance with the licensee's procedures.
Chemical standards and reagents were properly labeled, and none were found to be expired.
The inspector reviewed reactor water chemistry data for 1994 to determine compliance with Technical Specification requirements.
It was verified that the Technical Specification required chemistry sampling and analyses had been performed.
The review included recorded trends of the reactor water chemistry data.
The licensee had implemented an excellent chemistry data management system.
The licensee's chemical control limits were established according to the Electric Power Research Institute owner's group guidelines for boiling water reactor water chemistry and the reactor manufacturer's chemistry specifications.
The licensee had established action levels and corrective actions for out-of-specification chemistry conditions.
The inspector reviewed the chemistry monitoring program to measure and prevent the introduction of radioactivity into normally noncontami.nated plant systems.
Samples of the normally "clean".water sy'stems-were. routinel'y collected and'~"..
"'nalyzed to ensure that no radioactivity had beeii introduced, into totem..:"'The inspector also reviewed the chemical control pr'ogram to prevent the
'.
introduction of chemical contaminates into the plant's water sys'tems arid reactor water system.
The licensee was developing and implementing an improved consumable chemical material control program.
The inspector verified that all chemicals brought on site must be classified, properly labelled, placed on the approved chemical list, and a chemical permit issued for each chemical prior to its use on site.
A spot check of chemical containers throughout the plant was performed and all chemicals inspected were properly labeled and stored.
Source Term Reduction Pro ram The inspector discussed with the corporate chemist the licensee's plans for plant water chemistry control to implement the licensee's source term reduction program.
Hased on a study performed by the reactor manufacturer involving the analysis of WNP-2 fuel scraping and cobalt transport modeling, the following methods were recommended as means to accomplish the reduction of the existing cobalt-60 source term:
Reduce cobalt input via the feedwater system Depleted zinc injection Iron injection Chemical decontamination of the reactor recirculation piping Add a seventh filter demineralizer to the condensate system The licensee is presently developing a program to accomplish the above recommended actions and approve the necessary funding.
According to the licensee, funding for the zinc and iron injection project has been approved, and the project will probably start in early 1996.
The licensee has currently
placed a high priority on improving housekeeping during maintenance activities and especially during maintenance on Stellite components.
A high priority has also been placed on fixing or replacing worn Stellite components to reduce the introduction of cobalt into the plant's reactor water system.
Testing of special resin to remove metals (specifically cobalt)
from the condensate system has been scheduled during Cycle II.
Chemical decontamination of the reactor recirculation piping has been scheduled during Refueling ll, which is scheduled to begin in April 1996.
Confirmator Measurements During the inspection, the inspector provided prepared standard chemical solutions to the licensee for confirmatory measurement analyses.
The standard solutions were prepared by the Oak Ridge National Laboratory, Analytical Chemistry Division, for the NRC.
The NRC standards were analyzed by the licensee in the chemistry laboratory using routine analytical methods and
,instrumentation.
The analytical results of the chemical standards were used to verify the licensee's capability to monitor chemical parameters in the various station water systems with respect to Technical Specification requirements and industry standards.
In addition, the chemical analyses of the NRC standards were used to evaluate the licensee's analytical procedures with respect to accuracy and precision.
The results of the water chemistry confirmatory measurement analyses and their comparison with the NRC's certified known analytical concentrations are listed for the chemistry laboratory in Attachment 2.
Attachment 3 contains the criteria used to evaluate the analytical results.
The licensee's initial analytical results from the analyses performed in the chemistry laboratory indicated minor problems with the analyses for sulfate and silica.
The initial water chemistry analytical results indicated that
of the 27 analytical results (93 percent)
were in agreement or qualified agreement when compared with the NRC's certified analytical concentrations using the criteria presented. in Attachment 3.
~
The licensee's initial chloride midrange concentration analytical result was in qualified agreement, and the sulfate midrange concentration analytical result from the same NRC standard was in disagreement.
The chloride analytical result and the corresponding sulfate analytical result from the same NRC standard dilution were biased high indicating a possible instrument calibration problem or standard preparation problem.
The licensee prepared a new standard dilution and performed retest chloride and sulfate analyses on the midrange concentration diluted NRC standard.
The retest chloride analytical result was in disagreement, and the sulfate analytical result was still in disagreement by approximately 12 percent.
These biased high analytical results indicated a possible instrument calibration problem at the high concentration rang The licensee's initial silica high range concentration analytical result was in disagreement.
The analytical result was biased high indicating a
possible instrument calibration or standard preparation problem.
The licensee prepared a
new NRC standard dilution for the high range silica concentration and performed a retest silica analysis.
The retest analytical result was 'still in disagreement by approximately ll percent.
This biased high analytical result indicated a possible instrument calibration problem at the high concentration range.
The licensee's final analytical results from the analyses performed in the chemistry laboratory, after the retest analyses in an attempt to resolve the initial disagreements, remained at 93 percent agreement or qualified agreement with the NRC's certified analytical concentrations based on 27 analytical results compared.
The licensee's initial performance in the area of water chemistry confirmatory measurements showed above average performance for their first participation in this inspection program.
The two analytical disagreements were in the parts per million concentration range and were not considered to indicate any significant programmatic problems.
4.2 Conclusions A good water chemistry program was being implemented.
The chemistry laboratory and analytical instrumentation were being maintained satisfactorily.
An improved consumable chemical material control program was being developed and implemented.
Plans for plant. water chemistry control to implement the licensee's source term reduction program were being developed.
The licensee's initial performance in the water chemistry confirmatory measurements inspection program showed an above average performance in the water chemistry confirmatory measurements area.
RADIOLOGICAL CONFIRMATORY MEASUREMENTS (84750)
The inspector reviewed the radiochemistry program including facilities and equipment, implementation of a quality control program for radiochemistry measurements, and performed radiological confirmatory measurements to determine agreement with commitments in the Updated Safety Analysis Report and compliance with the requirements in Technical Specifications 3/4.4.5 and 6.8. 1, and the Offsite Dose Calculation Hanual.
5. 1 Discussion Radiochemistr Anal tical Pro ram The inspector reviewed the radiochemistry analytical program and determined that the licensee had implemented satisfactory procedures to meet commitments in the Updated Safety Analysis Report and the Technical Specifications and Offsite Dose Calculation Manual'requirement The inspector inspected the chemistry laboratory and the radiochemistry counting facility and determined that the licensee had sufficient state-of-the-art analytical instrumentation to perform the required radiochemistry analytical measurements.
The inspector verified that the radiochemistry counting facility's instrumentation was properly calibrated, and that an excellent quality control program was being implemented.
The inspector verified that the licensee was using calibration standards traceable to the National Institute of Standards and Technology.
The inspector accompanied and observed a chemistry technician collect and prepare for analysis of the radioactive gas sample from the steam jet air ejector system, the radioactive waste liquid sample from the Equipment Drain Tank 4B, and the reactor water sample.
The inspector also observed a
chemistry technician prepare the charcoal cartridge sample and air particulate Filter sample by spiking the two sample types with reactor water, since the main stack vent charcoal cartridge and air particulate samples did not contain sufficient radioactivity to measure.
The sampling and preparation of the samples for analyses were performed in accordance with approved procedures.
The inspector noted that the chemistry 'technicians observed were familiar with the various sample collection, preparation, and analysis procedures used during the inspection.
The steam jet air ejector off-gas sample was collected in accordance with Sampling Procedure 12.5.23A,
"Recombiner Sampling and Analysis," Revision 1,
dated January 18, 1994.
To facilitate the use of a calibrated flow-through glass sample bulb for collection of the steam jet air ejector off-gas sample, the alternate sample method described in the procedure was used to collect the off-gas sample.
The glass sample bulb was installed in the" sample line using quick-disconnect couplings and tygon tubing as described in the procedure.
During the collection of the sample, moisture vapor droplets formed in the tygon tubing and the glass sample bulb.
When the chemistry technician removed the tygon tubing from the glass sample bulb, two of his finger tips became contaminated from the moisture vapor droplets trapped in the tygon tubing.
This method of sample collection is not routinely used, and the off-gas sample is usually not handled directly at the collection point nor contaminated on the outside of the sample collection container.
Surgeons gloves were available in an area nearby to the sample point but were not used when performing the sampling.
The inspector noted that the sampling procedure did not contain any radiological precautions for handling the alternate sampling apparatus.
This observation was discussed with the licensee during the inspection.
The licensee stated that they would add a note and radiological precautions for using the alternate sampling method in the procedure.
Health physics personnel were contacted when the contamination was discovered on the chemistry technician's finger tips during a hand frisk survey performed prior to exiting the sampling area.
The health physics technician who responded to the request for help effectively controlled the contamination, surveyed the area, and assisted in the decontamination of the chemistry technician's fingers.
The appropriate personnel contamination report was complete Confirmator Measurements Durin the ins ection ra Radiological confirmatory measurements were performed on the following samples:
Equipment Drain Tank 48 Sample Air Particulate Filter Sample Spiked with Reactor Water Charcoal Cartridge Sample Spiked with Reactor Water Steam Jet Air Ejector Off-Gas Sample Reactor Water System Sample 1994 Capability Test Sample The radiological confirmatory measurement tests consisted of comparing the analytical results from the licensee's radiochemistry counting facility with the NRC Region IV laboratory's analytical results.
The NRC Region IV laboratory's measurements were referenced to the National Institute of Standards and Technology by laboratory intercomparisons.
The licensee was maintaining four high purity germanium detectors in the radiochemistry counting facility.
At the time of the inspection, Detectors ORT-1, ORT-2, and ORT-3 were being used routinely for isotopic analysis of radioactive samples to demonstrate compliance with Technical Specifications and Offsite Dose Calculation Manual requirements.
Detector TEN-1 was being reserved for analyses of only very low environmental activity level samples and, therefore, was not used during the inspection for performing confirmatory measurements.
Individual sample analytical results and their comparison with the NRC analytical results are tabulated in Attachment 4.
The tabulated analytical results from the individual licensee's detectors are listed in the order indicated in the heading of each data table.
A summary of the analytical results is as follows:
g p
,
diological analytical measurements were performed in the licensee's radiochemistry counting facility on five samples collected by the chemistry department staff.
The samples were analyzed by the licensee using routine methods and instrumentation.
Following the inspection conducted on site, the licensee shipped either the identical or split samples to the Region IV office for analyses by the inspector in the Region IV laboratory.
(1)
E ui ment Drain Tank 4B Sam le Of the five radionuclides originally identified by the licensee, only four radionuclides were identified by the NRC Region IV laboratory due to the low original radionuclide activity in the sample and radioactive decay during shipment.
The fifth radionuclide (Cr-51)
had decayed to below the NRC Region IV laboratory's minimum detectable activity prior to analysis of the sample and; therefore, no comparison was made between the analytical results for Cr-5 The licensee's radionuclide analytical results obtained from analyses using Detectors ORT-2 and ORT-3 were in agre'ement with each other.
Only one radionuclide identified by both the NRC and the licensee was in agreement with only one detector used by the licensee.
The seven disagreements between the licensee's and the NRC's analytical results were due to possible plate-out of the radionuclides on the sample container walls during shipment even though the sample was acidified after collection to help prevent deposition from happening.
This plate-out of the radionuclides in the sample reduced their concentration in the shipped sample to measurable quantities not equivalent or in agreement with the licensee's analytical results.
Air Particulate Filter Sam le S iked with Reactor Water Of the nine radionuclides identified by the licensee and the NRC, two radionuclides were originally below the licensee's minimum detectable activity and not identified, and four radionuclides were not identified by the NRC Region IV laboratory due to radioactive decay during shipment to below the NRC Region'V laboratory's minimum detectable activity prior to analysis of the sample.
Therefore, no comparison of analytical results was performed on six of the nine radionuclides originally identified in the sample by either the licensee or the NRC.
The licensee's radionuclide analytical results obtained from analyses using Detectors ORT-1 and ORT-2 for six radionuclides were in agreement with each other.
Only the analytical results of three radionuclides identified by both the NRC and the licensee were in agreement with both detectors used by the licensee.
Charcoal Cartrid e
Sam le S iked with Reactor Water Of the 10 radionuclides identified by the licensee and the NRC, three radionuclides were originally below the licensee's minimum detectable activity and not identified, and four radionuclides were not identified by the NRC Region IV laboratory due to radioactive decay during shipment to below the NRC Region IV laboratory's minimum detectable activity prior to analysis of the sample.
Therefore, no comparison of analytical results was performed on seven of the ten radionuclides originally identified in the sample by either the licensee or the NRC.
The licensee's radionuclide analytical results obtained from analyses using Detectors ORT-1 and ORT-2 for seven radionuclides were in agreement with each other.
Only the analytical results of three radionuclides identified by both the NRC and the licensee were compared and were in agreement with both detectors used by the licensee.
Steam Jet Air E 'ector Off-Gas Sam le Of the six radionuclides identified by the licensee and the NRC, five radionuclides were not identified by the NRC Region IV laboratory due to radioactive decay during shipment to below the NRC Region IV laboratory's minimum detectable activity prior to analysis of the
-13-sample.
Therefore, no comparison of analytical results was performed on five of the six radionuclides originally identified in the sample by either the licensee or the NRC.
The licensee's radionuclide analytical results obtained from analyses using Detectors
.ORT-1, ORT-2, and ORT-3 for five radionuclides were in agr'cement with each other.
Only the analytical results of one radionuclide identified by both the NRC and the licensee were compared and were in agreement with the three detectors used by the licensee.
(5)
Reactor Water S stem Sam le Of the 12 radionuclides identified by the licensee, 6 radionuclides were not identified by the NRC Region IV laboratory due to radioactive decay during shipment to below the NRC Region IV laboratory's minimum detectable activity prior to analysis of the sample.
Therefore, no comparison of analytical'esults was performed on 6 of the
radionuclides originally identified in the sample by the licensee.
The licensee's radionuclide analytical results obtained from analyses using Detectors ORT-1 and ORT-2 for the 12 radionuclides were in agreement with each other.
Only the analytical results of 6 radionuclides identified by both the NRC and the licensee were compared.
The analytical results of five radionuclides identified by both the NRC and the licensee were in agreement with both detectors used by the licensee, and the analytical results of one radionuclide were in disagreement with both detectors used by the licensee.
The licensee's radiochemistry counting facility's isotopic analytical results from the samples listed in Attachment 4 which were compared showed 92 percent agreement with the NRC's isotopic analytical results based on 24 agreement results out of 26 total analytical results compared exempting the analytical results from the equipment drain tank sample due to plate-out and circumstances beyond the licensee's or the inspector's control.
The criteria used to compare the analytical results is presented in Attachment 5.
The licensee's performance in the area of radiological confirmatory measurements was consistent with the performance achieved during the previous NRC inspection of this area in November 1993.
The licensee performed radiological confirmatory measurements during the fall of 1994 on a quality assurance liquid capability test sample prepared by the NRC's reference laboratory, the Department of Energy's Radiological and Environmental Sciences Laboratory, in Idaho Falls, Idaho.
The licensee's analytical results were compared to the sample's certified radionuclide activities, and the results of the analytical results comparisons are presented in Attachment 4, Sample 6.
The analytical results for tritium, iron-55, strontium-89, and strontium-90 were in agreement.
5.2 Conclusions A good radiological analytical measurement program was being implemented.
The licensee had properly calibrated and maintained state-of-the-art radiological
counting instrumentation.
The licensee's performance in the area of radiological confirmatory measurements was good and consistent with the performance achieved during the previous NRC inspection of this area in November 199 Attachment 2 WATER CHEMISTRY CONFIRMATORY MEASUREMENTS RESULTS Chemistry Laboratory WASHINGTON NUCLEAR PROJECT -2 NRC INSPECTION REPORT: 50-397/95-22
Chloride Analysis (Ion Chromatography)..:::
Sample 92A-8 WNP-2 Results (ppm)
20.6~.08 NRC Results (ppm)
19. 42M. 54 WNP-2/NRC Ratio 1.06 Comparison Decision Agreement 92B-42 39.97M.41 36. 4~1. 12 1.09 qualified Agreement Retest - prepared a
new chloride standard dilution and performed retest analysis 92B-87 40.93%1.52 36.4&1.l2 1.12 Disagreement 92C-81 72.0~.13 77.01&.59 0.94 Agreement Z
Sulfate Analysis (Ion Chromatography)
Sample 92A-8 WNP-2 Results (ppm)
21.44&.81 NRC Results (ppm)
19.42&.26 WNP-2/NRC Ratio 1. 10 Comparison Decision qualified Agreement
Attachment 2 (cont'd)
Copper Analysis (Inductive'ly Coupled Plasma)
Sample 92G-80 WNP-2 Results (ppm)
21.1+0.5 NRC Results (ppm)
20. 2H. 2 WNP-2/NRC Ratio 1.04 Comparison Decision Agreement 92H-32 42.~.1 40.3&.4 1.06 Agreement 921-43 84.4+0.9 81.0+1.0 1.04 Agreement
Iron Analysis (Inductively Coupled Plasma)
Sample 92G-80 WNP-2 Results (ppm)
20.3+0
~ 2 NRC Results (ppm)
19.~. 2 WNP-2/NRC Ratio 1.02 Comparison Decision Agreement 92H-32 40.2+0
~ 2 39. 8+0. 4 1.01 Agreement 921-43 79.2+0.7 79.5+0.7 0.99 Agreement
Nickel Analysis (Inductively Coupled Plasma),:-.-.:.::::~:;:;::.:.::.:::,:::-:-:;:,:;.:.
":.:::::::;::::..'.":::..::;::
Sample 92G-80 WNP-2 Results (ppm)
20.1+0 '
NRC Results (ppm)
19.9+0
~ 2 WNP-2/NRC Ratio 1.01 Comparison Decision Agreement 92H-32 40.2W.3 40.0+0.4 1.00 Agreement 92I-43 79.~.6 80.~.8 0.99 Agreement
Attachment 2 (cont'd)
Sodium Analysis (Inductively Coupled Plasma)
Sample 92J-31 WNP-2 Results (ppm)
4.&1.2 NRC Results (ppm)
5.32.18 WNP-2/NRC Ratio 0.85 Comparison Decision Agreement 92K-84 10.2&.2 10.20'.30 1.00 Agreement 92L-159 16. 5+0. 6 15. 5&j4.40 1.06 Agreement
Silica Analysis (UV-VIS Spectroscopy)
Sample 92S-91 WNP-2 Results (ppm)
12.7&.4 NRC Results (ppm)
12.17.13 WNP-2/NRC Ratio 1.04 Comparison Decision Agreement 92T-45 26.&1.2 28.3~.36 0.94 Agreement 92U-156 65.~.4 60.14.99 1.09 Di sagr cement Retest prepared new silica standard dilution and performed retest analysis 92U-135 66.~.5 60.14.99 1.11 Disagreement
Attachment 3 CRITERIA FOR COMPARING WATER CHEMISTRY ANALYTICALMEASUREMENTS The following are the criteria used in comparing the results of the capability tests and verification measurements.
The criteria for the judgement limits was based on the data from Table 2. 1 of NUREG/CR-5244,
"Evaluation of Non-Radiological Water Chemistry at Power Reactors,"
applied to Oak Ridge National Laboratory data.
Licensee values within the plus or minus two standard deviations range of the known values are considered to be in agreement.
Licensee values outside the plus or minus two standard deviations range but within the plus or minus three standard deviations range of the know values are considered to be in qualified agreement.
Licensee values greater than the plus or minus three standard deviations range of the known values are in disagreement.
The standard deviations were computed using the average percent standard deviation values of each analyte in Table 2. 1 of NUREG/CR-5244.
Analyte Sample
':.':";;Agi'.eeiiierit'::;,;,";.:::,.":.:.,'.:"..qual:,i'fi'e'd:;::Agreeiiie'nt::."'.::'.
Ammonia 92M 92N 920 99.02 - 120.54 275.70 334.26 436.48 527.08 93.64 125.92 261.06 348.90 413.85 549.71 Boron 92D 92E 92F 1028 1070 2977 - 3099 4941 5183 1018 1080 2947 - 3129 4880 5244 Chloride 92A 92B 92C 18.0 - 20.8 3.8 7.4 17.3 - 21.5 3.0 6.6
Attachment 3 (cont'd)
Analyze
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- :;::,Sampl e':,':;:,:',.:>:,,',.::,
,';--;'Agreemerit,'<'!,'..'"";-."
f}u'al":i':fied::,':'Ag'r.'eem'eiit:,"';
Chromium 92G 92H 92I 18.0 - 22.0 35.9 - 44.5 7.3 1.0 3.6 7.8 Copper 92G 92H 92I 1.1 3.6 74.2 - 87.8 17.3 - 23.1 33.9 - 46.7 7 '
Fluoride 92A 92B 92C 1.9 3 '
77.9 - 92.3 14.6 - 25.8 3.3 7.8 Hydrazine 92P 92Q 92R 12.83 13.63 29.96 38.28 52.00 61.04 12.63 13.83 27,88 40.36 49.74 63.3 Iron 92G 92H 92I 1.2 3.7 6.4 1.9 3.7 64.7 - 94.3 Lithium 92JJ 92KK 92LL 4.05 - 5.81 10.9 - 13.9 21.4 - 27.2 3.61 - 6.25 1.7 2.6
Attachment 3 (cont'd)
Analyze Sample
'greement Range gual ifi;ed'.'A'gr'cement
.',:
...,Range,:
Nickel 92G 92H 92I 1.2 36.6 - 43.4 77.1 - 82.9 1.9 3.0 7.3 Sil ica 92S 92T 92U 10.40 13.97 26.32 30.40 56.53 63.75 9.43 14.87 25.30 31.42 54.73 65.55 Sodium 92J 92K 92L 4.37 - 6.27 9.00 11.4 1.3 3.90 6.74 8.30 12.1 1.2 Sul fate 92A 92B 92C 1.3 3.8 7.7 1.3 3.2 6.9 Zinc 92X 92Y 92Z
Attachment 4 RADIOLOGICALCONFIRIVIATORYIVIEASUREMENTRESULTS WASHINGTON NUCLEAR PROJECT-2 NRC INSPECTION REPORT: 50-397/95-22 Nuclide Cr-51 WNP-2 Results (pC i /ml )
<7.40E-7 7. 1&3. 20E-7 NRC Results (pCi/ml)
<5.23E-7 WNP-2/NRC Ratio Comparison Decision No Comparison No Comparison Mn-54 3.9~.90E-7 3.02.90E-7 1. 85+0. 29E-7 2.13 1.63 Disagr cement Agreement Co-58 3.07al.OOE-7 3.42&.90E-7 1.03&.26E-7 2.98 3.32 Disagreement Disagreement Co-60 7.5~.50E-6 8.4&A%.50E-6 2.09j4.08E-6 3.63 4.06 Disagreement Disagreement 2n-65 2.04&.30E-6 2.07.30E-6 5. 9~. 71E-7'.41 3.46 Disagreement Disagreement
Attachment 4 (cont'd)
Nuclide Na-24 WNP-2 Results (pCi/Sample)
1.87+0.49E-4 1.88+0.37E-4 NRC Results (pCi/Sample)
<3.28E-2 WNP-2/NRC Ratio Comparison Decision No Comparison No Comparison Cr-51
<6.60E-4
<5.80E-4 4.71'.44E-5 No Comparison No Comparison Hn-54
<5.70E-5
<3.90E-5 2.04z5.23E-6 No Comparison No Comparison Co-58
<8.4E-5 7.07~1.94E-5 5. 6&1. 05E-5 1.25 No Comparison Agreement Co-60 1.3~. 22E-4 1.45+0.26E-4 9.52a1.04E-5 1.37 1.52 Agreement Agreement Cu-64 4.91'.21E-2 5. 1~. 93E-2
<2.54E+1 No Comparison No Comparison Zn-65 1.0~.37E-4 1.3~.27E-4 9.9&j2.39E-5 1.06 1.30 Agreement Agreement
Attachment 4 (cont'd)
AIR PARTICULATE FILTER SAMPLE SPIKED WITH REACTOR MATER (cont'd)
Sampled:
15:45, PDT, July 18, 1995 Radiochemistry Detectors:
QRT-1 and ORT-2 Nuclide Tc-99m WNP-2 Results (PCi/Sample)
2.0~.17E-3 1.74+0.15E-3 NRC Results (PCi/Sample)
<1.56E+3 WNP-2/NRC Ratio Comparison Decision No Comparison No Comparison 1-133 2.04&.42E-4 2. 0~. 41E-4
<2.92E-3 No Comparison No Comparison
CHARCOAL CARTRIDGE SANPLE SPIKED WITH REACTOR MATER Sampled:
15:45, PDT, July 18, 1995 Radiochemistry Detectors:
ORT-1 and ORT-2 Nuclide Na-24 WNP-2 Results
{pCi/Sample)
3.47+0.72E-4 3.51+0.55E-4 NRC Results (PCi/Sample)
<3.33E-2 WNP-2/NRC Ratio Comparison Decision No Comparison No Comparison Cr-51
<1. 03E-3
<7.70E-4 1. 1~. 26E-4 No Comparison No Comparison Hn-54
<7.90E-5
<4.80E-5 1.0~.36E-5 No Comparison No Comparison Co-58 1.36+0.34E-4 1.37+0.27E-4 1.05+0.07E-4 1.30 1.30 Agreement Agreement Co-60 2.59+0.34E-4 2. 1~. 31E-4 1.77&.llE-4 1.46 1.24 Agreement Agreement
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Attachment 4 (cont'd)
- Samr led "-"'09'32 '.-.PDT""Jul ~"'18=";1995':;4. ~ ~"""
-'".~-""'I<-':~~: ';:!'F~
':.:,: Ra'di o'che'mi'stry;..'.'.Detec't'o Nuclide Xe-133 WNP-2 Results (pCi/cc)
1. Ol&.14E-4, 1.2~.28E-4 9. 67+1. 57E-5 NRC Results
,(pCi/cc)
1.01&.15E-4 WNP-2/NRC Ratio 0.99 1.18 0.95 Comparison Decision Agreement Agreement Agreement Xe-135 1. 66+0. 10E-3 1.62&.09E-3 1.53&.09E-3
<9.59E-1 No Comparison No Comparison No Comparison Xe-138
<1.00E-1 4.03.94E-2
<O.OOE+0
<1. OOE+20 No Comparison No Comparison No Comparison Kr-85m 3.13+0.22E-4 2.8~.20E-4 3.09+0.25E-4
<4.18E+5 No Comparison No Comparison No Comparison Kr-87 2.0~. 15E-3 2.00+0. 14E-3 1.75+0.15E-3
<1.00E+20 No Comparison No Comparison No Comparison Kr-88 1.0~.09E-3 1.02&.llE-3 1.0~.11E-3
<6.03E+12 No Comparison No Comparison No Comparison
Attachment 4 (cont'd)
REACTOR MATER SYSTEM SAMPLE 20 ml (20 ml scintillation via)3 Sampled:
15:45, PDT, July 18,
$ 995 Radiochemistry Detectors:
ORT-I and ORT-2 Nuclide Na-24 WNP-2 Results (pCi/ml)
2.2&j4.15E-4 2.22&.14E-4 NRC Results (pCi/ml )
<1.27E-2 WNP-2/NRC Ratio Comparison Decision No Comparison No Comparison Mn-54 1.84.35E-5 1.8~.35E-5 8.07zl.OSE-6 2.28 2.34 Disagreement Disagreement Co-58 7.93.56E-5 7.73&.54E-5 7.8~.24E-5 1.02 0.99 Agreement Agreement Co-60 1.4~.08E-4 1.3~.08E-4 1.26+0.03E-4 1.07 Agreement Agreement CU-64 4.64.31E-2 4.64M.30E-2
<1. 20E+1 No Comparison No Comparison Zn-65 1. 14M. 10E-4 l.l~.lOE-4 1.12&.04E-4 1.02 1.04 Agreement Agreement Sr-91 1.9~.19E-4 1. 73.
<7.21E+00 No Comparison No Comparison Mo-99 1.3~.26E-4 1. 43&. 19E-4 1.56+0.05E-4 0.87 0.92 Agreement Agreement
Attachment 5 CRITERIA FOR COMPARING RADIOCHEMISTRY ANALYTICALMEASuREMENTS 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 judgement 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
'
- 7 8-15
50
200
> 200 AGREENENT'::RATIO:.".:;
0.40 - 2.50 0.50 - 2.00 0.60 1.66 0.75 1.33 0.80 1.25 0.85 1.18 The above criteria are applied to the following analyses:
(1)
Gamma Spectrometry (2) Tritium in liquid samples (3) Iodine on adsorbers (4) "Sr and "SR determinations (5) Gross Beta where samples are counted on the same date using the same reference nuclide.