IR 05000409/1987005

Insp Rept 50-409/87-05 on 870316-20.No Violations or Deviations Noted.Major Areas Inspected:Qa/Qc of Analyses in Lab,Internal Audits,Training & Qualifications of Chemistry Staff & Review of Previously Identified Open Items

ML20206G215
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	04/08/1987
From:	House J, Januska A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206G179	List: IR 05000409/1987005 ML20206G176
References
50-409-87-05, 50-409-87-5, NUDOCS 8704140477
Download: ML20206G215 (10)

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i l U. S. NUCLEAR REGULATORY COMMISSION

REGION III ,

l Report No. 50-409/87005(DRSS)

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Docket No. 50-409 License No. DPR-45 Licensee: Dairyland Power Cooperative 2615 East Avenue - South La Crosse, WI 54601

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Facility Name: LaCrosseBoilingWaterReactor(LACBWR)

Inspection at: LACBWR, Genoa, Wisconsin i Inspection Conducted: March 16-20, 1987

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i Inspectors:

// haw J. E. House MF/F7 i

Date ' aswlv A.G.hanuska / - 8- 6 'l i

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Date C A t a t-H.C.khumacher,[ief Approved by: Y-B -67 i Radiological Effluents and Date j Chemistry Section i

j Inspection Summary:

Inspection on March 16-20,1987(ReportNo. 50-409/87005(DRSS)) '

f Areas Inspected: Routine, announced inspection of: (1) chemistry including

! quality assurance / quality control of analyses in the laboratory, observations '

of technician performance in the laboratory; (2) training and qualifications l

ofthechemistrystaff;(3)

)reviously identified open items. licensee internal audits; ancI (4) review of

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lesults: No violations or deviations were identified, i

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j 8704140477 870409 ADOCK 05 gDR g9

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DETAILS 1. Persons Contacted

• J. Parkyn, Plant Superintendent

• L. Nelson, Health and Safety Supervisor

• R. Wery, Quality Assurance Supervisor i A. Hansen, Senior Health Physics Technician J. Gaynor, Health Physics Technician G. Roediger, Health Physics Technician i M. Land, Hea}th Physics Technician i *K. Ridgway, Resident Inspector

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• Denotes those present at the exit interview on March 20, 198 . Licensee Action on Previous Inspection Findings

(Closed)0)enItem(409/85010-01): Revise waste shipment procedure Procedure lSP-04.1, " Disposal of Spent Resin Filter Media as l Radioactive Waste Using a Hittman High Integrity Liner, was revised

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on January 17 1986 (Issue 8) to bring Attachment 2, Table 2 into l conformancewIth10CFR61.55 Table 2,WasteClassification. Procedure HSP-04.2, " Disposal of Dry Active Waste," was also revised on i January one of the minimum i requirements for waste documentation and certificat17, 1986 (Issue 2) to (1

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methodology in 9.4 for determination of isotopic breakdown for each

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drum to be shipped and (3) provide, as an attachment, a listing of the i isotopic mix and percent of isotopes in an average drum.

, (Closed)OpenItem(409/85021-02): Analyze split sample for beta, 4 gamma, H-3, Sr-89 and Sr-90 and report results to Region III.

Results of an analysis performed by the licensee's environmental

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contractor on a spiked liquid are listed in Table 2; comparison criteria are given in Attachment 2. The lone disagreement, Sr-90, was nonconservative as was the Sr-90 disagreement discussed in a previous report 1 Subsequent sampling is discussed in Section under Open Item 409/86016-03. This item is closed but the Sr-90 problem will be tracked under 86016-0 (0 pen)OpenItem(409/86016-03): Analyze retention tank sample for gross beta, tritium, Sr-89 and Sr-90 and report results to Region III. Preliminary results of the retention tank sample, although not tabulated as an attachment to this report, indicate disagreements for both Sr-89 and Sr-9 The licensee has agreed to split a first quarter liquid release composite sample between the environmental contractor, another company under contract who also i performs radiological analyses and the NRC's reference laborator .

I&E Report No. 50-409/86016(DRSS) ,

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Com)arisons of the results will be made to determine which, or if eitler, contractor should perform future release analyses for the licensee. Because the Sr-90 results have been consistently nonconservative, the licensee further agreed to apply appropriate correction factors to annual reported liquid effluent releases for 1985 and 1986 in the form of errata assuring at the same time that no past individual release was above regulatory limit (Closed) Open Item (409/86016-01): Investigate the Xe-135 disagreement before the next offgas sample is collected. The licensee made three new gas standards using a liquid standard in the gas geometry. Two of the standards were used to determine a new calibration curve which was within 10% of the previous curve. The third standard was analyzed as an unknown and the results accurately reproduced the activity of the liquid used. Selfabsorptionfactorsusedfortheliquidstandard and then applied to the " gas samples appear to be the proble Resolution of this problem is discussed in Section (0 pen)OpenItem(409/86016-02): Evaluate the use of air particulate and gas standards supplied by an independent manufacturer. Based on the problem discussed in Section 2.d and a bias noted in air particulate analyses obtained from calibrations also derived using a liquid to simulate another medium, the licensee stated that gas and air particulate standards will be obtained commercially and used for the next normal calibration, scheduled for Octobe . Management Controls, Organization, Training and Qualification The inspectors reviewed the management controls and organization of the Health and Safety Department. All chemistry and health physics measurements are performed by a group of ANSI qualified technicians who report to the Health and Safety Su)ervisor. Discussion of assay procedures and instrumentation wit 1 laboratory personnel indicate that they are competent. At present, a training program is under development and will be presented to INP0 later in the year. The program was not examined during this inspection, however, if it has not been approved or examined by INP0 at the time of the next laboratory inspection it will be reviewe No violations or deviations were identifie . Water Chemistry Control Program Theinspectorsreviewedthelicensee'swaterchemistrycontrolprogram ,

that is outlined in LACBWR HSP-07.0 " Liquid Sampling; and HSP-0 " Schedule of Liquid Samples and Analysis." Selected data were reviewe Control charts are not used to trend data in nonradiological chemistry although results are recorded in tabular form. This was discussed with the licensee and those parameters considered to be most relevant to water quality by the Health and Safety Department will be plotte ',

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No violations or deviations were identified.

1 Plant Systems Attecting Water Quality Control r

1 Makeup water for the reactor is obtained by treating raw water from a

, series of deep wells. Primary treatment (flocculation) is unnecessary

! and the purification process is limited to demineralizer beds. Inline

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conductivity meters are used to provide continuous data on water i

quality. In addition, periodic sampling and analysis is outlined in LACBWR HSP-07.0 " Liquid Sampling Procedures." performed as

No violations or deviations were identifie , Implementation Of Chemistry QA/QC Program

i The inspectors reviewed the chemistry laboratory arograms including i

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)hysical facilities and laboratory operations. T1e laboratory is'small aut space appears to be adeguate for the amount of testing require ,

House (eeping was good. Equipment included a Hach 18900 turbidity meter, j YSI conductivity meter, Orion s)ecific ion electrodes (pH & chloride) and

, a B&L 2000 Spectrophotometer. Lack of modern instrumentation requires that metal analyses be done by colorimetric procedures which resulted in

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i bias and imprecision problems during analysis of NRC samples - see Section Reagent bottles were properly labeled and expiration dated. None were

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observed that had passed the expiration date. A few reagents were noted i' that did not have a receipt date; this was discussed with the license Although reagent ) reparation is detailed in individual procedures, there is no central log)ook for reagent preparation and documentatio (

1 Improvements in reagent preparation documentation were discussed with the i licensee. Instrument calibration schedules and records are maintained in e log book.

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i Selected chemistry procedures were reviewed. In general, they are well written but need updating due to the following observations: The calibration range for standard curves in certain procedures is i different from the calibration range actually used. Calibration :

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ranges for iron, co)per, nickel and silica are prepared differently i in the laboratory tlan called for by the procedure.

i Procedure details for preparation of the chloride calibration curve

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are vague and the data are plotted on a semilog rather than a linear i scale. This results in a curve instead of a linear plot and is

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difficult to read in certain range The chromium procedure is based on a titration and calculations are j dependent on reagents consumed during the reactio No chromium

control is called for as a check on the overall system. A control j should be included.

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. Controls are used in most procedures, however, they are prepared from the same stock solutions used in setting up the calibration curv An independent control should be used in each assay and must be prepared from a different source (manufacturer, lot number or in-house preparation) than that used to set up the calibration curv The inspectors discussed their concerns with the licensee who agreed to review and revise these procedures by May 30, 1987. (0 pen Item 50-409/87005-01). These procedures will be reviewed in a subsequent inspectio During a review of the licensee's boron procedures, the inspectors noted that the present method for low level boron analysis (carminic acid)

requires that fresh indicator be prepared daily. Since the procedure is used infrequently a more stable method is desirable. The licensee stated that a different boron analysis is being developed and will be ready by May 15, 1987. (0 pen Item 50-409/87005-02). Implementation of this procedure will be monitore Unknown samples are obtained from the corporate laboratory on a quarterly basis and are analyzed by the technicians. This provides for an interlaboratory cross check and a means of monitoring technician performanc Standard curves are not prepared each time an analysis is performe Curves are prepared periodically and a control is run along with sample At present, trend charts are not maintained for these data and there are no acceptance criteria for determining whether or not the control value and the calibration curve are in agreement. The inspectors and licensee discussed a method of utilizing past data to establish a mean + 20 acceptance criterion comparable to performance criteria currenIly used for radiological detector systems. Thelicenseeacknowlesgedtheinspectors comment No violation or deviations were identifie . Measurement Control Program Evaluation The inspectors provided the licensee with samples for analysis. These samples were prepared and analyzed by Brookhaven National Laboratory (BNL) for the NRC. The samples were diluted by licensee laboratory personnel to bring the concentration within the range normally analyze Analyses were performed in triplicate and routine procedures were use These analyses are used to verify the licensee's ability to monitor various Five analytes were measured chemical parameters of p(lant water at three concentrations see Table 1). chemistr Of 15 comparison analyses, 12 were in agreement with BNL results and three were in disagreement - see attachment 1 for acceptance criteri . .

The 40 ppm chloride comparison exhibited a significant bias (23%) and was in disagreement. The 10 and 15 ppm iron comaarisons each had a considerable bias (26% & 24%) and although t1ey exhibited reasonable precision, they were in disagreement. The three nickel analyses were in agreement with the BNL results but exhibited both bias and imprecisio The statistical acceptance criteria outlined in attachment 1 permits an elevated imprecision to compensate for bias in the results. The inspectors concern over the nickel assay was noted by the licensee and another method is being investigate No violations or deviations were identifie . Licensee Internal Audits The inspectors examined licensee internal audit 70-86-1 performed in 1986 by the QA department. The laboratory was reviewed in detail and several o)en items identified. These items have been satisfactorily addressed by t1e Health and Safety Supervisor. Written responses were reviewed and these appear to be adequat No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involves some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Section . Exit Interview The inspectors reviewed the scope and findings of the inspection with licensee representatives denoted in Section 1 on March 20, 1987. The inspectors discussed the non-radiological confirmatory measurement program results and the need to revise procedures to conform with current practic During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee representatives did not identify any such documents or processes as proprietar Attachments: Table 1 Non-Radiological InteriaboratoryTestResults Attachment 1, Criteria for Comparing Analytical Measurements Table 2, Cross Check Pesults,4thQuarter1986 Attachment 2, Criteria for Comparing Analytical Measurements.

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l ATTACHMENT 1  !

j CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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This attachment provides criteria for comparing results of the capability tests, li Theacceptancelimitsarebasedontheuncertainty(meanvalue(Y),where standard deviation) of the j ratio of the licensee's mean value (X) to the NRC s

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(1) Z = X/Y is the ratio, and L

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(2) S is the uncertainty of the ratio determined from the propagation of j t6euncertaintiesofthelicensee'smeanvalue,S,andoftheNRC's x mean value, S .1 Thus, y  :

i Sz2 = Sx2 + sy2 so that j T T T I

i SZ =Z Sx2 + sy2 T T t ,

i I The results (absolute areofconsidered value one minus tothebe in ag)reement ratio is less than orwhenequalthe bias in to twice thethe ratio

uncertainty in the ratio, i.e.

i l 1-Z l<2S' z i

1 National Council on Radiation Protection and Measurements, A Handbook of

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Radioactivity Measurements Procedures, NCRP Report No. 58, Second toition, 1985, pp. 322-326 (see p. 324).

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TABLE 1 l

l Licenseel Analysis NRC Valuel Value Ratio Dilution Analyte Method YiS XtS ZiS

Comparison Factor (ppml (ppm 7 Chloride Specific Ion Electrode 241 .0 0.8310.14 A 1000 37.41 i .2310.07 D 1000 80.St .21 .01io.09 A 1000 Iron Colorimetric 4.8910.35 5.8710.46 1.2010.13 A 200 9.55i0.34 12.01 .2610.05 D 100 14.710.42 18.2 1.55 1.2410.11 D 100 Copper Colorimetric 4.6810.24 5.41 .151 A 400 9.6610.49 10.8i .1210.07 A 400 14.51 .811.59 1.09io.12 A 400 Nickel Colorimetric 5.0910.26 9.1313.06 1.79 0.61 A 200 10.21 .612.62 1.2410.26 A 200 15.31 .911.62 1.1710.11 A 200 Silica Colorimetric 54.31 .710.58 0.92i0.096 A 500 1091 .6 2.62 0.9410.065 A 500 160 .42 0.9610.03 A 2000

Reported as concentrate concentrations but analyzed at diluted level

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TABLE 2

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CROSS CHECK RESULTS

.l 4 QUARTER 1986 i

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SAMPLE CONTRACTOR ANALYTICS RATIO RESOLUTION RESULT

, VALUE VALUE CONTRACTOR:

pCi/cc pCi/cc ANALYTICS

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i Sr-89 7 E-04 8.23 E-04 0.85 17 A Sr-90 7 E-05 1.27 E-04 0.55 1 D

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1 ATTACHMENT 2  ;

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

't i This attachment provides criteria for comparing results of capability tests

and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this l progra ;

2 . i 4 In these criteria, the judgment limits are variable in relation to the comparison 1 of the NRC's value to its associated one sigma uncertainty. As that ratio, I referred to in this program as " Resolution", increases, the acceptability of a i licensee's measurement should be more selective. Conversely, poorer agreement should be considered acceptable as the resolution decreases. The values in the ratio criteria may be rounded to fewer significant figures reported by the NRC i Reference Laboratory, unless such rounding will result in a narrowed category of l acceptance, j

RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement  !

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! <4 0.4 - 2.5

! 4- 7 0.5 - 2.0 j  !

j 8- 15 0.6 - 1.66  !

16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 j 200 - 0.85 - 1.18

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? Some discrepancies may result from the use of different equipment, techniques, I and for some specific nuclides. These may be factored into the acceptance  !

! criteria and identified on the data sheet, j ,

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