IR 05000440/1987002

Insp Rept 50-440/87-02 on 870126-30 & 870203,05,06 & 12 Telcons.No Violations or Deviations Identified.Major Areas Inspected:Chemistry Program Including Procedures, Organization,Training & QA & Water Chemistry Control

ML20212B101
Person / Time
Site:	Perry
Issue date:	02/20/1987
From:	Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212B066	List: IR 05000440/1987002 ML20212B062
References
50-440-87-02, 50-440-87-2, NUDOCS 8703030475
Download: ML20212B101 (9)

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U.S. NUCLEAR REGULATORY COMMISSION i

REGION III

Reports No. 50-440/87002(DRSS)

Docket Nos. 50-440; Licenses No. NPF-58 Licensee: Cleveland Electric I'1uminating Company (CEI)

Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1

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Inspection At: Perry Site, Lake County, Ohio Inspection Conducted: January 26-30, 1987 (Onsite)

, February 3, 5, 6, and 12, 1987 (Telephoneconversations)

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Inspector: R. B. Holtzman <Sdv/a'-7 Date k/

Approved By: M. C. Schumacher, Chief Radiological Effluents and MN//7 Date Chemistry Section Inspection Summary

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Inspection on January 26-30; February 3, 5, 6, and 12, 1987 (Report No. 50-440/87002(DRSS)

! Areas Inspected: Routine announced inspection of: (1) chemistry program, including procedures, organization, training, and quality assurance, and

. (2) water chemistry control, and (3) confirmatory measuren.ents of

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non-radiological samples.

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Results: No violations or deviations were identified.

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i Ob0 o O R D0500o440 070223 l Plw i

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DETAILS Persons Contacted 1F. Stead, Manager, Perry Plant Technical Department (PPTD),

Cleveland Electric Illuminating Company (CEI)

IS. Kensicki, Technical Superintendent, PPTD/CEI 1S. Wojton, General Supervising Engineer, Radiation Protection Section/CEI

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1J. J. Lausberg, Supervisor Ops. Systems and Programs, NQAD(0QS)/CEI 18. D. Walrath, General Supervising Engineer-0perations Quality, NQAD/CEI 1,30. Reyes, Plant Chemist, PPTD/CEI

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IP. A. Russ, Compliance Engineer, PPTD/CEI

< 1,38. S. Ferrell, NRC Interface-L&CS, PPTD/CEI 2J. J. Grimm, QA/QC Chemistry Coordinator, PPTD/, I T. L. Burger, Radiation Protection Technician (R, ), PPTD/CEI i

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G. S. VanWay, RPT, PPTD/CEI P. Barton, Chemistry Consultant

D. J. Piller, Chemistry Supervisor, PPTD/CEI E. J. Traverso, Chemistry Supervisor, PPTD/CEI

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1K. A. Connaughton, Senior Resident Inspector, NRC

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The inspectors also interviewed other licensee personnel in various i departments in the course of the inspectio Denotes those present at the plant exit interview on January 30, 198 Telephone conversation held February 3, 198 Telephone conversations held February 5 and 6, 198 . Management Controls, Organization and Training

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The inspector reviewed the organization and staffing of the Chemistry Unit and changes since the last inspection.4 The Plant Chemist reports to the the General Supervising Engineer-Radiation Protection. Six staff members and 20 technicians report to the Plant Chemist who is also aided by three Chemistry Consultants. TheyappeartobequalIfiedchemists. The Unit has a recently-appointed QA/QC Coordinator who is a knowledgeable chemist i familiar with quality assurance and quality control principles.

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l 4 Region III Inspection Report No. 50-440/87070.

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The inspector reviewed the status of the INP0 accreditation for the chemistry technician training program. Top corporate management has directed this program to be developed rapidly; a draft Accreditation Self-Evaluation Report is scheduled for submission to INP0 by March 31, 1987. An accreditation visit from INP0 is planned for August or September 1987. The status appears to be satisfactory for timely completio No violations or deviations were identifie . Water Chemistry Control The inspector reviewed the licensee's water chemistry control program which is directed by POP 0804, " Plant Chemistry Control Policy," Revision 0, ef fective dated September 2,1986. This policy is implemented in Procedure OM1A: PAP-1102, " Plant Chemistry Control Program," Revision 0, effective date September 18, 1986. This is a general program that requires the determination of various parameters, including conductivity, chloride, silica, dissolved oxygen, and Fe, Cu, N1, Cr, and boron. It does not require the determination of sulfate and fluoride reactor coolant as recommended by the EPRI and BWR Owners Group BWR Water Chemistry Guidelines, although sulfate is determined routinely. The sampling frequencies, data logging forms, data trending requirements, and action levels (limiting conditions of operation) for the various systems and chemical parameters are given in this procedure. The administrative limits and action levels are consistent with the BWR Water Chemistry Guideline No violations or deviations were identifie . . Implementation of the Chemistry Programs The licensee provides adequate floor, hood and bench space in the laboratories. The laboratories are essentially the same as described in the two previous reports.6,6 The housekeeping was satisfactor The Dionex 2020i Ion Chromatograph was fully operational for the analyses of chloride and sulfate at very low concentrations with detection limits of one and five ppb for the two species, respectivel The chloride was checked daily and sulfate weekly; within a few weeks, the latter will be checked daily, als Overall, the laboratory appears to be operating satisfactoril No violations or deviations were identifie Reports No. (50-440/85058; 50-441/85021).

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. Implementation of the QA/QC Program in the Chemistry Laboratory

i The inspector reviewed the non-radiological Chemistry QA/QC program described in the procedures and implemented in the laborator The program was based on the chemistry procedure OM1E: RAP-0204,

Chemistry Unit Analytical Quality Control Program, Revision 1, November 7, 1985, with a change dated January 15, 198 The program consists of three main parts, an intralaboratory spiked and split samples arogram i (mainly for the testing of technician performance), an interla) oratory comparison program with split samples from vendor laboratories, and a program for the calibration and maintenance of the counting room instruments.

For the cold (non-radiological) analyses the licensee uses check and calibration standards for setting up and checking the operation of the instruments. For the chloride analysis on the ion chromatograph (IC)

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the instrument is checked with two standards along with several blanks

! (the use of several blank checks is critical because of the potential for contamination by environmental chloride). Results are acce) table when duplicate samples have peak heights within 110% of each otle The atomic absorption spectrophotometer (IL aa/ae Spectrophotometer i

Model 551) is calibrated with four standards and a blank. As quality checks, the machine plots the calibration curve on a video screen and displays the apparent concentrations of the standards. These data are 1 used to provide a check on instrumental performance. The control limits require the apparent values of the calibration standards to be within 110% of the actual value l The licensee has various programs in place for quality control of the

instrumentation and analyses, but they are usually based on arbitrar percentage limits, which are not supported by statistical analysis. y The test results are posted in the respective instrument logbooks, but only those within the control limits are posted, so that proper statistical j analysis and controls can not be applied.

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The inspector discussed with licensee representatives some weaknesses in

. the quality control program and possible corrective measures:

i The results of the intralaboratory (RCT performance) tests

! should be tabulated by individual RCT, as well as by type i of analysi Control charts should be used with the non-radiological chemistry

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instrumentation and analyses, with warning and control limits based on the calculated uncertainties, e.g., standard deviations of the j actual data.

l More than one stock standard reagent should be used in making calibration and check samples to improve the chances of detecting I deterioration of the standard stock reagents.

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More specific instructions should be written for the treatment

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of out-of-limit results in Procedure RAP-0204 for both the intra-and inter-laboratory analyse An interlaboratory comparison program should be set up for cold chemistry analyses, at least for chloride, sulfate, silica, iro and copper in the concentration ranges normally used in the laboratory, Additional analyses should be added to the intralaboratory program to cover the the procedures normally used, e.g., sulfate, silica, iron and coppe Set up a program to require duplicate analyses on some fraction of the actual samples.

l Implementing the above suggested changes will help the laboratory to maintain better control over its analyses and to better demonstrate

! the credibility of their results to both plant management and to the i NRC by better documenting the various QC parameters for convenient i

assessment. These suggestions are not necessarily exhaustive and should not be construed to limit the implementation of other QC activitie The licenste representatives agreed to institute the above suggestions, except for the use of multiple stock solutions (3) and to do duplicate analyses (7). They will, however, consider these for incorporation into the program (some are already in it). They agreed to implement these 4 items by November 1987. Progress of this implementation will be followed in a subsequent inspection under Open Items (50-440/87002-01).

! While presently assessment of the QA/QC data is weak, the licensee's i QA/QC program appears to provide a good basis for the development of a i satisfactory guality assessment program, particularly for the control of the analytical procedures and the proficiencies of the RCT No violations or deviations were identifie . Non-radiological Confirmatory Measurements The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor chemical parameters in various plant systems with respect to various Technical Specification and other regulatory and administrative requirement These samples had been prepared, standardized, and periodically reanalyzed

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(to check for stability) for the NRC by the Safety and Environmental Protection Division of Brookhaven National Laboratory (BNL). The samples

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were analyzed by the licensee using routine methods and equipment,

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The samples were diluted by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate similarly to routine samples. The results are presented in Table 1 and the criteria for agreement in Attachment 1. These criteria for agreement are based on comparisons of the mean values and estimates of the standard deviations (sd) of the measurements. Consideration was given to the fact that the uncertainties (sd) of the licensee's results were not necessarily representative of the laboratory's because they were obtained by one analyst doing the analyses over a short period of time. Consequently when the licensee sd was less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the sd of the ratio Z (Sz inAttachment1).

Fifteen of the 20 licensee results were in agreement with those of BN However, when the agreement criteria of three sd normally applied by the licensee, were used, one additional agreement was achieved for the chloride and for one boron analyses, as shown in the last column of Table 1. The licensee's sodium values, including the two disagreements showed a persistent positive bias possibly caused by residual contamination on laboratory glassware. Licensee representatives plan to examine this proble The boron results, which differ from the BNL values by 6.8% or more indicate that the laboratory has a problem in determining accurately that the boron concentrations in the standby liquid control tank are in conformance with the T/S limits. At the present solution volume in the tank of about 4480 gal. the T/S (Fig. 3.1.5.1) allows the sodium pentaborate concentration to vary between 13.2 and 13.8%, an implied variability of about 2%. This is substantially lower than the difference between the licensee and BNL values found in this comparison. To obtain credible values, the uncertainties (sd) in the accuracy of the analyses should be about one-half the latter value, or about +1%. This was discussed with the Plant Chemist, who stated that they were checking the procedure, OM12A: CHI-10, " Boron Mannitol Potentiomentric Method,"

Revision 0, September 20, 1985, to determine the possible causes of the

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discrepancies, such as the effects of absorption of atmospheric carbon f dioxide and a possibly defective boron standard solution. They are also

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planning to use an alternate check on the analysis by standardizing the sodium hydroxide titrant against an acid standar Because of delays in starting these measurements during the inspection, and some difficulties in setting up the samples due to contamination of the highly diluted solutions from the leaching of chloride and sulfate l

from the volumetric flasks used in the dilutions, the chloride and sulfate i measurements were not completed by the end of the inspection. The licensee j

agreed to submit these results and their conclusions on the boron analysis i

These will be followed in subsequent inspections under Open l

to Reg (ion II Items 50-440/87002-02).

No violations or deviations were identified.

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. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee, or both. Open items disclosed during the inspection are discussed in Sections 5 and . Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on January 30, 198 The inspector discussed the weaknesses in the QA/QC program and the suggested changes in it, including the uses of control charts for non-radiological analyses, and adding non-radiolgical analyses to the intra- and interlaboratory comparison programs. They agreed to make changes to the programs, as noted in Section 5. Further findings were discussed in telephone conversations with the Plant Chemist and other licensee representatives on February 3, 5, 6, and 12, 198 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 insnection. Licensee representatives did not identify any such documents or processes as proprietar s Attachments: Table 1, Non-radiological Interlaboratory Test Results, 1st Quarter 1987 Attachment 1, Criteria for Comparing Analytical Measurements

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TABLE 1 Non-Radiological Interlaboratory Test Results Perry Nuclear Power Plant, Units 1 and 2 January 26-30,1987 Comparison Analysis NRC Licensee Ratio Compari-Parameter Method son Y sd(n) X sd(n) Z sd(n) NRC 2sd 3sd Concentration, ppb Chloride IC 12.0 i 1.6(7) 1 .8 0.98 0.15 A 18.7 1 0.60(7) 2 . 8 1.12 0.10 A 4 .1(8) 46.4 1 .15 0.05 DA Sulfate IC 10.0 1 0.45(7) 1 .4 1.03 1 0.06 A 20.5 t 1.2(7) 20.5 i .00 0.10 A 40.4 i 1.5(7) 36.9 t .91 0.043 A Silica Spectro- 5 .6(7 5 . 5 0.95 t 0.10 A photo- 109 1 7.0(7 10 .0(6) 0.98 0.09 A metric 80.0 1 2.5(7 84.0 1 .05 0.035 A Concentration, ppm Boron Titra- 985 i 10(7) 1052 1 27 1.068 0.030 DA tion 2980 50(7) 3328 1 57 1.12 1 0.027 DD Iron AAS 4.89 0.35(13) 4.95 0.09 1.012 i 0.075 A 9.55 1 0.34 1 .18 1.047 0.042 A 14.7 1 0.42 15.78 1 0.25 1.073 0.042* A Copper AAS 4.68 0.24(12) 4.54 1 0.03 0.970 0.050 A 9.66 1 0.49(14) 9.50 0.06 0.983 1 0.050 A 14.5 i 0.6(13) 1 .09 1.076 t 0.045 A l Sodium AES 4.58 0.5 6) 6.58 1 0.04 1.44 0.19* D l 9.23 1 0.8 6 12.3 1 0.06 1.33 0.14* D

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14.4 1 0.8 6 1 .09 1.08 1 0.06 A Value i standard deviation (sd); n is number of BNL analyse The number of licensee analyses is 3 unless otherwise noted, A = Agreement 0 = Disagreement Licensee criterion for agreement, 13 s * Used BNL uncertainty for licensee's uncertainty

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D e ATTACMENT I

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Criteria For Comparing Analytical Measurements This attachment provides criteria for comparing results of capability test In these criteria the judgement limits are based on the uncertainty of the ratio of the Itcensee's value to the NRC value. The following steps are performed: (1) the ratio of the licensee's value to the NRC value is computed ratto = Licensee Value ;

NRC value (2) the uncertainty of the ratio is propagated.I

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If the absolute value of one minus the ratio is less '.han or equal to twice the ratio uncertainty, the results are in agreement. (ll- attels2 uncertainty)

Z = l' then 3* = 3* + II y Z2 K2 Y2 (From: Bevington, P. R., Data Reduction and Error Analysis for the Physical Sciences, McGraw-Hill, New York, 1969)

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