IR 05000440/1989027
| ML19354D650 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/05/1989 |
| From: | House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19354D649 | List: |
| References | |
| 50-440-89-27, NUDOCS 8912290005 | |
| Download: ML19354D650 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION e
REGION III
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Report No. 50-440/89027(DRSS)
License No. NPF-58 l
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Docket No. 50-440 l
l Licensee:
The Cleveland Electric Illuminating
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Company F
10 Center Road Perry, OH 44081
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Facility Name:
Perry Nuclear Power Plant, Unit 1 r
Inspection At:
Perry Site, Perry Ohio
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L Inspection Conducted:
October 30 through November 3, 1989 (Onsite)
November 8 and 16, 1989 (Telephone Discussions)
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Inspector:
J. E. House
/2- /- #7 t
Date 4/[jk A
k Approved By:
M. C. Schumacher, Chief
- ~ W Radiological Controls and Date l
Chemistry Section Inspection Summary Inspection on October 30 through November 16, 1989 (Report No. 50-440/89027(DRSS))
Areas Inspected:
Routine announced inspection of (1) the chemistry program, including procedures, organization and trainin84750); (3)g (IP 84750); (2)
Reactor systems water quality control programs (IP Quality assurance / quality control programs in the laboratory (IP 84750); (4) nonradiological confirmatory measurements (IP 79701) and (5) review of past open items and violations (IP 92701).
Results:
Implementation of the laboratory QA program appeared to be adequate.
The plant is committed to a water quality program and chemistry parameters are monitored with trend charts.
Overall water quality appeared to be adequate.
Licensee performance in the nonradiological confirmatory measurements program was very good, s912290005 891215 ADOCK0500gO PDR Q
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DETAILS
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Persons Contacted (
2R. DiCoca, Compliance Engineer
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2C. Elberfeld, Operations Analyst 2A. Lambacher, Audit Coordinator 20. Piller, System Engineer
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20. Reyes, Plant Chemist
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2E. Root, Manager, Operations Support 20. Shelton, General Supervisor, Chemistry
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2M..Takacs, Quality Assurance Auditor
2D. Wells Auditor
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J. Grimm, Chemistry Specialist J. Kutney, Quality Control Chemist 2P. Hiland, Senior Resident Inspector, NRC G. O'Dwyer, P.esident Inspector, NRC
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The inspectors also interviewed other licensee personnel in various departments in the course of the inspection.
2 Denotes those present at the plant exit interview on November 3, 1989.
2.
Licensee Action on Previous Inspection Findings (IP 92701)
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a.
(Closed) Open Item (No. 50-440/87002-02):
Licensee to correct the difficulties in the boron analytical method.
The licensee's three boron determinations in the current comparison program were all
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agreements, b.
,(C,losed)OpenItem(No. 50-440/88008-02):
Licensee to resolve problems with atomic absorption analyses (AAS) and elements of
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the QA/QC program.
The licensee has implemented multiple point calibration curves, independent controls, a technician testing program and statistically based control charts.
The AAS were all
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agreements and the licensee is continuing to investigate-problems with the instrument (Sections 5, 6)
(Closed) Violation (No. 50-440/88018-01):
Licensee has failed to c..
maintain.three chart recorders for chemistry in-line instrumentation.
The licensee has returned the three recorders to operational status.
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Corrective action taken to prevent extended delays in repairing process
' monitoring equipment include higher priorities for process instrumentation work orders and work order reviews by Chemistry Management or the responsible System Engineer to ensure that appropriate repair priorities
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are assigned to this instrumentation.
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3.
Management Controls, Organization and Training (IP 84750)
The inspector reviewed management and organization of the Radiation Protection bection (RPS) which includes the Chemistry Unit.
The management structure of this group has undergone a major revision since
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the last inspection.
The RPS which formerly was part of the Technical Department now reports to the General Manager, Operations Department.
However, responsibility for plant water systems (water quality) remains with a systems engineering group in the Plant Technical Department.
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Operations and the Technical Department report to the Vice President, Nuclear.
The RPS also has a new manager, the former Corporate Health Physicist, who appeared to be. knowledgeable in the area of chemistry.
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organization of the chemistry unit is similar to that described in a previous report (Region III Inspection Report No. 50-440/89004).
One additional specialist has joined the unit to assist in special projects.
The overall structure of the chemistry unit appeared adequate to manage the the QA/QC programs in the laboratory.
No violations or deviations were identified.
4.
Water Chemistry Control Program (IP 847501 The inspector reviewed the water chemistry control program as defined in OM1A: PAP-1102, Plant Chemistry Control Program, Revision 2, February 2, 1989 which is consistent with the EPRI BWR Owners Group Guidelines.
Management's commitment to this program and its role in maintaining chemistry parameters for plant water systems is contained in P0P-0804, Plant Chemistry Control Policy, Revision 0, September 2, 1986.
The, licensee maintains a computer data base of chemistry parameters from which trend charts are generated.
A review of selected records from December 1988 to October 1989 indicated that water chemistry is within the EPRI Guidelines.
Although adequate, overall water quality was somewhat lower immediately after the refueling outage owing to unavailability of the reactor water cleanup system for several days due to equipment problems.
As run time increased following the outage, chemistry parameters appeared to be improving.
Chemistry parameters are monitored daily by chemistry management; weekly and monthly reviews are conducted by chemistry and plant management.
Corporate management receives a monthly report.
No violations or deviations were identified.
5.
Nonradiological Confirmatory Measurements (IP 79701)
The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to various Technical Specification, administrative and other regulatory requirements.
These samples had been prepared, standardized,
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and periodically reanalyzed (to check for stability) for the NRC by the i
Radiological Sciences Division of Brookhaven National Laboratory (Bhl).
The samples were analyzed by the licensee using routine methods and equipnent.
A single dilution was made for each sample by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in a manner similar to that of routine samples.
The results are presented in Table I which also contains the criteria for agreement.
These criteria are based on comparisons of the mean values and estimates of the standard deviations (SD) of the measurements.
The licensee will also prepare a sample of reactor coolant spiked with fluoride, chloride and sulfate to be split with an NPC contractor laboratory.
The licensee will determine the concentrations of the analytes and the results will be sent to Region III for comparison with the values determined by the contractor laboratory. This will be followed under Open Item No. (50-440/89027-01).
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The licensee determined 9 analytes at three concentrations each. Of the initial 27 analyses, 21 were completed during the inspection.
Problems with the Atomic Absorption Spectrophotometer prevented the licensee from completing the netal analyses while the inspector was onsite. These six remaining determinations along with a reanalysis of the high silica unknown were reported to the Region by telephone the following week.
The licensee had agreements in 19 of the 21 analyses completed onsite. One analysis was a qualified agreement and one was a disagreement.
The disagreement was the high level silica which had a negative bias of 17%.
The six metal determinations and the reanalyzed silica (using a newly prepared calibration curve) were all in agreement.
Although the results of the nonradiological confirmatory measurement program were good, a few assays exhibited biases.
The middle and high sodium levels had positive biases of 11 and 15%, respectively. The
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low and middle sulfate levels had an 8% positive bias.
The sulfate bias
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could have been caused by the low concentration ranges measured on the ion Chromatograph.
The inspector discussed instrument calibration which is the most likely source of the biases with a licensee representative.
No violations or deviations were identified.
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6.
Implementation of the Chemistry QA/QC Program (IP 84750)
l The inspector reviewed the QA/QC program for nonradiological chemistry as defined by OM1E: RAP-02C4, Chemistry Unit Analytical Quality Control Program, Revision 2. January 28, 1988.
The laboratory has the elements of an adequate QA/QC program in place.
Progress in this area is due, in part, to the organizational structure which includes a Quality Assurance Chemist.
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The licensee had indep.ndent controls for all assays and plots their values l
on cortrol charts.
These charts appeared adequate; however, the metal
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analyses were still charted using the recovery i 10% instead of plotting the mean value i the standard deviation.
The inspector discussed plotting
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techniques along with possible biases in selected charts with a licensee l
representative who agreed to review the charts in question.
i The licensee has an intralaboratory testing program in which technicians r
are given unknowns prepared by the QA Chemist.
This program has statistically based acceptance criteria and technicians whose analyses i
fall outside of the acceptance range are retested using duplicate
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samples.
Both results must be within i 2 standard deviations or the
person must be requalified on that particular assay.
A review of j
selected records indicated that technicians were being tested in r
accordance with the procedure.
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A second part af this program is the interlaboratory comparison program.
The unknowns prepared for the interlaboratory program are sent by the licensee to an outside laboratory for analysis.
A review of selected data indicated that the licensee's in house analyses of these unknowns for iron
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and copper (AAS) had unusually large standard deviations which were
approximately 20% of the mean value.
The independent laboratory that
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analyzed the same material reported standard deviations of approximately
2% of the mean.
Licensee representatives acknowledged that problems
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existed with the AAS and were investigating the cause.
Improvements in the AAS analyses will be followed under Open Item No. (50-440/89027-02).
The licensee's value for the silica unknown in the interlaboratory comparison was about 20% lower than that of the outside laboratory which was similar to comparison with high BNL unknown before recalibration (Section 5).
The Interlaboratory Comparison program appeared to be adequate.
No violations or deviations were identified.
7.
Audits and Appraisals (IP B4750)
The inspector reviewed the most recent internal quality assurance audit of the chemistry program, Number PIO 89-23, conducted from August 21 through October 11, 1989.
The audit team appeared to address in adequate
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' detail in the chemistry QA/QC program and overall plant water systems.
The report contained six recommendations.
As this audit report was obtained by the inspector prior to its issuance to chemistry management,
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followup of the recommendations could not be evaluated.
This will be reviewed in subsequent inspections.
No violations or deviations were identified.
8.
Open Items Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee, or both.
Open items disclosed during the inspection are discussed in Sections 5 and 6.
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9.
Exit Interview I
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The scope and findings of the inspection were reviewed with licensee
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representatives (Section 1) at the conclusion of the inspection on November 3, 1989.
The inspector discussed Open Items in Sections 2, l
5, and 6, observations of the chemistry QA/QC programs, plant water l
chemistry and the results of the nonradiological confirmatory
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measurements program.
The inspector discussed the likely informational-l content of the inspection report regarding documents and processes l
reviewed by the inspector during the inspection.
The licensee did not
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identify any such documents or procesces as proprietary.
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Attachments:
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Table 1, Nonradiological Interlaboratory
Test,Results, October 3 - November 16, 1989
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TABLE 1 Nonradiological Interlaboratory Test Results Perry Nuclear Plant October 30 - November 3, 1989
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Analyte Nethod Conen Ratio Aceptance Ranges Result 1 2sd 1 3sd p2h Chloride A
IC 5-10 1.06 0.933-1.067 0.900-1.100 A
B 10-20 0.97 0.919-1.081 0.887-1.113 A
C 5-10 0.95 0.926-1.074 0.895-1.105 A
Sulfate A
<5 1.08 0.895-1.105 0.842-1.158 A
B 5-10 1.08 0.895-1.105 0.868-1.132 A
C 10-20 1.04 0.900-1.100 0.867-1.133 A
Iron G
AA/FL 200 0.97 0.904-1.096 0.854-1.146 A
H 400 1.04 0.003-1.097 0.857-1.143 A
I 100 1.01 0.903-1.097 0.855-1.145 A
Copper G
AA/FL 200 0.98 0.904-1.095 0.859-1.141 A
H 100 0.99 0.904-1.096 0.857-1.143 A
I 100 0.99 0.904-1.096 0.857-1.143 A
Nickel G
AA/FL 200 1.00 0.936-1.064 0.906-1.094 A
H 400 0.94 0.938-1.062 0.908-1.092 A
I 100 0.99 0.938-1.062 0.907-1.093 A
Chromium G
AA/FL 200 0.96 0.905-1.095 0,855-1.145 A
H 100 0.98 0.903-1.097 0.854-1.146 A
I 100 0.97 0.903-1.097 0.853-1.147 A
Sodium J
AA/FL 50-100 1.04 0.863-1.137 0.784-1.216 A
K 10-20 1.11 0.859-1.141 0.786-1.212 A
L 20-50 1.15 0.862-1.138 0.789-1.211 A+
Silica S
Spec 20-50 1.05 0.906-1.094 0.859-1.141 A
T 100 0.92 0.909-1.091 0.860-1.136 A
U 100 0.83 0.907-1.093 0.857-1.143 D
Rerun U
20-50 0.94 0.907-1.093 0.857-1.143 A
PIm Boron D
Titr 1000 0.98 0.979-1.021 0.968-1.032 A
E 3000 1.01 0.979-1.021 0.968-1.032 A
F 5000 0.98 0.979-1.021 0.968-1.032 A
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Methods:
Titr
- Titration IC
- Ion Chromatography
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- Spectrophotometry 3M
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AA/FL - Atomic absorption spectrophotometry (flame)
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Conc: Approximate concentration analy ed.
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Ratio of Licensee mean value to NRC mean value.
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The SD in the fifth and sixth columns represents the
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c.oefileient of variation obtained from averaging licensee data from the preceding cycle (Table 2.1 of NUREG/CR-5244).
The licensee value is considered to be in agreement if it falls
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within the i 2 SD ranc(, a qualified agreement if it lies outside i 2 SD but withia 1 3 SD; and in disagreement if it is outside the i 3 SD range.
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Result:
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= Agreement: Licensee value is within 12 SDs of the NRC mean value.
A+ = Qualified agreement, licensee is between 1 2 and 13 SDs of the NRC value.
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= Disagreement: licensee value is outside i 3 SDs.
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