IR 05000445/1990029
| ML20059J298 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/30/1990 |
| From: | Murray B, Nicholas J, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20059J248 | List: |
| References | |
| 50-445-90-29, 50-446-90-29, NUDOCS 9009190257 | |
| Download: ML20059J298 (26) | |
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- APPENDIX (v
' 4.S. NUCLEAR REGULATORY COMMISSION, u.. , , lc REGION'IV- , , p, y, " [, NRC Inspection Report:. 50-445/90-4 Operating License: NPF-87 50-446/90-29-Construction Permit: -CPPR-127? Dockets: L50-445 m P 50-446 f ., ' l ' ' ' Licensee: TV Electric ' - s U Skyway Tower >
400 North Olive Street, L.B.~81 e' -t- < , U ' ' . Dallas, Texas -75201 g Facility Name: Comanche Peak' Steam. Electric Station (CPSES) J ,
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' Inspection At: CPSES Site, Glen' Rose, Texas-
InspectionConducted:. July 23-27, 1990
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Q j Inspectors: ) k[L8 ! NhI @' 'J. B. Nicholas,c5enior Rapiation.; Specialist. 0 ate / h x Facilities Radiological Vrotectio_n Section l /?blU $$bbW b' Iy.. L. ~WiToorn, Ra'dihtion Spevialist, Facilities D6te ' U; * ' Radiological Protectior; Section-
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. - Approved: d MM/'/ ' M BNurray, Chief,' Facili ~ 's Radiological 04te ' Protection Section , . Inspection Summary [ y -@! = Inspection Conducted July 23-27, 1990 (Report 50-445/90-29) t Areas Inspected: Routine," unannounced inspection of the licensee's Unit 1 m water chemistry and radiochemistry programs including water chemistry and radiochemistry confirmatory measurements.
% Results:. The licensee had implem.ted a water chemistry program and _ radiochemistry program in accord ace with NRC requirements.
The water 90, chemistry and radiochemistry programs were being conducted in accordance with . m Final Safety Analysis Report (FSAR) and Technical Specification (TS) " i 9009190257 900910 PDR ADOCK 05000445 O PNV ' , ' > - - - - - - - - - - - - - - - - - - -. . - - - - -
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3' , , p, j) s =. " ' y n ,, E 'requireme'nt's. :The -l'icensee's' chemistry staf f -had experienced a personnet ' .turnoverPof approximately 10 percent during the past 15 months.
The. licensee" , had performed comprehensive ' quality assurance.(QA) surveillances and' audits'in.
the water chemistry'and radiochemistry areas.. The licensee's chemistry L staffing,' training,' and qualification programs were adequate to support plant . operations.1The results of the nonradiological water chemistry confirmatory ' ~ measurements showed 100 percent agreement which' indicated an improvement over zthe 89'percentLagreement achieved during the previous NRC water chemistry.: confirmatory, measurements' inspection in September 1989.
The radiological confirmatory measurements results for the radiochemistry counting room; indicated'98 percent agreement and for the health physics (HP) counting? room ~ showed.93 percent' agreement which were consistent with the radiochemistry 98 percent and>the HP.100 percent agreement achieved during the last NRC.
inspection ofsthis area in~ September 1989.
Within-the areas inspected, no violations or deviations were identified.
All-fpreviously identified open items, unresolved items, violations, and' deviations-in' the' chemistry area-have been resolved and closed.
Inspection Conducted July 23-27, 1990 (Report 50-446/90-29) Areas Inspected:.No inspection of Unit-2-was conducted.
Results:.Not applicable.
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' jL q.a LTVElectric- , ' w c~.
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, "f ; ' A. l B. Scott,- Jr., Vice President, Nuclear Operations l
- L. G. Barnes, Technical Staff Training Manager
- *0. Bhatty, Issue: Interface Coordinator, QA- , , ' ' *D.: M. Bozenian,- Chemistry / Environmental Manager y C. M.,Corella, Senior Chemist-3! 4-' ' *E. T. Floyd,. Radiation Protection Technician ' . D. W. Fuller,; Chemistry Training Instructor.
N.'S. Harris, QAiSpecialist t J.' L.L Hill,. Primary Chemistry Laboratory Coordinator , x , y
- T;.A.-Hope; Licensing Engineer B.EL. Lantz,._-QA Specialist
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D. E. Massey,? Chemistry Technician, W - *G. P.-McAffee,. Operations QA Manager '*R. B. McCamey, Senior Chemist- . '
- J.
F.,McMahon, Nuclear l Training Manager
- F..P. Miller -QA Specialist.
M y'y-G. BE Moore,-Chemistry Supervisor i< G. G. Nichols','. Senior Chemist.
M.s.GJ 011ver;. Professional Staff Training Supervisor > g
- R. J.E Prince.. Radiation Protection Manager '
' 1R. L.,Ramsour,< Radiation Protection Supervisor, L*T. G;:Spalding,' Chemistry Supervisor.-
a < C. J. : Stanley,. Professional-Staf f Training Program Coordinator y , SL W. Swam, Technical Training Supervisor.
i .R. L. Theimer," Chemistry Supervisor , > ' a r NRC . ' , >a
- S.'D.. Bitter, Resident-Inspector
.) Others ,
- E. F. Ottney, Project Manager, Citizens Association for Sound Energy (CASE)
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- Denotes thoseLpresent during the exit meeting on July 27, 1990.
Q. ' 2.
Organization > and -Management Controls t ' '
.The inspectors reviewed the licensee's organization, staffing, and staff functional assignments related to the water chemistry and radiochemistry programs to determine agreement with commitments in Chapter'13 of the FSAR and compliance with the requirements in Section 6.2 of the Unit 1 TS.
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pg g i-4- , Q< g4 ' t b., , , N The inspectors _ verified.that the organizational structure'of the <' < ' ~ Ichemistry/ environmental section (C/ES) was'as defined in the FSAR.and TS.
. The'C/ES staff assignments and management-controls were, reviewed:for the: A# ' assignment of responsibilities for the management and implementation' ofE
- the CPSES water chemistry and radiochemistry programs.
Theiinspectors; +
w-verified that'the administrative controls and program implementing! , - @m ,, responsibilities were adequately described in position descriptions andl approved procedures.. The inspectors noted' thatt in June.1990 the: g '\\
, M chemistry / radiochemistry staff organization had.been changed to a six shift rotation.
Each shift crew was composed of a lead; chemistry , @& technician and three chemistry technicians.
The shif t' crews.were working e $s l12-hour _ shifts.
The present chemistry / radiochemistry organization was % composed of 1 managerp 3 supervisors, 5 chemists,i4flaboratory _ _ N coordinators, and 24 shift chemistry technicians. including the' lead shift _ y technicians.
The use of laboratory coordinators and lead-shif t chemistry ,
- Y technicians on shift crews.was improving the performance, coordination..
' and implementation of the water chemistry and radlochemistry programs, y , s' ? The _ inspectors reviewed the~ staffing of the CPSES C/ES and. noted,, since : M
- W the previous NRC chemistry / radiochemistry inspection in September 1989',
i[( h that five new chemistry technicians had been added bringing!the totali % J permanent chemistry technician staff to 16; The licensce's C/ES' staff had W experienced' a personnel increase of approximately-10 percent during 'the past 15 months.
The C/ES was supplementing the permanent chemistry. F' . W technician staff with 10 contract chemistry technicians. -The' inspectors g were informed that the C/ES had 13 new positions recently approved to i replace the 10 contractor positions and increase the chemistry / N, radiochemistry staff by three new staff positions. The.CPSES staffing
appeared adequate to support the licensee's water chemistry and-radiochemistry programs.
Q', >d No violations or deviations were identified.
,, , % 3._ Training and Qualifications &,
- M-The. inspectors reviewed the licensee's training and qualification program M*
for chemistry / radiochemistry personnel including education and experience, adequacy and quality of training, and employee knowledge and qu'alification
, f" requirements-to determine agreernent with commitnients in Chapter 13 of the FSAR and compliance with the requirements-in Sections 6.3 and 6.4 of the , Unit 1 TS.
i [c, Whl The inspectors reviewed the education and experience backgrounds of the W present-CPSES chemistry / radiochemistry staff and determined that all y(, chemistry / radiochemistry supervisory and technical staff met the education , iD and experience qualification requirements in the FSAR and Unit 1 TS.
It M was determined that the licensee had an adequate, qualified staff to meet b'M shift staffing requirements.
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, Theinspectorsreviewedtheblicensee'strainingprogramfor . < . chemistry / radiochemistry personnel including a review of selected station-j" '- - nuclear training department 4 procedures, chemistry training instructors' qualificationsc chemistry training facilities, chemistry training program: l ' , procedure, chemistry department qualification guide, chehtistry . . . on-the-job / qualification' area catalog, chemistry technician training and
' qualification matrix,echemistry continuing training schedule for 1990, selected chemistry and radiochemistry training lesson ~ plans, and selected chemistry and radiochemistry. personnel training records.' The inspectors i , found the licensee's chemistryt raining program was being implemented in-l t ' accordance with CPSES procedures.
It.was determined that the CPSES . , chemistry training program was in the' final review process for Institute ' ' ' of.. Nuclear.' Power. Operations accreditation.
': . . , The licensee'had developed an adequate.' chemistry training facility and was - ' implementing a satisfactory initial and continuing chemistry training , o' program.
The four chemistry training instructors were well qualified.
' Chemistry shift. crews were attending regular training cycles every i 6th week of their rotational shift assignments.
The four laboratory coordinators were being scheduled to attend training along with one of the, shift crnws.
The review ofLthe chemistry technician training . qualification records' indicated that only three of the present permanent d ' chemistry technicians had not completed their training and qualifications
' in all qualification areas designated in the chemistry training 1 i procedures.
These three recently-hired chemistry technicians were ' j n currently undergoing their initial training program and were scheduled to complete their required initial chemistry training program by the end of 1990.
S ' The inspectors reviewed lesson plans and lecture notes for selected ' chemistry training courses and found them to be satisfactory. 'All lesson j' plans;had been developed for all courses listed on the chemistry training.
matrix.
] The inspectors reviewed selected chemistry and radiochemistry personnel i training records.
Posteccident sampling system (PASS) training was being conducted semiannually and was included in the annual chemistry continuing 1 training program.
All chemistry / radiochemistry technical staff had ' received semiannual PASS training.
The chemistry / radiochemistry staff . training records were complete and well maintained by the C/ES training , coordinator.
This was considered a strength to the C/ES training program.
- ~' However, the inspectors-noted some concerns regarding the completeness of the nuclear training department's computerized training records.
These concerns were discussed with the licensee during the inspection and at the ) exit meeting on: July 27, 1990.
The licensee stated that they plan to - review the chemistry personnel nuclear training department's t - nputerized . training records.
The. inspectors reviewed the nuclear training department's technical staff H and manager training program.
The manager training program was discussed with the professional staff training supervisor and professional staff . -,
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. . training program coordinator. -The inspectors' reviewed the; technical ~ staff ' and manager training = program course content and curriculum and.found 'it to ' be comprehensive..Most of. the training courses' listed have been developed and many'of the courses have been taught =to the licensee's managers and . supervisors.
The inspectors rev_iewe'd thejproposed training matrix for the . chemistry / environmental manager,' chemistry supervisor, chemist, . . environmental supervisor,.and environmental specialist positions and found the proposed training curriculum satisf actory.
The proposed initial training for-licensee's managers, supervisors, and technical staff is to be completed during the 2 years following the final approval of the training matrix for each manager and' technical staff.. position.
In addition to the initial training program, selected c'ourses in the individual position training matrixes have been designated for continuing and recurrent training.
The inspectors determined that the development of this new training area for managers and technical staff was on schedule.
No violations or deviations were identified.
4.
-QA Program.
The' inspectors reviewed the' licensee's audit and surveillance programs regarding water chemistry'and radiochemistry activities to determine agreement with the commitments in Chapters 13.4 and 17.2 of the FSAR and compliance with the. requirements in~Section 6.5.2.8 of the Unit 1 TS.
The inspectors reviewed selected QA survei11ance and audit procedures, surveillance and audit schedules for 1989 and 1990, QA surveillance and audit' plans-and checklists, and the qualifications of surveillance inspect'obs'and audit 6rs. ' Surveillance and audit' reports of QA activities performed-ddring'1989 and 1990:in the areas related to the-water chemistry and radiochemistry programs were reviewed foriscope to ensure thoroughness of-program evaluation; LThe QA surveillances and QA audits reviewed were designed to ensurt compliance with the FSAR, Unit l'TS', and CPSES procedures.
The inspectors reviewed surveillance and audit plans, '. checklists, and findings and confirmedcthat the identified findings were reviewed by licensee's management and that corrective actions to audit findings had been completed and documented in accordance with QA procedures.
The inspectors determined that the QA surveillances and QA audits had been performed by qualified personnel knowledgeable in chemistry and radiochemistry activities at' nuclear power facilities.
The inspectors reviewed the QA surveillance and QA audit reports listed in Attachment 1 to this report.
, No violations or deviations were identified.
5.
Light Water Reactor Chemistry Control, Chemical Analysis, and , Confirmatory Measurements The inspectors reviewed the licensee's water chemistry control and analysis program including implementation of a water chemistry control program, facilities and equipment, implementation of a quality ,
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control (QC) program for chemical measurements, and water chemistry confirmatory measurements to determine agreement with commitments in Chapter 10 of the FSAR and compliance with the requirements in Sections 3/4.4.6, 3/4.5.4, 3/4.6.2.2, 3/4.9.1, and 6.8 of the Unit 1 TS.
The inspectors' review of the water chemistry program found the licensee had revised and approved administrative procedures, surveillance procedures, chemistry control procedures, instrument calibration and QC procedures, and analytical procedures.
A review of selected procedures revised since the previous NRC water chemistry inspection in September 1989 indicated that the licensee had sufficient programmatic procedures to meet the commitments of the FSAR and Unit 1 TS requirements.
The procedures reviewed are listed in Attachment 1 to this report.
The inspectors inspected the secondary and primary chemistry laboratories and laboratory equipment.
The secondary chtmistry and primary chemistry laboratories were equipped with the necessary chemicals, standards, reagents, labware, and analytical instrumentation to perform the required chemistry analyses to suppor+ plant operation and maintain compliance with TS requirements.
The inspectors reviewed selected C/ES procedures for operation, calibration, and QC of the laboratories analytical instrumentation used for analysis of the NRC water chemistry standards to determine adequacy and accuracy of the licensee's water chemistry measurements program.
The secondary chemistry and primary chemistry nonradiological laboratory analytical instruments had been calibrated in accordance with approved procedures and an instrument QC program had been implemented.
The licensee was using QC charts to trend QC data and instrument performance.
The licensee had established criteria to identify and evaluate data biases in QC data and changes or trends in instrument performance.
The licensee had implemented a program of using independent chemical standards for calibration and QC measurements of chemistry analytical instrumentation.
The inspectors provided standard chemical solutions to the licensee for nonradiological confirmatory measurements analyses.
The chemical standards were analyzed by the licensee in both the secondary and primary chemistry laboratories using routine methods and equipment.
The final results of the nonradiological water chemistry confirmatory mea' irements showed 100 percent agreement with the NRC certified standard values.
These results indicated an improvement in nonradiological water chemistry analytical performance over the 89 percent agreement during the previous NRC chemistry confirmatory measurements inspection in September 1989.
The results of the measurements comparisons are summarized in Attachments 2, 3, and 4 to this report.
No violations or deviations were identified.
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Radiological' Chemistry Control, Radiochemical ~Analysig,, and' Confirmatory "' ' Measurements-
, l .' o zThe inspectors: reviewed the licensee's radiochemistry control and analysis'. ' !.. program including analytical procedures, facilities and equipment,-
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implementation and radiochemistry control of the reactor coolant system + , U and secondary water systems, implementation of a counting instrument' -
calibration and QC' program, and radioanalytical confirmatory measurements-W to determine agreement with the commitments in Chapters =5 and 9 of.the-M FSAR and com)liance with the requirements in Sections 3/4.4.7,3/4.7.1;4,- and 6.8 of t1e Unit 1 TS.
. g , ~ The inspectors reviewed selected radiochemistry analytical procedures ,4' revised and approved since the previous.NRC inspection of radiochemistry' s activities in September 1989 and determined that the licensee had o , l established and implemented satisfactory radioanalytical procedures to.
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" meet.the commitments in the FSAR and the Unit 1 TS requirements.
l Radiochemistry and'HP procedures for tha operation, calibration, and QC:of t J P-the radiochemistry counting room and Hr, counting room instrumentation used
for analysis of the radiological confirmatory measurements were reviewed.
The inspectors reviewed the licensee's records for 1990 involving instrument calibrations and QC in both counting' rooms.
It was verified , that the radioanalytical counting instruments fiad been <:alibrated in ' accordance with approved procedures and an instrument QC program had been implemented.
The licensee was using QC charts to trend QC data and instrument performance.- Radiological confirmatory measurements were performed on a standard.and .. split. samples by.the licensee and the inspectors in the Region IV mobile " . laboratory onsite.
The standard and samples were analyzed by.the licensee using routine methods and equipment.
The radiological confirmatory measurements included analyses performed in the radiochemistry and HP ' counting rooms.
This involved comparison of analytical results-from four- . detectors.
The licensee's radiological confirmatory measurements results . l for the radiochemistry counting room indicated 99 percent agreement and for the HP-counting room showed 100 percent agreement with the NRC H> analyses results.
These results were consistent with the radiochemistry 98 percent agreement and the HP 100 percent agreement during the previous NRC radiological confirs.atory measurements inspection conducted in September 1989.
The results of the measurements comparisons are summarized in Attachments 2, 5, and 6 to this report.
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No violations or deviations were identified.
7.
Exit Meeting The inspectors met with the resident inspector and the licensee representatives identified in paragraph 1 of this report at the conclusion i F of the inspectien on July 27, 1990.
The inspectors summarized the scope < and findings of the inspection and the results of the water chemistry and , . . . . .. . . .. .
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~ radiochemistry corifirmatory_ measurements as' presented.-in tHs reports The ~ ' licensee'did not identify _ as proprietary any of the materials provided to, - . _ or reviewed by, the inspectors during.the inspections ~ ~ , , 1.
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, .. . , f l', ' ' ' ATTACHMENT 1 - , " ' iJ Comanche' Peak Steam Electric Station i ir i ! ]3 NRC' Inspection Report 50-445/90-29r 50-446/90-29 ' Documents Reviewed lp . ,
Y Procedure- .. Revision Date.
H .
~ No.
Title ? . . . . . --lU 1.
- Station Administration-(STA) Manual
_ STA-101-Nuclear Operat_ ions Organization
04/20/90:
" STA-105 Nuclear Training Department
07/14/89! Administration
g ' STA-1061 ' Nuclear Training Records
07/14/89 ~ STA-108: Professional Staff Training and.
0-06/08/90
Development Program ' . .STA-110 CPSES Training Representative
, 02/23/90. j Qualifications and Responsibilities STA-609 . Reactor Coolant-Water Chemistry Control
12/22/89 Program-L STA-610 ' Secondary Water Chemistry ControliProgram '4 12/01/89 - , Yi 2.. Training Manual-(TRA)
- TRA-303-Chemistry Training Program
02/09/90 ' a 3.
Chemistry / Radiochemistry Manual-(CHM)" < LCHM-101 Chemistry / Radiochemistry Administrative
11/14/89 Control , ! . CHM-104 Chemistry / Radiochemistry Quality -Control
08/11/88 Program , LCHM-107 Laboratory Shfety Program
03/15/88 < ' . CHM-501 Chemistry Control of the Steam Generators 4 07/10/90 ' , CHM-503 Chemistry Control of the Condensate and
03/28/90 Feedwater System . .. - . ) m - ^
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Y' . Procedure ' FE - No.
Title-Revision .Datei , % Y I', , CHM-505 Chemistry Control' of the Secondary 4- .12/18/89-Support' Systems- . CHM-506? Chemistry Control of the Primary System
05/11/90 '
'4.
. Chemistry / Radiochemistry Instruction (CLI)-Manual
CLI-100 . Operation and Calibration of the Atomic-
07/10/89l - Absorption Spectrometer Model 560' CLI-101-Determination'of, Metals.Using the
07/10/89 , ,560 A.A; ~CLI-150 zOperation and Calibration of the UV-VIS
05/01/89 ? '
- Spectrophotometer
CLI-154' Determination of Hydrazine-
L05/01/89 j - CLI-156 Determination of Soluable Silica
05/01/89
.CLI-180 . Operation ard Calibration of the Flame
07/09/87 ( Photometer r q -
- C LI-181'-
Determination of Lithium-2 07/11/86 < - CLI-182-Determination of Sodium-
'07/i1/86.
' CLI-250 Operation and Calibration of the 4-12/21/89 '! Dionex 2010i Ion Chromatograph.- d , - CLI-251 Determination of Trace Ions by Ion;
12/21/89-d ' Chromatography ] -CLI-300 Operation / Calibration of the Autotitrator' 3-03/22/90
1 CLI-338 ' . Determination-cf Boron (Autotitrator)
01/15/90 .l , . l CLI-339 Determination of Boron Using Mettler . 01/11/90
DL 25 Titrator j 'CLIh700 Operation and Calibration of Liquid
04/07/87 ' Scintillation Counter 'l CLI-702 Liquid Scintillation Counter. Program
04/18/90 ' Generation CLI-705 Determination of Tritium in Water
11/14/89 Samples - Liquid Scintillation Counter n i . . . .. I
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L Title '
- Revision
.Date.
] ' 1m ( , ~ , .. .,. s f.' CLle760; Operation and Calibration of the Gamma-5.
/12/08/892 '
, 3! -Spectrometer r . .. J CLI-770-Gamma-Analysis of Water 3-06/05/89;
, , , ~5.-- -Quality Assurance'(QA) Surveillances and Audits: e
QA Surveillance (QAS)-90-414,'" Primary Chemistry Activities,": performed February 5-8, 1990: .'
, QAS-90-451; " Unit-1 Initial Startup Activities," performed March 5-11,- . 1990.
r . QAS-90-454,'" Unit-1 Initial Startup Activities," performed March 12-18,- -1990' y.
QAS-90-457, " Unit-1= Initial LStartup Activities," performed March 19-25, [ - 1990 ! ' - t QAS-90-486,D" Unit-1.. Initial Startup Activities;" performed May/ 7-13, < 1990.
L.QAS-90-490, Chemistry Laboratory and Administrative Control Evaluation," ! parformed May 8-14, 1990- ~~ ,s ' QA Audit Report: f QAA-89-27A, " Operations Chemistry," performed - ', ' . August 16-23, 1989 Operations Quality. Assessment' Team - Chemistry, performed November 15-23,
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, - Analvtical Measurements- . >
4 _g' Comanche Peak Steam Electric Station p wl II NRC ~ Inspecti on : Report : 50-445/90-29; 50-446/90-29 ' , , Ir ' '
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Water Chemistry-Confirmatory = Measurements-i , s During the inspecti on, standard chemi cal soluti ons-were provi ded.to6 r
- the linensee forLanalysis.
.The standard solutions were prepared by-
Jth& Drookhaven National. Laboratory (BNL),-Safety and Environmental .i i - Protec ti on Di vi si on, - f or the.NRC.
The standards-were analyzed by the-J licensee using routine methods and equipment.
The analysis of- 'chemi c al standards is used. to verif y the licensee's capability to monitor chemi cal parameters in.various ' pl ant -systems wi th respect Lto: Technical Specification. (TS) requirements and other. industry l ' standards.- 'In addition, the anal yses of standards areoused to evaluate the licensee's analytical procedures with respect to accuracy / anc g-ecision.
'The results ofethe measurements comparisons are listedcin Attachment 3.
Attachment.4 describes the criteria used to compare the resul ts.
i '! All standards were. analyzed in triplicate at three concentrations spread over the licensee's normal-calibration range.
, t The licensee's; original an al yti c al results indicated problems with-the analyses for ammonia.
The original results showed 24 of the 25.
l results.were in agreement using-the criteria presented in Att'achment 4.
The licensee's original ammonia low range concentration result was in disagreement and biased high.
The licensee prepared:new P ammoni a calibration standards and recalibrated the spectrometer.
-The licensee prepared a new dilution of BNL standard-88M and , reran the ammonia anal ysi s.
The retest result for the ammonia low range concentration was.in agreement.
The licensee's final analytical results, after the. retests to resolve .the original disagreement, indicated 100 percent agreement with the BNL results based.on 25 results compared.
The. licensee's chemistry section performance in the area of non-r ad i ol og i c al water chemi st r y confirmatory measurements showea an improvement over the 89 percent agreement achieved during the last NRC inspection of this area in September 1999.
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.i 2) Radiol oaical Confirmatorv Measurements f f m The radiochemistry confirmatory measurements.were performed on the - f ollowing standard and samples in the NRC Region IV mobile l'aboratory at Comanche Peak Steam' Electric St ation during the inspection.
( l') NRC Scott Charcoal Cartridge Standard (34120-109) (2) Unit-1 Waste Li qui d' Sampl e (1 _ iter Marinelli Beuker) -(3) Unit-1 Containment Atmosphere Sample (1 L Gas Marinelli Beaker) j (4) Uni t-1 RCS Li quid Sampl e.(20ml Scintillation Vial) , ' -(5) Unit-1 RCS Gas Sampl e (15cc Gas Serum Vi al) (6) Unit-1 RCS Crud Sample (Particulate Filter) (7) Unit-1 Reactor Coolant' System Tri tium Sample ..The radiological confirmatory measurement tests consisted' of comparing the analysis resulto of the licensee and the NRC Region IV mobile laboratory.
The NRC's mobile l aboratory measurements are ref erenced tcr the National Institute of Standards and Technology by laboratory i nt er c omp ar i son s. - Confirmatory measurements are made only for those . nuclides Identified by the NRC:as being present in concentrations I greater than 10 percent of ~ the respecti ve i sotopi c' values f or liquid and gas concentrations as. stated in 10 CFR Part 20, : Appendix B.
Table II.
.The llcensee. maintains four high-purity germanium detectors in the radiochemistry counting room and one high-purity germanium detector in the health physics counting room for a total o-f five detectors.
One of the radiochemistry counting room detectors was out of service at the time of the inspection.
These detectors are used routinely for
isotopic anal ysi s of radioactive samples to demonstrate compliance L with TS and regulatory requirements.
The analytical results from the four detectors i n' servi ce duri ng the inspection were compared with the NRC results.
The detectors-labeled (2), (3), and (4) are located and maintained in the radiochemistry counting room and are primarily used for isotopic analysis of reactor cool ant system samples and radioactive waste samples.
The detector located and maintained in the ealth physics counting room is primarily used f or isotopic analysis building atmosphere.
The respective analytical results are
orted for each detector.
The licensee performed the reactor ,olant system tritium analysis on their liquid scintillation counting vstem in the radiochemistry counting room.
The individual sample 1alyses and comparison of analytical results of the radiological .onfirmatory measurements are tabulated in Attachment 5.
Attachment 6 describes the criteria used to compare the analytical results.
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,, . , The li censeet s radi ochemi stry secti on gamma i sotopi c1 resul ts from the . samples listed-in Attachment 5-showed 98 percent agreement with the ,NRC analysis results based on 105 agreement results out of 107 total results compared.. The licensee's tritium result of the reactor , - cool ant sampl e was in agreement wi th the NRC analysis resul t.
The E ' ' -licensee's radiochemistry section performance in the. area of-
- r adi ol ogi c al confirmatory measurements demonstrated the same high
- quality of performance of 98 percent agreement achieved during the 7last NRC ' inspection of this area in September'1989.
The licensee's health physics section gemma isotopic results f rom the ' samples listed-in Attachment 5 showed 93 percent agreement with the , NRC analysis results based on 27 agreement results out of 29 total-results compared.. The licensee's health physics section perf ormance in the area of radiological confirmatory measurements showed a consi st en t performance with the 100 percent agreement achieved during the last NRC inspection of this area in September 1989.
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' i .t h: ATTACHMENT,1 ! t.jp Water Chemistry Confirmatory Measurements Results , .,, ' Comanche Peak Steam Electric Station j < NRC Inspection _ Report:' 50-445/90-29; 50-446/90-29 ! i 1.
Chl ori de - Anal _vsi s (1-50 ppb) Ion Chromatography
CPSES Results NRC Results Comparison Sample (pob) (pob) Decision j i BBA 14.0 15.0 Agreement [ 888 29.6 31.0 Agreement.
! BBC 45.6 47.5 Agreement 2.
Fl uoride Anal ysi s (1-20 ppb) Ion Chromatography y ! 't CPSES Results NRC Results Comparison ' Sample (oob) (pob) Decision ( BBA 4.3 4.8 Agreement l 888 10.7 9.6 ~ Agreement 88C 15.0 14.8 Agreement
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Sul f ate Anal ysis (1-50. ppb) Ian Chromatography- '-[ ' ' L CPSES Results NRC Results Comparison j l' .Samole (oob) ( p o b _)_ _ Deci si on ! 88A 9.7 9.5 Agreement l .888 20.0 ,19.0 Agreement BBC 31.3 30.0 Agreement i 4., Baron Analysis (10-3500 ppm) Manitol Titration CPSES Results NRC Results Comparison , - Sampl e. ( o p -n ) (com) Decision 88D 101.0 103.0 Agreement BBE 298.6 299.0 Agreement 88F 512.3 510.0 Agreement BBE 3000.0 2990.0 Agreement ! ! -.. . .. . .
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, 6tTACHMENT 3
i ' - 5, Li thium Analysis (0.1-?.O ppm). Flame Atomic Absorp ti on
't CPSES Results NRC Results Comparison Bampl e - (ppmL (ppmL Deci si on 88J 1.93 1.98 Agreement [ ! DBK 1.00 0.90 Agreement BOL 0.70 0.66 Agreement-6.
Ammonia Analvnin (100-1000 ppb) Spectroscopy CPSES Results NRC Results Comparison Samoln (oob) (pph.L Deci si on OBM 120.0 102.0 Disagreement BBN 316.6 310.A Agreement 800 S20.0 500.0 Agreement ! Retest - prepared new DNL standard dilution, prepared new ammonia
calibration standards, performed new instrument calibration, and performed retest analysis , ODM 130.0 136.0 Agreement 7.
Hydr a r i nen Ann!vsis (1-2500 ppb) Spectroscopy CPSES Ret NRC Results Comparinon Sample (nob) 1DEkl.
Epcision OBP 110.0 102.0 Aar aemtn 800 85.0 04.6 Cqreement BOR 333.0 330.0 ngreement O.
Silica Analysis (S-1000 ppb) Spectroscopy ClaES Results NRC Results Comparison _pob) Decision ( Egmole (opb) l 87G 49.6 S2.0 Agreement .87T tOO.O 104.0 Agreement 87U 303.0 314.0 Agreement
he i , . , .. > . e . ATTACHMENT 4
! ' CRITERIA FOR COMPARINO WATER CHEMISTRY ANALYTICAL MEASUREMENTS The f ollowing are the criteria used in comparing the results of the capability tests and verification measurements.
The criteria for the judgement limits are based on the data from Table 2.1 of NUREG/CR-5244, " Evaluation of Non-Radi ol ogi cal Water Chemistry at Power Reactors."
Licensee values within the plus or minus two
stadnard' deviations range of the BNL 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 DNL knonn values are considered to be in qualified agreement.
Retest results which are in qualified agreement will receive additional attention.
Licensee values greater than the plus or minus three standard deviations l range Of the BNL known values are in disagreement.
The standard [ deviations were computed using the average percent standard l deviation values of each analyte in Table 2.1.
i The ranges for the data in Attachment 3 are as f ollows: Agreement Qualified Areement , Ampute Analvte Ranne Ranoe , OOA F 4.2 - S.4 4.0 - S.6 C1 14.0 - 16.0 13.5 - 16.3 G0 8.5 - 10.5 8.0 - 11.0
l 888 F B.4 - 10.2 0.0 - 11.2 ' C1 28.5 - 33.5 27.5 - 34.5 SO 17.0 - 21.0 16.5 - 21.5 l
88C F 13.0 - 16.6 12.2 - 17.4
C1 44.0 - 51.0 42.5 - 52.5
27.0 - 33.0 26.0 - 34.0
t I BOD
100 - 105 99.7 - 106 88E D 293 - 305 289 - 308 88F
499 - 521 494 - 526 l BBE D 2926 - 3054 2894 - 3086 l 88J Li 1.70 - 2.26 1.57 - 2.39 dBK Li O.84 - 1.11 0.77 - 1.19 BBL Li O.57 - 0.75 0.52 - 0.80 l t ! -. - ?
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Agreement Qualified Areement Amoule Analvte Ranoe Ranoe BBM NH 92 - 112 87 - 117
BBN NH 200 - 340 265 - 355
000 NH 452 - 548 428 - 572
BBP NH
110 90 - 114 -
000 NH 70.0 - 91.2 74.8 - 94.4
BOR NH 311 - 364 298 - 377
87S SiO 47.0 - 57.0 45.4 - 60.2
07T SiO 94.5 - 113 89.4 - 110.2
87U SiO 284 '- 343 269 - 359
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ATTACHMENT S ' Radi ol oni cal Confirmatory Measuresment Results i ,. Comanche Peak Steam Electric Station ! l NRC Inspection Reports 50-445/90-293 50-446/90-29 ! s
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NFC Scott Charcoal Cartridae Standard (34120-109) CPO22A (Standardized: 11:00, CST, January 1, 1990) L i Standard was analyzed by radiochemistry on detectors (2), (3), and (4) ' and by health-physics. The results of the analyses are reported for each detector in the above stated arder.
CPSES Results NRC Results CPSES/NRC Comparison Nuclide (uCi/ sample) (uCi /sampl e) Eatto tecisign . Hg-203 7.28tO.73E-2 9.6410.30E-2 0.76 Agreement l 6.87tO.84E-2 0.71 Disagreement 6.9710.87E-2 0.72 Disagreemont 7.02io.58E-2 0.81 Agreement, ' Co-60 0.9310.03E-1 1.02to.01E-1 0.91 Agreement } ' O.9410.04E-1 0.92 Agreement O.90iO.04E-1 0.00 Agreement 0.92iO.03E-1 0.90 Agreement , Cd-109 1.22io.07E40 1.3110.01E+0 0.93 Agreement 1.2410.09E+0 0.95 Agreement 1.1SiO.11E40 0.00 Agreement 1.09tO.07E+0 0.03 Agreement .i ! Co-57 2.92io.16E-2 3.5610.03E-2 0.02 Agreement-3.OSiO.20E-2 0.06 Agreement 3.07iO.27E-2 0.06 Agreement i 2.7310.11E-2 0.77 Disagreement ( Ce-139 4.2610.35E-2 4.7910.04E-2 0.09 Agreement 4.32iO.41E-2 0.90 Agreement
4.2310.41E-2 0.08 Agreement i 3.77iO.31E-2 0.79 Disagreement f Sn-113 0.95to.OSE-1 1.OOtO.01E-1 0.95 Agreement 0.95iO.06E-1 0.95 Agreement 0.9310.06E-1 0.93 Agreement 0.BSiO.04E-1 0.85 Agreement , k
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ATTACHMENT S
l CPSES Results NRC Results CPSES/NRC-Comparison , Nuclide (uC1/ samp l e) (uCi/ sample) Patto Decision Cs-137 0.32io.48E-2 9.0610.04E-2 0.92 Agreement 8.6710.60E-2' O.96 Agreement 8.22io.57E-2 0.91 Agreement-0.OSiO.47E-2 0.09 Agreement-Y-00 1.5910.06E-1 1.7410.01E-1 0.91 Agreement 1.6210.08E-1 0.93 Agreement 1.5410.07E-1 0.06 Agreement 1.SSiO.06E-1 0.89 Agreement 2.
Unit-1 Waste Liould Samnle (1 Liter Marine *11 Beaker) CPO19A-(Sampled: 9:32, CDT, July 23, 1990) Sample was analyzed by radiochemistry on detectors (3) and (4) and by hea.th physics.
The results of the analyses are reported for each detector in the above stated order.
CPSES Results NRC Results CPSES/NRC Comparison Nuclida IpC1/ml) (uCi/ml) Ratio Decision Na-24 S.7111.27E-7 7.92io.49E-7 0.72 Agreement 6.2911.44E-7 0.79 Agreement '6.OSiO.91E-7 0.76 Agreement Mn-54' 2.4110.66E-7 1.96tO.23E-7 1.23 Agreement 2.07tO.66E-7 1.06 Agreement 1.9610.30E-7 1.00 Agreement Co-SO 1.75io.19E-6 1.60iO.06E-6 1.09 Agreement , ! 1.0410.21E-6 1.15 Agreement 1.89tO.12E-6 1.10 Agreement l Tc-99m 2.SSiO.44E-7 3.14tO.27E-7 0.01 Agreement 2.6710.SSE-7 0.85 Agreement p 2.8710.32E-7 0.91 Agreement L I-131 S.SS10.79E-7 S.OSiO.37E-7 0.9S Agreement ~ S.1910.86E-7 0.09 Agreement 6.3710.62E-7 1.09 Agreement 1-133 1.2110.15E-6 1.0310.OSE-6 1.17 Agreement: 0.99iO.14E-6 1.00 Agreement E 1.17tO.11E-6 1.18 Agreement
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Unit-1 Containment Atmosobere SamDie (1 L Gas Marinelli Beaker) CPO21A ! (Sampled: 15:09, CDT, July 24, 1990) I Sample was analyzed by radiochemistry detectors (3) and (4) and by health physics.
The results of the analyses are reported for each detector in the above stated order.
, CPSES Results NRC Results CPSES/NRC Comparison
Nuclide (uCi/ sample) (uti/samole) Epti o pecision l t Ar-41 5.7411.31E-4 S.0510.54E-4 0.98 Agreement
4.5711.27E-4 0.78 Agreement 5.20il.29E-4 0.09 Agreement
t Xe-133m 6.68tl.75E-4 9.7610.99E-4 0.68 Agreement 7.8912.10E-4 0.01 Agreement 0.7111.49E-4 0.09 Agreement Xe-133 1.2410.09E-1 1.2210.01E-1 1.02 Agreement 0.99tO.14E-1 0.81 Agreement t 1.0410.06E-1 0.05 Agreement Xe-135 No Result (1) 4.2811.10E-3 No Comparison
No Result (1) No Comparison
4.10il.23E-5 0.98 Agreement-(1) Isotope had decayed to below the lower limit of detection prior to anal ysis, t i
Unit-1 RCS Linuid Sample (Sml in 20ml Scintillation Vial) CPO170 (Sampled: 9:10, CDT, July 25, 1990) Sample was analyzed by radiochemistry on detectors (3), (4), and (2).
The results of the analyses are reported for each detector in the l above stated order.
CPSES Results NRC Results CPSES/NRC Comparison Nuclide (uCi/ml) (uCi/ml) Ratio Decision Na-24 1.2510.10E-3 1.22iO.03E-3 1.02 Agreement 1.2610.11E-3 1.03 Agreement l 1.20iO.10E-3 0.98 Agreement Co-58 2.40io.37E-4 1.96tO.19E-4 1.27 Agreement 1.90iO.31E-4 0.97 Agreement 2.2310.31E-4 1.14 Agreement
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[ CPSES Results NRC Results CPSES/NRC Comparison o =Mgelide (uCl/ml) (uCi/ml) Re.t i o Decision ' -' I-131 2.5410.5BE-4 2.2410.30E-4 1.13 Agreement 2.32iO.4BE-4 1.04 Agreement 2.2310.53E-4 1.00 Agreement 1-132 4.1010.15E-3 3.50iO.09E-3 1.15 Agreement 4.1610.17E-3 1.16 Agreement 3.78to.15E-3 1.0L Agreement I-133 1.9610.15E-3 1.7210.03E-3 1.14 Agreement 2.0110.15E-3 1.17 Agreement 1.8510.14E-3 1.08 Agreement I-134 6.2610.22E-3 6.22 0.40E-3 1.01 Agreement 6.32io.33E-3 1.02 Agreement 5.94to.22E-3 0.95 Agreement I-135 3.22iO.13E-3 3.32iO.11E-3 0.97 Agreement 3.62iO.14E-3 1.09 Agreevent 3.4110.13E-3 1.03 Agreement W-187 1.3110.12E-3 1.4810.15E-3 0.09 Agreement E 1.2710.11E-3 0.86 Agreement 1.2110.11E-3 0.82 Agreement Cs-138 7.1310.30E-3 7.0911.12E-3 1.01 Agreement 6.48io.66E-3 0.91 Agreement 6.6010.30E-3 0.93 (4greement 5.
Unit-1 RCS Gas Sample (2.0cc in 15cc Gas Vial) CPO18A ! (Sampled: 15:43, CDT, July 23, 1990) i l Sample was analyzed by radiochemistry on detectors (3) and (4).
I The results of the analyses are reported f or each detector in the above stated order.
' CPSES Results NRC Results CPSEG/NRC Comparison Nuclide (uCi/cc) (uCl/cc) Batic Deci si on u $ Kr-85m 2.92iO.19E-3 2.7810.06E-3 1.05 Agreement 3.08tO.21E-3 1.11 Agreement Kr-87 2.95iO.30E-3 2.72do.19E-3 1.00 Agreement 2.80iO.27E-3 1.03 Agreement Kr-80 4.5710.42E-3 4.1310.16E-3 1.11 Agreement 4.60iO.43E-3 1.11 Agreement ! i
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ATTACHMENT ji
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CPSES Results NRC Results CPSES/NRC Comparison Nitclide f uCi /ec) IgGj/cc) Ra t t o, Deci si on Xe-133 1.1910.OBE+O 1.0210.01E+0 1.17 Agreement 1.0710.16E+0 1.05 Agreement Xe-133m 1.7310.17E-2 1.6610.03E-2 1.04 Agreement 1.6910.17E-2 1.02 Agreement Xe-135 0.0510.74E-3 8.4910.07E-3 1.04 Agreement 0.3410.73E-3 0.98 Agreement 6.
Unit-1 RCS Crud Sample (Partisylate Filter) CPO20Q (Sampled: 11:42, CDT, July 24, 1990) Sample was analyzed by radiochemistry detectors (3) and (4) and by health physics.
The results of the analyses are reported for each detector in the above stated order.
CPSES Results NRC Results CPSES/NRC Comparison Nuclide (uti/ sample) (uCi/nample) Ratio Deci si on Be-7 1.1110.15E-1 1.3710.09E-1 0.01 Agreement 1.1810.16E-1 0.06 Agreement-0.99 0.13E-1 0.72 Agreement Cr-51 2.6510.23E-1 2.3910.06E-1 1.11 Agreement 2.63tO.21E-1 1.10 Agreement 2.5610.20E-1 1.07 Agreement Mn-54 4.1411.21E-3 4.61dO.39E-3 0.90 Agreement 5.1111.11E-3 1.11 Agreement 3.6410.73E-3 0.79 Agreement Co-50 2.75tO.16E-1 2.5110.01E-1 1.10 Agreement 2.6910.15E-1 1.07 Agreement 2.7110.14E-1 1.00 Agreement Zr-95 6.2410.38E-2 5.78to.12E-2 1.08 Agreement 6.2710.35E-2 1.08 Ap eement 6.26tO.32E-2 1.08 Agreement j Sb-122 E.65tl.07E-3 3.7510.77E-3 0.71 Agreement 3.8611- '3E-3 1.03 Agreement No Hesult (1) No Comparison
.W-187 2.60iO.34E-2 2.5310.20E-2 1.03 Agreement 2.8910.37E-2 1.14 Agreement 2.15tO.50E-2 0.85 Agreement . _ _
_ _ - ._ b pa.4 '.' - o j ', e . ' o- .1. ATTACHMENT 5
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! iI CPSEE Results NRC Results CPSES/NRC Comparison t Nuclide (uCl/samole) (uci /sampl e) Ratio Deci si on % Nb-95 2.90io.25E-2 2.5410.06E-2 1.11 Agreement 2.9210.23E-2 1.11 Agreement 2.70iO.20E-2 1.06 Agreement ' , S Zr-97 2.9510.18E-1 2.5810.02E-1 1.14 Agreement i, 2.BodO.14E-1 1.08 Agreement t
2.72io.13E-1 1.05 Agreement' .Tc-99m 4.62iO.90E-3 4.6610.60E-3 0.99 Agreement u 5.20il.02E-3 1.11 Agreement 4.45tO.40E-3 0.95 Agreement , Ba-139 5.5510.54E-1 4.6SiO.17E-1 1.19 Agreement 5.26tO.42E-1 1.13 Agreement 5.24tO.67E-1 1.13 Agreement Cc-144 2.1610.54E-2 1.0910.27E-2 1.14 Agreement ' 2.27tO.56E-2 1.20-Agreement No Result (1) No Comparison
Np-239 2.5910.25E-2 2.0710.20E-2 0.90 Agreement 2.06tO.24E-2 1.00 Agreement 2,40to.10E-2 0.04 Agreement , (1) Isotope was not included in the health physics isotope library at the time of analysis.
7.
Unit-1 RCS Tritium Sample (2.Om1 in 20ml Scintillation Vial) y (Sampled: 15:45, CDT, July 23, 1990) CPSES Results NRC Results CPSES/NRC Compar2 son Nuclide (uCi/ml) (uCl/ml) Ratio Decision H-3 1.7110.01E-1 1.9610.02E-1 0.87 Agreement ! !- >
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a y'*e , , . ' e h ATTACHMENT 6 CRITERIA <FOR COMPARING RADIDCHEMISTRY ANALYTICAL MEASUREMENTS
The following are the criteria used in comparing the results of capability tests and verification measurements.
The criteria are based on an empirical relationship established through prior experience and this program's analytical requirements.
. 1 In these criteria, the judgement limits vary in relation to the comparison of the resolution.
NRC VALUE
- 0 Resolution a
i NRC UNCERTAINTY 'l LICENSEE VALUE l Ratio
___ i NRC VALUE Comparisons are made by first determining the resolution and then rer. ding acrocs the same line to the corresponding ratio.
The following table shows the acceptance values.
! - ), RESOLUTION AGREEMENT RATIO _ _ <4 0.40 - 2.50 4 -7 0.50 - 2.00 ! B-15 0.60 - 1.66 16 - SO O.75 - 1.33 51 - 200 0.00 - 1.25 >200 0.05 - 1.10 j ! __ _ ! The above criteria are anplied to the following analyses: I (1) Gamma Spectrometry (2) Tritium in liquid samples (3) Iodine on adsorbers O
(4) Sr and Sr determinati ons (5) Gross Beta where samples are counted on the same date using the same reference nuclide.
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