IR 05000454/1986032

Insp Repts 50-454/86-32 & 50-455/86-28 on 860902-05,09 & 11. No Violation or Deviation Noted.Major Areas Inspected:Plant Chemistry & Radiochemistry,Including Mgt Controls & Organization & Readiness for Operation

ML20211A284
Person / Time
Site:	Byron
Issue date:	10/01/1986
From:	Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211A261	List: IR 05000454/1986032 ML20211A256
References
50-454-86-32, 50-455-86-28, NUDOCS 8610150060
Download: ML20211A284 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/86032(DRSS); 50-455/86028(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Byron Nuclear Generating Station, Units 1 and 2

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Facility Name:

Inspection At: Byron Site, Byron, IL Inspection Conducted: September 2-5, 1986 Telephone discussion, September 9 and 11, 1986 Inspectors: R . /0///d Date!

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Y M. C. Schumacher, Chief

@ Ho Radiological Effluents and Date Chemistry Section M. C. Schumacher, Chief (,

Approved By:

Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on September 2-5, 9, and 11, 1986 (Reports No. 50-454/86032(DRSS);

50-456/86028(DRSS))

Areas Inspected: Routine unannounced inspection of plant chemistry and radiochemistry, including management controls and organization, chemistry staffing, water chemistry quality control programs, facilities and equipment, quality assurance / quality control of analytical measurements, chemical

. processes and practices of controlling chemical impurities, with emphasis on readiness for operation of Unit Results: No violations or deviations were identified during this inspectio PDR ADOCK 050004S4 G PDR

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DETAILS, 1. Persons Contacted 1,2R. E. Querio, Byron Station Manager, CECO R. Tuetken, 5tartup Superintendent, CECO R. Pleniewicz, Production Superintendent, CECO W. Burkamper, Quality Assurance (QA) Supervisor (Operations), CEC 0 R. A. Flahive, Rad-Chem Supervisor, CECO 1,3D. Herrmann, Station Chemist, CECO E. E. Falb, U-2 Testing Supervisor, CECO A. J. Chernick, Regulatory Assurance Supervisor, CECO W. P. Dijstelbergen, PED-On-Site, Ceco A. D. Britton, QA Inspector, Ceco J. B. Snyder, QA Inspector, CECO K. E. Yates, Nuclear Safety, Ceco Z. Luke, U-2 Startup Test Engineer (STE), Ceco E. M. Zittle, Regulatory Assurance Staff, CECO J. Langan, Licensing-Compliance, Ceco K. Lurkins, Chemist, CECO W. Scheffler, Chemist-Group Coordinator, Ceco R. Boyer, Chemistry Staff, CECO W. McNeill, Rad-Chem Technician (RCT), CECO J. Dickinson, Rad-Chem Technician (RCT), CECO G. Vickery, Chemist, CECO B. Raeburn, Chemist, CECO T. McPharlan, STE, CECO F. Doty, STE L. Wolfenden, STE S. Dawson, STE D. Johnson, STE D. May, Rad-Chem Training Coordinator, CECO 1J. M. Hinds, Jr. , Senior Resident Inspector, NRC 1J. A. Malloy, Resident Inspector, NRC l iW. D. Shafer, Region III, NRC The inspectors also interviewed other plant personnel during the course of the inspectio Denotes those present at the exit intervie Telephone discussion held on September 9, 198 aTelephone discussion held on September 11, 198 . Licensee Actions on Previous Inspection Findings (0 pen) Open Item (50-454/86011-01; 50-455/86009-01):

Analyze liquid for gross beta, H-3, Sr-89 and Sr-90 and report results to Region III. The licensee analyzed a split of a release tank sampl The results of the analyses from the NRC Reference Laboratory, the Radiological Environmental Sciences Laboratory, Idaho Falls, Idaho, and those from the licensee are given Table 1

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_ along with the comparison criteria in Attachment 1._ An agreement was

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obtained for H-3 ard a disagreement in the gross beta compariso . Because of the low concentrations and the large statistical uncertainties of Sr-89 and Sr-90,.these nuclides were not compared and'not shown. The disagreement in the gross beta values appears to be due to different treatment of the. samples by the. licensee and the NRC; the latter added a filter aid (a powdered filter paper) to provide a large surface area for nuclide adsorption, while the licensee did not process the sample until just prior to analysis several weeks later. Similar activities were obtained both by the

- licensee and licensee contractor., A subsequent check by the licensee indicated that a substantial fraction of such a sample plated out in the bottle surfaces. The 1.icensee agreed to prepare future comparison samples for counting shortly after collection, but delay the counting until it can be done simultaneously with RESL. The licensee also agreed to analyze for Sr-89 and Sr-90 in a spiked sample to be sent from RES (0 pen) Open Item (50-454/86011-02; 50-455/86009-02): Review E-Bar input value in Appendix A3 of Procedure No. BCP-230-3 and change as

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appropriate. The licensee reviewed and recalculated the E-Bar values that differed from the NRC values. The results obtained were

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essentially identical to those of the _NRC, except for those of Cs-137 which appeared to have an error in the recalculation of the gamma-ray energy and the Ba-140 for which the licensee value appeared to. include more photon emissions than did the NRC value. This item will remain open until these differences are reconciled and the station procedure is appropriately modified.

, (0 pen) Open Item (50-454/86011-03; 50-455/86009-03): Evaluate alpha

counting capabilities on Canberra and document. Because of

! differences between the NRC's and the plant's evaluation of alpha activities on air filter samples, and the'very low efficiencies of the licensee's counters for air particulate filters, the licensee

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evaluated the alpha counting efficiencies using EPA air filter samples with known activities supplied by the NRC in March 1986. It appears that the efficiency values used for water samples, reduced by 10-20%, would be suitable for the air filter efficiencies. The

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licensee agreed'to evaluate the calibrations and to document the conclusion (0 pen) Open Item (455/83039-15): Complete installation of the Sentry High Radiation Sampling System (HRSS) primary coolant sampling

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capability on Unit 2. The inspectors discussed the status of preop

! test PS 2.061.60 for the Primary Sampling System (PSS) with the cognizant test engineer. This system is designed for both routine

and post accident sampling. System testing-was completed with three

exceptions: sampling from the Auxiliary Building Floor Drain Tank

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(ABFDT), sampling from the Auxiliary Building Equipment Drain Tank (ABEDT), and accident condition sampling from the Radwaste Module of i

the PSS.

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I ABFDT sampling was not demonstrated owing'to a design problem which i

. prevented a sample from being drawn from the two inch tank 2 . recirculation line. A design change to install a throttling valve to create back pressure sufficient to draw a sample will be.

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propose Pump. problems, since repaired, prevented sampling from

.the.ABED Accident condition sampling from the rad waste module was'to be demonstrated with a sample from the ABFDT, but was-

-postponed owing to the problem noted there. These tests which are i- being tracked by deficiency reports, are expected to be completed well before fuel load.

E Sample flow rates in the Demineralizer Module were observed in hot

functional testing to be less than predicted owing to the use of a sampling system design pressure higher than actually present at the CVCS demineralizers being sample An Action Item Record I recommending use of increased flushing times in chemistry sampling

procedures is expected to compensate for this design proble A separate Chemistry Analysis' Panel (CAP)' consisting of_in-line monitors for various non-radiological variable such as conductivity, dissolved oxygen, chlorides, pH and sodium was eliminated from the

Unit 2 PSS by modification M61-1-85-0644. The Unit 2, lines were-instead rerouted to the installed Unit 1 CAP. This change from the FSAR-described system was documented in a licensee 50.59 review that concluded there was no unreviewed safety question. The modification was completed after preop testing of the system. .Thus, the capability of achieving flow to Unit 1 CAP has not been~

demonstrated.

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At the exit interview, the inspectors expressed concern regarding the

possibility of cross flow between units via the common CAP,

particularly when one unit is at~ system pressure and the'other is i not. Licensee representatives indicated that valves within the ,

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sampling system should prevent such an occurrence,'but no details were discussed.- This was further discussed by telephone with the i plant superintendent on September 9,-1986, who stated that this concern would be further examined by the station. The

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superintendent was also informed that the modification had been discussed with the Licensing Project Manager in NRR who intended to (- review the matter. This item will remain open pending final review i

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of installation and testing of this system which is required for fuel load. Licensee representatives at the exit interviews stated l that installation and testing of the primary sampling system would be completed prior to fuel loa , Management Controls and Organization l The inspectors reviewed the organization and staffing of the

Radiation-Chemistry (R/C) Group. The organizational structure was j unchanged since the previous Report 1, but a new Rad-Chem Supervisor, to

! whom the Station Chemist reports, has been appointed. The Group now has l a Lead Rad-Chem Foreman, five Rad-Chem Foremen, and 39 Rad-Chem Technicians-(RCTs). ,

i 1NRC Region III Reports No. (50-454/86011; 50-455/86009).

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The inspectors reviewed the scheduling of the RCTs in the chemistry i- laboratory. On the day shift, they rotate.between the Radiatio Protection and Chemistry Groups on a 12-week cycle that results in their being in the laboratory about.five weeks and on radiation protection assignments for seven weeks; this absence from the-laboratory is not conducive to maintaining RCT proficiency ~in specialized laboratory

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functions. The licensee representatives acknowledged this long-standing

concern of the inspector No violations or deviations were identifie . Training and Qualifications The inspectors reviewed the status of the training and qualifications of the Foremen and the RCTs. The Foremen are qualified by experience and

training as specified by ANSI N18.1-1971. The RCTs have all completed the tasks for the_ chemistry portion of the classroom and 0JT of the

qualification / certification program. The Rad-Chem Training Coordinator-expected them to complete the few remaining tasks, which relate to i

radiation protection, by the end of September'1986. Since, only nine of the RCTs meet the_ criterion of ANSI N18.1-1971 of three years experience in the field, one of which is training, the licensee has assigned at _

least one ANSI qualified Rad-Cher. Foremen on each shift in accordance with_

a previous commitment 2, l No violations or deviations were identifie . Control of Chemicals

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The inspectors reviewed the licensee's program to restrict and control the use of chemicals throughout the plant to maintain system integrity.

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This program appears to be operating effectively. . Permanently mounted

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signboards showing the five classifications of chemicals and their usage are posted throughout the plant. Plant chemicals used in large quantities .

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such as sulfuric acid, ammonia and hydrazine, are controlled by storage in segregated. locked areas and room No violations or deviations were identified.

. Implementation of the Chemistry and Radiochemistry Programs-

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The inspectors reviewed the chemistry and radiochemistry programs, including the physical . facilities, laboratory operation, counting room practices, and QA/QC practices in the laborator The laboratory space and facilities were adequate as noted-in the

_ previous report . The facilities were well-maintained and the 2NRC Region III Reports-No. 50-454/83-08; 50-455/83-06).

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3NRC Region III Reports No. (50-454/85028; 50-455/85022).

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housekeeping was goo The 1aboratory has acquired and is now usin several instruments including several gas and ion chromatographs, a

. Beckman plasma DCP spectrometer, specific ion probe: instrumentation, total organic carbon analyzers, and automatic titrators for boron; analysis. These instruments are being effectively used-by the RCTs

.with good management oversigh The counting room had good radiological equipment, two ORTEC gamma-ray

. . spectrometers with associated DEC PDP 11/44 computers and four shielded-7_

detectors, three Ge and one Ge (Li);.three Canberra alpha-beta

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proportional counters with automatic sample changers, one of which was a low background system; a Tennelec Model LB 1000 low-background

. alpha-beta proportional counter with automatic. sample changer; an Eberline SAC-4 alpha scintillation counter; and two Packard Tricarb 5 multisample liquid scintillation counter The inspectors observed an RCT collect routine liquid reactor coolant samples from the primary sampling system on the Sentry HRSS panel. The

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RCT told the inspectors that the small waste tank under the sampling panel sink had been backing up and that there would be some contaminated

water inside the panel after flushing the lines. The Chemist in charge of'this system. stated that it was due to a leaking air valve that was pressurizing the system. The valve was in the process of being repaired.

!- The RCT took extra care in wiping the outsides of the bottles that were wetted by this water. The RCT appeared to understand his job and the various problems associated in sampling the RC No violations or deviations were identifie . Quality Assurance and Quality Control in the Laboratory l

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The QC. program for chemistry laboratory instruments consists of monthly performance checks in accordance with Procedure No. BAP 599-51,." Byron i Status Chemistry / Radiochemistry Performance Check Program," dated March 29, 1985. The results are tabulated on data' sheets but are not

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plotted to trend performance and most of the data sheets do not list the

, test acceptance limits. This program is not very useful for day-to-day l_ QC surveillance.

Performance checks with appropriate standard solutions are also made in conjunction with each instrument use. These results could provide the basis for a good QC program. However, the data are entered only on the-individual analysis sheets and are not trend plotted or otherwise

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. organized in a manner that could be useful. The need for improving

' laboratory QC was discussed with chemistry supervision and at the exit L~ interview. The inspectors concerns were acknowledged and it was stated

! that plans for improvements in this area were being developed with completion expected by November 1986.

i i The inspectors reviewed the licensee's program of performance testing of

the RCTs based on BAP 599-50, " Byron Station Chemistry Unknowns Tes Program Description," Revision 1, April 9, 1986, with samples provided

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. by th'e' Analytical Chemistry Group. Coordinator. The tests are required twice yearly'and have been performed four times since 1984 on chloride and fluoride in.the 100-200 ppb range and boron in the 1000-2000' ppm range (ranges required by-Technical Specifications). Limits for fractional > deviations of the results from the known values were set at

. 15% and 20%, warning, and disagreement, respectively, for chloride and fluoride results; and 3 and 6%, as the respective limits for boron,

- analyse The-chloride analysis results have more variability than the others with 16 warnings and.three retests of 28 RCTs in 1984. . Subsequent tests have shown improvement with only one retest _and no warnings observed for 39 RCTs tested in May 1986. In the May 1986 tests the mean fractional deviation (absolute) from the.known values were about_8-10%

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for the. chloride and fluoride tests,'and about 0.7% for the boro ~

While the' licensee's method of tracking individual RCT test results.is adequate, the inspectors pointed out that the overall test variability could be better demonstrated by using the variance or standard deviation

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rather than,the summed fractional deviations which tend to average nea zero regardless of the magnitude of the individual results. Test bias should be assessed by comparing'the test mean with the standard _ values.

These parameters are also more amenable to statistical interpretation The current program is limited, with only three analytical procedures

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being tested. However, it is operating regularly, and licensee representatives indicate their intention to expand its scop In the counting room QC program, instrumental performance checks are made daily and the results tabulated and plotted on control charts. An additional control is provided by the AAIS which removes the counter from service when the results of the check' source are outside the acceptance

, limits of 2 sigma counting statistics based on the expected source valu The inspectors noted that the charts should be better labelled to include the sources used in the checks, the_ significance of the control limit lines, and that it would be useful to keep them in the counting room together with a performance history log for each instrumen Overall, the laboratory and counting room QC programs appear to be improving, but still show some weaknesses. Licensee progress in this area

- will be examined during subsequent inspections (0 pen Item

! 50-454/86032-01; 50-455/86028-01).

No violations or deviations were identifie . Water Sampling, Monitoring and Processing

. Unit 1 Operations

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The. inspectors reviewed Unit 1 water chemistry analysis results and observed sampling and monitoring equipment in the plant. Chemistry _

group supervision maintains generally good awareness of the status

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of system chemistry with extensive use of tables and trending of the

. various parameters. Licensee representatives indicated that they

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had for the most part little difficulty in maintaining system-

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chemistry within administrative guidelines and action level Reactor Coolant System (RCS) conductivity running at 1.2 to, paho/cm (July 1986) was slightly above the corporate guidelines of -

1.0 paho/cm. Efforts to determine the cause of this problem hav not been successfu RCS iodine concentration appears to have stabilized at abo'ut 1.4E-2 pCi/g indicating minor fuel pin leakag Licensee representatives stated that fuel will be sipped during the first refueling outag The licensee is experiencing difficulty maintaining dissolved oxygen

- (00) concentration in the primary water storage tank. Despite

' repair of a vacuum deaerator in the line from the makeu demineralizers, D0 levels are running at about 3 ppm in contrast with the Westinghouse'100 ppb guideline However, this does not appear to affect oxygen levels measured in the RCS hot leg which are within the guidelines. Licensee representatives stated that they are continuing to pursue this proble The licensee has. extensive in-line monitoring on the secondary  ;

system. The steam generator blowdown panel has in-line monitors with recorders for specific and cation conductivity, pH, and sodiu Because of questions about the accuracies of.the sodium monitors their results are used only for trending. In addition, the plant has an'in-line ion chromatograph.for. continuously monitoring of chloride, fluoride, sulfate and ammonia. The secondary sampling panels also have in-line monitoring capabilities for specific cation conductivities, pH, dissolved oxygen, hydrazine, morpholine and turbidit For the Unit 1 panel, the data from all the monitors at r various locations are collected by a Datalogger unit and plotted on one sheet so that the overall conditions can be seen at a glanc The inspectors reviewed the biweekly " standardization," an intercomparison program in which the chemistry group compares readings fo the in-line instruments with the results from grab samples. When the pH values are widely discrepant, e.g., greater than about 0.2 units, the monitor is adjusted to the grab sample value. This comparison is important because a static calibration with buffers done by the Instrument Maintenance Group gives values different from those of the grab samples of the very pure flowing water in the secondary system. Conductivity and sodium readings are only compared with grab sample values, since these instruments are not easily adjuste The inspectors noted that the existing procedure for calibration of

these in-lines instruments does not ensure the coordination of the efforts of both groups (Chemistry and Instrument Maintenance) and that the chemistry group work, which is done by supervisory i personnel, was not covered by a detailed procedure. This topic was discussed at the exit interview where licensee representatives stated that these concerns would be addressed. This will be

, examined during a subsequent inspection (0 pen Item 50-454/86032-02; 50-455/86028-02).

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' Unit 2 Preoperational Testing

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The inspector reviewed the status of preoperational testing of; systems relating to water chemistry with cognizant test engineer Items related to the Primary Sampling System,~ Test PS 2.061.60, are discussed in.Section 2 of this repor _

CVCS demineralizers-(mixed bed, cation bed, and boron thermal regeneration) were tested for flow rates, temperature control; and

- pressure drops during hot functional-testing. The cognizant test engineers stated that the applicable requirements were met. The test, CV 2.018.67, had been field completed but not yet approved.

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A number of Action Item. Records (AIRS) have been written that will require resolution prior to FLOL. The Station Chemist stated that this additional. flushing time was already required by the Unit-1 procedure and would be carried over to the Unit-2 procedur Demineralizer capability _was not tested during hot functional, but

will be tested during the period of low power physics testin Preop Test 2.061.70 on the Secondary Sampling System has been

! completed and reviewed by the Test Review Board (TRB) and the Project Engineering Department (PED) and is now awaiting station acceptance._ One section~of the test involving conductivity.- -

monitoring of water from the condenser trays could not be completed-i during hot functional testing and will be delayed to startup when there is sufficient steam in the condenser. This test, which is not required for fuel load,_will be tracked by the station under AIR 6-86-2083. It will be reviewed during a subsequent inspection

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(0 pen Item 455-86028-02).

Demineralizers for makeup, condensate polishing,.and blowdown are shared between both units and were tested in conjunction with Unit 1 startu Testing.with reference to Unit 2 was to demonstrate

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acceptable flows and pressure drops. These tests have been essentially complete. Performance of these demineralizers is tracked by the licensee as part of the Unit 1 routine chemistry-surveillance program.

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10. 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 Section 7 and .

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1 Exit Interview

, The inspectors reviewed the scope and findings of the inspection with licensee representatives listed in Section 1. The inspectors noted their concerns about the rotation of the RCTs between the Chemistry and Radiation Protection groups and the likely loss of proficiency in the

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laboratory, the need.for improved QA/QC for laboratory instrumentation (tabulation and plotting of performance check results), the need_for ensuring coordination between-Chemistry and IM work on in-line monitors,

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and possible' problems of cross-contamination between reactor coolant systems through the interconnection of the two units through the Chemical Analysis Panel. Additional discussions with licensee representatives were held by telephone on September 9 and 11 to determine the resolution of items discussed during the inspectio During the inspection, the inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. Licensee representatives did not identify any such documents or procedures as proprietar Attachments:

1. Table 1, Confirmatory Measurements Program Results, 1st Quarter 1986 Attachment 1, Criteria for Comparing Analytical Measurements

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1aboratory, the need for improved QA/QC for laboratory instrumentation (tabulation and plotting of performance check results), the need for ensuring coordination between Chemistry and IM work on in-line monitors, and possible problems o# cross-contamination between reactor coolant systems through the interconnection of the two units through the Chemical Analysis Panel. Additional discussions with licensee representatives were held by telephone on September 9 and.11 to determine the resolution of items discussed during the inspectio During the inspection, the inspector discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. Licensee representatives did not identify any such documents or procedures as proprietar Attachments:

1. Table 1, Confirmatory Measurements Program Results, 1st Quarter 1986 Attachment 1, Criteria for Comparing Analytical Measurements l

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s TABLE 2 lQ U S NUCLEAR REGULATORY COMMISSION

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OFFICE.0F INSPECTION AND ENFORCEMENT

CONFIRMATORY MEASUREMENTS PROGRAM FACILITY: BYRON

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FOR THE 1 QUARTER OF-1986

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NRC LICENSEE- LICENSEE:NRC -

SAMPLE . ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T

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L'OASTE G BETA 3.7E-06 1.3E-07 2.2E-06 0.0E-01 6.0E-01 2.8E 01 D H-3 1.9E-03 3.0E-05 1.9E-03 0.0E-01 9.8E-01 6.5E 01 ~ A T. TEST RESULTS:

-A= AGREEMENT

D= DISAGREEMENT

• = CRITERIA" RELAXED N=NO COMPARISON ~

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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS 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 progra In these criteria, the judgment limits are variable in relation to the comparison of the NRC's value to its associated one sigma uncertainty. As that ratio, referred to in this program as " Resolution", increases, the acceptability of a 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 Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement

<4 0.4 - 2.5-4- 7 0.5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 200 - 0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides. These may be factored into the acceptance criteria and identified on the data sheet.

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