IR 05000454/1987013

Insp Repts 50-454/87-13 & 50-455/87-12 on 870303-04 (Onsite) & 870306,09 & 16 (Telcons).No Violations or Deviations Noted.Major Areas Inspected:Chemistry Program,Including QA & Water Qc,Procedures,Training & Organization

ML20204F642
Person / Time
Site:	Byron
Issue date:	03/18/1987
From:	Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204F412	List: IR 05000454/1987013 ML20204F407
References
50-454-87-13, 50-455-87-12, NUDOCS 8703260233
Download: ML20204F642 (6)

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U.'S NUCLEAR REGULATORY COMISSION REGION III-

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Reports'N /87013(DRSS);50-455/87012(DRSS)

Docket No ; 50-455 License Nos. NPF-37; NPF-66 Licensee: Commonwealth Edison Company Post Office Box 767

Chicago,;IL 60690 Facility Name: Byron Generating Station, Units 1 and 2 Inspection At: Byron Site, Byron, Illinois-

-Inspection Conducted: March 3-4,~1987 (On-site) .

March 6, 9, and 16, 1987 (Telephone conversations)

Inspector: RB o z n 3/Af/87 yter

&,ihyul/u Approved By: M. C. Schumacher, Chief 7

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Radiological Effluents and Date

' Chemistry Section

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Inspection Summary i-

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Inspection on March 3, 4, 6, 9, and 16, 1987 (Reports No. 50-454/87013(DRSS);

50-455/87012(DR55))-

l Areas Inspected: Routine announced inspection of the chemistry _ program,

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including procedures, organization, training, and quality assurance and water quality control.

Results

:No violations or deviations were identified.

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. A DETAILS 1. Persons Contacted 1R. C. Ward, Services Superintendent, Byron, CECO 1,20. Herrmann, Station Chemist, Byron, CECO 10. Robinson, Onsite Nuclear Safety, Byron, CECO 1E. M. Zittle, Regulatory Assurance, Byron, Ceco 1A. D. Britton, Quality Assurance, Byron, CECO

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V. Junlowjiraya, Analytical Chemistry Group Leader, Byron, CECO W. Scheffler, Operational Group Leader, (Chemistry), Byron, Ceco K. Lurkins, Engineering Assistant, Byron, CECO R. Boyer, Engineering Assistant, Byron, CECO 2,3R. Luczak, Group Leader of Radiochemistry Services, Technical Service Center, CECO IP. Brochman, Resident Inspector, NRC 1 Denotes those present at the plant exit interview on March 4, 198 Telephone conversations held March 6, and 16, 198 aTelephone conversations held March 9, and 16, 198 . Licensee Action on Previous Inspection Findings (Closed).0 pen Item (50-455/83039-15): Complete installation of the Sentry High Radiation Sampling System (HRSS) primary coolant sampling capability for Unit 2. This system appears to be complet In a previous inspection the inspector observed the collection of a simulated emergency accident sample, but the Chemical Analysis Panel containing the the instrumentation for the analysis of chloride, 3H and hydrogen had not yet been connected to the Unit 2 HRS It 1as subsequently been connected and licensee representatives

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stated that it is operational and is tested for operability and

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calibration weekl This item is close (Closed) Open Item (50-455/86028-03): Licensee will test conductivity monitoring of water from the condenser trays when sufficient steam l

is available. The licensee is operating the monitoring system with 19 of the 20 sampling points (the other is blocked and is being

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repaired). However, at present, the system needs special care to l keep it operating, due partly to particulates from the condenser surfaces (welding and grinding residues) still entering the water and blocking the pressure regulators. A licensee representative stated that the reliability will be improved as 80% power is reache The licensee is considering modifying the system to improve reliability by moving some of the sample lines to the condensate pump intak Since the monitoring system appears to be generally, operable and an alternative, although less efficient system, is available for monitoring condenser cooling water in-leakage (conductivity on the discharge side of the condensate pumps), this item is considered closed.

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~ .(0 pen) Open Item (50-455/86037-01): Licensee to consider improvements intheprocedures'forthecollectionofpost-accidentsamplesfrom the High Radiation Sampling System (HRSS In a previous inspection, the inspector had.noted that the dilution valve in.the Unit 2 system

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-was reversed, so'that during the dilution operation, the valve handle

~ pointed against, rather than.with~ the sample flow into the collection vial. .The-inspector observed that to correct for this deficiency, the licensee had marked.the mimic board with an arrow to note the Ldirection in which the handle should be turned for sample collectio The licensee representative stated that RCT training on the system

.will be presented during the second guarter of 1987 and would be completed by June 30, 1987. The training will be reviewed in an-inspection after this date. This item is not considered to restrict the level of power operatio (Closed) Open Item (50-454/86032-01; 50-455/86028-01): Licensee to improve QA/QC programs in the laboratory in areas of instrument performance tests and RCT testing. A review of the QA/QC program showed progress since the previous inspection on this progra All of the trained RCTs participated in the performance tests of the. Technical Specification-related analyses, chloride, fluoride, boron and lithium.' For this group, all of the results were.in agreement with the given concentrations. The results and Lthis program are discussed.further in Section 4. This item is closed and will be followed under subsequent inspections of the QA/QCprogra . Management Controls, Organization and Training The inspector reviewed the organization and staffing of the Chemistry Group and changes since.the last inspection.6 The Group is headed by

- the Station Chemist, who re) orts to the Rad / Chem Supervisor. The organization was recently clanged to bring in an experienced chemist-with a Master of Science degree in analytical chemistry. Two Group Leaders, one operational and the other analytical, and the Chemistry Foreman, who supervises the RCTs, report to the Station Chemist. A

. Chemist,.a Chemical Engineer and a Contract Assistant are in the

! Operational group, while a Chemist and three Engineering Assistants i report to the Analytical Chemistry Group Leader. This organization

! appears to be suitable for operating the laboratory and relieves the

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-Station Chemist of supervision of a large number of chemists.

F The Radiation / Chemistry Group has 39 qualified RCT In addition, four

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new RCTs have been hired and have just started training at the Braidwood

' Production Training Center. These extra technicians will make it possible i to maintain sufficient personnel in this group in the presence of

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attrition due to RCT relocation and promotion No violations or deviations were identifie Region'III Inspection Reports No. (50-454/86032; 50-455/86028).

h 6 Region III Inspection Reports No. (50-454/86032; 50-455/86028).

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J 4.' ' Implementation of the QA/QC' Program in the Chemistry Laboratory

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The inspectors reviewed the Ch'mistry e QA/QC program described in the procedures and implemented in the laboratory. The program is required by Procedures BAP 599-47, " Byron Station Quality Control Program,"

. Revision 1,'May 12, 1986,"BAP 599-50, " Byron Station Chemistry Unknowns Test Program Description, Revision 1, April 9, 1986,.and BAP 599-51

" Byron. Station Chemistry / Radiochemistry Performance Check Program," ,

Revision 2, February 21, 198 The RCTs have been tested for proficiency only in analyses related to Technical-Specifications (T/S): high-level (100-200 ppb) chloride'and and lithium b fluorideabsorption atomic by specific ion electrodes, boron spectrophotometr by titration,its The acceptance lim were f20% y of the expected values for chloride, fluoride and Li and 3% for boro The RCT proficiency appears to be improving, since all of their result were within the acceptance limits. However, the inspector expressed concerns that.the limits appeared to be unrealistically broad, since even with more reasonable narrower limits, as for example, 15, 10, 5 and 1%

there would for the have chloride, been only afluoride, lithium few failures per and test.boron, respectively,ide Moreover, the chlor and fluoride unknowns were at the relatively high concentrations of 100-200 ppb, rather than at the lower concentration range (10-20 ppb)

required for secondary system chemistry where the analyses are more difficult to d The Station Chemist noted he had previously planned that future tests would require more stringent acceptance limits and that the program would be expanded by the addition of at least one analytical method in each round of tests. He agreed to consider doing RCT_ performance checks at concentrations appropriate to secondary system

. chemistry analyses in the near futur .The . licensee participates quarterly in a corporate non-radiological interlaboratory comparison program with samples supplied by the CECO Technical Support Center. The Center has also recently instituted a radiological interlaboratory comparison coolant. sample divided in various ways, program a liquid using sample for a split reactor gamma analysis, a filter for solids (crud), gross alpha, gross beta, and H- The Tech Center has not yet completed the analysis of the result The laboratory does not use control charts for performance checks on non-radiological analyses; licensee representatives noted that they are waiting for the issuance of the corporate directive on QA prior to implementation.-(Thishasapparentlyjustbeencompletedandapproved.)

The inspector noted that the program in the draft document appears to be generally adeguate. However, he was concerned that the proposed implementation timetable accompany 1ryg the directive appears to be excessively drawn out, i.e. completion of some of the programs may be delayed for up to thirty months after approval. However, it appears that much of the delay relates to various aspects of setting up the system, including the rewriting of procedures and the development and implementation of training programs for staff and RCTs. Licensee representatives agreed with inspector concerns that much of the basic

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program, 'especially control charts and analytical aerformance checks could be implemented much soone The investigate this question, their priorities, yand furtier the agreed to availability of their resources, and to propose a schedule for implementation by April 5, 1987. The scheduling and development of the non-radiological QA/QC program, improvement of the RCT testing, and. implementation of control charts will be followed at subsequent inspections under Open Item (50-454/87013-01; 50-455/87012-01).

The inspector reviewed some aspects of the radiological QA/QC program relating to instrument contro Control charts of counts vs. date have been implemented from check-source data collected by the AAIS com) uter system and plotted by graphics programs developed by the CECO Tec1 Cente Two-sigma control limits are given on the graph. These control limits are also used by the AAIS to automatically determine the acceptability of an instrument on the performance check. The inspector noted two weaknesses in the system. First, no data logs were kept on the counts, so that supervisors could not readily tell or track the number of times the system had failed its performance checks. Such data might show up various problems with the system, its operations, and/or with the RCT Licensee representatives agreed to consider implementing data logs, either with RCT entries or from retrieval of the numerical data from the AAI Secondly, the total counts from some of the the check sources, including those from Am-241 for the alpha / beta counter, were very low, on the order of 2000 total counts per test, rather than the more standard practice of more than 10000 count The resulting poor counting statistics (large uncertainties) tend to hide instrumental and operational variabilities of the counters themselves and defeat the purpose of the performance check, which is to test the instrument itsel The basis of this operation was apparently derived from a Tech Center memorandum that recommended low counts in the performance check to reduce the number of out-of-limit tests because the AAIS took the counter off-line until a 4 subsequent test showed the results to be within the 2-sigma limits derived from counting statistics. In the inspector's discussions with the Tech Center Radiochemistry Group Leader, he agreed to modify this recommendation and to consider modification of the AAIS. Improvements in the radiological QA/q program, such as the use of performance check data logs and increases in the number of check counts will examined in subsequent inspections mder Open Item (50-454/87013-02; 50-455/87012-02).

The licensee's QA/QC program appears to provide a good basis for the develo) ment of a satisfactory quality assessment program, particularly when t1e corporate QA directive is implemente No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the 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 ?

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.. Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on March 4, 1987. The inspector discussed the Open Items in Section 2 and concerns about the guality control progra The RCTs are tested periodically for proficiency on only four of the many analyses done in the laboratory, and control charts are not used on most of the non-radiological analyses. Licensee representatives agreed to look into the inspectors concerns relating to the QA/QC program and submit a schedule for implementation of various aspects of the program that can be set up in the near future (Section 4). Further discussions were held in a telephone conversation with the Station Chemist on March 6, and 16, 1987 and with the Tech Center Radiochemistry Group Leader on March 6, 9, and 16, 198 During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee representatives did not identify any such documents or processes as proprietar . _ ___ _ _ - _ _ _ _ _ _ _ .