IR 05000456/1986037

Insp Repts 50-456/86-37 & 50-457/86-29 on 860728-0807.No Violations or Deviations Noted.Major Areas Inspected: Chemistry/Radiochemistry Program,Including Water Chemistry Control,Procedures,Facilities & Mgt Control

ML20214L399
Person / Time
Site:	Braidwood
Issue date:	08/21/1986
From:	Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214L396	List: IR 05000456/1986037 ML20214L394
References
50-456-86-37, 50-457-86-29, NUDOCS 8609100133
Download: ML20214L399 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/86037(DRSS); 50-457/86029(DRSS)

Docket Nos. 50-456; 50-457 Licenses No. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: July 28-31 and August 1, 5 and 7, 1986 Inspector: .' .' Holtz 8/dO/T[_,

Dhte'

4ll,)hd/4 W Approved By: M. C. Schumacher, Chief /

Radiological Effluents Date and Chemistry Section Inspection Summary Inspection on July 28-31 and August 1, 5 and 7, 1986 (Reports No. 50-456/86037(DRSS); No. 50-457/86029(DRSS))

Areas Inspected: Routine, announced inspection of: (1) chemistry / radiochemistry program, including water chemistry control, procedures, facilities, management controls, training and qualifications, quality assurance and quality control; (2) Confirmatory Measurements Program, including discussions of results of a spiked sample of a liquid, a particulate filter and charcoal cartridge adsorbers; and (3) actions taken on previous open item Results: No violations or deviations were identifie PDR ADOCK 0500

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DETAILS 1. Persons Contacted

L. E. Davis, Assistant Superintendent, Technical Services, Bwd

R. D. Kyrouac, Station Quality Assurance Supervisor, Commonwealth Edison Company (CECO)

1,2R. E. Aker, Radiation Chemistry Supervisor, Bwd

J. K. Jasnosz, Engineer, Regulatory Assurance, Bwd L. M. Kline, Regulatory Assurance, Bwd L. A. Literski, Emergency Plan (GSEP) Coordinator, Bwd 1,'M. J. Andrews, Station Chemist, Bwd 2D. M. Keneally, Environmental Health Physicist, CECO T. Keith, Station Health Physicist, Bwd J. Burns, General Chemist, Bwd R. F. Rysner, Chemistry Engineering Assistant, Bwd R. Vebras, Unit Chemist, Bwd M. Sayers, Instructor, Support Group Training, Bwd C. Ricketts, Training Consultant, MEC L. Rundlett, Training Consultant, MEC J. McIrityre, Laboratory Foreman, Bwd The inspector also interviewed several other licensee personnel during the course of the inspection, including chemistry and health physics personne Denotes those present at the plant exit interview on August 1, 198 Telephone conversations on August 5, 198 * Telephone conversation on August 7, 198 . Licensee Action on Previous Inspection Findings (0 pen) Open Item (50-456/81-XX-01): NRC to collect water samples from Braidwood city wells and wells from the Thelma Corbin Farm in Wilmington, Illinois, after the Braidwood Station is in operation, and to analyze for gross alpha, gross beta, gamma analysis, and tritiu In 1980 preoperational samples of the T. Corbin farm well water and Braidwood city wells were collected and analyzed. Results indicated that levels of radioactivity were within those found in northern Illinois due to the presence of the naturally occurring radium and daughters and potassium-40. This item will remain open until samples are collected and analyzed after the plant becomes operationa (0 pen) Open Item (50-456/84-03-01; 50-457/84-03-01): Establishment and implementation of generic and site specific training programs for Radiation Chemistry Technicians (RCTs). The inspector reviewed the progress made in establishing and implementing the generic and site-specific training programs for the RCTs. Twenty-nine RCTs have completed the generic training program presented at the Production Training Center. Twenty-three have completed their qualifications /

certification for on-the-job training (0JT), five will complete this certification within a month, and the sixth will qualify by FLO !

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However, on review of the certification records, the inspector noted that all, except one of the radiochemistry qualification items had been " waived" for as long as three months after " start of operations".

After the inspector apprised the licensee representatives of the necessity for this qualification, they agreed to train and certify the RCTs in the essential elements of this group prior to FLOL (by September 8,1986). This training will include the handling of radioactive sources and operating the Canberra alpha-beta counters and the AAIS gamma spectrometry system. This item will remain open pending completion of these qualifications and certification c. (Closed) Open Item (50-456/84-03-03; 50-457/84-03-03):

Implementation of the Chemistry / Radiochemistry QC program and revision of BwPD 200-1 to include a radiochemistry QA/QC progra Procedure BwPD 200-1 has been satisfactorily revised and incorporated in BwCP PD-7. This Open Item will be closed and-implementation of the QA/QC program will be followed as discussed in Section 7 of this repor d. (0 pen) Open Item (50-456/86017-01; 50-457/86015-01): Licensee to install 3 additional air samplers in the field by 5% power. The licensee installed and operated three additional-environmental air sampling stations on July 26, 1986. The inspector observed that the units were operating, but tests on unit L-19 (blocking the filter intake) showed substantial leakage of air into the intake train after the filters. The other units, L-20 and L-21, demonstrated 4 some leakage. In addition, the Tygon tubing had not been installed on the pump exhausts to prevent recirculation of exhaust air into the intake. A corporate representative stated that the contractor's testing procedures will be modified within a few weeks to incorporate the above -testing method into the weekly collection procedure and the tubing will be installed. This' item will remain open and be examined in a subsequent inspectio e. (0 pen) Open Item (50-456/86017-02; 50-457/86015-02): Collection of samples and operation and calibration of in-line monitors for secondary chemistry control and testing of condensate polishers and makeup water demineralizer systems. The inspector observed the steam generator (SG) blowdown sampling system in the hot laboratory and the secondary water sampling system in the turbine buildin Licensee representatives stated that both systems were operable and used in the integrated hot functional (IHF) tests. Because the secondary _ side had no water, the inspector could not observe their operability. The blowdown panel had for each SG unit five in-line monitors, each with an associated strip recorder (specific conductivity, cation conductivity, pH, sodium and dissolved oxygen)

that had been calibrated during the IHF test The secondary panel appeared to be operational with in-line monitors for specific and cation conductivities and pH. Other in-line monitors have yet to be installed, but they ara not essential for power operation. This item remains open for examination of operation of the system prior to criticalit a

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3. Management Controls and Organization The inspector reviewed the management controls and organization of the Radiation-Chemistry Department for implementation of the chemistry /

radiochemistry programs and found them to be basically the same as described in the previous inspection report.2 The department has added a Lead RadChem Foreman who can supervise the RCTs in their :hemistry tasks during the off-shift hours when the Chemistry Foremen are not onsite. The chemistry group has lost a chemist (Chemical Engineer), who

, is being replaced by a chemistry consultant with four years of chemistry experience at Byron. He will probably start the first part of September and remain until the commercial operation of Unit 2. Additionally, the corporate Technical Support Center will supply staff members with special expertise; the first has experience in the AAIS system and will start in the counting room at FLOL. The licensee has hired 11 new RCTs, but they will not be qualified for at least another nine month No violations or deviations were identifie . Training and Qualifications The training and qualifications of the chemistry staff were reviewed in the previous report.2 The status of RCTs training and qualification is described in Section 2.b of this repor The RCT certification program is being revised in conformance with INPO standards that require the approval of each step in specific tasks prior to certification of the task. Also, where applicable, performance checks must be documented; e.g., a trainee's analytical results on a blind sample will be recorded on the qualifications form. This program will improve the ability of the supervisors and inspectors to judge RCT qualification Further, the licensee is planning to implement a continuing training program for RCTs to start January 1987. The station anticipates being ready for INP0 accreditation by about September 198 No violations or deviations were identifie . Radiological Environmental Monitoring (REMP) Program The inspector, in addition to examining the new air samplers (Section 2.d),

reviewed the progress of the preoperational collection of atmospheric iodine by charcoal adsorbers. Checks of the " Sample Collection Logs"

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showed that they had been collected regularly since they were installed in May 1986, but results presently are available only through the first month (May) of collection. Positive iodine results attributable to the Chernobyl incident were observed on many of the sample No violations or deviations were identified.

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2RIII Inspection Report (50-456/86017; 50-457/86015)

" Ibid

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6. Implementation of the Chemistry and Radiochemistry Program The inspector reviewed licensee progress in implementation of the chemistry and radiochemistry program Some additional laboratory instruments have been obtained, such as a Beckman Plasma Spectrometer and a Dionex ion chromatograph (IC), for a total of three ICs. No work was being done with radioactive samples in the hot laborator The counting room appears to have sufficient space and good ventilation and to be generally adequate, in conformity with the requirements of the FSAR. Two of the four Ge gamma spectrometers have been calibrated for various geometries each on two or more shelves: three liquid, a gas, charcoal adsorber cartridge;xand a particulate filter. The other two detectors are scheduled for calibration in September 1986. The Packard Tri-Carb liquid scintillation counter (LSC) was calibrated with a sealed tritium source from the LSC vendo From the inspector's review of the control charts and performance testing described in the following section, it appears that the RCTs are improving their analytical abilities. As noted in Section 2.b, they have not yet demonstrated capabilities of working with radioactive samples. The inspector informed the licensee at the Exit Interview that these capabilities will be required by FLO Progress in this area will continue to be followed under Open Item No. 50-456/84-03-01; 457/84-03-01 (Section 2.b).

No violations or deviations were identifie . Implementation of the QA/QC program in the Chemistry and Radiochemistry Laboratories The inspector reviewed the progress of the chemistry and radiochemistry QA/QC program described in the' previous report.' Since May 1986 the nonradiological QC program has'been modified to include instrumental performance checks on the analyse's of chloride and fluoride (specific ion probes), high level boron (automatic titrator), and silica and hydrazine (spectrophotometric). The res'alts of analyses of standards are tabulateo'and graphed. Control limit: are not shown because the procedures are still under development and the results are highly variable. The charts have been very useful in helping to resolve various problems, such as substantial reduction of variability in the boron analysis from 3-4% to less than 1% of the mea They also demonstrated the need for more careful control of the hydrazine indicator solutio The variabilities of the fluorfde and chloride results have' decreased substantially since May, but they still appear somewhat high (10 to 20%).

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The licensee will establish analytical control limits based on actual performance data after the results appear to be stabilized and about 40 data points are accumulate The licensee has implemented the performance tests program on the RCTs with unknowns for the analyses of boron, low-level chloride and fluoride, silica, and hydrazine. Acceptance limits were not given and the chemists used their own discretion in determining acceptability. The inspector's review of results of 31 sets of tests for about 15 RCTs indicated variability ranging from less than 3% (boron) to about 30% (chloride).

It is difficult to judge RCT proficiency because problems were occurring in the various analyses, as noted above, and many of the performance checks were done prior to the resolution of these problems. The licensee representative stated that acceptance limits would be developed when sufficient data have been accumulated. This matter will be reviewed during a subsequent inspection (0 pen Item 50-456/86037-01; 50-457/86029-01).

The station also participates in a newly initiated corporate interlaboratory comparison of analyses in a primary reactor coolant matrix of chloride, fluoride, lithium, aluminum, magnesium and calciu The first intercomparison showed deviations of 8% to 65% from the known values. Similar variabilities were obtained in the sample of secondary system matrix. The results of the second comparison were not yet available, but the intralaboratory precision based on three analyses by different RCTs of each constituent appeared to be good, again, except for chloride and fluoride. This comparison will be reviewed during a subsequent inspection (0 pen Item 50-456/86037-02; 50-457/86029-02).

For the radiological instruments, control charts are currently maintained only for the Canberra alpha-beta counters, the only instrument presently in routine use. The licensee agreed to begin regular performance checks and control charts on the Ge and liquid scintillation system Some control is maintained on these instruments by the AAIS system which requires them to pass performance checks based on 2 sigma counting statistics before use. Failure of this check automatically removes the counter from service until a successful test is made. The licensee is also participating in the developement of a corporate radiological interlaboratory comparison program. In the interim the licensee stated its intention to participate in a split sample comparison program with a vendor. Counting room QC will be reviewed during a subsequent inspection (0 pen Item 50-456/86037-03; 50-457/86029-03).

Progress in implementing the QC program in the laboratory has been substantial since the previous inspection. Licensee management appears to be aware and supportive of a good QA/QC program, as represented in the chemistry procedures and program description. However, the rotation of the RCTs between chemistry and radiation protection groups, with the resultant short tour in the laboratory is generally considered a poor laboratory management practice. As the inspector noted in the Exit Interview, it makes quality control difficult, reduces technician proficiency and requires increased supervisory attention. Otherwise,

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the staff appears to have good support from management in implementing their own programs and in obtaining help from the corporate Technical Support Center. The QA/QC program and improvements described above should help to develop and improve the capability of both chemists and RCT No violations or deviations were identifie . Confirmatory Measurements The licensee's capabilities for radiochemical analyses were examined under the Confirmatory Measurements program in which the licensee analyzed a spiked liquid sample containing tritium, mixed gammas, Sr-89, Sr-90, and Fe-55 supplied by the NRC hrference Laboratory, the Radiological and Environmental Sciences Laboratory (RESL), Idaho Falls, Idah In addition, the inspector supplied samples of spiked charcoal adsorber cartridges and a spiked particulate filte Comparisons of the results of the analyses from the licensee's laboratory with the NRC values are presented in Table 1. The acceptance criteria are given in Attachment 1. The Sr-89, Sr-90, and Fe-55 results from the licensee's offsite contractor were not yet availabl The licensee obtained 17 agreements in 19 comparisons. The two disagreements involved the tritium spike, which probably resulted from faulty preparation of the scintillator cocktail, and Co-57 on a particulate filter (F SPIKE 1) counted on one of the licensee's detectors. The Co-57 disagreement may have been due, in part, to poor counting statistics, but a weakness in the calibration method for the AAIS system may have contributed to this effec In this system the efficiency curve is derived from a fit of a single straight line to the logarithm of the efficiency data vs. energy, while the actual curve for the detector peaks at 100-200 key. While this curve is suitable for the higher energies, the fit is poor at the lower ones and probably overestimates the detector efficiency in the region of the efficiency peak (100-200 kev). This effect was also seen in the spiked charcoal cartridge data (C SPIKED and C SPIKE 1) comparisons on the two detectors where the Co-57 values, although in agreement, were considerably lower than the NRC valu Because some of the problems (disagreement in the H-3 values and poor agreement in the mixed gamma sample), the licensee agreed to resolve the problems in the disagreements by doing additional work on the H-3 analyses and checking the calibration of the detectors at the Co-57 peak. This will include doing additional tritium analyses, participating in a crosscheck program with a vendor with mixed gamma samples and generally achieving greater familiarity with these analyses prior to FLOL. Another spiked mixed gamma and tritium sample will be sent from RESL, in which the licensee will analyze for tritium and do isotopic

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analyses with different samples to compare the various liquid sample geometries, such as for the 14-m1 vial, the one-liter bottle and the 450-m1 Marinelli beaker. The results of these analyses and those sent to the contractor will be examined in a subsequent inspection under Open Item (50-456/86037-04; 50-457/86020-04).

No violations or deviations were identifie . Water Sampling and Monitoring Systems

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'The status of the water sampling systems has not changed substantially since the previous report." Further discussion is presented in Section Routine primary system samples of reactor coolant and dissolved gasses are to be taken from the High Radiation Sampling System (HRSS). This system, originally designed for emergency use only, is being modified with valves suitable for routine use and is not scheduled to be operational until October 198 Licensee representatives were informed that this system must be operational and able to supply routine primary coolant samples by FLOL. This will be examined in subsequent inspections (0 pen Item 50-456/86037-05; 50-457/86029-05).

No violations or deviations were identifie . Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action by the NRC or licensee or both. Open items are discussed in Sections 2 and 6- . Exit Interview The inspectors reviewed the scope and findings of the inspection with licensee representatives (Section 1) at the conclusion of the inspection on August 1, 1986. The licensee acknowledged the inspector's concerns and agreed that prior to FLOL to:

complete RCT certification, including completion of the radiochemistry qualifications for the handling of radioactive samples and operation of counting room equipment;

' have the HRSS operational for the routine collection of reactor coolant samples; and

• analyze another RESL sample for the Confirmatory Measurements progra .

Additional telephone conversations were held with licensee representatives on August 5 and 7, 1986 to determine the resolution of items discussed during the inspectio " Ibid

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During the interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectors. Licensee representatives did not consider the proposed content as proprietar Attachments: Criteria For Comparing Analytical Measurements Table 1 - Confirmatory Measurements Program

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TABLE 1 U S NUCLEAR REGULATORY COMMISSION

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} OFFICE'OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM i

FACILITY: ERAIDWOOD FOR THE 3 GUARTER OF 1986

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NRC =-

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LICENSEE---- ---LICENSEEINRC--

4 SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T i

H3 SPIKE H-3 9.0E-05 2.0E-06 4.7E-05 0.0E-01 5.2E-01 4.5E 01 D

L SPIKED CS-137 8.2E-05 2.5E-06 9.9E-05 0.0E-01 1.2E 00 3.3E 01 A CO-60 7.3E-05 1.4E-06 8.7E-05 0.0E-01 1.2E 00 5.2E Ol' A MN-54 5.0E-05 1.0E-06 6.3E-05 0.0E-01 1.2E 00 5.1E 01 A l L SPIKE 1.CS-137 8.2E-05 2.5E-06 9.!E-05 0.0E-01 1.1E 00 3.3E 01 A CO-60 7.3E-05 1.4E-06 8.5E-05 0.0E-01 1.2E 00 5.2E 01 A MN-54 5.0E-05 1.0E-06 5.4E-05 0.0E-01 1.1E 00 5.1E 01 A

F SPIKED CO-57 2.4E-04 1.5E-05 2.5E-04 0.0E-01 1.0E 00 1.6E 01 A

{ CO-60 1.3E-02 1.6E-04 1.5E-02 0.0E-01 1.1E 00 8.3E 01 A

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CS-137 1.9E-02 1.7E-04 2.0E-02 0.0E-01 1.0E 00 1.1E 02 A j F SPIKE 1 CO-57 2.4E-04 1.5E-05 1.6E-04 3.6E-05 6.8E-01 1.6E 01 D

CO-60 1.3E-02 1.6E-04 1.5E-02 0.0E-01 1.1E 00 8.3E 01 A j CS-137 1.9E-02 1.7E-04 1.9E-02 0.0E-01 1.0E 00 1.1E 02 A

! C SPIKED CO-57 1.4E-04 4.7E-05 8.2E-05 0.0E-01 5.8E-01 3.0E 00 A I CO-60 6.1E-03 2.4E-04 5.9E-03 0.0E-01 9.7E-01 2.5E 01 A l

CS-137 7.6E-03 2.3E-04 7.6E-03 0.0E-01 1.0E 00 3.3E 01 A t C SPIKE 1 CO-57 3.0E-04 5.6E-05 2.0E-04 0.0E-01 6.7E-01 5.4E 00 A i CO-60 1.4E-02 3.7E-04 1.4E-02 0.0E-01 1.0E 00 3.8E 01 A

{ CS-137 1.8E-02 3.6E-04 1.8E-02 0.0E-01 1.0E 00 4.9E 01 A i

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T' TEST RESULTS:

i A= AGREEMENT i D= DISAGREEMENT l *= CRITERIA RELAXED 1 N=NO COMPARISON l

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ATTACHMENT 1

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. CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS -

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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 otethis progra ,

In these criteria, the judgment limits are variable in relation to the com-parison of the NRC's value to its associated one sigma uncertaint As that ratio, referred to in this program as " Resolution", increases, the acceptability of a 1.icensee's measurement should be more selectiye. Conversely, poorer agreement should be considered acceptable as the resolution decreases. The values in the ratio criteria may be rounded toefewer significant figures to maintain statistical consistency with the number of 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

<3 No Comparison jt3 and <4 .5 2.4 and <8 .0 J_8 and <16 .67 jt,16 and <51 0.75 - 1.33 251 and <200 0.80 - 1.25

,1200 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 shee )