IR 05000456/1987008

Insp Repts 50-456/87-08 & 50-457/87-07 on 870205 & 17-20. No Violation or Deviation Noted.Major Areas Inspected: Chemistry Program,Including Procedures,Organization,Training & Qa,Water Chemistry Control & Measurement Samples

ML20212P030
Person / Time
Site:	Braidwood
Issue date:	03/06/1987
From:	Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212P020	List: IR 05000456/1987008 ML20212P016
References
50-456-87-08, 50-456-87-8, 50-457-87-07, 50-457-87-7, NUDOCS 8703130252
Download: ML20212P030 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/87008(DRSS);50-457/87007(DRSS)

Docket Nos. 50-456; 50-457 Licenses No. NPF-59; 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, Braceville, Illinois Inspection Conducted: February 5 and 17-20, 1987 (On-site)

February 25 and 26, 1987 (Telephone conversations)

Inspectors: R ' oltzm 5/W87 LIate

? .3/5~/87 Date '

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Approved By: M. C. Schumacher Chief RadiologicalEffluentsand Date

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Chemistry Section

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Inspection Summary Inspection on February 5, 17-20, and 25 and 26, 1987 (Reports No. 50-456/87008(DRSS);

50-45//8/00/(DR55))

Areas Inspected: Routine announced inspection of: (1) chemistry program, including procedures, organization, training, and quality assurance, (2) water chemistry control, and (3) confirmatory measurements samples by two NRC inspectors and one consultan Results: No violations or deviations were identifie I PDR ADOCK 05000456 G PDR ,

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DETAILS Persons Contacted 1E. E; Fitzpatrick, Station Manager, Braidwood (Bwd):

IC. W. Schroeder, Services Superintendent, Bwd IL. E. Davis, Assistant Superintendent, Technical Services, Bwd

'1R. E. Aker, Radiation-Chemistry Supervisor Bwd

'IP. Barnes, Regulatory Assurance Supervisor, Bwd, 1M.-Takaki, Regulatory Assurance, Bwd 1T.' W. Simpkin, Regulatory. Assurance, Bwd 1,2M. Andrews, Station Chemist, Bwd J. Burns, General Chemist, Bwd R. F. Rysner, Chemistry Engineering Assistant, Bwd J. McIntyre, Laboratory Foreman, Bwd-L. A. Literski, Emergency Planning W. Lloyd, Chemistry Engineeringistant, Ass Bwd (GSEP) Coordinator,-Bwd P. Holland, Regulatory Assurance, Bwd S. Larson, Tech Staff Engineer, Bwd

.R. Aulinskis, Chemical Engineer, Ceco Technical Center M. Beaumont, Radiation. Chemistry Technician (RCT), Bwd 1W. Kropp, Senior Resident Inspector, Construction, NRC The inspectors also interviewed other licensee personnel in various departments-in the course of the inspectio ~

1 Denotes those.present at the plant exit interview on February 20, 198 Telephone conversations held February 25 and 26, 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 operatio No change in status from the previous inspection has occurred. This item will remain open until samples are collected and analyzed after the plant becomes operationa (Closed)OpenItem(50-456/86017-01;50-457/86015-01): Licensee to install three additional air samplers in the field by 5% powe These air samplers had been installed and were operating

satisfactorily. However, the Tygon tubing that prevents ,

! recirculation of the exhaust air had not been installed until

, October 3, 198 The inspectors observed that these units had j the required tubing.

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. (0 pen)0penItem(50-456/86017-02;50-457/86015-02): Collection

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of samples and operation and calibration of in-line monitors for secondary chemistry control and testing of condensate polishers and makeupdemineralizers(MUD) system. Licensee re)resentatives stated that the secondary sampling panel was operable, aut because of construction in the secondary panel room, the inspectors were unable to observe the panel and collection of samples. Only the conductivity monitors were operable and calibrated. The collection of samples will be reviewed by the inspectors at a subsequent inspection prior to criticalit However, review of instrument calibrations may be extended to a time prior to 5% powe (Closed) Open Item (50-456/86037-01; 50-457/86029-01): Licensee will establish acceptance limits for the RCT performance tests in non-radiological chemistry. The licensee set limits on the RCT performance tests at 120% pass-fail limits for the analyses by pb chloride and 100 ppb fluoride specific standards, ionand probes limitsof of2511 p% for titration of a 1000 ppm boron standard. As all the RCTs with completed qualification cards have subsequently been tested, this item is considered close (Closed)OpenItem(50-456/86037-02 50-457/86029-02): Review of corporate interlaboratory comparison; of non-radiological analyse The inspectors reviewed the results of corporate interlaboratory tests of non-radiological analyses for June 1986 (in a letter of September 1986). For a primary matrix with 300 ppm of boron, the results appeared to be adequate (120%) compared to those of the reference laboratory (the SMAD laboratory at the CECO Technical Center) values for fluoride, calcium and lithium, but they differed substantially for chloride, aluminum, and magnesiu For the secondary system matrix the sulfate, silica, iron and copper values were within 110%, while those for chloride, fluoride and

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sodium differed by more than 120% from the given values. Similar problems were noted at two other laboratories. These results appeartodemonstrateweaknessesinthelaboratoryQA/QC-program (Section6). This item is considered closed; it will be followed with the development of the general QA/QC progra (Closed)OpenItem(50-456/86037-04;50-457/86029-04): The licensee will determine gamma, H-3, Sr-89, Sr-90 and Fe-55 activities in a RESL spiked sample in various geometries and report the results to Region III. Since the licensee obtained satisfactory agreements in the previous sample, except for Sr-89 and Sr-90, a new spiked sample was sent from RESL, which the licensee sent to the contractor laboratory. The results are shown in Table 1 along with the acceptance criteria in Attachment 1. The Sr-89 and Sr-90 values are in agreement, but the Fe-55 value is in disagreement. The licensee agreed to analyze another sample for Fe-55. This will be followed underOpenItem(50-456/87008-01;50-457/87007-01).

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. (Closed)OpenItem(50-456/86037-05;50-457/86029-05): High Radiation Sampling System (HRSS) to be fully operational for supplying routine primary coolant samples by FLOL. This system was previously completed and tested, but because of modifications made on it and because sam)les could not be drawn without pressure in the vessel, 0)erability of' tie system could not be assured to supply samples from tie reactor coolan During this inspection,.the inspectors observed an RCT satisfactorily collected a sample from this system. This item is close (Closed)OpenItem(50-456/86051-01;50-457/86039-01): The RCTs to become ANSI qualified. The progress of the the ANSI qualifications of the RCTs has been followed. At present.14 are qualified under ANSI N18.1-1971, and about ten more will be so by the end of this year. This item is closed and will be followed under the general training and qualifications of the RCT (0 pen)OpenItem(50-456/86051-02;50-457/86039-02): RCTs to qualify in the collection of samples from RCS and secondary system and to demonstrate this. Twenty eight RCTs have completed their qualification cards and another has completed everything, exce)t the final oral examination. The requirements for sampling of t1e HRSS and secondary system had been waived previously because these systems were not operable. Those for the HRSS have been completed, but those for the secondary, system have not bee This item will remain open to be closed prior to criticality.

i (Closed)OpenItem(50-456/86051-03;50-457/86039-03): Development of instrumental aerformance checks QA/QC program in counting room to be inspected. T1e inspectors reviewed the progress of the QC program for the radiological instrumentation. The licensee has set u) and maintains data sheets and control charts on the performance cleck sources for the Ge gamma systems, the low-level Canberra 2000 Series alpha / beta counters (the high-level system is not presently in use),

and the two Packard liquid scintillation counters. Total source counts have been increased to a minimum of about 10,000 per test to obtain better statistics. Control limits have been set at two standard deviations, based on counting statistics. A comments column and the expected and limiting values have been placed on the logsheets tohelptheRCTsandlaboratorysupervisorstobetterjudgethe results of the performance checks. This item is closed and progress of this program will be followed under the NRC confirmatory measurements and QA/QC program (Closed)OpenItem(50-456/86051-04;50-457/86039-04): Licensee to submit results of radiological intercomparison program with vendo The inspectors reviewed the results of a radiological interlaboratory comparisonbetweenthelicenseeandavendor(Analytics I H-3,gammasourcesina14-ccvialandinaliquidsampie,nc.)with and I-131 on a cartridg The results were all agreements, based on the NRC criteria. There appeared to be some problem with the lower-energy i gamma rays Ce-144 and Ce-141 in that their activities were

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substantially lower, relative to the vendor's values with ratios of about 0.85-0.90, compared.to ratios greater than unity for the other This appears to be due to the use of the CECO AAIS software which fits to the logarithm of the data a straight-line calibration curve, rather than a peaked curve that better approximates the actual efficiency curves of Ge detectors. The chemist stated that the fitting routine is being modified by the. Tech Center to mitigate the )roblem. The agreements in this intercomparison demonstrate that t1e calibrations of the detectors are adequate. This item is considered close . (Closed)OpenItem(50-456/86051-05;50-457/86039-05): LicenseeQC Department to review RCT performance check program in next audit of chemistry. In review of the audit from the Ceco Quality Assurance Department of the chemistry program (QAA-210-86-02), the inspectors found that the audit item relating to the proficiency testing of the RCTs had been waived because the RCTs were still undergoing training (January 1986). Because of the importance of maintaining RCT proficiency, licensee representatives noted the inspectors'

concerns and agreed to examine this item in the subsequent audi An inspector's (EG&G, Idaho) review of this issue on February 5, 1987,showedthattheBraidwoodQADepartmenthaddoneamonthly surveillance (QAS-20-86-184, November 24,1986) andtheCECoQA Department had done Audit 20-87-02, January 1-9, 1987, relating to RCT )erformance testing. These audits addressed NRC concerns about t1e lack of acceptance criteria, corrective actions to be taken for failure of a test, and examination of test result These matters were resolved by niodification of the procedure This item is close . Management Controls and Organization The inspectors reviewed the organization and staffing of the Chemistry Group and changes since the last inspection.3 The Group is headed by the Station Chemist, who reports to the Rad / Chem Superviso Four and a Chemists, Chemistry two Engineering Consultant reportAssistants, two Chemist to the Station Laboratory Foremen, In addi tion a chemical engineer with experience in computers and radiochemistry instrumentation from the CECO Technical Center assists in the counting room and is scheduled to be in this plant at least until June 198 The staff appeared to be adequate to handle the laboratory, but the inspectors noted their concerns that because of the large number of

, RCTs,thestaffmighthavedifficultiesintrainingandmaintaining/gC RCT proficiency, working out analytical problems and developing a QA progra Licensee representatives noted these concerns and will consider the No violations or deviations were identifie Region III Inspection Reports No. 50-456/86051; 50-457/86039

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.. Water Chemistry Control-The inspectors reviewed the licensee's water chemistry control program which is directed by BwCP PD-1, "Braidwood Station Primary Chemistry Program," Revision 0, May 1, 1985 for the primary system and BwCP PD-4,

"Braidwood Station Secondary Water C5emistry Program," Revision 1, December 4, 1986, for secondary chemistry. The latter procedure has been only slightly modified with temporary changes of Revision 0 to allow for greater laboratory flexibility during the start-up phase of the operation The administrative limits and action-levels are consistent with the Electric Power Research Institute and Steam Generators Owners Group, Secondary Water Chemistry Guideline No violations,or deviations were identifie . Implementation of the Chemistry Programs The inspectors reviewed the progress in implementation of the primary and

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secondary systems chemistry programs. The laboratories have good bench,

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fume hood and floor spac The housekeeping was very goo The analytical equipment was state-of-the-art instrumentation, including a Beckman DCP Plasma Spectrometer, a Perkin-Elmer Model 5000 Atomic Absorption Spectrophotometer with both flame and gra)hite furnace attachments and automatic sample changers, three dual-unit )ionex Model 2020i Ion Chromatographs, Metrohm Autotitrators for boron analyses, gas chromatographs, total organic carbon (TOC) analyzers, microprocessor-based Orion Model EA940 Analyzers for )H and specific ion electrodes operation, and Beckman 0U-30 programma)le Spectrophotometer The inspectors observed an RCT collect a routine sample of reactor coolant from the HRSS (Section 2g) and determine'the boron concentration with the Autotitrator. He appeared to be generally knowledgeable about the work and followed the procedures. No problems were noted in the collection and analysis of the sampl The inspectors noted an improvement in the procedures for chloride and fluoride analyses by specific ion electrodes. The calibration curve, which is basically linear, is now plotted on a linear grid, rather than the previously used semilogarithmic grid. This allows for more accuracy in both plotting and reading the graph, and provides a better indication of the precision of the calibration dat Overall, the laboratory appeared to be adequate for the proper operation of the plant and to be operating satisfactoril No violations or deviations were identifie _-

4 Implementation of the QA/QC Program in the Chemistry Laboratory The inspectors reviewed the non-radiological Chemistry QA/QC program described in the procedures and implemented in the laboratory. The and secondary water chemistry control program is required by the primary (Section 4) and implemented in BwCP PD-7 grogramsBwCPPD-1andBwCPPD-4 Braidwood Station Chemistry Quality Control Program," Revision 2, February 18, 1986 and BwCP PD-8, "Braidwood Station Chemistry Performance Evaluation Program," Revision 1, December 22, 198 At present the RCTs are tested for proficiency only in the analyses of low-level chloride and fluoride by specific ion electrodes and of boron by titration (Section2d). Despite the rather high acceptance limits of 20 % for the chloride results about one-third of the RCTs failed at least one test and some failed several. This appears to be a weakness in the analysis that the licensee representatives were aware of and trying to correct by additional training and modifications of the procedure Environmental contamination by chloride was one There were fewer failures in the boron analysis, problem despite the being tighterstudie acceptance level of 11%.

-The licensee is participating quarterly in a corporate non-radiological interlaboratory comparison program with samples supplied from the CECO Technical Support Center (Section 2e), and in a radiological interlaboratory program with a vendor (Section 2k).

Control charts are used only with a few of the non-radiological analyses to maintain control of the procedures, namely, on the chloride, fluoride, boron, silica and hydrazine analyses. Licensee representatives were waiting for completion of the new corporate quality assurance program before they extended their program. The inspectors noted that, based on a limited perusal, the program in the draft document appears to be generally adequate. However, they,were concerned that the proposed implementation timetable accompanying 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. Licensee representatives noted these concerns and agreed to send a copy of the completed directive to Region III and to discuss a schedule for 1mplementation of the QA program at that tim Resolution of these concerns will be followed at subsequent inspections under Open Item (50-456/87008-02; 50-457/87007-02).

The licensee's QA/QC program appears to provide a good basis for the development of a satisfactory quality assessment program, particularly when the corporate QA directive is implemente No violations or deviations were identifie . .. . - _ . -. ~

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Open' items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action-

-on the part.of the NRC or licensee, or both. Open items disclosed during the inspection are discussed in Sections 2 and '

- ' Exit Interview The scope and findings of the inspection were reviewed with licensee

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representatives (Section 1) at the conclusion of the inspection'on February 20, 1987. The inspectors discussed concerns about the cuality .

control program. The chemistry staff appears to be heavily burcened

in training and testing the large number (39) of RCTs. The RCTs are tested periodically for proficiency on only thre'e of the many analyses done in the-laboratory, and control charts are not used on most of the non-radiologicl. analyses. Licensee representatives agreed to look into the inspectors concerns relating to the.QA/QC program after the corporate directive is approved-(Section 6). Further discussions were held in a telephone conversation with-the Station Chemist on February 25 and 26, 1987.

I During the exit interview, the inspectors discussed the likely

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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 .

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- Attachments:

l 1. . Table 1, Confirmatory

Measurements Program

! . Criteria for Comparing Analytical Measurements l

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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 4 Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement

<4 0.4 - .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 i criteria and identified on the data sheet.

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TABLE 1 U S NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PRCGRAM FACILITY: BRAIDWOOD FOR THE 1 QUARTER OF 1987

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LICENSEE- ---LICENSEE NRC----

SAMPL ISOTOPE RESULT ERROR RESULT ERROR RATIO REG T t

L SPIKED FE-55 6.7E-05 1.3E-06 5.2E-05 1.2E-06 7.7E-01 5.1E 01 D SR-89 1.1E-04 3.0E-06 1.3E-04 1.6E-05 1.1E 00 3.8E 01 A :

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SR-90 1.1E-05 4.0E-07 1.0E-05 2.0E-07 9.5E-01 2.7E 01 A

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i T TEST RESULTS:

A= AGREEMENT D= DISAGREEMENT

• = CRITERIA RELAXED N=NO COMPARISON l

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