IR 05000456/1987012
| ML20212R097 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/17/1987 |
| From: | Holtzman R, Schumacher M, Zibulsky H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212R081 | List: |
| References | |
| 50-456-87-12, 50-457-87-12, NUDOCS 8704240279 | |
| Download: ML20212R097 (58) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/87012(DRSS);50-457/87012(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: March 23-27, 1987 (On-si N April 1, 7, and 15, 1987 (Telephone conversations)
April 3, 1987 (Meeting at Region III Office)
Inspectors:
R.
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Date ON. / b l~
Approved By:
M. C. Schumacher, Chief Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on March 23-27, and April 1, 3, 7, and 15, 1987 (Reports No. 50-456/87012(DR55); 50-457/87012(DR55))
Areas Inspected:
Routine announced inspection of:
(1) the chemistry program, including procedures, training and quality assurance, and (2) confirmatory measurements of non-radiological samples.
Results:
No violations or deviations were identified.
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8704240279 870417 PDR ADOCK 05000456
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DETAILS 1.
Persons Contacted 3L. O. De1 George, Assistant Vice-President (Nuclear Engineering and Licensing), CECO 1,2,3C. W. Schroeder, Services Superintendent, Braidwood (Bwd),3L. E. D
3D. Farrar, Director of Nuclear Licensing, CECO 3S. Hunsader, Nuclear Licensing Administrator, CECO 3S. Hopewell, Chemistry Services Supervisor, Nuclear Services, Technical, Maywood, CECO 3M. E. Burgess, Group Leader, Analytical Chemistry Services, Nuclear Services Technical, Maywood, CECO 1,3,,sR.E.Aker, Radiation,ChemistrySupervisor,Bwd
5. Barnes, Regulatory Assurance Supervisor, Bwd P
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1M. Takaki, Regulatory Assurance, Bwd 1T. W. Simpkin, Regulatory Assurance, Bwd
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1,3M. J. Andrews, Station Chemist, Bwd 1J. S. Gosnell, QC Supervisor, Bwd 3D. Herrmann, Byron Station Chemist, CECO 4J. Bates, Chemist, Bwd J. Burns, General Chemist, Bwd R. F. Rysner, Chemistry Engineering Assistant, Bwd J. McIntyre, Laboratory Foreman, Bwd W. Lloyd, Chemistry Engineering Assistant, Bwd E. Carroll, Chemist, Bwd D. Southcomb, Radiation Chemistry Technician (RCT), Bwd 3J. Hind, Director, Division of Radiation Safety and Safeguards (DRSS), Region III, NRC 3W. D. Shafer, Chief, Emergency Preparedness and Radiological Protection Branch, DRSS, Region III, NRC 3M. Schumacher, Chief, Radiological Effluents and Chemistry Section, EMRP Branch, Region III, NRC 1,2,sT. M. Tongue, Senior Resident Inspector (Operations), NRC 1T. E. Taylor, Resident Inspector (Operations), NRC'
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The inspectors also interviet d other licensee personnel in various departments in the course of the inspection.
1 Denotes those present at the plant exit interview on March 27, 1987.
2 Telephone conversations held on April 1, 1987.
3 Denotes those present at the special meeting between NRC and Ceco
management personnel at the Region III Office on April 3, 1987.
4 Telephone conversations held on April 7, 1987.
STelepone conversations held on April 15, 1987.
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2.
Licensee Action on Previous Inspection Findings a.
(0 pen)OpenItem(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.
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 operational.
b.
(Closed) 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 demineralizers (MUD) system.
The construction work in the secondary system sampling panel room was complete.
The ins)ector observed that it was apparently complete and operable, and le observed an RCT collect samples from it.
Presently in-line monitoring is limited to specific and cation, calibrated conductivities on the condensate and feedwater systems and to dissolved oxygen in feedwater.
Other in-line instruments, including pH, hydrazine and sodium monitors referenced in Table 9, " Secondary Process Sampling Chemical Parameters," in Chemistry procedure BWCP PD-4, "Braidwood Station Secondary Water Chemistry Program," Revision 0, approved February 25, ion will be examined in subsequent ins 1985 are installed, but not calibrated.
The instrumentat underOpenItem(50-456/87012-01;50-457/87012-01)pections
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(0 pen) Open Item (50-456/86051-02 50-457/86039-02):
RCTs to c.
qualify in the collection of samples from RCS and secondary system and to demonstrate this.
The RCTs completed their training on the routine sampling of the RCS, and about 16 have completed trainin on operation of the secondary system sam) ling panel. On April 7,g 1987, a licensee representative stated tlat the remainder will be trained and their qualification cards completed by April 15, 1987.
This item will remain open as a criticality item until the training and qualification cards are verified.
d.
(0 pen)OpenItem(50-456/87008-01;50-457/87007-01): The licensee agreed to analyze a sample from RESL for Fe-55 and report the results to Region III.
This analysis has not yet been completed.
(Closed)OpenItem(/QCdirectivetoRegionIIIandtodiscuss 50-456/87008-02;50-457/87007-02):
Licensee e.
tosendcorporateQA implementation schedule at that time.
The licensee had not yet received the approved directive at the time of this inspection, but a licensee representative did provide the inspectors with a copy of a recent draft of this directive.
However because of the resultsofthemeasurementsonthenon-radiologicalNRCsamples supplied by the inspectors, as discussed in Sections 4 and 7 of this report, licensee representatives agreed to develop and implement a QA/QC, program for these types of samples immediately.
This item is considered closed and develo will be followed under Open Item (50-456/pment of this program 87012-02;50-457/87012-02).
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3.
Management Controls, Organization and Training The inspectors did not review this area, except for the training of the RCTs as discussed in Section 2c of this report.
No violations or deviations were identified.
4.
Non-Radiological Confirmatory Measurements The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor chemical parameters in various plant systems with respect to various Technical Specification and other regulatory and administrative requirements.
These samples had been pre)ared standardized, and periodically reanalyzed (to check for staaility) for the NRC by the Safety and Environmental Protection Division of Brookhaven National Laboratory (BNL).
The samples were analyzed by the licensee using routine methods and equipment.
The samples were diluted by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory, and run in triplicate similarly to routine samples.
The results are presented in Table 1 and the criteria for agreement in Attachment 1.
These criteria for agreement are based on com the standard deviations (s.d.)parisons of the mean values and estimates of of the measurements.
Consideration was given to the fact that the uncertainties (s.d.) of the licensee's results were not necessarily representative of the laboratory's because they were obtained by one analyst doing the analyses over a short period of time.
Consequently when the licensee s.d. was less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the s.d. of the ratio Z (S in Attachment 1).
Fifteen of the 29 licensee results were in disagreement with those of BNL.
In addition, instrumental problem prevented licensee analysis of sodium.
Only the baron analysis, which showed good agreement appeared to be without problems.
It was also the only analysis for which independent calibration and control standards were used.
The copper results showed a constant bias of about 7%, indicating a possible problem with the calibration standard.
Ammonia obtained with the specific ion probe showed a bias at lower concentrations, possibly due to an inappropriate fit of the calibration data to a straight line.
Licensee representatives stated these calibrations will be checked.
The causes of the disagreements could not be ascertained, although the
problem described above appeared to be present as did possible problems with contamination of standards, reagents and/o,r laboratory glassware.
More significant than the disagreement were weakness in the laboratory QA program such that those problems are not recognized and corrected.
At a minimum, two specific improvement are needed to enable the licensee to demonstrate control of the laboratory measurement systems; the use of quality control charts and associated assessment practices to trend
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performance data and the use of separate and independent (different lots or different suppliers) standards for calibration and performance checks.
These deficiencies were discussed at the exit interview at the close of the inspection, in telephone calls thereafter, and in a management meeting (Section 7) held in the Region III office on April 3, 1987, where licensee representatives presented a plan for an improved QA program.
No violations or deviation were identified 5.
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 Sections 2 and 7.
6.
Exit Interview i
The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on March 27, 1987.
The inspectors discussed their concerns about the quality assurance program (Section 4) noting that implementation of extensive QA improvements would be forthcoming in response to the corporate directive NSDD S25.
In res)onse to inspector concerns about the extended period (of up to 30 montis) for implementation allowed by the directive, the licensee agreed to submit an action plan within three weeks for accelerated implementation of this program.
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 proprietary.
7.
Management Meeting, April 3, 1987 Representatives of licensee management and Region III management (Section 1) met in the Region III office on April 3, 1987, to discuss improvementsinthelaboratoryQAprogram.
Licensee representatives described QA goals to be achieved under NSDD S25 over a period of six to 30 months following approval of the directive.
They also presented an aggressive plan for accomplishing these goals in a much shorter time at Braidwood.
TheplanincludedtheuseofQCcharts, independent calibration and performance standards, revision of chemistry procedures, and the training of technicians.
Target dates were established for submittal of procedures to the review committee with approval expected four to six weeks later.
Licensee representatives indicated that the required RCT training can proceed during the review period.
The target dates for ion chromatography (IC) analyses of fluoride and chloride, which are required by technical specification, and of sulfate are set for May 1, 1987.
Subsequent target dates include boron by autotitrator and chloride
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and ammonia by, specific ion probes (June 1, 1987), iron and copper by atomic absorption spectrophotometry (July 1, 1987) and hydrazine, ammonia, and silica by UV-visible spectrophotometry (July 1,1987). This plan is
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responsive to the inspector concerns raised during this inspection.
The station's progress in meeting /87012-02; 50-457/87012-02)
these targets will be monitored in future inspections. (0 pen Item 50-456
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Attachments:
1.
Table 1, Non-radiological Interlaboratory Test Results, Braidwood
2.
Attachment 1, Criteria for Comparing Analytical Measurements
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TABLE 1 Non-Radiological Interlaboratory Test Results Braidwood Nuclear Generating Station, Units 1 and 2 March 23-27,-_1987 b,c Comparison Analysis NRC Licensee Ratio Comparison i
Parameter Method Y i s.d.(n)a Xis.d.(n)a Z i s.d.a 12 s.d.
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Concentration, ppm
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Boron Titra-2980 1 50(7)
2999.3 1 0.2 1.006 1 0.017 A tion 4870 1 60(6)
4968.4 1 3.7 1.020 1 0.013 A Concentration, ppb Fluoride IC 11.6 i0.25(8)
9.74 i 0.09 0.84 1 0.03 D*
21.7 i 0.95(8)
20.28 i 0.11 0.935 1 0.041 A 41.7 1 1.4(7)
33.80 1 0.03 0.810 1 0.03 D
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9.40 1 0.86 0.078 1 0.12 A
18.7 i 0.60(7)
15.4 1 0.10 0.82 i 0.042 D*
l 40.2 1 1.5(8)
34.4 i 0.66 0.86 i 0.05 D*
Chloride Probe 12.0 11.5 21.3 i 1.2 1.77 i 0.24 D
l 18.7 1 0.6 28.7 11.2 1.53 1 0.08
40.2 i 1.1 55.0 1 0.0 1.37 i 0.04 D
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Sulfate IC 10.0 1 0.45(7)
14.7 i 4.3 1.47'.i 0.44 A
20.5 i 1.2(8)
14.5 i 1.3 0.71 1 0.08
40.4 1 1.5(7)
32.9 i 0.58 0.814 1 0.033 D
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Silica Saectro-27.1 1 2.8 39.0 1 2.6 1.44 i 0.18
ploto- '
54.5 i 3.5 58.5 1 0.59 1.07 i 0.07 A
metric 80.0 t 2.5 79.8 1 2.2 0.998 1 0.04 A
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125.0 1 6.9 1.28 1 0.12 D
95.5 13.4(14)
116.7 1 2.1 1.22 i 0.05 D
147 i 4(13)
164 i6 1.11 i 0.05
101 1 2.6 1.08 i 0.06 A
96.6 1 4.9(4)
103 i 0.58 1.07 i 0.05 A
145 16(13)
156.
i 1. 5 1.07 1 0.05 A
I Ammonia Probe 175 i 16 197 1 14 1.12 1 0.10 A
314 1 26 342 i 24 1.09 i 0.18 A
j 938 i 85 938 1 25 1.00 1 0.09 A
Hydrazine S)ectro-22.3 11.4(7)
21.2 1 0.56 0.95 1 0.065 A p 10to-56.9 i 0.7(7)
48.7 i 0.57 0.86 1 0.015 D metric 104 i 1(7)
118.9 i 3.8 1.14 1 0.04 D
i a.
Value i standard deviation (s.d.); n is number of BNL analyses.
i The number of licensee analyses is 3 unless otherwise noted.
b.
A = A reement D = D sagreement
- Used BNL uncertainty for licensee's uncertainty i.
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ATTACHMENT 1
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Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing results of the capability tests.
The acceptance limits are based on the uncertainty (standard deviation) of the ratio of the licensee's mean value (X) to the NRC mean value (Y), where l
(1) Z = X/Y is the ratio, and (2) S is the uncertainty of the ratio determined from the pfopagationoftheuncertaintiesoflicensee'smeanvalue,
S, and of the NRC's mean value, S.1 Thus, x
y S*
S*
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Z2-F- + k, so that z _ x
[S*2 s2D S =Zel
+ 1-
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z (X2 y2)
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The results are considered to be in agreement when the bias in the ratio
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(absolute value of difference between unity and the ratio) is less than or equal to twice the uncertainty in the ratio, i.e.
l 1-Z l $,2*S 7
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1.
National Council on Radiation Protection and Measurements, A Handbook of Radioactivity Measurements Procedures, NCRP
Report No. 58, Second Edition, 1985, Pages 322-326 (see
Page324).
i 4/6/87
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