IR 05000456/1987037
| ML20235U440 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/02/1987 |
| From: | Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20235U429 | List: |
| References | |
| 50-456-87-37, 50-457-87-35, NUDOCS 8710140092 | |
| Download: ML20235U440 (7) | |
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l U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/87037(DRSS); 50-457/87035(DRSS)
Docket Nos. 50-456; 50-457 Licenses No. NPF-59; CPPR-133 Licensee: Commonwealth Edison Company i
Post Office Box 767
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Chicago, IL 60690
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Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braceville, Illinois I pection Conducted:
September 21-23 and 25,1987 (0nsite)
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$ YrAbb y Inspector:
R. B. Holtzman Date f d$ /,wdc u
Approved By:
M. C. Schumacher, Chief
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Radiological Effluents and Date Chemistry Section Inspection Summary Inspection on September 21-23 and 25,1987 (Reports No. 50-456/87037(DRSS);
No. 50-457/87035(DRSS))
Areas Inspected:
Routine unannounced inspection of: (1) the chemistry program, including procedures, organization, and training; (2) primary and secondary
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systems water quality control programs; and (3) progress in the development I
of the quality assurance / quality control program in the laboratory.
Results: No violations or deviations were identified.
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DETAI,LS 1.
Persons Contacted
- E. E. Fitzpatrick, Station Manager, Braidwood (Bwd)
- R.'E. Aker, Radiation-Chemistry Supervisor, Bwd
- P. L. Barnes, Regulatory Assurance Supervisor, Bud
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- M. Takaki, Regulatory. Assurance, Bwd
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- R. D. Kyrouac, Station QA Supervisor, CECO
- J. B. Cronin, Station Chemist, Bwd
- F. D. Bevington,.QA Inspector, CECO
- L. M. Kline, Regulatory Assurance, Bwd
- R. C.. Bedford, Regulatory Assurance, Bwd
- W. E. Lloyd, Chemistry Engineering Assistant,.Bwd
- E. W. Carroll, Regulatory Assurance, Bwd M.' E. Burgess, Group Leader, Analytical Chemistry Services, Nuclear Services, CECO Z. Luke, Start-up Test Engineer,Bwd D.-Kozin, Chemist, Bwd R. F. Rysner, Chemistry Engineering Assistant, Bwd J. McIntyre, Chemistry Foreman, Bwd R. Erwin, Chemistry Foreman, Bwd T. Benoit, Radiation Chemistry Technician (RCT), Bwd M. Beaumont, RCT, Bwd
- T. E. Taylor, Resident Inspector.(Operations), NRC The inspectors also interviewed other licensee personnel in various departments in the course of.the inspection.
- Denotes those present at the plant exit interview on September 25, 1987.
2.
Licensee Action on Previous Inspection Findings a.
(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
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Wilmington, Illinois after the Braidwood Station is in operation.
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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.
(0 pen) Open Item (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.
c.
(Closed) Open Item (50-456/87012-01; 50-457/87011-01): To demonstrate the collection of samples, the operation and calibration of in-line monitors for secondary chemistry control,-and the testing of the condensate. polishers and the makeup demineralized system. The;
. sampling system and in-line monitors on Unit I were reviewed by the
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inspector and were operational and calibrated.
The sampling system has been completed for Unit 2 and was used during the Integrated Hot Functional Tests (IHFT).
This item is considered closed.
However, since for the Unit 2 panel, repairs and calibrations are still in progress, and the operability of this system can not be demonstrated until steam is available, those activities relating to Unit 2 will be followed in a subsequent inspection under Open Item No. 50-457/87035-01.
The collection of samples and the calibrations of the in-line instruments must be demonstrated by 5% power.
d.
(Closed) Open Item (50-456/87012-02; 50-457/78012-02): The licensee agreed to improve the laboratory QA program for chemical analyses by revising various critical analytical procedures.
The licensee revised the procedures for fluoride, chloride and sulfate by ion chromatography (IC) (scheduled for submission to the Onsite Review (OSR) Committee by May 1, 1987), boron by titration, and ammonia and chloride by specific ion probe (by June 1,1987), iron and copper by atomic absorption spectrophotometry, and hydrazine, ammonia and silica by UV/ visible spectrometry (by July 1, 1987).
Although no specific documentation on the above completion dates was available, the committed target dates appear to have been met, based on final approval six weeks after submission for OSR.
These procedures are fully-approved and in the procedures manuals, the RCTs are trained in the the revised procedures, and control charts have been started.
This item is considered closed. The program is discussed further in Section 6.
3.
Management Controls, Organization and Training The licensee has appointed a new Station Chemist, who reports to the Rad-Chem Supervisor, and is supported by five Chemists, four Engineering Assistants, and two Chemistry Foremen.
Prior to this assignment, the Station Chemist had been the General Chemist in the plant for several years.
She set up and supervised the counting room, is generally knowledgeable about matters relating to plant chemistry, has been responsible for developing the QA/QC program for analytical measurements,
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and has trained the Rad-Chem Technicians in chemistry and radiochemistry.
She meets the personnel requirements for radiochemist under ANSI N18.1-1971.
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Although the training and supervision of 39 RCTs who are in the laboratory only part-time appears to be a heavy burden on the staff, the organization appears to be adequate to do the chemistry required for plant operations.
No violations or deviations were identified.
4.
Water Quality Control Program for the Primary and Secondary Systems The inspector observed the HRSS used for routine sampling of the reactor coolant system (RCS) for Unit 2.
A licensee representative stated that it is operational and had been used to samp7e the RCS during the IHFT.
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r While use of the HRSS can not be demonstrated until the reactor vessel is pressurized prior to startup, a suitable alternative would be RCS. samples taken at local' points, e.g;, at the RHR-pump discharge. This sampling will-be observed at a subsequent inspection. The use of the HRSS for routine' samples must be demonstrated prior to attaining 5% power. These.
will be followed under Open' Item 50-457/87035-02-.
The representative also noted-that the in-line emergency Chemical Analysis-Panel-(CAP) was also operational, with the Unit 2 HRSS_being connected to the Unit 1 CAP through a system'of interlocked and check valves to prevent the interchange of fluids between the Units 1 and 2 reactor vessels, a-possible problem first identified 'in the similar CAP system at Byron.2 The inspector noted that secondary system sampling panels had in-line -
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instrumentation with strip chart recorders to continuously monitor pH, specific and cation conductivities, and sodium, and dissolved oxygen concentrations. This instrumentation appears to be a very useful adjunct to the laboratory grab sample program._ The operability of the Unit 2 panel will be followed in subsequent inspections under Open Item No. 50-457/87035-01 (Section 2c).
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'The inspector reviewed the program for trending water quality data for the various process chemistry parameters. The laboratory produced monthly trend charts for management showing the t' rends in the primary system for dissolved oxygen, chloride, fluoride and tritium concentrations.
In addition, the chemist also trended other parameters in the_ primary system,
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including lithium, hydrogen, silica and boron concentrations.
Lithium concentrations were maintained within the narrow limits of 1.6-1.8 ppm to prevent dissolution of the protective magnetite film on the reactor i
vessel. surfaces, as advised by Westinghouse specifications. Hydrogen is
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also maintained within. narrow limits to balance the effects of oxygen corrosion against hydrogen embrittlement.- Silica concentrations have i
gradually decreased as the reactor vessel and reagents have been cleaned
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up through operation.
The plant procedure controlling secondary water chemistry BwdCP PD-4,
"Braidwood Station Secondary Water Chemistry Program", Revision 0, February 22, 1985, generally conforms _with the recent EPRI Steam.
Generators Owners Guidslines (EPRI NP 5056-SR,' Revision 1, March 1987).
The main differences are that the procedure sometimes requires more frequent sampling and additional parameters to be measured than do the Guidelines. The procedure is presently being' revised to remove the unnecessary parameters, such as the determination of chloride in feedwater (measurable chloride concentration 'here would be associated with many times this amount in the steam generator blowdown). A detailed examination of the proposed revisions showed that.the relevant parameters were consistent with the Guideline recommendations.
The various parameters, measured at various sampling _ points, were plotted on charts 1.
Region III Inspection Reports (50-454/86041; 50-455/86037).
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generated periodically (weekly or monthly), including chloride, sulfate, fluoride, specific and cation conductivities, ammonia, dissolved oxygen and hydrazine.
The chemist is preparing to plot these by hand on a daily basis to obtain a more timely and satisfactory picture of system conditions and better control of the parameters.
Because the plant has been critical only since May 1987, the systems are still being cleaned up, so that some of the parameters are not fully under control, such as sulfate derived from turbine preservative that is leached from the blades and gets into the condensate.
In general, the various parameters representing contamination appear to be decreasing in satisfactory manner. The plant has not been out of Technical Specifications limits for chemistry and presently does not use the performance indicator of time out-of-specification.
While the water quality control program is still under development, it is presently very useful and is progressing satisf actorily.
No violations or deviations were identified.
5.
Implementation of the Chemistry Programs The inspector reviewed the progress in implementing the chemistry programs.
The laboratories have good bench, fume hood and floor space.
The housekeeping was very good.
The inspector observed several RCTs analyze routine samples on the UV/ visible spectrometers and ion chromatography.
They appeared to be generally knowledgeable about the work and followed the procedures.
In one of the analyses the RCT recognized some faulty results and, as called for by procedure, notified the foreman. They appeared to do well in the analyses.
Overall, the laboratory appeared to be adequate for the proper operation of the plant and to be operating satisfactorily.
No violations or deviations were identified.
6.
Implementation of the QA/QC Program in the Chemistry Laboratory l
The inspector reviewed progress of the development of the non-radiological
Chemistry QA/QC program. The program is required by the Corporate i
directive, Nuclear Stations Chemistry Quality Control Program, NSDD-25, January 1987, and implemented in the newly revised BwCP PD-7, "Braidwood
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Station Chemistry QA/QC Program," Revision 3, July 14, 1987.
In addition to the revisions of the procedures listed in Section 2d, the licensee has revised over 200 procedures to improve the laboratory QA/QC program, including those for making standard solutions, reagent control, and the overall QA program.
Most of these procedures are in the final stages of official approval.
The analytical procedures require the use of QC charts, and computer generated charts have been implemented for boron, fluoride, chloride, silica, and total organic carbon.
The control
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limits are set at +2. standard deviations, as presently mandated by the above Corporate directive. A logbook that contains the QC data, charts and maintenance information has been initiated for each instrument.
In conformance with NRC suggestions,- the procedures now require that the control standards be from different sources than the calibration standards.
The inspector noted several concerns about the program:
namely that the computer generated charts were not.likely to be timely and help the chemist and RCT notice deviations, that procedures were not available to control the production of the charts, and that the concentrations of the control standards to be used for the charts were not given in procedures.
Licensee representatives agreed to have the RCTs generate the charts to make them more timely, but they believed that placing the other information in procedures would restrict the flexibility of the chemists to modif.y conditions as analytical needs change.
Licensee representatives stated that the program would be fully-operational by November 1,1987, with control charts generated by the RCTs. Acceptance (control) limits would be based on +2 standard deviations for most analyses. This will
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be followed in subsequent inspections under Open Item (50-456/87037-03; 50-457/87035-03).
While the licensee normally participates in the quarterly corporate non-radiological interlaboratory comparison program, they did not do so in the last round because they were involved in the Unit 2 IHFT.
From the inspector's discussions with the corporate coordinator, it appears that the program has progressed to the point where the coordinator has sufficient data from the participating laboratories to set acceptance limits on the analytical data.
The results demonstrated that some of the analytical methods have weaknesses that produce large discrepancies from the known values. The Tech Center is investigating the causes and possible corrective actions for these deficiencies.
The licensee's QA/QC program has progressed satisfactorily since the previous inspection and it appears that it will be a good program.
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No violations or deviations were identified.
7.
Audits and Appraisals f
The inspector found that the Corporate QA Department had not audited the chemistry group since the previous inspection.
However, the Department had found, by analysis of data from a series of surveillance, a weakness
in the plant's system for maintaining temporary changes to procedures.
l This was particularly important for Chemistry because they are just progressing to the operating mode and must constantly modify their procedures. The QA Department found that RCTs using procedures with several temporary changes did not always obtain the whole set of changes, not all of the changes were in the controlled copies of the procedure books, and, because of the press of time, the RCT did not always check with the Main Files or the Shift Supervisor. The plant is now modifying the administrative procedures so that a procedure may have only one temporary change; all previous ones would be incorporated into the latest.
This appears to improve the reliability of procedure maintenance.
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No violations or deviations were identified.
8.
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, 4 and 6.
9.
Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on September 25, 1987.
The inspector discussed ~the sampling of the Unit 2 primary and secondary systems and the quality control program described in Sections 2, 4 and 6.
During the exit interview, 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 processes as proprietary.
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