ML17303B036
| ML17303B036 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/30/1988 |
| From: | Tenbrook W, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17303B033 | List: |
| References | |
| 50-528-88-08, 50-528-88-8, 50-529-88-08, 50-529-88-8, 50-530-88-08, 50-530-88-8, NUDOCS 8804190160 | |
| Download: ML17303B036 (15) | |
See also: IR 05000528/1988008
Text
U.
S ~
NUCLEAR REGULATORY COMMISSION
REGION V
Report
Nos.
50-528/88-05,
50-529/88-05
and 50-530/88-05
Docket Nos.
50-528,
50-529
and 50-530
License
Nos.
Licensee:
Arizona Nuclear
Power Project
P.
0.
Box 52034
Phoenix,
Arizona 85072-2034
Facility Name:
Palo Verde Nuclear Generating Station - Units 1,
2 and
3
Inspection at:
Palo Verde Site - Wintersburg,
Inspection
Conducted:
February 23-24,
1988,
February
29-March 3,
Inspected
by:
2) 3
W.
K.
e
rook,
Rad
tion Specialist
D te
Approved by:
G.
P.
u as,
Chief
Facility
s Radiological Protection Section
1988
igned
Signed
~Summar:
Ins ection durin
the
eriod of Februar
23-24 and Februar
29-March
3
1988
Re ort Nos.
50-528/88-08
50-529/88-08
50-530/88-08
radiochemical
analyses,
chemistry control, chemical analysis,
onsite followup
of inpector identified items
and plant tours.
Inspection procedures
30703,
79701,
84725
and 92701 were addressed.
Results:
Based
on the areas
inspected,
the licensee's
chemistry program
appears
to be adequate
to fulfillits safety function.
Strong performance
was
observed in the areas
of laboratory analytical control standards
for
non-radioactive
analytes
(Section 3) and plant chemistry control (Section 3).
Weak areas
observed
were the implementation of the interlaboratory
comparison
sample
program for radiological analysis
(Section 4) and one example of a lack
of attention to detail regarding proper implementation
and review of a gaseous
radioactive
release
permit (Section 4).
The latter example resulted in a
violation for failure to implement procedural
detection limits for
radioactivity analysis of a waste
gas
decay tank sample.
SS04190160
SS0330
PDf'DOCK 0500052S
Q
Persons
Contacted
Licensee
- L. Brown, Manager,
Radiation Protection
and Chemistry
- R. Butler, Director, Standards
and Technical
Support
- J. Cederquist,
Supervisor,
Chemistry Standards
"W. Doyle, Manager,
Unit 2 Radiation Protection
"R. Ferro,
Manager,
Unit 2 Chemistry
"D. Fuller, Manager,
Unit 1 Chemistry
C. Gray,
Lead Technician,
Unit 3 Chemistry
~J.
Haynes,
Vice President,
Nuclear
Production
~J.
Mann, Supervisor,
Health Physics Controls
R.
Ochoa,
Lead Health Physicist,
Health Physics Controls
~R.
Rouse,
Engineer,
Compliance
"J. Schlag,
Supervisor,
Radioactive
Waste Standards
~J.
Schmedeke,
Manager,
Operations
Computer
Systems
"J. Scott,
Manager,
Unit 3 Chemistry
- R. Selman,
Manager,
Central
Radiation Protection
"J.
Shawver, Scientist,
Chemistry Standards
"W. Sneed,
Manager,
Unit 3 Radiation Protection
- L. Souza,
Manager, guality Audits and Monitoring
- E.
Van Brunt, Jr.,
Executive Vice President,
D. Whitcomb, Senior Scientist,
Chemistry Standards
U.S.
Nuclear
Re ulator
Commission
"H. North, Senior Radiation Specialist,
Region
V
"T. Polich, Senior Resident Inspector,
Palo Verde
Denotes individuals attending exit interview on March 3,
1988.
Fpl 1 owu
92701
Open Item 50-528/87-04-01
(Closed)
This matter concerned
the capability
of vendor laboratories
to obtain accurate
measurements
of Sr-89/Sr-90
and
H-3 as reflected
by analysis of an
NRC blind sample.
The licensee's
contractor laboratory analyzed
the
NRC sample
and
had obtained
adequate
measurements
for Sr-89 and tritium, but had not obtained
adequate
accuracy for Sr-90.
The inspector
reviewed records
submitted to the
licensee
from the licensee's
contract laboratory describing the
contractor's participation in the Environmental
Protection
Agency (EPA)
Intercomparison
Program.
Two samples of Sr-90 in water were analyzed
by
the contractor in 1987.
The results of the
EPA intercomparison
indicated
adequate
agreement.
The licensee
did not submit any
additional'lind
samples
to its vendor laboratory beyond the sample provided by NRC.
Based
on the adequate
performance of the licensee's
contractor in the
intercomparisons
for Sr-90 in water,
1987, this item is considered
cl osed.
LWR Chemistr
Control
and Chemical
Anal sis
79701)
The inspector
reviewed guality Assurance
Audit Report
No.87-007,
"ANPP
Plant Chemistry".
The audit was conducted
March 6-April 3,
1987
and
was
applicable to all three units.
Content of the audit included
Systems
Chemistry Specifications
and Chemistry Control Instructions,
Nuclear
Sampling,
Document Control, Secondary
Water
Chemistry,
Post-Accident
Sampling.and
Laboratory Analytical Control.
An emphasis
was placed
on
Laboratory Analytical Control.
Three Corrective Action Requests
(CAR)
and four items requiring follow-up were generated
as
a result of Audit
87-007.
One
CAR, CA87-0041, involved safeguards
information and
had not
been closed at the time of the inspection.
The two remaining
CARs are
described
below:
CA87-0047, Failure to meet two week deadline for submittal of reviewed
surveillance test packages
to
SPGC.
CA87-0049, Various instances
of nonconformance
with chemistry procedures.
The inspector evaluated
the follow-up to CA87-0047
and CA87-0049.
The
response
from the Manager,
Chemistry Services
and subsequent
gA closeout
was
documented for both
CARs.
Given the number of deficiencies
described
in CA87-0049,
gA gave only partial approval
to the initial response,
and
requested
additional
commitment for more extensive
review of the subject
procedures
by chemistry personnel.
The final response
and
gA approval
were documented.
All four Monitoring Reports requiring followup generated
by Audit 87-007
were closed
by gA at the time of the inspection.
The inspector
examined twelve guality Monitoring Reports in the chemistry
area
from the year
1987.
Each Monitoring Report
had been closed at the
time of the inspection.
The inspector also verified that Chemistry
Control Instructions
(CCIs) for dispersant
addition to the Unit 1
essential
spray pond system
had been
issued
by Unit 1 chemistry in
response
to Monitoring Report ST-87-1011.
Changes
to the chemistry control
and analysis
program were identified in
two areas:
Sampling
and analysis practices
and laboratory facilities.
Procedure
"Sampling and Analytical Schedule",
has
been
amended to delete the circulating water
system analytical
s'chedule
and to
include
pH and halogen analysis
on closed cooling systems
and to specify
the frequency of Reactor Coolant System
(RCS)
ammonia analysis
during hot
functional testing.
Changes
to the unit laboratories
included the
procurement of a
new ion chromatograph for analysis of RCS..organic
acids
at Unit 2.
Contamination of the cold-side laboratory area
and steam
generator
blowdown demineralizer
system
had occurred in Unit 1 due to a
primary-to-secondary
system leak.
Areas with non-removable
contamination
remained at the Unit 1 wet racks
and sample sinks.
Cleanup operations
were continuing at the Unit 1 blowdown demineralizer
system.
No changes
were identified in chemistry control action levels or procedures
for
chemistry control implementation.
A major reorganization
of chemistry personnel
was completed in 1987 as
part of an overall reorganization of ANPP staff.
The Chemistry Services
Department,
under the authority of the site-wide Plant Manager,
had
previously implemented
the plant chemistry program via three Unit
chemistry organizations
answering to the Chemistry Services
Manager.
The
licensee's
reorganization
had eliminated the position of site-wide Plant
Manager
in favor of three Plant Managers,
one assigned
to each Unit.
Also, the Chemistry Services
Department
was eliminated in favor of a new
Chemistry Standards
Department.
Following the reorganization,
the
chemistry staff associated
with each Unit were under the authority of the
Unit's assigned
Plant Manager.
The inspector
observed that the Chemistry
Standards
Department did not have direct supervisory authority over the
Unit chemistry organizations.
The inspector did not identify any
new
administrative
channels
by which Chemistry Standards
could effect change
in the Unit chemistry organization.
At the time of the inspection, it
appeared
that the Chemistry Standards
Department's
means
for affecting
Unit chemistry performance
were programs for procedure
improvement,
such
as refinement of laboratory procedures
and systems
chemistry
specifications,
implementation of various aspects
of the laboratory
analytical control program,
and technical
assistance
to the Unit
chemistry organizations.
Given that the site-wide Chemistry Services
Department
was eliminated,
the performance
of the Unit chemistry
organizations
in implementing the chemistry program
and Chemistry
Standards
Department initiatives were particularly dependent
upon the
Unit Plant Manager
and Unit Chemistry Manager.
The inspector
reviewed Chemistry Control Instructions
(CCIs) at the unit
chemistry laboratories.
The chief sources
of CCIs were elevated
levels
of sodium (greater
than
20 ppb) in feedwater/steam
generator
blowdown and
ongoing
needs for control of pH and dispersant
in the essential
spray
pond system.
The Chemistry staff and
Radwaste staff of Units
1 and
2
were pursuing
means to minimize sodium intrusion to the secondary
system
by refining techniques
for condensate
demineralizer
regeneration
and
improving resin layering.
The sodium intrusion problem appears
to be
largely corrected in Unit 2.
Procedure
74CH-9XC16, "Sampling and Analytical Schedule",
Procedure
"Systems
Chemistry Specifications",
and Procedure
"Chemistry Control Instructions" basically constitute
the licensee's
chemistry control program.
'These
procedures
provide for analysis of
appropriate plant samples,
acceptance
criteria for analytical results,
and corrective actions for conditions out of specification.
The
licensee's
program fulfills the requirements
of technical specification 6.8.4,
item (c), Secondary
Water Chemistry.
The inspector
reviewed the licensee's
program for laboratory quality
assurance
for non-radioactive
analytes.
The Chemistry Standards
group
implements
an analytical blind program at each Unit laboratory.
The
analytes
and the
number of samples
analyzed
in 1987 are presented
below:
~Anal te
uantit
of Sam les
Hydrazine
27
Fluoride
Chl ori de
Sul fate
Sodium (25 ppb)
Silica
Phosphate
Ammonia
Total Organic
32
32
31
28
21
21
98
35
36
18
23
39
27
The analytic blind program
has
been effective in identifying problems in
Unit laboratories
such
as difficulties with copper analysis
in Unit l.
However, strict criteria for acceptance
and corrective action were not
implemented.
The Chemistry Standards
Department
was developing
more
rigorous acceptance
criteria for Unit laboratory measurements
of analytic
blinds.
The inspector
reviewed documentation
in Unit 2 and Unit 3 laboratories
associated
with the atomic absorbtion
spectrophotometer
(AA) and ion
chromatograph
(IC).
Spikes
and replicates
were provided as required for
the instruments
examined.
Verifications of calibrations
and
recalibrations
were performed
as required.
No control charts
were kept
for the
or calibration verifications
are
procedurally required before
each analysis to maintain instrument
accuracy.
The inspector
reviewed reactor coolant chemistry surveillances
for
dissolved
oxygen, flouride, chloride and boron at Unit 2 and Unit 3.
Results
were reported
as "less than" levels at both Units.
Unit 3 "less
than" values for fluoride and chloride were
one order of magnitude
below
TS requirements.
However, Unit 2 "less than" values
were approximately
equal
to the
TS values.
The Unit 2 Chemistry Manager explained that the
analysis for chloride was
more sensitive
than the "less than" value, but
the fluoride sensitivity by ion selective
electrode
was consistent with
the "less than" value,
100 ppb.
The ion selective electrode
is
considered
the method of choice for RCS fluoride monitoring by industry
groups.
Also, utility experience
indicates that good
RCS chemistry
control can reduce reactor coolant fluoride to less
than
50 ppb.
This
suggests
that an improvement of RCS fluoride measurement
sensitivity to a
level at or below 50 ppb should
be possible with the apparatus
available.
As noted above,
the Unit 1 and Unit 2 laboratories
have procured
advanced
ion chromatographs,
which has
been successfully
used for fluoride
analysis at Unit 3.
The inspector
discussed
with the licensee
representative
the valve in
reviewing reporting practices for analyses
to assure that "less than"
values actually reflect a measurement
below instrument sensitivity.
If
analytical sensitivity for for a given
RCS chemistry surveillance
are
approximately
equal
to the Limiting Condition for Operation,
then
analytical sensitivity provides
no operating margin below the
TS steady
'C
state limit.
This matter will be tracked
as
an "Open Item"
(50-529/88-08-01) for examination in a future inspection.
The licensee's
program for chemistry control
and analysis
appears
capable
of fulfillingits safety function.
An improving trend is noted in the
implementation of the analytical blind program.
Continued
management
support is encouraged
in the area of feedwater
sodium control to
disseminate
lessons
learned
between Unit organizations
involved in
secondary
chemistry
and condensate
demineralizer operations.
The
licensee
representative
indicated that they would review the adequacy of
analytical sensitivities for RCS chemistry
and reporting of data
from
survei llances.
No violations or deviations
were identified.
ualit
Assurance
and Confirmator
Measurements
for In-Plant
Radiochemical
Anal sis
84725
The inspector
reviewed the licensee's
program for quality assurance
of
laboratory radiological
measurements.
The Chemistry Standards
Department
began participating in a laboratory analytical blind program for
radioactive analytes
in 1987.
A private laboratory provided
a single set
of blind samples
on
a quarterly basis.
The samples
contained
alpha,
beta
and
gamma activity in solid, liquid and gas matrices
commonly found at
nuclear
power facilities.
Chemistry Standards
then provided the sample
set to each unit laboratory for analysis.
The licensee's
contractor for
this service is employed
by many other facilities in the U.S.,
and the
content of the program is regarded
as excellent.
The agreement criteria
used
by the contractor for assessing
the licensee's
results is
substantially similar to those
used
by the
NRC confirmatory measurements
program.
The administration of the radiological blind sample
program
has
encountered difficulties in 1987.
The sample set for the third quarter,
1987,
was misplaced prior to analysis
by the Unit laboratories.
The
sample set for the fourth quarter,
1987,
had not been
exchanged with Unit
2 laboratory.
The Unit 2 Chemistry Manager stated that radiological
blinds had not been analyzed in the Unit 2 laboratory since the October,
1987 reorganization of Unit chemistry personnel.
The inspector
examined selected quality control records
and practices
at
the Unit 1 and Unit 2 laboratories
for gas flow proportional
counters
(gross
alpha
and beta analysis)
and
gamma spectrometers.
Proportional
counters
had been annually calibrated for gross
alpha
and gross
beta
measurements,
and control logs and charts
were kept for alpha
and beta
efficiency response
and background.
Gamma spectrometers
had been
annually calibrated for the four liter Marinelli beaker
geometry,
and
control logs were kept for centroid channel, efficiency response
and
resolution,
each at two energies.
Control charts
were kept for
efficiency response
at two energies.
The inspector
examined
records of analyses
of cooling water hold-up tank
(CWHUT) samples,
Chemical
Waste Neutralizer
Tank
(CWNT) samples
and Waste
Gas
Decay Tank
(WGDT) samples to determine
compliance with chemistry
procedures
and radioactive effluent technical specification
requirements.
The
CWHUTs at Unit 2 and Unit 3 were analyzed shiftly for indications of
intrusion of activity to the
CWNTs.
The
CWNT was promptly surveyed for
total activity content
by Unit 2 chemistry laboratory following an
addition of activity in February,
1988, per
TS 4. 11. 1.3.
The inspector
reviewed
WGDT grab
sample
analyses
for radioiodine,
noble
gas
and particulates
at Unit 2 and Unit 3.
The analyses
for radioiodine
and particulates
were satisfactory at both Units.
However,
Gaseous
Radioactive
Release
Permit 882044,
Update
1, dated February
27,
1988
contained
an analysis of a
WGDT "B"
noble
gas
by Unit 2
chemistry laboratory that did not meet the lower limits of detection
(LLDs) required
by Procedure
"Gaseous
Radioactive Effluent
Release
Administrative Control", Appendix B, "Effluent Sampling
Schedule".
The inspector
noted that the licensee
does not employ an
~a
riori
LLO determination of measurement
system sensitivity for
radioactive effluent measurements,
but instead relies
on review of all
analytical
data
from the count room to insure that each
measurement
meets
properly
implemented,
would insure
adequate
sensitivity for each
analysis.
However, if the
LLDs were not met for a particular sample,
there
was
no
~a
riori data to verify that the measurement
method
was
adequate.
The subject analysis,
dated
February 25,
1988,
involved a
WGDT
"B" noble
gas
sample in a 9.2
ml vial, 1020 seconds
counting time.
The
required sensitivity for principal
gamma emitters
was
1 E-4 uCi/ml.
The
following detection limits exceeded
those required:
Radionuclide
Re orted Detection Limit
uCi/ml
Kr-87
Kr-88
1.6 E-4
1.9 E-4
3.6 E-4
The licensee
stated that the subject analysis
was part of an effluent
technician training activity, and the results
obtained
were intended to
verify that
WGDT "B" could be released within the limits of TS 3. 11.2. a.
The effluent technician verified that the release
was within TS 3. 11.2.a
limits, and identified the
LLD deficiency in the analytical
data.
Two
hours
had elapsed
since the initial sampling,
so an additional
sample
was
obtained in keeping with internal laboratory practice.
However,
laboratory technicians
erred in assuming
the initial sample
had fulfilled
all analytical
requirements.
The second
sample
was not analyzed
and the
permit was subsequently
issued with the deficient analytical
data
attached.
This occurred despite
review by an effluent technician
as
verified by initial on the "Permit Package
Checklist" under "Check for
Correct LLD's".
No completion or review signitures
were found on the
Ortec
"Gamma 1" data for the sample,
per internal laboratory practice.
WGDT "B" was released
to the environment
on February
26, 1988,'t 3:58
am.
The noble
gas activities exceeding
the procedural
LLDs were entered
into the Gaseous
Radioactive Effluent Tracking System after the inspector
identified the deficient analysis.
No Limiting Conditions for Operation
were exceeded
by the release.
It appears
that the cause of the analytical deficiency was
a poor
turnover between
the technician
who identified the
LLD deficiency in the
first sample,
and the laboratory personnel
responsible
for analysis of
the second
sample.
Procedures
for effluent administrative control,
effluent permits,
gaseous
effluent surveillance
and
gamma analysis
state
that
LLDs are to be met, but contain
no guidance
as to actions to be
taken for analyses
not meeting analytical sensitivities to insure that
adequate
analytical
data are obtained.
The inspector
reviewed six waste
gas
decay tank release
permits
from the
latter half of 1987.
No additional deficiencies
were identified.
This
is the second
incidence of radioactive effluent release
to the
environment without meeting required detection limits.
On August 7,
1987,
NRC Region
V received
Licensee
Event Report,
LER 87-016-00,
from
the licensee
describing the release
of liquid effluent from Unit 2
Chemical
Waste Neutralizer Tank to the onsite evaporation
pond without an
analysis
adequate
to meet the
by TS Table 4. 11-1.
The deficiency in the analysis
contained in Permit 882044
was
subsequently
identified as
an apparent violation of TS 6.8. 1
(50-529/88-08-02).
The
NRC mobile laboratory
was not operable at the time of the inspection.
Confirmatory measurements
will be performed
on split samples
and
replicate
samples
during
a future inspection.
The licensee's
program in the area of radiochemical
measurements
is
adequate
to carry out its safety function.
However, additional attention
is warranted to insure proper implementatation of procedures
for
radiological analytic blinds and review of analytical
data for
radiological effluents.
One apparent violation was identified involving
gaseous
effluent administrative control.
5.
Exit Interview
The inspector
met with the licensee
management
on March 3,
1988 to
discuss
the scope
and findings of the inspection.
The licensee
was
informed that the failure to obtain
a gas
sample analysis of Unit 2 waste
gas
decay tank "b" sufficient to meet the detection limits specified in
TS Table 4. 11-2 was
an apparent violation of TS 4. 11.2. 1.2.
1
P