ML18052B252
| ML18052B252 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/28/1987 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8709020102 | |
| Download: ML18052B252 (5) | |
Text
consumers Power POWERINli MICHlliAN'S PROliRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 August 28, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR-PALISADES PLANT -
RESPONSE TO CONCERNS IN NRG INSPECTION REPORT 50-255/87017 NRC Inspection Report 50-255/87017 dated August 13, 1987 identified a number of recommendations and concerns regarding the chemistry program at Palisades.
This inspection report specified a commitment for Consumers Power Company to submit a letter by August 28, 1987 addressing the concerns and recommendations identified in the inspection report and previously discussed during the inspection and during follow-up phone calls. Attached to this letter is Consumers Power Company's response to the recommendations and concerns.
The topics are numbered as they were numbered in Inspection Report 50-255/87017.
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, NRG NRC Resident Inspector - Palisades Attachment 8709020102 870828 PDR ADOCK 05000255 G
PDR OC0887-0141-NL04
- C£~1 1/f
l ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO CONCERNS IN NRC INSPECTION REPORT 50-255/87017 August 28, 1987 3 Pages OC0887-0141-NL04
RESPONSE TO CONCERNS IN NRC INSPECTION REPORT 50-255/87017
- 4.
"Implementation of the*Chemistry Program"
- a.
Laboratory Operations Concern:
A few bottles of purchased Atomic Absorption (AA) standards were not receipt dated.
Response
A review of in lab reagents confirmed several concentrated AA standards were not receipt dated.
These standards had not exceeded their expiration dates.
Once these standards are diluted for actual lab work, preparation and expira-tion dates are placed on the labels of the diluted stan-dards.
These diluted standards are checked weekly to insure the standards are useable.
No further action is planned.
- b.
Quality Assurance/Quality Control in the Laboratory Concerns:
(1)
Additional control charts are needed.
(2)
Control limits arbitrarily set at +/-20%.
(3)
Incomplete testing of *technicians with unknown samples.
Response
(bl) Additional control charts planned at this time include boron titrant strength and AA functional check results.
OC0887-0141-NL04 (b2) The inspection report indicated that an acceptance criteria of +/-20% was arbitrarily assigned fo~ setting instrument control limits, however there are numerous analytical methods in use with criteria tighter than
+/-20%.
A copy of Internal Correspondence Memo SKL86*025 dated June 27, 1986 was given to the inspection team that provided the statistical basis for the +/-20%
criteria that is mentioned in the inspection report.
Statistical test criteria analysis included in~
SKL86*025 included tests for phosphorus, hydrazine, sulfate, morpholine,. silica, chloride*, ammonia, conductivity,*metals, and pH; and recommended acceptance criteria ranging from +/-0.1% to +/-20% of mean value.
(See additional comments later in Section 5.)
2 (b3) Our chemistry technician qualification program which includes an evaluation of technician technique, is presently scheduled for formal ~cceptance by INPO in September, 1987.
A review of chemistry technicians.
participation in the unknown samples analysis program for the past year revealed the following:
Date of. Test Series Technicians Participating Qualified Employed Technicians
% Participation 9/86 12/86 4/87 7/87 13 10 9
9 13 13 11
. 10 100 77 82 90 Yearly Average =
87%
~11 technicians participated in the program at least twice in the past year.
All technicians were not utilized in each test series because they were off site for training (or vacations).
Because of the high level of technician participation and perf or-mance, it is.felt that the current practices are suff ic ien t.
- c.
Counting Room QA/QC Concern:
(1)
Control limits set at +/-5% of the mean counts for the alpha/beta counters, gross gamma counter, and' liquid scintillation counter.
(2)
Control charts for the gamma spectrometers.
Response
(1)
The limits for acceptable performance of the beta, gross gamma counter, and liquid scintillation. counter will be based on statistical analysis.
Implementa-tion of this revision will take place by the end of 1987.
OC0887-0141-NL04 (2)
The control charts for the gamma spectrometers will be improved through more frequent printing of charts.
As suggested by the inspector, only two energy lines will be used in the QC charts; one at a low energy (180 KEV) and one at a high energy (810 KEV).
The energy lines used are relatively intense and will yield good counting statistics. These changes will be implemented the end of 1987.
- 5.
Non Radiological Confirmatory Measurements Concern:
(1)
Acceptance criteria of +/-20% is excessively generous and without statistical foundations.
(2)
Use of one point calibration curves in non linear situations.
(3)
Independent controls must be included in analytical procedures.
3 Response: (1)
As stated earlier, not all acceptance criteria are set at
+/-20% and currently utilized criteria is based on statistics. However, since difficulty was experienced in attaining comparable results on the Ion Chromatograph analysis, the calibration interval for this instrument will be temporarily increased to weekly, and the daily fuI1ctional checks performed during this time will be statistically analysed to determine a new acceptance criteria range.
This trial period will begin in September, 1987.
Subsequent IC calibration intervals will be based on the trial period experience.
(2)
The current instruments (Ion Chromatograph and AA) are not able to handle multi point calibration curves.
Current chromium analysis methods will not be revised because the use of chromium (as chromate) as a corrosion inhibitor is being dis.continued, along with the need for this analysis.
(3)
The quarterly analysis of vendor supplied unknowns pro-vides an independent control check on the plant's calibra-tion standards.
The use of different lots or manufacturers to prepare calibration and functional check standards would double the number of standards in the stock room and in the laboratory above what is currrently being maintained.
Separate calibration and functional standards are, currently maintained for all counting instruments, the gas chromatograph, and pH meters.
Actual experience has shown that problems with the purchased standards are rare, and do not justify the added expense and additional bench space heeded in already cramped laboratories.
- 7.
Open Items - Open items will be tracked through AIRs.
- 8.
. Exit Interview Frequently the plant operates with chemical species at the detection limits of the instrumentation.
Good analytical techniques uses
- functional checks run in*~~' -.¥m~ ;ra\\l~e.
1~1;1 1.the'sample analysis.
At the limits of detection the errbts*in'measu:rement will be large, which is the reason for the sometimes large.£i+/-ZQ%),error limits for some of the functional checks.
OC0887-0141-NL04