IR 05000266/1988017

Insp Repts 50-266/88-17 & 50-301/88-15 on 880711-15.No Violations Noted.Major Areas Inspected:Chemistry Program, Including Procedures,Organization & Training,Reactor Sys Water Quality Control Programs & Qa/Qc Control Programs

ML20151R381
Person / Time
Site:	Point Beach
Issue date:	08/03/1988
From:	Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151R377	List: IR 05000266/1988017 ML20151R373
References
50-266-88-17, 50-301-88-15, NUDOCS 8808120150
Download: ML20151R381 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-266/88017(DRSS); 50-301/88015(DRSS)

Docket Nos. 50-266; 50-301

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Licenses No. DPR-24; OPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Power Plant, Units 1 and 2 Inspection At: Two Creeks, Wisconsin Inspection Conducted: July 11-15, 1988 (On-site)

July 18, 1988 (Telephone discussion)

Inspector: .' Itzm h h/ /

Date( Qawsbv Approved By: M. C. 5thumacher, Ch ef Radiological Effluents and Date Chemistry Section i Inspection Summary Inspection on July 11-15, 1988 (Report No. 50-266/88017(DRSS);

No. 50-301/88015(DRSS))

Areas Inspected: Routine, announced inspection of the chemistry program, including (1) procedures, organization, and training (IP 83722, 83723);

(2) reactor systems water quality control programs'(IP 79701); (3) quality assurance / quality control program in the laboratory (lP 79701); and (4) nonradiological confirmatory measurements (IP 79701).

Results: The licensee has an extensive water quality control program that conforms to the EPRI Steam Generator Owners and Primary Systems Guideline The nonradiological confirmatory measurements results were good and demonstrated only minor weaknesses in the chemical measurements QA/QC progra The licensee had identified the source and was in the process of correcting one problem, and agreed to look into possible solutions to other problem No violations or deviations were identified during this inspectio t 8808120150 880804 PDR ADOCK0500gg6

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4 4 DETAILS l-1.- Persons Contacted 1G. J. Maxfield, Superintend u t-Operations, WEPCo tK. R. Rathgaber, Specialist-Neclear-(Acting Superintendent, Chemistry), WEPCo 1 2T. L. Slack, Specialist-Nuclear, WEPCo 1F. A. Flentje, Administrative Specialist, WEPCo T. Fredrichs, Superintendent, Chemistry R. Arnold, Laboratory Supervisor, WEPCo J. Knorr, Regulatory Engineer, WEPCo D. Gesch, Specialist-Nuclear, WEPCo 1R. L. Hague, Senior Resident Inspector, NRC The inspector also interviewed other licensee personnel in the course of the inspectio Present at the plant exit interview on July 15, 198 Telephone discussion held July 18, 198 . Licensee Actions on Previous Inspection Findings (Closed) Open Item Nos. (50-266/87003-01; 50-301/87003-01_l: Licensee to improve instrument logs and reagent preparation documentatio The licensee implemented logbooks for each instrument that contained notes on changes, adjustments and repairs to the respective instruments. The reagent preparation documentation was modified by adding a logsheet that gave reagent preparation requirements, and reference to the preparer and date of preparation. ~ The details of preparation were in the appropriate RCT's notebook which was available in the laboratory. These modifications appear to provide suitable documentation control for-the laborator (Closed) Open Item Nos. (50-266/87003-02; 50-301/87003-02): Inspector reviewed progress in the QA/QC program relating to the assessment of technician proficiency tests and the implementation of control charts on instrument performance for all the laboratory analyses. The laboratory assesses the technicians' analytical proficiencies with a set of samples supplied by a vendor and diluted by the corporate Lab Services Department. Acceptance criteria are given for the results along with corrective actions to be implemented for results not in agreement. Licensee representatives stated that the program to test each technician twice yearly would be fully implemented this year; currently, eight of the 11 have been tested once. The laboratory has instituted QC charts for all of the laboratory analyses with control parameters based on statistical analyse This Item is considered closed and progress in the development of technician testing program and the QA/QC program will be followed under Open Item Nos. (50-266/88017-03; 50-301/88015-03) (Section 7).

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..- , (Closed)'Open Item Nos. (50-266/87003-03;'50-3'01/87003-03): . .

Licensee to assess-the:causes of disagreements;in,the nonradiological confirmatory measurements program with NRC samples. . . The problem causing the, disagreements-in.the confirmatory measurements were were not specifically resolved, butLquality of the'results. presented'

in Table 2 (this report)' demonstrate resolution of the problems probably due to more experience with the analyses and an improved-QA/QC progra (Close'd) Open Item Nos. (50-266/88005-04; 50'-301/88005-04):

' Licensee to analyze a liquid sample.for gross beta, H-3, Sr-89, and Sr-90 and report.the results to Region III. The licensee's results'of the. liquid sample are contained in Table 1; the comparison criteria are'given:in Attachment Sr-89 was not compared because the .results were less' than the lower limits..o detectio No violations or deviations were identifie . Management Controls, Organization, and Training (IP 83722; IP'83723)

The inspector reviewed changes in the management controls, organization and training in the Chemistry Department. The Superintendent-Chemistry (formerly the Radiochemist) reports to the General Manager, who, in turn, reports to the Plant Manager. Four Nuclear Plant Specialists, two Laboratory Supervisors and a Computer Systems Analyst' report to the~

Superintendent. . Of the 11 laboratory; technicians eight are qualifie under ANSI N18.1-1971 and three are trainees. The staff and' technician groups appear to be adequate to~do the required analyses for operating-the plant and developing the chemistry progra The licensee's Chemistry Technician training program was accredited by INP0 November 23, 198 No violations or deviations were identifie . Water Chemistry Control Program (IP 79701)

The inspector reviewed the licensee's water chemistry control' programs required by corporate Nuclear Power Department General-Policy 003,.

"Corporate Water Chemistry Policy," March 1, 1987. This' requires following the plant procedures PBNP 8.4.1, "Secondary Water Chemistry Monitoring Program," Revision 12, February 5,1988 and PBNP 8.4.2,

"Primary Water Chemistry Monitoring Program," Revision 5, August 7, 198 These are based on and conform to the EPRI Steam Generator Owners Group (SG0G), "PWR Secondary Water Chemistry Guidelines," NP-2704-SR, Revision 1, June 1984 and the EPRI NP-4762-SR, "PWR Primary Water Chemistry Guidelines," September 1986, respectively. Deviations from the limit require the approval of the Vice President Nuclear Powe .

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The licensee is working on various aspects of the secondary system to improve water chemistry. During outages, sludge is removed from the steam generators. Only about 50 pounds per generator was lanced from the relatively new (four year old) Unit 1 S/Gs in the last outage, compared to several hundred pounds from those in the older Unit 2. As discussed in the previous report in this area , the makeup water system l

capacity is being doubled to about 400 gallons per minute and the quality of the water will be improved due to markedly reduced organic conten While the system is still under construction, the clarification and softening sections are now in us The chemistry results data are stored in a versatile computer syste Data from the files can be displayed and printed, and they can be graphed, viewed on the terminal screen, and the plots printe The Laboratory Supervisor reviews daily printouts of the results and locks approved data in place. Daily, a one page summary is distributed to upper management and another summary is submitted to the control room The Superintendent presents results to upper management frequentl He agreed to consider the inspector's suggestion that certain of the parameters be trended regularly, such as cation conductivity, and chloride and sulfate concentrations in the secondary system. This will be reviewed in subsequent routine chemistry inspection No violations or deviations were identifie . Implementation of the Chemistry Program (IP 79701)

The inspector reviewed the chemistry programs including physical facilities and laboratory operation The conditions in the laboratory are essentially unchanged since the previous inspection2 , except that the new cold laboratory with adjacent chemistry offices is almost completed. The Chemistry Department is also trying to obtain a new counting room with less vibration and better temperature regulatio The inspector observed several technicians analyze the confirmatory measurements samples, including boron by titration, metals by atomic absorption spectrophotometry, and fluoride, chloride and sulfate by ion chrematography (IC). They appeared to be generally knowledgeable about the work and followed the procedure Overall, the housekeeping was good and the laboratories appeared to be adequate for the proper operation of the plant and to be operating satisfactoril No violations or deviations were identifie . Region III Inspection Report Nos. (50-266/87003; 50-301/87003). ibid 4 __

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'. i Nonradiological Confirmatory Measurements (IP 79701)

The inspector submitted chemistry. samples to the licensee for analysis as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to various Technical Specification and other regulatory and administrative requirements. These samples had been prepared, standardized, and pericdically reanalyzed (to check for stability) 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 equipmen 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 in a manner similar to that of routine sample The results are presented in Table 2 and the criteria for agreement in Attachment 2. These criteria are based on comparisons of the mean values and estimates of the standard deviations (SD) of the measurement Consideration was given to the fact that the uncertainties (SD) of the licensee's results were not necessarily representative of the laboratory's because they were usually obtained by one analyst over a short period of tim Consequently, when the licensee SD was less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the SD of the ratio Z (S zin Attachment 1).

The licensee also prepared two samples each containing a matrix to be split with BNL. To these were added analytes supplied by the inspecto Reactor water was spiked with the anions chloride, sulfate and fluoride, and a steam generator blowdown sample was spiked with the copper and iro The licensee determined the concentrations of the analytes in each of the samples and reported the results to Region III for comparison with the values to be determined by BNL. This will be followed under Open Item Nos. (50-266/88017-01; 50-301/88015-01).

The licensee analyzed 11 analytes at three concentrations each. In addition, chloride was analyzed by the mercuric nitrate titration method used for reactor coolant analyses (a T/S requirement). Of the initial 36 analyses, 34 of the results (94%) were in agreement with those of BN The disagreements included the low-level boron, and the mid-level chloride by the titration metho The low-level fluoride had a substantial bias, but because of the high variabilities the results were in agreemen In addition, the other two fluoride analyses and the silica analyses ,

had some persistent biases, which indicated possible problems with the l calibration standards. Laboratory personnel attribut.ed the silica biases i to the high silica blank in the laboratory deionized watar, a problem j that they had been working to resolv J l

For the chloride by titration, the BNL SD values were increased to

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a relative SD (RSD) of 5%, a reasonable value for the IC and possibly somewhat low for the titration. A rerun of the middle cbloride sample resulted in an agreement, using the 5% RSD for both the BNL and licensee results. This method appears to have a poor precision and is being replaced by an IC analysi . . . . . . ,

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. . j The two lower-level sets of boron analyses show substantial low biases of about 4%, with otherwise good precision of the measurements for both the BNL and licensee results. This appears to be due to some differences in the methods of analysis, that of a Westinghouse procedure used by the licensee and that similar to the ASTM D-3082 procedure used by BNL. The differences in the procedures appear to be that the licensee does not adjust the initial pH to 5.5 and dilutes the sample only minimally to less than 10 m1, compared to 100 m1 by BN This dilution affects the equivalence points and may result in the observed bias. Reruns by the licensee using a dilution of the sample to 200 ml resulted in a difference of only 1% in the low-level sample (Table 2), which was then an agreemen The 3000 ppm sample results were essentially unchanged. Similar negative biases were observed at other plants that used similar methods. The inspector has discussed this problem extensively with BNL, but the source of the bias has not yet been ascertained. This problem will be examined further in subsequent inspection Overall, the analytical program was good and the analytical results were-very good. It should be noted that although the analyses for each of the three dilutions of each anlayte were done by'different technicians, the licensee's reported precision values were comparable to those of BN The inspector discussed with licensee representatives apparent weaknesses in the QA/QC program, such as the lack of performance check standards that were independent of the calibration standards to check standard deterioration, i.e. from different lot Some other problems are discussed in Section Resolution of the problems with the biases in the fluoride, silica and boron analyses will be followed in subsequent I inspections under the Open Item No. (50-266/88017-02; 50-301/88015-02).

No violations or deviations were identifie . Implementation of the QA/QC Program in the Chemistry Laboratory (IP 79701)

The inspector reviewed the laboratory QA/QC program required by several procedures:

CAMP-001 PBNP Chemistry Quality Assurance Program, Revision 5, June 21, 198 CAMP-107 PBNP Analytical Intra-Laboratory QA Checks, Revision 2, May 6, 1988 CAMP-108 PBNP Analytical Spiking QA Checks, Revision 5, June 16, 1987 CAMP-109 Verification of Chemistry In-line Instruments, Revision 3, January 26, 1988 l

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These procedures control the various aspects of the QA/QC program, including control and trend charts, management responsibilities, laboratory services, equipment and supplies, chemicals and standards, and the elements of quality assessment. The licensee uses functional performance check (bias) control charts and a spiked sample program in which, for each analysis, the technicians spike samples with known standard The control limits on the charts are statistically-derived-from the spiked sample result The laboratory uses multiple calibration points, where possible,_and.in any case, functional checks are made in between the calibration point The technician performance is tested under an "intralaboratory" program, CAMP-107, with "unknowns" samples from a vendor (NUS) that are processed by the corporate Lab Services to bring the samples within the required concentrations used in the plan The results are checked for acceptability and tabulated for each analys Licensee representatives agreed to fully implement the procedure this year by testing each RCT with a full set of samples twice yearly (Section 2b). The inspector noted that while the laboratory has only an EPA interlaboratory comparison program, it could be expanded to cover plant analyses by rearrangement of these test result The inspector discussed with licensee representativec concerns about the QA/QC program. The instrument control charts had control limits determined by the results of tho spiking check program, rather that the data from the performance ciecks, so that the control limits were somewhat greater than the data on the chart warranted and did not show clearly the statistical variability of the analysi The representatives noted that by September 1, 1988 they will have these charts computerized and will automatically determine the statistics parameters from the chart data point Soma of the charts showed little variability due to using too few significant figures, i.e. the precision of the procedure and significant figures are shown by statistics and usually should not be chosen a priori and arbitraril The lack of multiple standards in which the calibration and functional check standards are from stock ~

solutions from different suppliers or from different lots from the same supplier, made it difficult to establish the causes of the biases observed in the confirmatory measurements, such are those in the fluoride and silica analyses (Section 6). A licensee representative stated that they will consider a program to have multiple standards availabl The QA/QC system has the basic elements of a good program, and it appears to be developing well. Progress in this program, two sets of tests per year for each technician, computerization of the control charts, and the use of multiple standards will be followed in subsequent inspections under Open Item Nos. (50-266/88017-03; 50-301/88015-03).

No violations or deviations were identifie l

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. Open Items i 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 bot Open items disclosed during the inspection are discussed in. Sections 6 and . Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on July 15, 1988. Observations on the QA/QC program and the confirmatory measurements were discusse To ai,in the discussion, licensee representatives were shown preliminary results of the nonradiological confirmatory measurements. Licensee representatives acknowledged the inspector's concerns on the QA/QC program, as discussed in Section 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 proprietar Attachments: Table 1, Radiological Interlaboratory Test Results, Point Beach, First Quarter 1988 Attachment 1, Criteria for Comparing Analytical Measurements (Radiological) Table 2, Nonradiological Interlaboratory Test Results, July 11-15, 1988 Attachment 2, Criteria for Comparing Analytical Measurements (Nonradiological)

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TABLE 1 U S NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM

,y FACILITY: POINT BEACH FOR THE 1 OUARTER OF 1988

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NRC----- -- ----L I CENSEE-- -- ---LICENSEE:NRC----

ERROR RESULT ERROR RATIO RES T SAMPLE ISOTOPE RESULT 1.4E-04 5.0E-06 1.1E-04 0.0E-01 7.6E-01 2.9E 01 A-L WASTE G BETA H-3 3.8E-01 5.0E-03 4.2E-01 0.0E-01 1.1E 00 7.6E 01 A SR-90 6.3E-07 3.0E-08 4.9E-07 0.0E-01 7.8E-01 2.1E 01 A T TEST RESULTS:

A= AGREEMENT

D= DISAGREEMENT

• = CRITERIA RELAXED NANO COMPARISON

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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 uncertaint As that ratio, referred to in this program as "Resolution", increases, the acceptability of a licensee's measurement should be more selectiv should be considered acceptable as the resolution decreases. Conversely, poorer agr The values in the ratio criteria may be rounded to fewer significant figures reported by the NAC Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE ri 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 and fordiscrepancies may result from the use of different equipment, techniques, some specific nuclide criteria and identified on the data sheet.These may be factored into the acceptance

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TABLE 2 Nonradiological Interlaboratory Test Results Point Beach Nuclear Power Plant July'11-15, 1988 Anal- Analysgs NRC Licensee" Ratio Compagi-yte Method son Y t SD X i SD(n) Z i SD 12 SD Concentration, ppb F- IC 11.3 i .0 i 1 .885 1 0.078 A 21.2 i .3 1 .958 i 0.030 A 41.4 1 .3 i .949 i 0.042 A Cl- IC 9.25 1 0.05 9.3 1 .005>i 0.065 A 18.6 1 .3 1 1. 2 1.038 1 0.065 A 38.3 1 .0 1 .044 1 0.047 A Cl- Titr 92.5 1 (1) 1.081 1 0.054 A 186 i 9 140 t (1) 0.753 1 0.052 D*

383 1 19 350 t (1) 0.914 1 0.045 A (rerun) 186 i 9 166 1 32 0.892 1 0.177 A Sul f- IC 9.75 i 0.70 9.7 1 .995 1 0.094 A ate 19.2 i .7 1 .026 1 0.081 A 39.0 1 .7 1 2. 3 1.018 1 0.067 A Cu AAS 400 1 6 403 i S 1.007 1 0.021 A 806 1 30 797 i 6 0.989 i 0.038 A 1200 1 30 1207 1 6 1.006 1 0.026 A Fe AAS 372 1 10 400 1 17 1.075 i 0.054 A 796 1 10 790 1 26 0.992 1 0.035 A 1170 1 30 1183 1 31 1.011 1 0.037 A Na AAS 121 1 14 102 i 16 0.843 1 0.164 A 212 1 12 205 i 10 0.967 1 0.072 A 316 i 18 309 1 12 0.978 1 0.067 A Li AAS 394 i 8 397 1 12 1.008 1 0.037 A 600 1 14 613 1 12 1.022 1 0.031 A 826 1 20 810 1 1 0.981 1 0.024 A NH 3 Spec 416 1 20 397 1 12 0.954 1 0.054 A 600 1 6 590 1 10 0.983 1 0.019 A 984 1 46 983 1 35 0.999 1 0.059 A .

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a Anal- Analysgs NRC Licensee Ratio Compagi-yte Method son Y i 50 X i SD(n)' Z i SD :12 S D Hyd- Spec 9.95 1 0.15 10.0 i ~ .005 1 0.015 A:

razine -25.0 1 .7 1 .988 1 0.027 A 50.0 1 .3 1 .986 1 0.01 Sili- Spec 52.8 1 .3 1 .915 i 0.105 A ca 104 1 4 99 i 5 0.952 1 0.060 A 157 1 2 150 i 5 0.955 1 0.034 A Concentration, ppm d

B Titr 1040 1 10 999 1 .961 1 0.013 D*

3089 i 41 2982 1 16 0.965 1 0.018 A*

5000 1 90 4978 1 16 0.996 1 0.018 A (rerun, 1040 1 10 1029 i (1) 0.989 t'0.010 A dilution) 3089 i 41 2986 i (1) 0.967 1 0.018 A* Value i standard deviation (SD); number of BNL analyses 6 to 8 per analyt The number of licensee analyses (n) is 3 unless otherwise note Analytical methods: Titr - titration IC - Ion chromatography AAS - Atomic absorption Spectroscopy (flame) A = Agreement 0 = Disagreement

• Substituted the BNL uncertainty for licensee's uncertaint Titration end point at pH l l

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ATTACHMENT 2 l

Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing results of the capability test 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 (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 Thus, x

S2z _ S2

x $y , so that Y~T,V

[S*2 3Y 2h S =Z*i +

z (X2 y2)

The results are considered to be in agreement when the bias in the ratio (absolute value of difference between unity and the ratio) is less than or equal to twice the uncertainty in the ratio, l 1-Z l 1 2*S z* 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).

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