W3F1-2010-0024, Submittal of Blind Sample Investigation Report

Submittal of Blind Sample Investigation Report

ML100750561
Person / Time
Site:	Waterford
Issue date:	03/15/2010
From:	Murillo R Entergy Nuclear South, Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
W3F1-2010-0024
Download: ML100750561 (9)

Text

Entergy Nuclear South Entergy Operations, Inc.

17265 River Road Killona, LA 70057-3093 Tel 5047396715 Fax 504 739 6698 rmurill@entergy.com Robert J. Murillo Licensing Manager Waterford 3 W3F1-2010-0024 March 15, 2010

-J U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Blind Sample Investigation Report Waterford Steam Electric Station, Unit 3 (Waterford 3)

Docket No. 50-382 License No. NPF-38

Dear Sir or Madam:

In accordance with the reporting requirements of 10 CFR 26.719(c)(1), Waterford 3 is submitting this report to discuss one blind performance drug testing discrepancy.

On December 29, 2009, a discrepancy in blind sample validity results was identified, which is associated with gas chromatography/mass spectrometry (GC/MS) interference while testing samples with PCP. The blind samples were purchased from the vendor to meet the various sample results required for blind specimens. The vendor provided Waterford 3 with two specimens from batch 0909PCPLO for use as a PCP positive at lower concentration which serve as false negative challenges, and two from batch 0912PCP for use as a positive PCP. One specimen from batch 0909PCPLO was sent to the primary confirmatory laboratory. The other specimen from batch 0909PCPLO and the two specimens from 0912PCP were sent to the secondary confirmatory laboratory.

The primary confirmatory laboratory returned the result of one PCP positive (false negative challenge) from batch 0909PCPLO. However, two blind samples from batch 0912PCP (PCP positive) and one from 0909PCPLO (PCP false negative challenge) were tested at the secondary confirmatory laboratory, and the results were unexpectedly reported as invalid due to gas chromatography/mass spectrometry (GC/MS) interference.

Waterford 3 completed an investigation associated with unexpected blind sample results on February 17, 2010; however the exact cause of the discrepancy could not be determined.

This Blind Sample Investigation Report (Attachment 1) is provided in accordance with the 30 day reporting requirement of 10 CFR 26.719(c)(1). A supplemental investigation is being performed to determine- if the exact cause can be determined via supplemental investigation methods. Entergy will provide to the NRC by April 30, 2010 a follow-up report documenting the results of the supplemental investigation.

A List of Regulatory Commitments contained in this report is contained in Attachment 2.

W3F1-2010-0024 Page 2 If you have any questions or require additional information, please contact Robert Murillo, Manager, Licensing at (504) 739-6715.

Sincere RJM/JDW

Attachment:

1. Waterford 3 Blind Sample Investigation Report

Attachment:

1. List of Regulatory Commitments

W3F1-2010-0024 Page 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Waterford Steam Electric Station Unit 3 P.O. Box 822 Killona, LA 70066-0751 U. S. Nuclear Regulatory Commission Attn: Mr. N. Kalyanam Mail Stop O-07D1 Washington, DC 20555-0001 Wise, Carter, Child & Caraway ATTN: J. Smith P.O. Box 651 Jackson, MS 39205 Winston & Strawn ATTN: N.S. Reynolds 1700 K Street, NW Washington, DC 20006-3817 Morgan, Lewis & Bockius LLP ATTN: T.C. Poindexter 1111 Pennsylvania Avenue, NW Washington, DC 20004 /

Attachment 1 W3F1-2010-0024 Waterford 3 Blind Sample Investigation Report

I to W3F1-2010-0024 Page 1 of 3 Identification of Condition:

On December 29, 2009, a discrepancy in blind sample validity results was identified, which is associated with gas chromatography/mass spectrometry (GC/MS) interference while testing samples with PCP. The blind samples were purchased from the vendor to meet the various sample results required for blind specimens. The vendor provided Waterford 3 with two specimens from batch 0909PCPLO for use as a PCP positive at lower concentration which serve as false negative challenges, and two from batch 0912PCP for use as a positive PCP. One specimen from batch 0909PCPLO was sent to the primary confirmatory laboratory. The other specimen from batch 0909PCPLO and the two specimens from 0912PCP were sent to the secondary confirmatory laboratory.

The primary confirmatory laboratory returned the result of one PCP positive (false negative challenge) from batch 0909PCPLO. However, two blind samples from batch 0912PCP (PCP positive) and one from 0909PCPLO (PCP false negative challenge) were tested at the secondary confirmatory laboratory, and the results were unexpectedly reported as invalid due to gas chromatography/mass spectrometry (GC/MS) interference.

Investigation:

The primary confirmatory laboratory reported the results as expected, while the secondary laboratory reported results that were not expected. Additional blind sampling was performed in an attempt to determine if there were any deficiencies in the testing process or procedures between the laboratories. Due to receipt of invalid results, the aliquots retained at Waterford 3 for blind samples from these same batches (0909PCPLO and 0912PCP) were sent as follows: one sample from batch 0909PCPLO went to the secondary confirmatory laboratory, and three samples went to the primary confirmatory laboratory, two from 0912PCP and one from 0909PCPLO. The primary and secondary confirmatory laboratories are the same company but are in different locations. Contrary to the expected results, all four of the samples submitted as part of the investigation were also reported as invalid due to GC/MC interference from both the primary and secondary laboratories.

Waterford 3 inquired with other sites in the Entergy fleet that use the same vendor and confirmatory laboratory to see what batches their blind samples came from and what were the status of their results. Indian Point reported that they had samples from batch 0909PCPLO, and the results were reported as expected. Indian Point uses the same company for confirmatory testing; however it is neither Waterford's primary nor secondary confirmatory testing laboratories. Arkansas Nuclear One (ANO) reported that they had blind samples from batch 0912PCP that had not been submitted. ANO-was then asked to send a blind sample to each one of the three testing laboratories. The results of blind samples sent were reported back as expected from the confirmatory laboratories that Waterford 3 and Indian Point use as their primary laboratories. The third sample was sent to Waterford 3's secondary confirmatory laboratory that reported unexpectedly an invalid result, again, due to GC/MC interference.

Because of the inconsistencies of the reported results, the laboratory director from the Waterford 3 primary confirmatory laboratory was contacted to ensure that all procedures, to W3F1-2010-0024 Page 2 of 3 policies and practices are standardized amongst their confirmatory laboratories. The director confirmed that all of their laboratories follow the same procedures, policies and practices. The laboratory director also compared the testing results of sample numbers 5571674, 5571775 and 5571675 (sent from ANO) for discrepancies and reported back that there was no evidence of any differences in the testing and reporting of the results.

The vendor providing the blind samples was also contacted. The vendor verified the blind samples have been prepared and tested in the same fashion for the past 15 years and could not provide an explanation of why the result from the same sample/lot number (0909PCPLO and 0912PCP) was tested and reported valid at times, and invalid at other times.

These blind sample discrepancies are not associated with the laboratory reporting of any false negative or false positive blind sample results described in 10 CFR 26.719(c)(2) or (c)(3), but pertains to blind sample unexpected results as "invalid" from gas chromatography/mass spectrometry (GC/MS) interference while testing blind samples with PCP.

Cause:,

The laboratory director from the primary confirmatory laboratory was asked if he knew why a sample from the same batch could report different test results. He stated that it could happen as a result of climate, how close a sample is to the expiration date, how long a sample was sitting out, etc. The exact cause of the discrepancies could not be determined.

Corrective Action:

Waterford 3's primary and secondary Health and Human Services (HHS) certified laboratories, and the Waterford 3 blind sample vendor has been informed of the unresolved discrepancies.

Blind samples are received from the vendor with established expiration dates, and are shipped to the laboratory for sampling before expiring. However, as part of efforts to determine the cause of the discrepancy results, Waterford 3 has established more restrictive internal expectations that when the blind samples are received, the blind samples will be shipped out to the confirmatory laboratory within two weeks.

Waterford 3 is utilizing a different vendor for PCP positive blind samples while resolving this validity discrepancy associated with PCP blind sample laboratory results. PCP samples from this different vendor have been purchased, and are expected to be received by March 17, 2010, and will then be sent to the primary laboratory for testing within the following week. Results of this sampling will be factored into the determination of what caused the validity discrepancy with PCP blind samples. Tracking of this follow-up action has been entered into the Waterford 3 Corrective Action Program (CR.-WF3-2009-07699) and is expected to be completed by April 2, 2010.

to W3F1-2010-0024 Page 3of 3 Waterford 3's primary confirmatory laboratory is coordinating with the sample vendor and agreed to conduct their own investigation by receiving a blind sample of PCP specimen and analyzing it to get a baseline of its performance. The remaining aliquots of the blind sample will be stored in the refrigerator and at room temperature. This action by the laboratory is to imitate the conditions of shipment and storage that the specimen may experience. The primary laboratory will analyze these samples and provide Waterford 3 with a report of their findings. Tracking of this follow-up action has been entered into the Waterford 3 Corrective Action Program (CR-WF3-2009-07699) and is expected to be completed by April 16, 2010.

Follow-up Reporting:

Waterford 3 completed an investigation associated with unexpected blind sample results on February 17, 2010; however the exact cause of the discrepancy could not be determined.

This report is provided in accordance with the 30 day reporting requirement of 10 CFR 26.719(c)(1). A supplemental investigation is being performed to determine if the exact'

'cause can be determined via supplementalinvestigation methods. Entergy will provide to the NRC by April 30, 2010 a follow-up report documenting the results of the supplemental, investigation.

Attachment 2 W3F1-2010-0024 List of Regulatory Commitments to W3F1 -2010-0024 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED COMPLETION DATE COMMITMENT (Check one)

(If Required)

ONE-TIME CONTINUING ACTION COMPLIANCE Waterford 3 completed an investigation X 4/30/2010 associated with unexpected blind sample results on February 17, 2010; however the exact cause of the discrepancy could not be determined. This report is provided in accordance with the 30 day reporting requirement of 10 CFR 26.719(c)(1). A supplemental investigation is being performed to determine if the exact cause can be determined via supplemental investigation methods. Entergy will provide to the NRC by April 30, 2010 a follow-up report documenting the results of the supplemental investigation.