IR 05000282/1989007

Insp Repts 50-282/89-07 & 50-306/89-07 on 890306-10.No Violations Noted.Major Areas Inspected:Chemistry Program, Including Procedures,Organization & Training & Primary & Secondary Sys Water QC Programs

ML20248G064
Person / Time
Site:	Prairie Island
Issue date:	03/30/1989
From:	Holtzman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248G056	List: IR 05000282/1989007 ML20248G051
References
50-282-89-07, 50-282-89-7, 50-306-89-07, 50-306-89-7, NUDOCS 8904130301
Download: ML20248G064 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-282/89007(DRSS); 50-306/89007(DRSS)

Docket Nos. 50-282; 50-306 Licenses No. DPR-42; DPR-60 Licensee: Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 Facility Name: Prairie Island Nuclear Generating Plant, Units 1 and 2 Inspection At: Prairie Island Site, Redwing, Minnesota Inspection Conducted: March 6-10, 1989 (0nsite)

Inspectors: R.'B. Holtzman 1/J*d't ;

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. E. House J-J o - 1r f Approved By: W M.C. Schumacher, Chief #4e'M1 Radiological Controls and Date Chemistry Section Inspection Summary Inspection on March 6-10, 1989 (Reports No. 50-282/89007(DRSS); No. 50-306/89007(DRSS)) Areas Inspected: Routine announced inspection of: (1) the chemistry program including procedures, organization and training (IP 84750); (2) primary and secondary systems water quality control programs (IP 84750); (3) quality assurance / quality control program in the laboratory (IP 84750);

  (4) nonradiological confirmatory measurements (IP 79701); and (5) the Radiological Environmental Monitoring Program (REMP) (IP 84750).

Results: The licensee has an extensive water quality control program that conforms to the EPRI Steam Generator Owners Group Guidelines. Primary water standards are under development. The water quality was generally very good with low levels of contaminants and a good Chemical . Performance Index (CPI).

The nonradiological confirmatory measurements results were good, but demonstrated some weaknesses in the QA/QC program. The licensee identified weaknesses in the measurements program and corrected them. The REMP appeared to be operating satisfactoril No violations or deviations were identifie $04ikbbi

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DETAILS Persons Contacted

 *E..L. Watzl, Plant Manager, NSP-PI
 *D. A'. Schuelke, Superintendent, Radiation Protection
 *S.'J. Lappegard, Plant Chemist
 *T. M. Gatten, Chemistry Coordinator D. Mendele, General Superintendent, Engineering and Radiation Protection D. Larimer, Radiochemistry Supervisor A. Re:leran, Radiation Protection Specialist (RPS)

M. Walsh, RPS J. Hopkins, RPS J. Lucas, RPS K. Mueller, Biologist, Environmental Regulatory Affairs Department, NPS

 *T. J. O'Connor, Resident Inspector, NRC The inspectors also interviewed other licensee personnel in various departments in the course of the inspectio *Present at the Exit Meeting on fiarch 10, 198 . Management Controls, Organization, and Training (IP 84750)

The Chemistry Group manager, the Radiochemistry Supervisor, reports to the Superintendent of Radiation Protection, who, in turn, reports to

 'the General Superintendent of Engineering and Radiation Protection. The Supervisor is supported by the Plant Chemist and the Chemistry Coordinator, who supervise eight Radiation Protection Specialists (RPS). The RPSs are permanently assigned.to the chemistry laboratory, although they do perform health physics duties, especially on the.back shift. All are qualified as technicians under ANSI N18.1, 1971.

l While the chemistry group is small, they appear to be well qualified, and with the help of a highly computerized data management system, are able i to do the required analyses efficientl The Chemistry RPS training program was accredited by the National Nuclear Accrediting Board of INP0 on November 24, 198 No violations or deviations were identified.

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3. Water Chemistry Control Program (IP 84750) The inspectors reviewed the water chemistry control program that is defined by Northern States Power Company Nuclear Power Production Policy, Chemistry Policy 3.1, Revision 0, June 26, 1987 and Radiation Protection Implementation Procedure 3002, Revision 2, Secondary Water Chemistry Guidelines, April 6, 198 These documents commit the licensee to the EPRI Owners Group Guidelines for secondary water quality and they appear to be consistent with the Guidelines. Waivers of the Action Levels must be approved by the plant manager. Licensee representatives stated that the procedure for Primary Water Chemistry has been completed and is ready for distributio Inline process monitors and sample panels are located in the laboratorie The monitors for steam generator blowdown cation conductivity, total conductivity, hydrazine, sodium, pH, dissolved oxygen and dissolved hydrogen are located in the hot laboratory while those for condensate and feedwater are located in the cold laboratory. These parameters include hydrazine, conductivity, pH, cation conductivity, dissolved oxygen and sodium. All monitors and recorders appeared to be functionin The licensee is in the process of adding data loggers to acquire real time data from the process monitors which will be processed by the laboratory computer syste Trend charts for secondary water chemistry are maintained by the license A review of selected data for the previous year indicated that chemistry control parameters for secondary water are well within the EPRI Guidelines and overall water quality is good. Chemistry parameters are monitored by laboratory management daily. Data is reported to the plant manager weekly unless a control parameter is out of limits, then it is reported immediatel The water quality control programs appear to be satisfactory and well ru No violations or deviations were identifie . Implementation of the Chemistry Program (IP 84750) The inspectors reviewed the chemistry programs, including physical facilities and laboratory operation Housekeeping was good and bench space was adequate for the analyses performed. The laboratories were well equipped. The hot laboratory has much state-of-the-art instrumentation: four Dionex AI 400 Ion Chromatograph units controlled by Hawlett Packard Model HP 9133/HP 300 computers (PC) used for anion and cation analyses, one unit of which uses gradient elution that permits the separation of the formate and acetate peaks from that of fluoride; a Varian Spectra AA-40 atomic absorption / emission (AAS) unit controlled by a 05-15 Data Station, with flame and graphite tube and vapor generation accessories; a Mettler MemoTitrator using the inflection-endpoint for boron; and Spectronic 601 Spectrophotometers with 5-cm cells for l hydrazine and low-level silica analyse _ _ _

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l l The reactor sampling systems are convenient to the laboratories; the I secondary and blowdown sampling panels are in the cold and hot laboratories i respectively (Section 3), while those for the primary, both routine and d post-accident, are in a room adjacent to the hot laborator The inspectors observed several RPSs analyze the confirmatory measurements samples on the ion chromatography, the AAS, and the boron autotitrato They were generally knowledgeable about the work and followed the procedures. They appeared to do well in the analyse Overall, the laboratories appeared to be adequate for the proper operation of the plant and to be operating satisfactoril No violations or deviations were identifie . Nonradiological Confirmatory Measurements (IP 79701) The inspectors 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 periodically reanalyzed (to check for stability) for the NRC by the Safety and Environmental Protection Division of Brookhaven National 1 Laboratory (BNL). The samples were analyzed by the licensee using i routine methods and equipmen ! The samples'were diluted by licensee personnel as necessary to bring the l 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 1 and the criteria for agreement in Attachment These criteria for agreement 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 obtained by one analyst over a short period of time. 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 in , Attachment 1). Further,whentheuncertaintiesofboththelicenseeand ' BNL appeared to be excessively small for an analytical method, values of ralative standard deviations (RSD) of 3% were substituted for the SD.

l The licensee also prepared a sample of reactor coolant spiked with fluoride, chloride and sulfate to be split with BN The licensee determined the concentrations of the analytes and submitted the results to the inspectors to be compared to those to be determined by BNL. This will be followed under the Open Items No. (50-282/89007-01; . No. 50-306/89007-01).

! The licensee determined 11 analytes at three concentrations each and achieved agreement in 27 of the initial 31 analyses (87%). The two lower-level boron results were excluded from this assessment (see below).

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The silica and hydrazine spectrophotometric results showed substantial '. negative biases in the high level samples. The results improved markedly after recalibration and the implementation of calculated straight-line regression curve The boron analyses of the two lower-level samples showed negative biases of about 4%. These biases are substantial when consideration is given to the inherently high precision of the analytical method and the importance of the results to reactor operations, especially in a PWR. In this case the licensee used an inflection endpoint. Similar negative biases were j observed at other licensees in Region III. The source of the bias has not yet been ascertained; the inspectors in conjunction with BNL are working to resolve this problem prior to subsequent inspection The licensee will modify the hydrazine and silica procedures to check the calibration linearity periodically and to use the calculated straight line regression analysis. Implementation of these will be followed in subsequent inspections under Open Items No. (50-282/89007-02; No. 50-306/89007-02).

Overall, the results of the analyses were good. Laboratory personnel demonstrated a willingness and good ability in determining the causes of the biases and disagreement i No violations or deviations were identifie . Implementation of the QA/QC Program in the Laboratory (IP 84750) The inspectors reviewed the chemistry laboratory quality assurance program as defined by Radiation Protection Implementation Procedure 3004, Chemistry Quality Assurance, Revision 2, August 31, 1988. The licensee has multiple point calibration curves for most instruments, except for certain analyses (anions) on the Ion Chromatograp A single point calibration curve is used for these analyses on this instrument. However, a weekly 3 point calibration curve is run in order to assure linearity within the concentration ranges being measure In addition, the instrument is calibrated during each shift which reduces drift, an effect attributed to temperature fluctuations. Licensee representatives stated that control standards used are from different manufacturers or lots than those used to prepare calibration solution The licensee has control charts for all assays. Charts are stored in a computer data base and are readily available to laboratory personne There is little documentation available in QA procedures that defines the charts or describes their construction. This is a weakness that is compounded by the fact that the charts are not in the standard format of a mean value + two standard deviations (SD). The licensee plots accuracy as the deviation from the mean value using a percentage scale which ranges from zero to + several hundred percent. Precision is plotted as the l absolute value of the difference between two controls of the same concentration. The licensee has agreed to document these methods in their QA procedures and to investigate plotting the commonly accepted system of a mean value 2 SD _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

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The licensee maintains an extensive intralaboratory comparison progra Technicians are tested daily by analyzing an unknown QA check sample for each analysis that they perform. Check sample results must be within allowed tolerances or the data from the remainder of the run cannot be entered into the computer. The licensee does not have a statistically based acceptance criterion but uses a percentage of the standard value, usually + 10%. Technicians are also tested semiannually on all assay The licensee is reviewing the acceptance criterion to determine whether a more conventional statistically based system would be more appropriat The licensee's Interlaboratory comparison program is somewhat weak in that unknown samples corresponding to EPRI Guideline parameters are not routinely analyzed. A review of selected data from the previous year indicated that few samples relevant to the water chemistry control program were analyzed. Licensee representatives agreed to upgrade this program by obtaining samples of this type from the corporate service cente Progress in control chart procedures and plotting, as well as that of the interlaboratory comparison program will be followed under Open Items

No. (50-282/89007-03; No. 50-306/89007-03).

No violations or deviations were identifie . 0)eration of the Radiological Environmental Monitoring Program (REMP) IP 84750) The inspectors reviewed the REMP, including the 1987 Annual Radiological Environmental Monitoring Report, the 1988 monthly environmental progress report (January - December,1988), the air sampling stations, and the maintenance record The Annual Report appeared to comply with the REMP requirement All of the required samples were collected and analyzed, except as noted in the report, and a perusal of the results showed them to be reasonabl The 1988 report appeared to be acceptable; only one TLD was missing and 11 milk samples were not collected because the cows were not on j pasture. The test and maintenance records of the air sampling stations

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showed the systems to be maintained within specifications and the records to be complet The inspectors toured the air sampling stations around the plant and observed the licensee representative check the systems for operability (vacuum) and demonstrate the procedure for adjusting the constant flow regulators with a calibrated Rotameter. The inspectors noted a concern that, although each of the parts of the collection train was tested for air inleakage, the train as a whole was not so tested by some procedure, such as blocking the face of the filter holder. In addition, they noted that the flowrates drifted over the calibration period by as much as 25%, but that no corrections were made to the total volume sampled, or on the acceptable level of change. The licensee representative agreed to consider

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th'ese concerns and to submit a letter to Region III on their resolutio This will be followed under Open Items No. (50-282/89007-04; 50-306/89007-04).

The REMP appeared to be operating satisfactoril No violations or deviations were identifie . Audits and Appraisals (IP 84750) .-

   'The inspectors reviewed the most recent Corporate Audit (AG 88-34-22) of the chemistry laboratory conducted during December 19 and 29,1988 and January 10-27, 1989, along with.the laboratory's subsequent respons One finding and eight observations were made. The auditors appeared to address in adequate detail the nonradiological chemistry quality assurance program. Items identified in the audit appear to have been addressed in a timely manne No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, 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 5, 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 March 10, 1989. The inspectors discussed their observations on the quality control program, the confirmatory measurements and the REM The licensee has agreed to review and correct program weaknesses observed by the inspector During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee representatives did not identify any such documents or processes as i proprietar ]

l Attachments: Table 1, Nanradiological Interlaboratory Test Results, March 6-10, 1989 Attachment 1, Criteria for Comparing . Nonradiological Measurements l

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! . ATTACHMENT 1 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 f ne 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 b b b* z _ x F- F # k, so that S 2Y S z

    = Z * )(S*2 + Y y2)
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     (X2 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 < 2*S 7 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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TABLE 1 Nonradiological Interlaboratory Test Results Prairie Island Nuclear Generating Plant, Units 1 and 2 March 6-10, 1989 a c Analyte Analytigal NRC Licensee" Ratio Comparison Method Y 1 SD X 1 SD Z 1 SD 12 SD Concentration, ppb Fluoride IC 5.63 + 0.50 5.00 i 0.10 0.889 i 0.107 A 10.6 7 .0 .943 0.050 A 20.7 1 .7 1 .903 0.034 0 (rerun) 2 .4 2 .9 1.000 0.048 A Chloride IC 4.63 0.03 4.50 i 0.10 0.972 0.023 A 9.33 0.15 9.33 1 .000 0.036 A 1 .3 17.2 1 .900 1 0.034 D+

  (rerun) 1 .3 20.7 1 .084 1 0.046   A+

Sulfate IC 4.88 1 0.35 4.50 1 0.10 0.922 0.084 A-9.58 0.68 9.70 0.30 1.013 0.080 A 19.5 1 .7 .959 1 0.032 A (rerun) 19.5 i .2 1 .036 0.056 A Silica Spec 5 .8 4 .0 0.877 i 0.065 A* 104 .7 1 .834 0.045 D* 157 1 .0 0.904 0.052 A (rerun) 5 .8 4 .8 0.902 1 0.050 A

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104 1 .4 0.971 1 0.038 A 157 .0 0.987 1 0.014 A Fe AA/FL 372 10 402 6 1.081 0.041 A* 796 10 791 1 1 0.994 1 0.013 A 1170 30 1161 11 0.992 0.027 A Cu AA/FL 400 6 411 2 1.028 0.016 A q 806 30 798 1 2 0.990 0.037 A 1200 30 1184 3 0.987 0.025 A Cr AA/FL 792 20 803 28 1.014 0.044 A , 1540 20 1506 25 0.978 0.021 A L 2320 1 40 2252 1 40 0.971 0.024 A l l l l i l

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Table 1 Cont'd 2' .. a a c Analyte Analytigal NRC Licensee Ratio- Comparison Method Y +'SD X + SD' 'Z + SD +2 SD' Na' Em 3 .5 32.0 1 0.1' 1.060 i 0.188- A 53 .1 1.208'i 0.097 D* 79.0 - '87 i .101 i 0.072 A ' NH 3 IC 416 20 480 1 7 1.154 i 0.078 A*

   '1200 1 12 1268 19 1.057- 0.033 A+

1968 92 2120 1 16 :1.077 i 0.051 A Hydra- Spec 1 .3 20.0 i .005 1.0.016 A zine 49.9 i .7 1 .956 1 0.030 A+ 100 -.i .7 i .927 1 0.039- A+

  (recal)d  19.9 'i .0 1 .005 i 0.016 A 49.9 i . .7 1.012 1 0.017 A 97.9 i 2.3-
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100 i .979 0.025 A Concentration, ppm

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Boron Titr 1040 10 1000 1 1 0.962 1 0.013 D* 3089- 41 2968 27 0.961 i 0.018 D* 5000 1 90 4933 i 73 0.987 1 0.023 A Value + standard deviation (SD); number of BNL analyses is six to nine'. The number of licensee analyses is thre Analytical methods: Titr - titration IC - Ion chromatography Spec - Spectrophotometric, 5-cm cell AA/FL- Atomic absorption Spectroscopy  ;

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Em - Emission spectrometry (using AA) A = Agreement D = Disagreement d. (recal) - recalculated results after recalibration, but did not reru * Substituted the BNL uncertainty for licensee's uncertaint + Substituted +3% RSD for both the BNL and licensee uncertainties

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