IR 05000237/1988003
| ML17199U386 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/19/1988 |
| From: | Holtzman R, House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| References | |
| 50-237-88-03, 50-237-88-3, 50-249-88-03, 50-249-88-3, NUDOCS 8802250364 | |
| Download: ML17199U386 (13) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/88003(DRSS); 50-249/88003(DRSS)
Docket Nos. 50-237; 50-249 Licenses No. DRP-19; DRP-25 Licensee:
Commonwealth Edison Company Post Office Box 767 J Chicago, IL 60690 Facility Name:
Dresden Nuclear Power Station, Units 2 and 3 Inspection At:
Dresden Site, Morris, Illinois Inspection Conducted:
January 12-15, 1988 (Onsite)
January 25, 1988 (Telephone Conversation)
7J!~J4 Inspectors:
R. B. Holtzman
~
J. E. House
~//~
Approved By:
M. Schumacher, Chief Radiological Effluents and Chemistry Section Inspection Summary
- 2//?/r,P Date L/;t/8'r Date '
~M Date Inspection on January 12-15, and 25, 1988 (Reports No. 50-237/88003(DRSS);
No. 50-249/88003(DRSS))
Areas Inspected:
Routine announced inspection of: (1) the chemistry program, including procedures, organization, and training; (2) reactor systems water quality control programs; (3) quality assurance/quality control program in the laboratory; and (4) nonradioactive confirmatory measurement Results:
No violations or deviations were identified.
0 '">?50364 880219 88 ~~
- DETAILS Person Contacted
- J. W. Wujica, Production Supervisor, Dresden Nuclear Power Station (DNPS)
- D. A. Adam, Rad/Chem Supervisor, DNPS
- E. Armstrong, Regulatory Assurance Supervisor, DNPS
- J. R. Williams, Regulatory Assurance, DNPS
- W. R. Betourne, Site QA, CECo
+*D. Morey, Lead Chemist, DNPS K. Neal, Unit Chemist, DNPS K. Whittum, Technical Coordinator, Chemistry, DNPS J. Rund, Auxiliary Systems Chemist, DNPS V. Whitfield, Chemistry Engineering Assistant, DNPS R. Berg, QA Coordinator, Chemistry Engineering Assistant, DNPS J. Ruettinger, Chemistry Laboratory Foreman, DNPS D. Ferrari, Rad/Chem Technician (RCT), DNPS V. Howard, RCT, DNPS L. Schmudde, Training Instructor, DNPS
- M. C. Schumacher, RECS Section Chief, Region Ill, NRC The inspectors also interviewed other licensee personnel in various departments in the course of the inspectio *Denotes those present at the plant exit interview on January 15, 198 +Denotes those present during the telephone conversation held on January 25, 198.
Licensee Action on Previous Inspection Findings (Closed) Violation 50-237/86026-05:
Licensee failed to take the required four-hour sample of reactor coolant during Unit 2 startup on July 13, 1986 (LER 86-018, August 18, 1986, Docket 50-237).
In a second similar event on December 12, 1986, the licensee failed to determine the I-131 content in a routine reactor coolant sample collected from Unit 3 (LER 86-023, December 24, 1986, Docket 50-249).
The latter event was not cited as a violation because it was similar to the former, had a similar cause, and was within the time period for corrective action The procedures governing the sampling and measurement of parameters of reactor coolant were deficient in the instructions for defining the sampling periods, measurements, and notification of the proper personnel for these operation To address these problems, the chemistry procedure DCP 1600-12,
"Technical Specification Reactor Sampling Requirements, 11 was revised (Revision 2, approved April 10, 1987) to provide adequate directions to the Radiation Chemistry Technicians (RCTs) and Foremen using this procedur The inspectors' review of the continuing Training Program records showed that during the first quarter of 1987, all RCTs and the foremen involved in the sampling procedure recei~ed training on Technical Specification requirements relating to chemistr The violation and the two LERs are considered close.. (Closed) Open Item Nos. (50-237/86014-01; 50-249/86016-01):
Effectiveness of RCT training program will be reviewed by observing the laboratory performance of the RCT The inspectors observed the RCTs performing various analyses in the laboratory, including a boron titration, atomic absorption analyses, and ion chromatographic and spectrophotometric analyse They appeared to be reasonably knowledgeable about the analytical methods and laboratory techniqu This item will be reviewed further in subsequent routine chemistry inspection (Closed) Open Item Nos. (50-237/86014-04; 50-249/86016-04):
Licensee to upgrade inline monitors for dissolved oxygen, pH, conductivity, and other parameter The licensee has replaced the older inline monitors with state-of-the-art instrumentation, including conductivity, dissolved oxygen and pH meters that have improved stability, accuracy, require less maintenance, and result in lower radiation dose Output data can be continuously monitored in the Chemistry offic Some units are on transportable sample stations for additional versatilit This work appears to have progressed well; it will be followed in subsequent routine chemistry inspection (Open) Open Item Nos. (50-237/86014-06; 50-249/86016-06):
Licensee to make numerous plant modifications to comply with the BWR water quality control progra The inspectors' review of this program showed that the reactor coolant sampling panels had been redone, additional sample cooling capacity was added for increased accuracy of the conductivity measurements and the surrounding areas had been cleaned up and painte The other elements of this item were not examined, including the installation of sodium analyzers in the hotwell, modification of the resin regeneration equipment to reduce resin waste during condenser leakage, installation of resin samplers in the condensate demineralizer, makeup water degassers, and the installation of a separate dedicated cleanup system fo~ the suppression pool wate These will be reviewed in a subsequent inspectio (Closed) Open Item Nos. (50-237/86026-03; 50-249/860031-03):
Licensee to repair leaky valve on the Unit 2 Reactor Building Sample Pane The licensee has subsequently rebuilt this pane It appeared to be operational and clea (Open) Open Item (50-237/87008-01; 50-249/87007-01):
The licensee agreed to split a waste tank sample and determine the gross beta, H-3, Fe-55, Sr-89, and Sr-90 concentrations and report the results to Region II The comparison of the reported licensee results and those from the NRC Reference Laboratory and the Radiological Environmental and Safety Laboratory (RESL) of the Department of Energy, Idaho Falls, Idaho are presented in Table 1 of this report with agreement criteria in Attachment The licensee had three disagreements in f1ve analyse The causes of the
- disagreements were not ascertaine The low values of the strontium isotopes may have been caused by plate out on the containers and incomplete recovery by the licensee contracto The differences in the Fe-55 values is being explored with the licensee and contracto The licensee agreed to analyze a spiked sample from RESL and report the results to Region II Management Controls, Organization, and Training The management of the Chemistry Group has been revised extensively since the previous inspection in this area. 1 A new Lead Chemist was appointed about six months ag Although he has not previously worked permanently in a nuclear plant, he appears to be qualified under ANSI 3.1-197 He received a Bachelor of Science degree in Chemical Engineering, and was at the Corporate Technical Center, Nuclear Services Technical for four years where 30-40% of his time was spent at nuclear generating. station He has had several courses in Nuclear Engineering and radiochemistry, including a three-month assignment at Byron for Unit 2 startup and work on Radiochemistry problems at Dresden (six man-months).
The laboratory has a Technical Coordinator supervising a Radiochemist, the Spectrometer Room Engineering Assistant (EA), and the QC Chemis The Group has applied for an additional position of Laboratory Chemis The Operational coordinator supervises the Unit Chemist, Auxiliary Systems Chemist, and the Chemical Control E The Laboratory Foreman directly supervises the analyses, especially the new ion chromatographic system, while an RCT acting as Chemistry Foreman does the laboratory scheduling, et This latter position has been authorized to be permanent in February 198 The Rad/Chem Department has 49 RCTs, all ANSI qualifie The chemistry laboratory has about seven RCTs on the day shift and one on each backshift, who also do health physics wor The problem of proficiency loss with rotation of RCTs between health physics and chemistry was mitigated to some extent by having a fulltime Laboratory.Forema The staffing appears to be adequate to perform the required chemistry for plant operation The licensee's RCT training program was certified by INPO on January 28, 198 No violations or deviations were identifie.
Water Chemistry Control Program The inspectors reviewed aspects of the Water Chemistry Control Progra Plant water specifications and sampling protocols are defined by DCP 1200-5, "Reporting Conditions For Selected Laboratory Analyses,"
Revision 9, December 1987, and DCP 1600-12, "Technical Specification 1 Region III Inspection Reports No. (50-237/86026; 50-249/86026).
Reactor Coolant Sampling Requirements, 11 Revision 2, April 198 charts are plotted for reactor coolant and feedwater parameters Trend listed 1200-5 in the above document The administrative limits given in DCP conform to the BWR Owners Group Guideline Actual levels of contaminants in reactor water systems are maintained well below the recommended limits of the Owners Group Guidelines and the licensee appears to have chemical contamination under contro Vigorous implementation of chemical control program (Section 7) appears to have contributed to the low-levels of contaminants in the RC New, improved inline conductivity and dissolved oxygen instrumentation continuously monitor water quality (See Section 2c).
A new Dionex inline monitoring system is on orde Licensee management appears to be aware of the value of a good water quality control program and committed to maintaining contaminant levels at a minimu No violations or deviations were identifie.
Implementation of the Chemistry Program The inspectors reviewed the chemistry programs including physical facilities and laboratory operation The hot laboratory is being rebuilt with special facilities for nonradiological trace-level analysi At present, these facilities are located on the turbine floor of Dresden Unit 1 building in a temporary structur This laboratory is well equipped, well lighted and ventilated through HEPA filter It has a state of the art computerized Oionex Ion Chromatography (IC) (Auto Ion 400) system, a Brinkman fiber optic PC800 Colorimeter, an Orion EA940 Ionalyzer, and a Horiba PIR-2000/Dohrman Total Organic Carbon Analyze A small hot lab in the main laboratory area houses a Perkin Elmer 5000 Atomic Absorption Spectrophotometer (AA).
The inspectors observed several RCTs analyze the confirmatory measurements samples by titration, UV/visible spectrophotometry, AA, and ion chromatograph They appeared to be generally knowledgeable about the work, followed the procedures, and did well in the analyse Overall, the laboratory 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 The inspectors submitted chemistry samples to the licensee for analysis as part of a program to evaluate the laboratory 1 s capabilities to monitor nonradiological chemistry parameters in various plant systems with respect to various Technical Specifications and other regulatory and administrative requirement 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 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 These criteria for *agreement are based on comparisons of the mean values and estimates of the standard deviations (s.d.) of the measurement Consideration was given to the fact that the uncertainties (s.d.) 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 tim Consequently when the licensee s.d. was less than that of BNL, and a disagreement resulted, the BNL value was substituted for that of the licensee in calculating the s.d. of the ratio Z (S in
.
z Attachment 2).
The licensee also prepared two samples to be split with BN To these were added analytes supplied by the inspecto Reactor water was spiked with the anions, chloride and sulfate, and samples of condensate were spiked with the cations, copper, iron, nickel and chromiu The licensee will determine the concentrations of the analytes in each and the results will be sent to Region III for comparison with the values determined by BN This will be followed under the Open Item Nos. (50-237/88003-01; 50-249/88003-01).
The licensee analyzed nine materials at three concentrations eac Of the 27 analyses, 24 or 89% were in agreement with the BNL value The three disagreements involved boron whose results were biased lo There appears to be a systematic problem with the assay that could not be completely resolved by the licensee during the inspectio Subsequent review of the low level boron assay by the licensee resulted in modifications based on the ASTM D 3082 Method B (1984) (Mannitol Potentiometric Method).
Reanalysis of a second set of boron samples resulted in agreement with the BNL dat The licensee indicated that the low level boron assay will be revised and based on the above listed ASTM procedure instead of an earlier (1971) Standard Methods Procedur This assay will be reviewed in the next chemistry inspectio The low level sulfate analysis was biased high (24%) but in agreement owing to a large standard deviation; similarly, the low level fluoride was biased 19% low but was in agreemen The licensee was experiencing some difficulties with the ion chromatograph that may have contributed to the fluctuation in the fluoride and sulfate assay The Dionex 2020i has recently been upgraded to an Autoion 400 system and the licensee is gaining operating experience with the syste Given the capabilities of the instrumentation for precision and accuracy, further operating experience should result in improved analytical performanc The metal analyses with one exception (middle level chromium) exhibited low biases up to 7%.
This is indicative of a systematic error in the
atomic absorption methodologies, e.g., problems with the standards and could represent a developing proble No violations or deviations were foun.
Implementation of the QA/QC Program in the Chemistry Laborator The inspectors reviewed the nonradiological QA/QC program in the laborator The program is defined by NSO Directive NSOO-S25, 11 Nuclear Stations Chemistry Quality Control Program Manual, 11 Revision 0, January 198 The licensee has multiple point calibration curves for all analyses including the Autoion 400 (IC) System which uses a five point curve with a quadratic fitting procedur Control charts, stipulated under Section 7.0 of NSOO-S25 are in-place, except for the low level boron assay and for the recently upgraded and modified IC syste The licensee is considering modification to the charts that would include plotting the mean +/- standard deviation The present method plots a target value along with standard deviation As the target value does not represent the mean, the charts lack symmetry and trends are difficult to observ Implementation of control charts will be followed under open items (50-237/88003-02; 50-249/88003-02).
The licensee incorporates controls in the analytical procedures; however, the control material is not necessarily of a different lot number (or manufacturer) than the calibration material and is therefore not truly independen This is a weaknes The inspectors reviewed the licensee's interlaboratory comparison program that is managed by the corporate Technical Cente Individual CECo plants analyze samples provided by the Center and compare their results to calculated (not analyzed) values from the Technical Cente Results appear to be reasonable in most cases and a review of the data suggests that the system is improvin A comparison of licensee data with that of an outside laboratory (NWT) for a CECo sample showed good agreemen This program will be followed in subsequent inspection The licensee's RCT testing program (Section 9.3, NSOD-S25) was reviewed by the inspector Each Monday the RCTs in a given lab are required to analyze check samples for chemistry procedures they will be using that wee Reagents prepared in-house appeared to be labeled with a standard format, and purchased reagents were receipt date No outdated reagents were observe Instrument maintenance logs are located with the instrument The licensee appears to have an adequate QA system for instruments and reagent The licensee has developed an extensive chemical control program (OAP 16-1, Revision 4 and OAP 16-2, Revision O) for determining what industrial chemicals are allowed or used in the plan Nuclear grade material are utilized when ever possibl All chemicals in the plant (except laboratory or process chemicals) are labeled and stored as
require Two goals of the program are reduction of total organic carbon in plant radwaste water and decreased usage of chlorinated hydrocarbons in plant system Licensee representative stated that resin bed usage for waste water cleanup had decreased by about 50% in the past yea Overall, the licensee's performance indicates a commitment to development of a good measurements control program, and the response to the boron assay difficulties indicates a willingness to respond to NRC initiative No violations or deviations were observe.
Open Items 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 January 15, 198 The inspectors discussed the Open Items in Section 2 as well as observations on the quality control and confirmatory measurement program License representative agreed to review the boron analysis (Section 6) and to implement control charts for boron plus those analyses performed on the ion chromatograp The licensee also agreed to review plotting the mean value of independent control on the control chart either in addition to or in place of the true valu The inspectors noted the progress in the QA/QC program since the previous inspectio 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 inspectio Licensee representatives did not identify any such documents or processes as proprietar Attachments: Table 1 Confirmatory Measurements Program (Radiological) Attachment 1, Criteria for comparing analytical measurements (Radiological) Table 2, Nonradiological Interlaboratory Test Results, January 12-15, 1988 Attachment 2, Criteria for Comparing Analytical Measurements (Nonradiological)
TABLE 2 Nonradiological
.
a Interlaboratory Test Results Dresden Nuclear Generating Station, Units 2 and 3 January 12-15, 1988 Analysi5 Oil ution NRC(BNL)
Licensee Ratio Comparison c Analyte Method l:x y +/- s.d.(n)
x +/- s.d.(n)
z +/- s. +/- 2 Concentration, ppb Fluoride IC 2000 11. 6 +/- 0. 25(8)
9.42 +/- 1.56 0.812 +/- 0.136 A
2000 21. 8 +/- 0. 95(8)
21.87 +/- 0.55 l. 003 +/- 0. 050 A
2000 41.8 +/- 1.4(7)
40.23 +/- 5.49 0.962 +/- 0.135 A
Chloride IC 2000 12.1 +/- 1. 6(7)
1 +/- 1. 28 0.868 +/- 0.156 A
2000 18.7 +/- 0.6(7)
17.73 +/- 0.92 0.948 +/- 0.058 A
2000 40. 3 +/- 1.1(8)
38.27 +/- 0.93 0.950 +/- 0.035 A
. Sul fate IC 2000 10.0 +/- 0.45(7)
12.4 +/- 1. 3 1. 243 +/- 0.144 A
2000 20. 5 +/- 1. 2(8)
2 +/- 0.78 1. 015 +/- 0. 070 A
2000 40. 4 +/- 1. 5(7)
40. 54 +/- 1. 5 1. 002 +/- 0. 053 A
Silica Spec 2000 27.15 +/- 2.8(7)
3 +/- 0.57 1.105 +/- 0.116 A 2000 5 +/- 3. 5(7)
57.53 +/- 2.86 1. 056 +/- 0. 086 A 2000 80.0 +/- 2. 5(7)
7 +/-.985 +/- 0.058 A Concentration, ppm Iron AAS
0.489 +/- 0.035(13)
0.461 +/- 0.004 0.943 +/- 0.068 A
0.955 +/- 0.034(14)
0.917 +/- 0.007 0.960 +/- 0.035 A
1. 47
+/- 0.042(13) 1. 40
+/- 0.008 0.952 +/- 0.028 A Copper AAS
0.468 +/- 0.024(12)
0.448 +/- 0.005 0.957 +/- 0.050 A
0.966 +/- 0.049(14) 0.915 +/- 0.005 0.947 +/- 0.048 A
1.45 +/- 0.06(13)
1. 382 +/- 0. 008 0.953 +/- 0.040 A Nickel AAS
0.51
+/- 0.026(6)
0.491 +/- 0.011 0.963 +/- 0.054 A
1. 02
+/- 0. 03(7)
0.993 +/- 0.06(6) 0.974 +/- 0.065 A
0. 765 +/- 0. 02(7)
0.741 +/- 0.015 0.969 +/- 0.032 A Chromium AAS 2.5 2.04
+/- 0.12(6)
1. 885 +/- 0. 020 0.924 +/- 0.055 A
0.941 +/- 0.03(6)
1. 008 +/- 0. 009 1.071 +/- 0.0471 A*
2.86
+/- 0.16(6)
2.75
+/- 0.038 0.963 +/- 0.056 A Boron Titr
1000 +/- 10(7)
947
+/- 0(3)
0.947 +/- 0.014 D
3024 +/- 46(7)
2883
+/- 6(3)
0.953 +/- 0.021 D
4947 +/- 61(6)
4772
+/- 0(3)
0.965 +/- 0.017 D
Boron Ti tr
1000 +/- 10(7)
1021. 7 +/- 5. 8(3) 1. 022 +/- 0. 012 (Rerun)
3024 +/- 46(7)
3023
+/- 28(3)
1. 000 +/- 0. 018
4947 +/- 61(6)
5042
+/- 46(3)
1. 019 +/- 0. 016 Value+/- standard deviation (s.d.); n is number of BNL analyse The number of licensee analyses is 3 unless otherwise note Analytical methods:
Titr - titration IC
- Ion chromatography Spec - Spectrophotometric AAS
- Atomic absorption Spectroscopy (flame) A = Agreement D = Disagreement
- Substituted the BNL uncertainty for licensee's uncertaint A A
A
TABLE 1 LI S NUCLEAR REGULA TORY COMM I ~;SI ON OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM FACILITY: DRESDEN FOR THE 2 QUARTER OF 1987
NRC-------
LICENSEE----
---LICENSEE:NRC----
SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T
L 1,,.1ASTE G BETA 3.2E-06 H-3 7. lE-04 FE-55 1. 3E-05 SR-89 4.3E-08 SF~-90 3. 1 E-08 T TEST RESULTS:
A=AGREEMENT
-
- AGREEMENT TERI A RELA)::ED COMPARISON 1.3E-C>7 3.5E-06 1. OE-05 6.4E-04 2.0E-07 1. 7E-05 1. lE-08 1.0E-08 5.0E-09 (5.0E-09 O. OE-01 1. 1E (10 2.5E 01 A
0. OE--0.0E-O. 1E 01 A
O. OE-01 1. 3E 00 6.7E (11
[I O.OE-01 2.3E-01 3.9E 00 D
O.OE-01 1. 6E-01 6.2E 00 D
ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurement 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 Conversely, poorer agreement should be considered acceptable as the resolution decrease The values in the ratio criteria may be rounded to fewer significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement
<4 0.4 -.5 -.6 - 1.66 16 -
0.75 - 1.33 51 - 200 0.80 - 1.25 200 -
0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclide These may be factored into the acceptance criteria and identified on the data shee. ".. "'
ATTACHMENT 2 Criteria for Comparing Analytical Measurements This attachment provides criteria for comparin~ results of the capability test ~The acceptance limits are based on the uncertainty (standard deviation) of the I 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 p~opagation of the uncertainties of licensee's mean value, Sx, and of the NRC's mean value, SY. 1 Thus, 5z
_ 5x
~ so that rr - xr * vr'
s = z * f 5/ + :.l \\~
z
\\x2 v~
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,.
National Council on Radiation Protection and Measurements, A Handbook of Radioactivit~ Measurements Procedures, NCRP Report No. 58, Second Edition, 1985, Pages 322-326 (see Page 324).
."
4/6/87