IR 05000237/1990008

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Insp Repts 50-237/90-08 & 50-249/90-07 on 900213-15.No Violations Noted.Major Areas Inspected:Chemistry Program, Including Procedures,Organization & Training,Qa/Qc Program in Lab & Nonradiological Confirmatory Measurements
ML17202H612
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 03/13/1990
From: Holtzman R, Schumacher M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17202H571 List:
References
50-237-90-08, 50-237-90-8, 50-249-90-07, 50-249-90-7, NUDOCS 9003230006
Download: ML17202H612 (11)


Text

{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No ~37/90008(DRSS); 50-249/90007(DRSS) Docket No ~0-237; 50-249 License Nos. DPR-19; DPR-25 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Power Station, Units 2 and 3 Inspection At: Dresden* Site, Morris, Illinois Inspection Conducted: February 13-15, 1990 (On-site) Inspector: {{, B ;LH::-.M~-"' R. 8. H6lt;-~~r\\1.V. -;?;J//dv~~ Approved By: M. C. Schumacher, Chief Radiological Controls and Chemistry Section Inspection Summary Date Inspection on February 13-15, 1990 (Report Nos. 50-237/90008(DRSS); 50-249/90007(DRSS)) Areas Inspected: Routine, unannounced inspection of: (1) the chemistry program, including procedures, organization, and training (IP 84750); (2) the hydrogen

  • water chemistry (HWC) program (IP 79701); (3) quality assurance/quality control program in the laboratory (IP 79701); (4) nonradiolgical confirmatory measurements (IP 79701); and (5) the Radiological Environmental Monitoring Program (IP 84750).

. . . .

  • Results:

The nonradiological chemistry confir.tDatory *measiJ'rement resul,ts.. wer_e very goo the:'.:laboratory has a*good.QA/Qc.program*tor analytical measureme:nts, which is being deve 1 oped furthe The.staff was. generally.knowl edgeab 1 e and competen The 'REMP appears to be operating~s*atisfactorfl No violations or deviations were identifie *

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DETAILS Persons Contacted

L. F. Gerner, Tech~ical Superintendent, DNPS 1.D. Morey, Chemistry Services Supervisor, DNPS

D. Saccomundo, Health Physics Supervisor, DNPS

F. D. Bevington, Quality Programs, CECo . K. Peterman, Regulatory Assurance Supervisor, DNPS

R. Falbo, Regulatory Assurance Assistant, DNPS 1, 2 K. Whittum, Chemi.stry Group Leader-Technical, DNPS D. Malauskas, Chemistry Group Leader-Operations, DNPS J. Rund, Auxiliary System Chemist, DNPS R. Holman, GSEP Coordinator, DNPS. The inspector al so interviewed other licensee personnel. in various departments in the course of the inspection. * 1Present at the plant exit interview on February 15, 199 Telephone conver~ation held on March 1, 199. Licensee Action oh Previous Inspection Findings (Closed) Open Item Nos. (50-237/88028-01; 50-249/88029-01):. Licensee to return the gas diluters on the HRSS containment air samplers to the manufacturer for rebuilding and recalibration of valve volumes.* The inspector's review of the documentation showed that the diluters had been overhauled and the valve volumes recalibrated and cer'tified by the manufacturer (Radiological and Chemical Technology, Inc.) to be 0.14 ml each. the licensee represeQtative stated that these values were within the Technical Speci fi cation r*equi rements of a factor of two of the conservative 0.1-ml value used previousl (Closed) Open Ite~ Nos. (50-237/88028-02; 50-249/88029-02): Licensee to install a new electrochemical potential and crack-growth monitor on the Unit-2 recirculation pipes to monitor the effects of hydrogen water c*hemistry (HWC) and to review the environmental* radiation levels due to the HW The station obtained and installed an E~P and crack-growth morii tor. * :Th~ sys'teiji "'i S*,:.pr,esent ly' befog. :

  • conditioned for operation (Section :4).

The lrispector reviewed the .data on the environmental r~di~tion.levels in s~me of the office. ::: *:-, ~

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-.~." The.radiation 1eve1 s* indicated by TLD measurements in the Hea 1th

  • Physics Office (formerly the Tour Center)-and the**Gatehouse s*ince oper.at ion of the HWC system in 1983 appeared to *have risen at most only 1-2 mrem/quarter relative to those in, the year prior; this*

increase is probably within.the limits.oL.measurement.uncertaint (Closed) Open Item No (50~237/88028-03; 50-249/88029-03): The licensee split with Brookhaven National Laboratory (BNL) an RCS sample spiked with chloride, fl~oride and sulfate, analyzed it,

\\. .. 1' and sent the results to Region III for comparison with the BNL results.. The results of the comparison are shown in Table 1 and the acceptance criteria in Attachment The results showed two of the three results to be in agreement; the chloride result, although in agreement, had a large positive bia We were.unable to resolve the differences beca~se of the uncertainties in the BNL result However, because of the similarities in the licensee's

  • three. results, whichindicates*a possible dilution problem, and

. the good agreements obtained during the present inspection, this item is considered to be satisfactorily close (Closed) Open Item Nos~ (50-237/88028-04; 50-249/88029-04): The licensee. improved the procedure for the anioh analyses on the ion chromatograph (IC), and the metal analyses on the ~tomic absorption spectrophotometer (AAS).

The quality of the IC standards was improved by revising laboratory practice to use a more accurate commercially-available aqueous standard (allowable under the IC procedure). *The procedure has been updated and is in the final approval stag The problems with the metal analyses were not fully-resolved, but the AAS was replaced by a more sophisticated model with a Zeeman effect background correcto. Management Controls, Organization and Training (IP 84750) The Chemistry Department organization has been little changed since the previous inspection in this area. 1 The Chemistry Services Supervisor now reports to the Technical Superintenden Reporting to the Supervisor are the Operational Group and Technical Group Leaders, supported by three and four staff members, respectively, and an additional Laboratory Foreman has been added for a total of thre There are still 14 permanently-assigned chemistry technicians (CT), all qualified as CTs under the standard ANSI N18.1-197 The staffing appears.to be adequate to perform the required chemistry for plant operation The permanent assignment of technicians to Chemistry appears to be a substantial improvement in laboratory capabilities and technician proficiencie No v1olations or deviations were identifie. ~:.. ' ' "~ .. The inspect.or reviewed*aspe.cts of the"hydrogen water c*hem1stry (HWC) in which. hydrogen is added to the feedwater*. to reduce oxygen l eve 1 s in the .**. RCS to limit*.corrosion. *licensee representatives noted th~t despite the

  • /*. use of' this process over about five years, *cracks were found in the recirculation and cleanup inlet pipes in a recent ultrasound test (UT)

progra While.the recirc pipe damage was considered to be intergranular 1Region III Inspection Report Nos.(50-237/88028; 50-249/88029).

.. i stress corrosion cracking (IGSCC), it was not apparent that the cracks occurred since the implementation of HWC; it is believed that they were observed due to improved UT:techniques and a chemical decontamination that may have removed debris from the crack Because the cracks in the inlet pipe had a different pattern, the cause was attributed to thermal stress, rather than to IGSCC. *To optimize the HWC, the licensee obtained and installed a new electrochemical potential (ECP) and tra~k arrest verification (CAV) monitor much sooner than previously scheduled (Section 2c).

Sampling lines are presently being conditioned with-oxygenated water to provide accurate values of ECP and CA Licensee representatives expect the monitor to be operational about July 199 No violations cir deviations were identifie. * Implementation -of the Chemistry Program (IP 84750) The inspector reviewed the chemistry programs, including physical .facilities and 1 aboratory operation The 1 aboratori es are greatly improved over previous years; the laboratory has been completed, traffic of nonlaboratory personnel through the area has been stopped and the entire laboratory was made into a radiological controlled are Housekeeping and bench space were adequate for the analyses performe Laboratory instrumentation has been improved; a riew computer-operated Autoion 455 Model III two-unit Dionex Ion Chromatographic system has been added and the IC equipment upgraded; and the atomic absorption spectrophotometer (AAS) was upgraded to a computerized Perkin-Elmer Model 5100 AAS with a Zeeman background corrector furnac Overall, the laboratory appeared to be adequate for the proper operation of the plant and to be operating satisfactoril Licensee management is aware of the value of a good water quality control program, and has improved both the laboratory facilities and its organization (Section 3).

No violations or deviatidns were identifie Nonradiological Confirmatory Measurements (IP 79701) The inspector submitted chemistry samples to the licensee for analyses . as part of a program to evaluate the laboratory's capabilities to monitor nonradiological chemistry parameters in various plant _systems with respect to *v~rious.Technical *Specifica~*;on and other :treguJatory.~and -Ciaiil.inistrative

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requirements. *. These samples had 'been prepared*/':'lstandard1zed"~* and* . periodicall_y reanalyzed (to *che_c~. for ~tability) for. the,NRC by _the

  • * Safety and' Environmental Protection Divis.ion ~of Brookhaven* Natfonal Laboratory (BNL).

The samp 1 es were analyzed *1by the 1 i cen_see using rou~foe methods and equipmen * '*

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  • The samp 1 es were di 1 uted by * 1 icensee personne 1° as necessary to bring the concentrations within the ranges normally analyzed by the 1 aboratory, and 2 Ibi.

,. ...... *:*. run in triplicate in a manner si~ilar to that of routine sample The results are presented in Table 2 with the the criteria for agreement presented at the end of the tabl These criteria are derived from the BNL results of the present samples and the relative standard deviations (RSD) derived from the results of the 1986 interlaboratory comparisons from the various plant laboratories in the study (Table 2.1, NUREG/CR-5422).

The acceptance criteria were that the licensee's value should be within +/- 2 SD of the BNL value for agreement and between 2 and 3 SD for qualified agreemen * the licensee analyzed nine analytes at thr~e concentrations each, except that six samples of boron were analyze Of the initial 30 analyses, 26 were in agreement and two were qualified agreement (Table 2) for a total agreement of 93% with the BNL value The disagreements included the results from a nickel and a silica sampl A rerun of th~ high-level silica brought it into agreemen However, the bias was still low; the licensee is examining the possible effects of low temperatures on color development. The change in bias of the results from the low to the high concentration samples. indicates the possibility of silica contamination in the deionized water used for dilution.* The disagieement in the nickel analysis appears to be due. to a defective sample or dilution erro Some of the problems appear to be due to the use of a new AAS with procedures still under development, and the sample matrix, which contains all four metal ions in approximately equal concentrations, is not that normally analyzed by the laborator The licensee's results were very good and greatly improved over those in the previous inspection. 3 Resolution of the discrepancies above will be followed in subsequent routine inspections in.this area. . No violations or deviations were identifie Implementation of the QA/QC Program in the Chemistry Laboratory (IP 79701) The inspector reviewed the nonradiological QA/QC program in the laborator This program is governed by procedure DCP 1900-3, 11Chemistry Quality Control,

Revision 3, March 31, 1988, ~ispresently beini update They have control charts for all analyses as noted previousl The charts were good and well maintained in the logbooks of the. respectiye i~~r_uments. The . inspector. noted *that the charts w9uld b(!. ~m~.r~t~u~ef~J.:.,jJ *~~~tPr.evj~.us

  • completed one were kept along with* the ongoing c*ha:rt."'.The.. lieensee representative agreed to follow. this su.ggest.ion......... *** *

The technician performance test program "(as reviewed. *In the light of

    • .the 'permanent assignment of the CTs to Chemistry, the*** ncensee modified
  • the program to have the CTs spend time at the Corporate Production Training
  • ,Center at Braidwood annually for requalification training and testing on the instrumentation, which was identical to that in the plan In the Ibi Ibid..

., * initial session the CTs set~p and calibtated each of the insttuments and ran a performance check ~tandard. The acceptance limits were the two-sigma control limits for the instrument used in the plant laborator Only one of the results was out.of the acceptable rang This program had the advantages that an independent chemist observed the CTs and each CT ran each of the analyses, some of which they did not necessarily do in their own work over the year, due to scheduling problem In the future sessions the program will be enhanced to require the running of blind sample *

  • The 1 i censee results in the corporate i nterl aboratory comparison was good over 1988; running 89-100% agreement, but they dropped in the first two quarters of 1989 to the 70-76% range. *These improved to 96-100% in the subsequent two quarter The inspector noted to litensee representatives that the QA/QC program has progressed well and appears to be a good program as planne Further progress of this program will be followed in subsequent routine chemistry inspection *

No violations or deviations were identifie Radiological En~ironmental Monitoring Program (REMP) (IP 84750) The inspector reviewed the licensee 1s REMP, including the two latest (1987 and 1988) Annual Environmental Reports, inspected several environmental air sampling stations, and discussed aspects of the program with the Health Physics.Superviso The program is operated. by CECo corporate personnel and collect the environmental sample The sample~ are collected and analyzed, by a vendor laboratory (Teledyne, Inc.) who also makes the report The Annual REMP Reports conformed to the Technical Specification requirements, including lists of missing samples and the availability onsite of the individual measurement data (the cumulative monthly reports January to December of the respective years).

The inspector noted that the text summary stated that there was no effect of the plant on the environment; however, some of the 1988 samples showed measurable levels of up to 1100 pCi/liter of H-3 (LLD 200 pCi/liter). This is below the Technical Specification reporting level of 20,000 pCi/lite The licensee representative stated that samples listed<were part of the shared values from the.areas around the GE Fuel Reprocessing Facility in Morris.* The licensee will note reasons for such anomalies in future report The inspector observed the operation of five air sampling station They appeared to be operating satisfactorily, except J-03 in which th weak vacuum was observed.while.blocking the filter face, indicating air inleakage after the sample hea Moreover, a single individual could not simultaneously observe the flow ~eter and check the vacuum whil blocking the filter by hand. -After the inspector noted his concerns, the licensee agreed to correct this proble Otherwise, the REMP appeared to be operating satisfactoril No violations or deviations were identifie " ,.. Open Items Open items are matters which have b~en 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 No open items were diiclosed during. the inspection;

1 Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section* 1) at the conclusion of the inspection on February 15, 1990, and in a telephone discussion on March 1, 1990, with a Chemis The inspector discussed the Open Items in Section 2 and observations on the quality control program and the confirmatory measurement He noted the progress in the QA/QC program since the previous inspectio The inspector noted that the data indicates that the HWC apparently did not significantly increase radiation levels in the Health Physics office and Gatehous He discussed the REMP and the problem with the air sampler 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 inspectio Licensee representatives did not identify any such documents or processes as proprietar Attachments:* Table 1, Nonradiological Split Sample Intercomparison, June 1989 Table 2, Nonradiological Interlaboratory Test Results, February 13-15, 1990 Attachment 1, Criteria for Comparing Analytical Measurements (Nonradiological)

TAB.LE 1 Nonradiological Interlaboratory Split Sample Results Dresden Nuclear Power Station June 1989 Analyte * Matrixa Analys~s NRC Licensee Ratio Comparisonc Method * Y +/- SD X +/- SD Z +/- SD

  • +/-2 SD toncentration 2 E~b Fluoride RCS IC 24.8 +/- 2 25.5 +/-. 028 +/- 0. 083 A

Chloride RCS IC 16.3 +/- 2 . 24:4 +/-. 497 +/- 0.260 A* Sulfate RCS IC 50.2 +/- 1. 5 25.1 +/-.500 +/- 0'.426 D* Matrix: RCS* Reactor Coolant System.* ~. Analytical method: IC Ion Chromatatography Comparison: A Agree D Disagree (See Attachment 1 for agre~ment criteria.). "--.-,t f).

. Analyte Fluoride Chloride Sulfate Iron Copper Ni eke l Chromium Silica

  • '(rerun)

Boron (New set) Boron (Old set) TABLE 2 Nonradiological Confirmatory Measurements Results Dresden Nuclear Power Station February 13-15, 1990 Method1 Conc2 Ratio3. Acceptance Ranges 4 +/- 2RSD +/- 3 RSD .ePE A IC

1. 050 0. 875-1.125 0. 813-1. 187 B

Q.967 0. 875-1.125 0. 813-1. 187 c

0.922 0. 875-1. 125 0:813-1.187 A IC

1.000 0: 933-1. 067 0. 900-1. 100 B

0.932 0. 917-1. 081 0. 879-1. 121 c

0. 977 0. 926...:1. 074 0. 895-1. 105 A IC

1. 011 0.895-1.105 0. 842-1. 158 B

0.958 '- 0. 895-1.105 0.868-1.132 c

0.947 0. 900-1. 100 0. 867-1.133 G AA/FL 500 0.976 0. 904-1. 096 0. 854-1. 146 H 900 1. 002 0. 903-1. 097. 0.857-1.143 I 1500 1. 015 o~ 903-1. 097 0. 855-1. 145 G AA/FL 500 1. 055 0. 904-1. 095 0. 859-1. 141 H 900 1.040 0. 904-1. 096 0. 857-1.143 I 1500 1.047 0. 904-1. 096 0. 857-1.143 G AA/FL 500 0.920 0. 936-1. 064 0. 906-1. 094 H.. 900 0.648 0. 936-.1. 064 0. 906-1. 094 I 1500 0~942 0. 936-1. 064 0. 906-1. 094 G AA/FL 500 1.112 0.905-1.096 0. 855~ 1. 145 H 900 1.063 0. 905-1. 096 0. 855-1. i45 I 1400 . 1. 068 . 0. 905-1. 096 0.855-1.145. .. * ,.

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. ri. 859-1.141 T ... ;..

o. 987 *. 'o. 906-L 094 0.,859-1.141 u

0. 776 . 0.966-1. 09 o.*as9-L 141 u

0.928 0. 906-1. 094 0':859-"1.141. . . *i*.. * .. ;*.*.. D Ti tr 1000 0;981 0. 9*79.:.i. 021 0.968-1.032 E 3000 1.006

  • . 0. 979-1. 021

. 0. 968-1. 032 f, 5000 0.987 0. 979-1. 021' 0. 968-1. 032 D Ti tr 1000 1. 001 0. 979-: 1. 021 0. 968-L 032 E 300.005 0. 979.-1. 021 0. 968-1. 032 F 500..009

  • O. 979-1. 021 0. 968-1. 032 Result 5 A

A A

  • A A

A A A A A A A* A A A A+ D A A+ A A . ~:: .A.. A

  • o A

.. A A A A A A

1Methods: Titr - Titration . IC - Ion Chromatography Spec - Spectrophotometry AA/FL - Atomic absorption spectrophotometry (flame) 2Conc: Approximate c6ncentration analyze Ratio of Licensee mean value to NRC mean valu The RSD in the fifth and sixth columns represents the coefficient of variation

  • obtained from averaging licensee data from the preceding cycle {Table 2.1.of NUREG/CR~5244). The licensee value is considered to be in agreement if it falls within the+/- 2 RSD range; a qualified agreement if it lies outside+/- 2 RSD but within +/- 3 RSD; and in disagreement if it is outside the +/- 3 RSD rang *

5Result: A = Agreement: Licensee value is within +/- 2 RSDs of the NRC mean valu A+= Qualified agreement, licensee is between+/- 2 and+/- 3 RSDs of

the NRC valu *

D = Disagreement: licensee value is outside +/- 3 RSDs. . -:,* ' ......_:.*.~.

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( ATTACHMENT 1 Criteria for Comparing Analytical Measurements

  • This attachment provides criteria. for comparing results of the capability tests..

The acceptance limits are based on the uncertainty (standard deviation) of the ratio of the licensee's mean value (X) to the NRC mean valu~ (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

_ 5/

l, so that rr - xr + vz-s = z * ~

+ :.:t_ .(52 SJ~ 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, I 1-Z I ~ 2*Sz. National Council on Radiation Protection and Measurements, A Handbook of Radioactivit~ Measurements Procedures, NCRP Report No. 58, Seconii Edition, 1985, Pages 322-326 (see* Page 324).

4/6/87 }}