IR 05000237/1991013
| ML17174A724 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/20/1991 |
| From: | House J, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17174A723 | List: |
| References | |
| 50-237-91-13, 50-249-91-12, NUDOCS 9105290358 | |
| Download: ML17174A724 (8) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Reports Nos. 50-237/91013(DRSS); 50-249/91012(DRSS)
Docket Nos. 50-237; 50-249 Licensee:
Commonwealth Edison Company 1400 Opus Place Downers Grove, IL 60515 License Nos. DPR-19; DPR-25 Facjlity Name:
Dresden Nuclear Generating Station, Units 2 and 3 Inspection At:
Dresden Site, Morris, Illinois Inspection Conducted:
April 30 - May 3, and May 8, 1991 (On site)
May 13, (Regional visit)
Inspector: ?(~~
J. E. House
~~/
Date
Approved ~~
By: C~ Schumacher, Chief Radiological Controls and Chemistry Section Date Inspection Summary Inspection on April 30 - May 3, and Ma) 8, 1991 (Report No /91013(DRSS); 50-249/91012(DRSS)
Areas Inspected:
Routine unannounced inspection of: (1) the chemistry program including procedures, organization and training (IP 84750); (2)
reactor systems water qual]ty control programs (IP 84750); (3) quality assurance/quality control program in the laboratory (IP 84750); (4)
nonradiolgical confirmatory measurements (IP 84750); and (5) the Radiological Environmental Monitoring Program (REMP) (IP 84750).
Results:
The licensee's water quality control program conforms to the EPRI BWR Owners Group Guidelines. Overall water quality was very goo The nonradiological confirmatory measurements were goo Labor~tory instrumentation and the QA/QC program were adequate. The chemistry technician testing program was well manage The REMP appeared to be satisfactor No violations or deviations were identifie *
9105.2903i::; PDR ADoc~ 9105.21 G
" 05000237 PDR
- DETAILS Persons Contacted 1R. Berg, Training Coordinator, ONGS 1G. Bergan, Nuclear Safety, ONGS 1F. 0. Bevington, Nuclear Quality Programs, ONGS 1E. 0. Eenigburg, Station Manager, ONGS 2L. Gerner, Technical Superintendent, ONGS J. Golden, Supervisor, Environmental Monitoring, CECo 1R. Holman, G-SEP Coordinator, DNGS 1K. Kociuba, Superintendent, Nuclear Quality Programs, DNGS 1o. Lowenstein, Regulatory Assurance Analyst, ONGS D. Malauskas, Quality Assurance Chemist, ONGS D. Morey, Supervisor, Chemistry Services, DNGS 1K. Neal, Unit Chemist, DNGS 1K. Peterman, Regulatory Assurance Supervisor, ONGS 1o. Saccomando, Supervisor, Health Physics Services, ONGS K. Whittum, Chemist, DNGS,
1M. Peck, Resident Inspector, NRC
~Present at the Exit Meeting on May 8, 1991 Regional visit, May 13, 199 Management Controls Organization and Training (IP 84750)
Management structure of the laboratory is similar to that previously described, Region III Inspection Report Nos. (50-237/90008; 50-249/90007).
The Lead Chemist, two chemistry laboratory supervisors (Foremen), the Waste Products Chemist and the Quality Assurance Chemist report to the Chemistry Services Superviso Fourteen Chemistry Technicians (CTs) report to the Laboratory Supervisors. Reporting to the lead chemist are Unit Chemists, HRSS Chemist, Radiochemist and two Laboratory Chemist Low turnover in the department results in stability. Supervisors and technicians were knowledgable and technically competen The staffing appeared adequate to perform the required chemistry for plant operation No violations of deviations were identified Water Chemistry Control Program (IP 84750)
The inspector reviewed the water chemistry control progra The operational chemistry limits and action levels were consistent with the EPRI BWR Owners Group Guideline The licensee is replacing the reactor coolant sample panels and in-line monitoring systems (silica, pH and conductivity).
In addition, an in line Ion Chromatograph (IC) has been acquired to monitor chloride, fluoride, sulfate, nitrate, sodium,
- *
potassium, calcium and magnesiu Real time monitoring capability will be provided by data loggers and a data acquisition recorder. The licensee's new make up demineralizer (MUD) system is operational. It is composed of two 150 GPM trains, each having separate anion, cation and mixed bed resin tank Chemistry parameters are reviewed daily by laboratory personnel and by plant management in the daily report~ Trend charts including reactor power levels are available for assessing reactor water parameters including conductivity, silica, dissolved oxygen, sulfate, and chlorid Trend charts for feedwater parameters have been discontinued, however the data is reviewed daily and is trended in tabular for Licensee representatives stated that feedwater quality was good and since little information was gained from these trend plots they were discontinued. A review of the tabular data for feedwater confirmed the feedwater qualit A review of selected data indicated that Units 2 and 3 reactor water has remained below Action Level 1 except for excursions during power changes or during startup/shutdown conditions. Conductivity for both units appeared to averaged less than 0.1 uMHO/cm, chloride was less than 3 ppb and sulfate was less than 4 pp The overall high quality of Reactor water was demonstrated by the Chemistry Performance Index chart for 1990 based on chloride, sulfate and conductivity. The facility has deep bed demineralizers which can process 100% of the condensate. This is a design strength and contributes to maintaining water quality.
No violations or deviations were identifie Confirmatory Measurements (IP 84750)
The inspectors 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 regulatory and administrative requirements. These samples had been prepared, standardized, and periodic~lly 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 A single dilution of each sample was prepared by licensee personnel as necessary to bring the concentrations within the ranges normally analyzed by the laboratory~ and run in a manner similar to that of routine sample The results are presented in Table 1 which also tontains the criteria for agreement. These criteria are based on BNL analyses of the standards and on the relative standard deviations (RSD) derived from the results of the plants participating in the 1986 interlaboratory comparisons. (Table 2.1, NUREG/CR-5422).
The acceptance criteria were that the licensee's value should be within 2 Standard Deviations of the BNL value for agreement and between 2 and 3 SD for qualified agreemen A qualified agreement may indicate a bias in the assay.
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The licensee determined seven analytes at two concentrations each, three analytes at one concentration and one analyte at three concentration Of the initial 20 analyses, 16 were agreements, 3 were qualified agreements and 1 (low level iron) was a disagreemen The iron had a negative bias of approximately 20%, however, it became an agreement when it was rerun. There was no apparent reason for this disagreement as another iron unknown of similar concentration exhibited a small negative bias of 5% and was an agreemen The analytical results were good, however some of the analyses required considerable effort on the part of laboratory personnel due to an apparent contamination problem experienced with the Ion Chromatograph (IC) or glassware used for dilution of interlaboratory comparison unknown The licensee was very successful in analyzing a sample of sodium and lithium on the I Peak separation was excellent even though the two elements elute closely and the lithium concentration was about four times that of sodiu This method (IC) may be superior to Atomic Absorption Spectrophotometry for quantitating these elements in nuclear plant No violations or deviations were identifie Implementation of the QA/QC Program in the Laboratory (IP 84750)
The inspector reviewed the chemistry QA/QC program as defined by
"Nuclear Stations Chemistry Quality Control Program Manual", Revision 8, July 16, 199 The licensee has control charts, independent controls and multiple point calibration curve One improvement noted was that the previously completed control chart was left in the instrument manual providing the technician with the instrument's performance history. The control charts are statistically based. Standard deviation (SD) and control limits are set at + 2 S Charts are reviewed by chemists dail Data from selected control-charts reviewed appeared to have a random scatte The licensee's corporate Interlaboratory Comparison Program results for 1990 and the first quarter of 1991 were approximately 92% agreement The inspector reviewed selected data from this progra Most of the analyses were within 8% of the corporate values which represents good performanc The licensee's Chemical Technician (CT) Testing Program is conducted by the Production Training Center (PTC). CTs spend about one week annually at the PTC analyzing unknowns prepared by supervisors. The program appeared to be well manage CTs are required to turn on the instrument, perform the necessary calibration, run a performance check (control),
analyze the unknown, run the second performance check and report the results. Control limits are based on plant chemistry laboratory control charts, and unknown acceptance criteria are based on an INPO standar A review of selected data indicated that CTs are being tested as required and the procedure is being followed. Analysis results were goo This program represents a laboratory strength.
The inspector examined and discussed operation of the HRSS system with licensee representatives. System oversight is assigned to a specific
chemistry staff membe Jhe inspector noted that an initialed surveillance checklist for January 22, 1991, indicated that the Unit two weekly operability surveillance (January 20-26, 1991) was performe However, the HRSS weekly operability surveillance form had not been initialed. A licensee representative stated that the surveillances had been performed but did not know why the form was not complete A licensee representative stated that in the near future, instrument readings demonstrating operability will also be recorded on the for The inspector noted to the Nuclear Quality Programs group (NQP) that QC of the HRSS system should be included in the chemistry surveillance progra Improvement in this area will be followed under Open Items (50-237/91013-01; 50-249/91012-01).
No violations or deviations were identifie.
Radiological Environmental Monitoring Program (REMP)(IP 84750)
The inspector reviewed the REMP including the 1990 Annual Environmental Report which appeared to comply with the REMP requirements. All of the required samples were collected and analyzed, except as noted in the report, and a survey of the results showed them to be reasonabl The inspector examined selected environmental air sampling stations around the plant and tested those systems for operability and leakag The pump and filter train on the air samplers on the seven observed sampling stations appeared to be operating satisfactorily, both with respect to vacuum and flowrat Each had a calibration and filter changeout record attached. The REMP is conducted by an outside vendor and managed by the licensee's corporate office. A review of the latest contractor audit by the licensee (Section 7) and discussions with licensee personnel indicated that licensee oversight of the REMP is adequat The REMP appeared to be conducted in an acceptable manne No violations or deviations were identifie.
Audits and Appraisals (IP 84750)
The inspector reviewed five corporate and site managed audits. Corporate Audit 12-90-I conducted June 18-22, 1990 reviewed the chemistry progra Auditors observed three CTs collect, process and analyze sample Sampling observations included CT adherance to radiological protection procedures during sample collection, sample line purging and proper labeling of sample container. The CT testing program, instrument calibration, chemicals, QC charts, preparation and labeling of standards were reviewe The ANSI qualifications of the three CTs being observed were reviewe The inspector noted to licensee representatives that the auditors should review the ANSI qualifications of all CT Nuclear Quality Programs (NQP) Audit Report Number 12-90-16 conducted May 4-25, 1990, of the Environmental Monitoring Program reviewed, in part, the REMP contractors radiological cross check program and Technical Specification sampling requirement *
NQP Audit Report Number 12-90-14, conducted November 30-December 17, 1990, focused on chemistr Required sampling, analysis results, use of independent controls, and RCT testing were reviewe The inspector reviewed a portion of an unfinished audit, NQP Audit Report Number 12-91-14 which reviewed environmental monitorin The auditor accompanied the REMP contractor on a weekly sampling round to verify that the REMP field activities were conducted according to licensee requirements and contractor sampling manua Air. particulate and surface water samples were collected. The auditor found this area to be acceptabl The licensee performed a corporate QA audit of the REMP contractor, Audit Report Number G-90-241, dated November 16, 1990. Auditors reviewed the contractor's QA program, procedures, records, Training and laboratory performance and the audit progra The licensee found the contractor laboratory to have an adequate program for sample analysis, *however, five findings were made which the contractor was required to address. A licensee representative stated that a follow-up audit of the contractor laboratory will be conducted to resolve the finding The licensee's audits were performance based and focused on QA programs and the performance of laboratory personnel. Findings from licensee internal audits were addressed in a timely manne No violations or deviations were identifie Open I terns 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 bot An open items disclosed during the inspection is discussed in Section * Exit Interview The scope and findings of the inspection were reviewed with. licensee representatives (Section 1) at the conclusion of the inspection on May 8, 199 The inspector discussed the confirmatory measurements results, laboratory QA/QC, plant water quality, audits and the REM 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 No violations of deviations were identified Attachments:
1. Table 1, Nonradiological Confirmatory Measurements Results, April 30-May 3, 1991
'
TABLE 1 Nonradiological Confirmatory Measurements Results Dresden Nuclear Station April 30-May 3, 1991 Analyte *
Method1 Concn2 Ratio3 Acceptance Ranges 4 Result5
+ 2RSD
+ 3RSD
~
Fluoride A IC
1.025 0.875-1.125 0.813-1.187 A
c
-
1.064 0.875-1.125 0.813-1.187 A
1.090 0.933-1.067 0. 900-1.100 A+
c
0.999 0.926-1.074 0.895-1.105 A
Sulfate A
.,
1.089 0.895-1.105 0.842-1.158 A
.J c*
1.005 0. 900-1.100 0.867-1.133 A
Iron G
AA/Fl lPPM 0.803 0.904-1.096 0.854-1.146 D
H 2PPM 0.945 0.903-1.097 0.857-1.143 A
Rerun G
lPPM 0.955 0.904-1.096 0.854-1.146 A
Copper G
AA/Fl lPPM 1.000 0.904-1.095 0.859-1.141 A
H lPPM 1.002 0.904-1.096 0.857-1.143 A
Nickel AA/Fl lPPM 0.956 0. 936-1. 064 0.906-1.094 A
G Chrome G
AA/Fl lPPM 1.100 0. 905-1.095 0.855-1.145 A+
H lPPM 1.054 0. 903-1. 097 0.854-1.146 A
I lPPM 1.112 0.903-1.097 0.858-1.147 A+
Sodium K
0.980 0.859-1.141 0. 788-1. 212 A
Lithium K
1.123 0.860.140 0.758-1.125 A
Silica s
Color
1.011 0.906-1.094 0.859-1.141 A
T
1.054 0. 090-1. 091 0.860-1.136 A
Ana lyte Method1 Concn2 Ratio3 Acceptance Ranges4 Result5 Boron E
F
~
3000 5000
+ 2RSD
+ 3RSD 0.988 0.979-1.021 0.968-1.032 A
0.990 0.979-1.021 0.968-1.032 A Methods: Titr - Titration IC
- Ion Chromatography Color - Colorimetric AA/Fl Flame Atomic Absorption Spectrophotometry Cone: Approximate concentration analyze.
Ratio of Licensee mean value to NRC mean valu.
The SD 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).
A result is considered to be in agreement if it falls within the+ 2 SD range; a qualified agreement if it lies outside + 2 SD, but within + 3 SD; and in disagreement if it is outside the : 3 SD rang.
Result:
A =Agreement: Licensee value is within +2 SDs of the NRC mean valu A+ = Qualified agreement, licensee is between + 2 and +3 SDs of the NRC valu D = Disagreement: licensee value is outside + 3 SDs *
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