IR 05000237/1992006
| ML17177A355 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/03/1992 |
| From: | Januska A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A354 | List: |
| References | |
| 50-237-92-06, 50-237-92-6, 50-249-92-06, 50-249-92-6, NUDOCS 9204100273 | |
| Download: ML17177A355 (10) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGIOtl III Reports Nos. 50-237/92006(DRSS); 50~249/92006(DRSS)
Docket Nos. 50-237; 50~249 litense N6s. DPR-19; DPR~25 Licensee:
Commonwealth Edison Company 1400 Opus Place Downers Grove~ IL 60515 Facility Name:
Dresden. Nuclear Generating Stat_ion, Units 2 an*d 3 Inspection At: Dresden Site, Morris, Illinois Inspection Conducted:
March lG - 19' 1992
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- Inspector:,~a-/?.
1 *. G. Januska /
Approved
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/;~if'~441 By:* M. c.-Schumachtr, Chief Radiological Ccntrdls and Chemistry Section *
Inspect1rin Summary.
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Ins~ettion on March 16 - 19, 1992 Report Nos. 50-237/92006(DRSS);
50-.49/92oo6(DRSS))
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Areas Insp~cted: Routine u~announced inspection of: {1) the chemistry program including procedures, organization and tratni~g (IP 84750); (2)
reactor systems water quality control programs (IP 84750); (3) quality assurance/quality control program in the laboratory (IP 84750); * (4)
nonradiological confirmatory measurements (IP 84750); (5) *thE Radiological Environmental Monitoring Program (REMP) (IP 84750); and (6) the close out of-open items from previous inspection Results: The licensee continued to maintain excellent reactor water quality and ranked high amorig the better performing plants *. The nonradiological confirmatory measurements continue to be goo The cor.tinuing chemistry tethnician training program appears to be comprehensiv~ and well manage...,73 920403 92041
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- DETAILS 1~
Persons Contacted *
1R. Berg, Chemistry Instructor P. Boyle, Unit 2 Chemist 1R. Budzynski, Chemistry Technician
. L Carroll, Regulatory Assurance 1o. Ferguson, Chemistry Technician 1L. Getner, Technical Superihtendent 1 K. Kociuba, Nuc.lear Quality Programs Superintendent 1o. Malauskas; Quali.ty Chemist
. 1o. Morey, Chemistry Supervisor L. Oshier, Lead Health Physicist-Operations 1R. Polk, Lab Supervisor
- 1c. Schroeder, Station Manager K. Shembarger, Reactor Engineer iJ. Strmec, Lab Chemist K. Whittum, Lead Chemist 1K. Shembarger, Regional Inspector, NRC
!Present at the Exit Meeting ~n March 19, 199 ;
Licensee Action on Previous Inspection Findings *(Closed) Open Item (50-237/91020~01; 50-249/91020-01):
Licensee to count a liquid sampie and report the results t~R~gion III for compariso The results ar~ contained in Table 1; the comparison.criteria are contained in Attachment Th~ comparison~ resulted* in two agreements, two no comparisons because of poor counting st~tistics and one disagreement for Fe-5 Because of the poor counting statistics and the Fe-55 disagreement, a spiked liquid sample will be sent to the licensee for analysis and comparison and will be followed under Open Item 50-237/92006-01; 50-249/92006-0 (Closed) Open I tern (50-237 /91013-01; 50-249/91012-01):
Quality Contro 1 (QC) of the High Radiation Sample System (HRSS) should be included in the Chemistry Survei.llance Progra Th.e inspector saw evidence in the Nuclear Quality Programs Field Monitoring Reports that QC of the HRSS has been performed on 10 occasions during 1991 and 1992.
. Manageme.nt Controls Organization and Training (IP 84750)
Management structure of the laboratory has changed since last reported in Region III Ihspection Report Nos. 50-237/91013; 50-249/9101 A Lead Chemist, Quality Chemist, Waste Products Chemist, Chemical Control Coordinator, Procedure~ Writer and Operations Manager, two of which are contracted positions and three degreed, report to the Chemistry Superviso Fourteen Chemistry Technicians (CTs)~ an increase of two technicians, report to two Laboratory Supervisors who in turn report to
the Operations Manage Reporting to the Lead Chemist ire a Lab Manag~ a Data Sp~cialist, Two Lab Chemists, Chemists for Unit 2 and Unit 3,
and a Rad~ast~ Chemist~ Five of these positions a~e filled by degreed employees; one is a contracto The contractor position will be filled by a Chemical Engineer who has accepted the positfo Previous ch~mist position responsibilities have been absorbed ~nt~*the positions.cur~ently under the Lead Chemis Turnover in the chemistry.department has been in low,.and *the staffing appeared adequate to perform the required chemistry for plant operations *. The personnel contacted appeared knowledgeable and technically competen No violations or deviations ~ere identified Water Chemistry Control Program* (IP 84750)
The inspector reviewed the water chemistry co.ntrol progra The operational chemistry limits and action levels were consistent with the EPRI BWR O~ners G~oup Guideline Sample panels have been installed *
.but have not been accepted for operation.. Reactor coola'nt samples are collected using the HRS In line Ion Chromatographs (IC) have been installed in each unit with th.e unit 2 system currently under tes *chemistry parameters are reviewed by laboratory personnel and trend plotted. Trend charts are available for tracking various. reactor and cleanup water parameters including conductivity~ silica, d.is~olved*
oxygen, sulfate, and. chloride along with reactor power lev'el The inspector reviewed selected trend charts.and supporting data which indicated that except for excursions during powe*r changes o*r during startup/shutdown conditions, conductivity, chloride and sulfate averaged.
less than 0.01 microSiemen/cm(uS/cm), 1.0 and 2.0 parts per billion (ppb)~
respectiv.ely, for both units, well be.low EPRI achievable values of less that 0.20 uS/cm, 15 and 15 ppb respectivel Feedwater conductivity and dissolved 'oxygen were gerierally within the achievable values of less that 0.06 uS/cm and within 20~5o*ppb~ Both units.ranked among the better performing plants in the country on an industry chemistry performance indei in 199 *
No violations or deviations were identifie.
Confirmatory Measurements (IP 84750)
The inspector submitted chemistry samples to the licensee for analyses a part of a program to.evaluate the laboratory's capabilities to monitor
- nonradiological chemistry parameters in variot.Js plant systems with
- respect to regulatory and administrative requirements..
These samples had been prepared, standardiZed, and verified for the NRCby the Analytical Chemistry Division of Oak Ridge National Laboratory (ORNL). The samples were analy'zed by the licensee using.routine methods and equipmen The samples were.. appropriately dHuted. by licensee.personnel and analyzed at_high concentrations and also within the ranges normally analyzed by *
the laborator In.both cases the equipment was appro_priately calibrated prior to performing the analyse A single analysis was performed on
each dilution in a manner similar to that of routine samples. The resuits are presented in T~ble 2 which.also contains the criteria for compari56 These criteria are based on ORNL analyses of the standards and on the relative standard deviations (RSD) ~erived from the results of the plants participating in the 1986 interlaboratory comparisons. (Table 2.1,
. NUREG/CR-5422).. The acceptance criteria were that the liceris~e's value*
should be within 2 Standa,rd Deviations of the BNL value for agreement and
. between 2 and 3 Sn for qualified agreemen A q~alified ag~eement may*
indicate a bias in the assa *
Jhe licensee analyzed multiple concentrations of Il analytes*.(Table 2).
Of the initial 38 an,alyses, 32 were agreements, 5 were qualified agreements and one was a disagreement. There ~ere three disagreements*
for nickel (not. shown on Table 2). The chloride disagreement had a bias *
- of 16% and ~fter recalibration the IC the result* became a qualifie agreement~* The metal unknowns are a matrix of iron, copper, nickel and i::hro~e~ Since the licensee calibrated each metal with a ~ui~ standard, an interference caused by a matrix effect of the ~etals was suspected as the cause of the disagreement The licensee recalibrated using solutions conta-ining all four metals and reanalysis of the three nickel concentrations resulted in agreement The ir0\\1 results however did not change appreciably-remaining qualified agreement Chemistry personnel involved in the dilution, calibration and analyses used good laboratory technique *
No violatibns or deviations were identified~ 'Implementation of the QA/QC Program in the Laboratory (IP84750)
The inspector reviewed*.the chemistry QA/QC program as defined by
"Nuclear Stations Chemistry Quality, Control Program Manual", Revisio, dated.December 31,.1991.. Since the last inspec~io~ of cold
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chemistry the Manual has been revised twice to.address control charts, c6rrective~act~ons and documentation,. standards, noric~emical calibrations, and trend chart The licensee has control charts,
- independent controls and multiple point calibration curves.*. Charts are reviewed by che~ists daily.* Data from selected control charts reviewed appeared to have a random scatte.
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The licensee's corporate Interlaboratory Comparison Program results for the third quarter of 1991 and the first quarter of 1992 ~ere 97% and 90%
agreements respectivel The 1992 ~ata included a new analysis, 6il, for the first time which accounted.for* three of the four disagreements *. The inspector ~oted no analyses differed b~ more than 9% from the corporate values _which is comparable* with results examined during the last inspection and represents good performanc The li~ensee's Chemical Technician (CT) Testing Program is conducted at the Production Training Center (PTC) as reported 1n Inspection Report Nos. 50-237/91013; 50~249/91012. Iil addition to this one week course*
three weeks of continuing. training is pr_ovioed to the CTs at the Dresden
- rraining Cente During the thre~ ~eeks modules, which include t6pics *
such as industrial events, OSHA, new instrumentation, trouble shooting of laboratory instruments, Radiation Protection, HRSS and GSEP are*
- presehte The inspector saw selected-personnel training files
- demonstrating that tests were given and passing grades achieve The program continues.to be a laboratory strengt *
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The inspector examined the operation of the Unit 3 HRSS system intluding a tour of the facility.. The operability of each unit's* sistem is the
- responsibility of one of the Unit Chemist The systems are current l used for the routine collection of primary coolant.samples until the sample panels are operational and accepte The inspecto~ reviewed th~
HRSS surveillance schedule and operability sign off *sheets and noted that
- although surveillances had been performed, on numerous occasions in late
. _ 1991 through March 1992 the sign off sheets had not been reviewed by eHher a chemist or a chemistry foreman (Lab Supervisor). This appeared tobe a repeat of the same problem noted in Inspection 50-237/91013;
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50-249/9101 Further discussion with the licensee revealed.that during a current procedure upgrade the procedure governing this surveillarice was rewritten but the old procedure was not deleted. All of th~ req~ired s~rveillances appeared !o have been performed a~d reviewed as require No violations or deviations were identifie.
Radiological Environmental Monitoring Program (REMP)(IP 84750)
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The inspector rev.ieWed th~ REMP includirig the 1991 Annu~l Environmental Report.and the December monthly report from the vendor which is a summary -
of ihe years monthly reports. * In addition the inspector compared the program which was implemented against the Technical Specifications requiremen The program for 1991 appeared to ctimply with the REMP requirements. Missed samples were appropriately identified and liste The inspector noted that low level positive tritium activity was seen in a nearby waterwell.in mid-1992 sample The licensee is investigating the.matter and has i.ncreased the frequency of samplin An in.let canal sample which also showed anomalous results is ~lso under inveitigatio The results of theie investigations will be reviewed during subsequent inspections (Open Ite~ 50-237/92006-02; 50-249/92006~02)
No violations or deviations were identifie.
Audits and Appraisals (IP 84750)
The inspector reviewed audits, as~essments and Field Monitoring Reports (FMRs).
Nuclear Quality Programs (NQP) Audit 12-91-12 conducted on
.. December 6-20, 1991 reviewed implementation of the Quality Assurance program for chemistr The audit.involved observation of personnel,**
the HRSS system, and calibration of inline instrument The audit determined that the HRSS was operable and that samples could be.draw Dresden Combined Assessment performed January 17-25, 199.1, indicated performance assessment of chemistr The assessment noted strengths in chemistry, equipment performance, HRSS operation, and quality controls
~pplied t6 the ion chromatograph~ *
No violations or deviations were identified..
5 Open I terns Open it~ms are matters which have been discussed wittt the licensee~ which will be reviewed further by the inspectors, and which involve some actiori onthe part of the NRC or licensee, or-bot An open items discfosed during the inspection is discussed in Sections 2 and ~ Exit Interview The scope and findings of the inspection were.reviewed with lic~nsee represeritatives (Section 1) at the conclusion of the ins~ectibrr on March, 19, 199 The inspector discusse9 the confirmatorymeasurements results, audits and the REM During the exit interview, the inspector discussed the lik~ly informational content of the inspection report wiih regard to documents or.processes reviewed by the*inspector.duririg the inspection. Licensee representatives did not identify any such document or processes as proprietar *
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Attachments:
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1.. Table 1 ~ Confirmatory Measurements Program Results, Second Quarter 1991 Attachment 1, Criteria for Comparing Analytical* Measurements Table 2, Nonradiological Confirmatory Measurements *
,Results, March 16-19, 1991
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TABLE 1 U.S. NUCLEAR REGULATORY COMMISSION
REGION III
FACILITY;. DRESbEN FOR THE 2ND QUARTER 19~1
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i~~~c~---~G~Ci5~~-~~~~0~c:-~~~~~~~~--ci~:~~c:--ciE:~~~:--~~~i5--~~~6C:-~~~GCi.
LIQUID G BETA H-3*
= AGREEMENT
= DISAGREEMENT N = NO COMPARISON 1.20E-06 7.09E-04 3.00E-09
&.OOE-09 *
1.91E~06
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CRITERIA RELAXED 6.00E-08 8~00E-06 8.00E-09 3.00E-09 5.00E-08 (1.20E-06 O.OOE+OO 1.00 2 A 6.20E-04 O.OOE+OO 0.87 8 A 2.00E-09.O.OOE+OO 0.67 N 5.26E-09 O.OOE+OO 0.88 N 1.09E-06 O.OOE+OO 0.57 3.D
TABLE 2 Nonradiological Confirmatory Measurements Results Dresden Nuclear Station
- March 16 - 19, 1992
. Ana lyte
2-.
R t. 3
. 1 5 Method Concn * *
a lo.
- Acceptance Ranges.
Resu t
+ 2RSD
+ 3RSD EE£ Fluoride A
0.874 0.875-1.125 0.813-1.187
~A+
B
.0.935 0.875-1.125 0.813-1.187 A
c
0.931 0.875-1.125 0.813-1.187 A
Chloride A
0~991 0.933-1.06. 900-1.100 A
B
1.017 0.919-1.081 0.887-1.113. A c
1.039 0.926-1.074 0.895-1.105 A
Sulfate A
1.041 0.895-1.105 0.842-1.158 B
0.. 992 0.895-1.105 0.868-1.132 A
c
0.969 0.900-1.100 0.867-1. 133 A
Fluoride A
IC*
20*
1.040 0.875-1.125 0~813-1.187 A
B
. 0. 969 0.875-1.12 ~813-1.187 A
c
0.976 0.875-1.125 0.813-1.187 A
Chloride A
1.157 0.933-1. 067 0.900.:1.100 D
B'
. 35 1.014 0. 919 -1. 081
. 0. 88 7-1. 113 A
c
1.017 0.926-1.074 0.895..,1.105 A
Rerun A
1 :078 0. 933-1. 067 0. 900-1.100 A*
Sulfate A
1.052
. 0.895-1.105 0.842-L158 A
B.
0.989 0 ~ 8 9 5 -1. IO 5. 0.868-1.132 c
0.933
. 0.. 900-1.100 0.867-1.133 A
Iron G
AA/F 1
0.888 0. 904-1. 096 0.854-1.146 A+
H
0.867 0.903-1.097
. 0.857-1.143 A+
I
. 1 0.865 0. 903-1.097 0.855-1.145 A+
Rerun G
0.885 0.904-1.096 0.854-1.146 A+
H
. 1 0.-872 0.903-1.097 0.857-1.143 A+
I
. 0.859 0. 903~1. 097 0.855-1.145 A+
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Copper G
AA/Fl
1. 056. 0.904-1.095
- o.859-1.141 A
H -
1.041 0.904-1.096 0.857-1.143 A
I
1.008 0. 904.:.1. 096 0.857-1.143 A
2
Acceptance Ranges 4
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Ana l_yte Method Concn Ratio Resu 1t.
+ -2RSD
+ 3RSD
Nickel Rerun H
I Chrome
.G H
I
. Sodium*
J K
L Lithium JJ KK *
LL Silica s
l Boron *
D E
F L
Methods:
0.946 0.936..:1.064
0. 951. 0.938-1.062 l
o. 955 0. 938-1. 062 AA/Fl
1.142 0.905-1.095
0.905
.0.903-1.097
0.9.75 IC
1.000
0.989
0.993 IC
0.875
0.916
. 0. 958 Color
1.032 100.
1.053
££!!!
Titr 1025 1.004 3025 1.000 5025 l.010 Titr - Titration IC.*
- Jrin Chromatography Color -
Colorimetri~ *
0.903-1.097 0.863-1.137 0.859"".1.141 0.862-1.138 0.859~1.141 0.860-1.140 0.861-1.139 0. 906-1. 094 0.909-1.091 0.979-1.021 0. 979-1. 021 0.979-1.021 AA/Fl
. Flame Atomic Absorption *
.Spectrophotometry Cone: Approximate concentratio~ analyzed. * Ratio of Licensee mean value to NRC mean valu.906-1.094 A
0. 908-1. 092 A
0.907-1.093 A
0.855-1.145
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A+
.0.854-1.14 A 0.853-1.147
.A 0. 784-L216 A
0. 7 88-1. 212 *A 0. 7 8.9-1. 211 A
0.793-1.207 A
' 0. 785-1. 215
- A 0.790..:1.210 A
0. 859..:1.14 A
. 0.860-1.136 A
0.968-1.032 0.968-1.032 0. 968-'1. 032 The SD in the fifth and sixth columns represents the coefficient of A A
. 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 ~greeinent if it lies outside + 2 SD, but wit~in + 3 SD; and in disagreement if it is outside*
the ! 3 ~D range.*
- Result:
A = Agreement: licensee value is within +2 SDs of the NRC mean A+ =
valu Qualified _agreement: licensee value is outside+ 2. and within.+3 SDs of the NRC valu D = Disagreement~ licensee value is outside+ 3 SD..
ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS
.. This attachment provides criteria for comparing results of capability tests and verific~tibn measurement The criteria are based on an empirical relationship which combi~es prior experience and the accuracy needs of this progra In the~e criteria, the judgment limits ate. variable in relation to the-
- . compa.rison of the NRC' s value to its associated one sigma uncertaint As that ratio, referred to in this program as "Resolution", increases, the acc_eptability of a licensee's. measurement should be more selective, Conversely, poorer agreement should be con~idered acceptabl~ as th resolution decrease The values in the ratio criteria may*be rounded
- to fewer significant figures reported by the NRC Reference Laboratory, un 1 ess such rounding wi 11 result in a narrowed category of acceptanc RESOLUTION
<4 4 -
8 -
16 -
51 -. 200 200 -
RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement NO COMPARISON 0.5 -*.6
- 1.66 0. 75 - 1. 33 0. 80 - 1. 25 0.85 - 1.18 Some discrepancie~ m~y res~lt from the ~se of different equipment, \\echniques, and for some specific nuclide These may be factored into.the acceptante criteria and i.dent ifi ed on the data sheet.