IR 05000254/1989005

Insp Repts 50-254/89-05 & 50-265/89-05 on 890206-10.No Violations Noted.Major Areas Inspected:Chemistry Program, Including Procedures,Organization & Training & Radiological Environ Monitoring Program & Qc/Qa Program in Lab

ML20235U601
Person / Time
Site:	Quad Cities
Issue date:	02/27/1989
From:	Holtzman R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235U599	List: IR 05000254/1989005 ML20235U596
References
50-254-89-05, 50-254-89-5, 50-265-89-05, 50-265-89-5, NUDOCS 8903090277
Download: ML20235U601 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports N /89005(DRSS); 50-265/89005(DRSS)

Docket No ; 50-265 Licenses No. DPR-29; DPR-30 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Quad Cities Nuclear Power Station, Units 1 and 2 Inspection At: Quad Cities Site, Cordova, Illinois Inspection Conducte : F bruary 6-10, 1989 (0nsite)

Inspector: B oltz n 2/R7/N Ddte ' '

Approved By:

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. C. Schumacher, Chief hhf Radiological Controls and Date Chemistry Section Inspection Summary Inspection on February 6-10, 1989 (Reports No. 50-254/89005(DRSS);

BO-265/89005(DRSS))

Areas Inspected: Routine unannounced inspection of: (1) the chemistry program, including procedures, organization, and training (IP 84750);

(2) reactor systems water quality and chemical control programs (IP 84750);

(3) quality assurance / quality control program in the laboratory (IP 84750);

(4) nonradiolgical confirmatory measurements (IP 79701); and (5) the radiological environmental monitoring program (REMP) (IP 84750).

Results: The most significant changes in Chemistry management have been the separation of the Chemistry Department from Health Physics and the permanent assignment of a group of technicians to the laboratory. The licensee has almost completed the installation of hydrogen injection systems in both units to improve the RCS water quality and to reduce IGSC However, the plant does not plan to operate the Verification Monitor which is important to optimization of the hydrogen flow for minimum radiation dose, until several months after the hydrogen water chemistry (HWC) is in use. The water chemistry control program generally conforms to the the EPRI BWR Owners Guidelines. Extensive use was made of chemistry parameter trend charts. The nonradiological chemistry confirmatory measurement results were good. Some of the problems were resolved prior to the end of the inspection. The laboratory has a good QA/QC program for analytical measurements, which is being developed further. The staff appeared to be knowledgeable and competent. The REMP appears to be operating satisfactoril No violations or deviations were identifie G T PDR ADOCK 05000254 i: .

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L . DETAILS Persons Contacted

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• T. Tamlyn, Production Superintendent, Quad Cities Nuclear Power Station (QCNPS)

R. Robey, Services Superintendent, QCNPS'

• R.- Hopkins, Quality Assurance, QCNPS

• J. Sirovy, Health Physics Services Supervisor, QCNPS

• P. Behrens, Chemistry Services Supervisor, QCNPS  ;

• W. Hanno, Teciinical Staff, QCNPS l

• T. Barber, Regulatory Assurance, QCNPS  !

S. Willoughby,-QA Inspector, QCNPS R. Wiebenga, Chemist,-QCNPS R. Hebeler, Laboratory Foreman, QCNPS R. Knight, Chemist, QCNPS

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J. Bucciferro, Chemist, QCNPS ,

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A. Lewis, Lead Health Physicist, QCNPS G. Kreuder, Contractor, Teledyne K. Griffith, Engineering Assistant, QCNPS

• R, Higgins, Senior Resident Inspector,'NRC

The inspector also interviewed other licensee personnel in various  !

departments in the course of the inspectio l

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• Present at the plant exit interview on February 10, 198 ! Licensee Action on Previous Inspection Findings (Closed) Open Item (50-254/87032-01; 50-265/87032-01): Licensee spiked and analyzed a reactor coolant' sample with anions and a feedwater sample with metals and split the samples with Brookhaven National Laboratory. The licensee submitted the results of the analyses to Region III on fluoride, chloride, sulfate, iron, copper, nickel, and chromium ions. The results are shown in Table 1 with

' the acceptance criteria in Attachment 1. The licensee had five agreements in six analyses. The BNL iron values appeared.to be too low and were not compared. The fluoride results were in disagreement, but since the licensee's method of analysis for this ion has changed and the results of this inspection were generally good, this item is considered close (Closed) Open -Item (50-254/87032-02; 50-265/87032-02): The licensee to revise the procedure for the preparation of the sulfate standar The licensee revised the Procedure QCP 600-2, Reagent Preparation, Revision 5, November 19, 1987 to correct the error in the preparation of the. sulfate standard reagen _ _ _ _ _ - _

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I (Closed) Open Item (50-254/87032-03; 50-265/87032-03): The licensee to implement quality control charts in the laboratory under Procedure QCP 1400-11, " Quality Control for Chemical Measurements,"

Revision 4, May 3, 1988. Generally satisfactory quality control charts were implemented under this procedure (See Section 8). Management Controls, Organization and Training (IP 84750)

The Chemistry Group has been reorganized since the previous inspection in this area.1 The Rad / Chem Department was separated into the Chemistry and Health Physics Departments with Chemistry headed by the Chemistry Supervisor (formerly the Lead Chemist), and supported by six Chemists, Chemistry Engineering Assistants, and a Laboratory Foreman. The most significant revision has been the permanent assignment of 13 Chenistry Technicians (CT).to the laboratory. All of the cts are qualified as Rad / Chem Technicians under the standard ANSI N18.1-1971. As the corporate management was in the process of an extensive reorganization, that of Chemistry to take into account the CT changes, has been delaye The staffing appears to be adequate to perform the required chemistry for plant operations. This separation of technician duties appears to be a substantial improvement in laboratory capabilities; it should increase technician proficiencies, and reduce the training and retraining work loads of the staf No violations or deviations were identifie . Water Chemistry Control Program (IP 84750) General Aspects The inspector reviewed aspects of the Water chemistry control program in the plant. The licensee's water chemistry program, QAP 300-22,

" Water Chemistry Control," Revision 6, April 4, 1988, conforms to the EPRI BWR Owners Guidelines and is required by the corporate directive N0D-517, "BWR Water Chemistry Control Program."

Management is extensively involved in the maintenance of water qualit Chemistry submits among others, a daily report to plant operations and management, a weekly report on the inline instrumentation-laboratory correlation results, a monthly chemistry summary report to upper manriement, and excursion reports as required. Chemistry maintains trend charts on the various parameters, including silica and conductivity in the reactor cleanup system, and conductivity in the reactor coolant system, and the sodium pentaborate concentrations and volumes in the Standby Liquid Control tanks. Data are supplied to the corporate Technical Support Center that maintains the INP0 CPI (Chemistry Performance Index), which is a sum of ratios of a set of chemistry parameter values relative to those of the EPRI guidelines. The trend charts show Action Levels and T/S limits, as 1 Region III Inspection Reports No. 50-254/87032; 50-265/8703 ._-_ _-_-_-_____-______ _ A

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' appropriate for the parameter The plant maintained general'ly low -

, levels of contaminants in the water; the CPI results indicate that

.the RCS water quality is goo The inline monitoring consisted of conductivity instruments on reactor water, condensate and feedwater, and dissolved oxygen meters

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on feedwater.- The instruments are checked weekly against laboratory-measurements and Work Requests are submitted if they are not within

acceptance limits. New sampling panels are being built with state-of-the-art inline instrumentatio b.- Hydrogen Water Chemistry The inspector rovined aspects of the planned hydrogen water chemistry (HWC) program i.,wM ch the licensee is to add hydrogen to the feedwater to reduce dissolved oxygen levels and improve the quality of the reactor coolant to limit intergranular stress corrosion cracking (IGSCC)< The hydrogen flowrate is maintained at the minimum tha will prevent corrosion by adjusting the electrochemical' potential (ECP) in a recirculation pipe sampling point to below -250 mV measured against a standard hydrogen electrod However, one difficulty experienced with the HWC is that its use results in enhanced volatility of N-16 produced in the reactor water with increased radiation levels in the turbine. Based on results'

from measurements at Dresden and other places, one might expect these levels to be substantial, and consequently produce-increased radiation levels in the turbine building and plant environs. Since-the radiation levels from the turbine appear to be proportional to the H2 flowrates, these rates should be optimized to be as low as possible,lwhile maintaining the proper ECP. However, the licensee is planning to operate the HWC with hydrogen injection rates based on the Dresden experience, for several months prior to installation of the Verification Monitor, which is an autoclave with ECP, crack growth and CERT.(Constant Extension Rate Testing) monitor .A secondary monitoring system using a dissolved oxygen monitor, which is less sensitive than the ECP, vill be used initiall The licensee has received a memorandum from the corporate Radiation j Protection Department mandating radiological survey requirements during operation of the HWC, but they were not very specifi The ALARA: aspects will reviewed in an upcoming inspectio Progress of '

the the-program to install the Verification Monitor system will be z followed in subsequent inspections under Open Item No. (50-254/89005-01; 50-265/89005-01).

Licensee management is aware of the value of a good water quality 1

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L control program, and has improved both the laboratory facilities and its organization (Section 3). The HWC system is a substantial

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commitment to improved water quality and reactor reliability.

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r Other substantial improvements have been scheduled over the next

'few years. These changes will be followed in subsequent routine inspection .No violati'ons or deviations were identifie . Chemical Control Program (IP 84750)

The inspector reviewed the chemical control-program that applies controls to the use of chemicals in the plant, implemented by the Quad Cities Administrative Procedures:

QAP 1000-5, Station Chemical Control, Revision 5, November 6, 1988, with lists of controlled chemicals:

QAP 1000-T2, Revision 2, April 3, 1988 QAP 1000-T3, Revision 2, April 3, 1988 QAP_1000-T4, Revision 2, April 3, 1988 The program coordinator actively oversees the activities to limit the chemicals in the plant that may damage the equipment or enter the RCS, especially through radwaste drains. The allowed chemicals are listed, maintained by the_ stockroom and carefully regulated by the coordinato Awareness training of plant personnel is done mainly in NGET. Waivers are allowed on the use of restricted chemicals that are necessary after the coordinator reviews them and gives users training in the proper handling of these chemicals. This system appears to be very useful in improving the maintenance of plant system qualit No violations or deviations were identifie . Implementation of the Chemistry Program (IP 84750)

The' inspector reviewed the chemistry programs, including physical facilities and laboratory operation Housekeeping and bench space were adequate for the analyses performed. The laboratory has added and is developing procedures for use of a computer-operated Dionex 4000 lon Chromatographic system and two Milton Roy Spectronic 401 UV/ visible Spectrophotometers with long path (5-cm) sample cells for improved sensitivity of silica 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 ' NonradiologicalConfirmatoryMeasurements(IP79701]

The inspector submitted chemistry samples to the licensee for analyses as part of a program to evaluate the laboratory's capabilities to monitor i nonradiological chemistry parameters in various plant systems with respect to various Technical Specification and other regulatory and administrative requirement These samples had been prepared, standardized, and i i

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' laboratory in the Radiological. Sciences Division of Brookhaven National Laboratory (BNL). The samples were analyzed by the. licensee using

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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

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Attachment These criteria for agreement are based on comparisons of the mean values and estimates of the standard deviations (SD) of the measurements. 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 larger of.the BNL value or a 3% relative !

standard deviation (RSD) was substituted for that of the licensee in :

calculating the SD of the ratio Z (Szin Attachment 1). '

In a limited program, the licensee analyzed eight materials at three concentrations each. Of the 24 analyses, 21 were in agreement with the BNL values (88%). The disagreements included the low-level fluoride and 4 chloride samples, and the intermediate iro The negative biases for the iron and copper analyses indicate that the concentrations of the calibration standards were higher than stated. The causes of these discrepancies were not ascertained. The fluoride and chloride were run at very low levels and could suffer from contamination 1 (chloride) or plateout (fluoride). The licensee agreed to look into these problem The licensee has the basic elements of a good QA/QC program; it utilizes ,

multi point calibrations on the AAS, IC and spectrophotometer, independen I performance check standards, and control charts with statistically-derived !

control limits. Resolution of these problems, especially in the AAS analyses, will be followed under Open Item No. (50-254/89005-02; 50-265/89005-02). i No violations or deviations were identifie i Implementation of the QA/QC Program in the Chemistry Laboratory (IP 84750) 1 The inspector reviewed the nonradiological QA/QC program in the laborator The program is required by the corporate manual, Nuclear Operation Division .

Chemistry Quality Control Program Manual, Revision March 15, 1988. It i requires the use.of control charts with statistically-derived control limits at the two-sigma level, multipoint calibrations, where applicable, and a definite minimum frequency of instrumental calibration The laboratory has control charts for all of the analyses, including those for chloride, sulfate, fluoride, nitrate, nitrite, for the AAS analyses of iron, copper, nickel, and chromium, and for the UV/vis spectrophotometric 6  !

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analysis of silica. Performance checks are made and plotted before and after each batch of samples. Some instrumental parameters are also tracked, )

such as peak area and peak heights on the ICs which can be used to indicate instreent (column) degradatio Although the laboratory program has a good QA/QC program, the inspector )

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noted some possible areas of improvement. The parameters of the charts !

(mean and standard deviation) should be determined at regular intervals, )

such as monthly or quarterly. The charts should be annotated to state the !

causes of problems in the data, e.g., instrument repairs, or recalibratio j The ICs are recalibrates only if there appears to be a defect, based on control chart or other data; it appears to the inspector that the IC should be calibrated (or normalized) at one point at least daily (multipoint calibration is probably too time-consuming for daily use),

since some parts of the instrument may be sensitive to room temperature variation, especially the conductivity cell detector. Infrequent calibrations for an unstable instrument may result in control limits that do not truly reflect the instruments capabilitie The technician performance test program was reviewe The technicians were required to do blind samples prior to starting their tours in the laboratory. These samples included pH, silica, chloride, sulfate, total organic carbon, and the metals, iron, copper, nickel and chromium analyses, with acceptance criteria based on 2-sigma limits derived from the control charts. This program is being revised to conform to the cts being permanently assigned to the laboratory. Each CT will be tested quarterly on part of the set of unknowns, so that annually they will have done the full set twic The licensee has two interlaboratory programs, one with a vendor, NWT, !

and one with the corporate Technical Support Center. The results with the vendor were generally good. No acceptance criteria were used, but the licensee's values were usually near the mean value of the other plants in the group of 10. The results in the corporate program showed improvement in 1987, but they dropped off in 1988 and in the fourth l quarter had 70% acceptable results (within 10% of the known values).

They showed somewhat poorer results than the other stations, partly because of late submission of results during an outage (a time of l heavy workload), and partly due to specific problems. The latter were resolved in a timely manne The inspector noted to licensee representatives that the QA/QC program has progressed well and appears to be a good program as planned. Further progress of this program will bc followed in subsequent routine chemistry inspection No violations or deviations were identifie I 9. Radiological Environmental Monitoring Program (REMP) (IP 84750)

i The inspector reviewed the REMP, including the 1987 Annual Environmental Report,1988 monthly environmental reports, the air sampling stations, and maintenance record l

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l The Annual Environmental Report appeared to comply with the REMP requirements. All of the required samples were collected and analyzed, l except.as noted in the report, and a perusal of the results showed them l to be reasonable. The 1988 monthly reports appeared to be acceptable.

l The test and maintenance records of the air nampling stations in 1988 showed the systems to be maintained within specifications and the records appeared to be complet The inspector toured the air sampling stations around the plant and observed the contractor-collector check the systems for calibration (flowrate and vacuum), operability, and leakage of the sampling trai The collector demonstrated satisfactory tests of both the pump and filter trai He found about half of the six filter trains leaked, which he attributed to hardening of a rubber gasket in the clam-shell iodine cartridge holder due to the low ambient temperature; he noted that this normally did not occur. The accompanying licensee representative will check with the corporate REMP supervisor for an estimate of the fraction of the air bypassed through the leak and for modifying the system to correct the difficulty. The resolution of this problem will be followed in subsequent inspections under Open Item No. (50-254/89005-03; 50-265/89005-03).

The REMP appeared to be operating satisfactoril No violations or deviations were identifie '

10. Audits (IP 84750)

The inspector reviewed recent audits of the REMP and Chemistry program The corporate QA Department has done extensive audits and surveillance of the REMP contractor in the past year in which they had five findings, several observations and one open item. These problems were partially due to the laboratory moving and were resolved in a timely manner. Two audits of the chemistry program had one finding, the lack of a plant training program on chemistry control. This is of recent origin and will take sometime for the Training Department to develop the progra One Observation was resolved in a timely manner. The audits appeared to have been thorough and to address possible problems in these program 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 inspector, 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 4, 7, ar.d _ ___-_

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12. , Exit Interview The scope and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on February 10, 1989. The inspector discussed the Open Items in Section 2 and observations on the quality control program and the confirmatory measurements. He noted the progress in the QA/QC program since the previous inspection. The problem of air inleakage in the air sampler filter trains was noted. The inspector discussed HWC and the ALARA program and the delay in installation of the Verification Monitor to optimize the hydrogen flow and radiation level. The ALARA will be reviewed in an upcoming inspectio During the exit interview, the inspector discussed the likely informational content of the inspection report with regard to documents or prccesses reviewed by the inspector during the inspection. Licensee representatives did not identify any such dccoments or processes as proprietar Attachments: Table 1, Nonradiological Interlaboratory Split Sample Results, March 1988 Attachment 1, Criteria for Comparing Analytical Measurements (Nonradiological) Table 2, Nonradiological Interlaboratory Test Results, February 7-10, 1989 i

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TABLE 1

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7.- ..Interlaboratory' Split Sample'Results f.; ' Quad Cities Nuclear Power Station November 1987 Analyte b

.. Analytigal NRC Licensee Ratio- Comparison

". LMethod .Y 1 SD X i SD- Z * 55 - i2.SD Concentration, ppb Reactor Coolant Water H Fluoride SIE 51.3 i .7 i .754 1 0.009 D

! -Chloride IC '47.7 1 .7 1 .063 t 0.070 A Sulfate IC 48.8 1 .4 1 0,3 1.074 1 0.073 A Feedwater

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N 1 Coppe AAS 520 1 20 470 .i (20)c 0.904 1 0.052 A

' Nickel AAS- 500, i 10 520 1 (10)c 1.040 i 0.029 .A Chromium AAS .503 1 -7 510 1 0 1.014 i 0.014 A

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'SIE Specific ~ ion' electrode IC .Icn chromatography ,

-AAS Atomic absorption spectrophotometry / Flame ' Comparison:

A Agree D Disagree N No Cocaparison (defective split) Uses BNL value for SD.

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• -ATTACHMENT-1  ;

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 the 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 pfopagationoftheuncertaintiesof-licensee'smeanvalue, 3

S , and of the NRC's mean value, S Thus, x

c2 z _ s-2-x 32 v p- p- + p , so that 32D S

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=Z*' [S*2 +1 1

{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, l 1-Z l 1 2*Sz*

~ National Council on Radiation Protection and Measurements, A Handbook of Radioactivity Measurements Procedures, NCRP-Rep ~ ort No. 58, Second Edition, 1985, Pages 322-326 (see Page-324).

4/6/87

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TABLE 2 Nonradiological Interlaboratory Test Results Qui lities Nuclear Generating Station February 6-10, 1989 a a c Analyte Analytigal NRC Licensee Ratio Comparison Method Y i SD X SD Z i SD 12 SD Concentration, ppb Chloride IC 4.63 1 0.03 5.30 1 0.10 1.146 1 0.022 D 9.33 1 0.15 9.'20 1 0.20 0.987 1 0.027 A 19.1 1 .8 1 .035 0.023 A*

Fluoride IC 5.63 1 0.50 4.30 1 0.50 0.764 1 0.112 0 10.58 i 0.20 10.6 1 .002 1 0.069 A 20.7 i .6 .899 1 0.075 A Sulfate IC 4.88 1 0.35 5.20 1 0.10 1.067 i 0.079 A 9.58 1 0.68 9.70 0.30 1.013 1 0.078 A 19.5 1 .6 i .005 1 0.030 A Fe AA/FL 372 i 10 375 i0 1.008 1 0.027 A 796 i 10 740 i0 0.930 1 0.030 D**

1170 1 30 1110 10 0.949 1 0.034 A*

Cu AA/FL 1000 1 15 940 10 0.940 i 0.031 A 2015 75 1870 10 0.928 1 0.049 A*

3000 1 75 2810 10 0.937 1 0.033 A*

Ni AA/FL 406 1 12 430 10 1.059 1 0.043 A 834 i 14 860 10 1.031 1 0.024 A  !

1210 i 50 1210 i0 1.000 1 0.058 A Cr AA/FL 1980 1 50 1933 1 12 0.976 1 0.025 A 3850 1 50 3780 0 0.982 0.013 A 5800 100 5453 12 0.940 1 0.032 A**

Silica Spec 26.4 1 .3 1 .996 1 0.056 A 5 .0 51.1 1 .983 0.039 A 7 .0 76.6 1 .976 1 0.015 A Value i standard deviation (SD); BNL did 6-9 analyses per lo The licensee analyzed 3 replicates for each sample, except only one for the metals Fe, Cu and N Analytical methods: IC - Ion chromatography Spec - Spectrophotometric AA/FL- Atomic absorption Spectroscopy (flame) A = Agreement D = Disagreement

• Substituted the BNL uncertainty for licensee's uncertaint ** Substituted an RSD of 3% for licensee's uncertaint ______ _______ -