IR 05000254/1993021
| ML20056D921 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/06/1993 |
| From: | Paul R, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20056D915 | List: |
| References | |
| 50-254-93-21, 50-265-93-21, NUDOCS 9308190014 | |
| Download: ML20056D921 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
REGION III~
Reports No. 50-254/93021(DRSS); 50-265/93021(DRSS)
Dockets No. 50-254; 50-265 Licenses No. DPR-29; DPR-30 i
Licensee: Commonwealth Edison Company
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1400 Opus Place Downers Grove, IL 60515 Facility Name: Quad Cities Nuclear Generating Station, Units 1 and 2 Inspection At: Quad Cities Site, Cordova, Illinois
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Inspection Conducted: July 19 through 27, 1993
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V i Inspectors: -/
u RiA. Paul
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- i adM M6/v 3. -
h. Shah
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Date Approved By: A/ d Ned I
/c V/4/9.)
'f J. W. McCormick-Barger, Acting Chief Date
Radiological Controls Section 1 t
f Inspection Summary Inspection on July 19-27. 1993 (Reports No. 50-254/93021(DRSS):
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50-265/93021(DRSS))
i Areas Inspected:
Routine, announced inspection oflthe radiation protection,
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gaseous radioactive waste, and solid radioactive waste and transportation
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programs, including organization and management controls (inspection
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procedures (IPs) 83750 and 86750), HEPA filters and charcoal adsorber systems
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(IP 84750), and audits and appraisals (IPs 83750 and-86750).
Also reviewed-
were licensee actions on previous ~ inspection findings.
k Results: The licensee's radiological controls program appeared well
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conducted; however, there were continuing problems associated with control. of w
contaminated material (section 6). The solid radwaste'and transportation
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program also appeared good (section 4). Housekeeping was good with only minor
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problems (section 6). One violation was identified for failure to conduct a i
surveillance of the standby gas treatment system iodide removal efficiency test in accordance with technical specifications (section 7).
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9308190014 930806 Mi i
PDR ADOCK 05000254 E
O PDR
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DETAILS 1.
Persons Contacted
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- R. Bax, Station Manager l
- D. Craddick, Maintenance Superintendent t
- D. Kanakares, Regulatory Assurance NRC Coordinator
- H. Hentschel, Operations Manager
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- A.
Lewis, Staff Assistant
- J. Leider, Technical Services Superintendent
- A. Misak, Regulatory Assurance Supervisor
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- S. Sober, Radiation Protection Manager
- J. Schrage, Corporate Licensing
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- G. Powell, Lead Health Physicist, Technical
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- A. Scott, System Engineer Supervisor
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- M. Zinnen, Lead Health Physicist, Operating
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R. Lubbe, System Engineer j
- D. Liao, Region III Inspector i
The inspectors also contacted other licensee and contractor employees.
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- Present at the exit meeting on July 27, 1993.
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2.
Licensee Action on Previous Inspection Findinos (IPs 837E0 and 84750)
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(0 pen) IFI (50-254/93006-01: 50-265/93006-01): Review of the area radiation monitor (ARM) calibration and surveillance program performed
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by health physics. The review revealed problems in the computer
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generated source decay curves which caused the trip-setpoints on the-two
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reactor building. vent TS monitors and the two refuel ARMS to be set in a
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non-conservative direction (16%). There were no safety significant-problems caused by this condition because the _ trip setpoints for the
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vent monitors were conservatively set a factor of 10 lower than the Offsite Dose Calculation Manual (ODCM) limits, and the refuel floor i
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monitors alarm setpoints were conservatively set at 20% lower than
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procedurally required. A licensee event report will be generated to
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describe the root cause and corrective actions. This item will be
reviewed in a future inspection.
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(0 pen) IFI (50-254/93006-02: 50-265/93006-02):
Licensee identified problems associated with High Radiation Area (HRA) controls.
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actions included installing swing gates across the entrance to HRAs to-barricade and conspicuously post these areas, and incorporating a video i
training tape on HRA controls into the station orientation program.
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These actions were effective at preventing recurrent problems since l
February 1993, and will continue to be reviewed at future inspections.
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s 3. ' Oroanization and Manaaement Controls (IPs 83750 and 86750)
The most significant changes in the overall administration of the radiological control program were the appointment of a new health physics services' supervisor (radiation protection manager (RPM)) and a i
new shipping health. physicist. The new RPM's qualifications met the
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technical specification requirements for the position, and the shipping
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health physicist appeared to have the technical background to fulfill
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that position. The remainder of the health physics' staff remained
stable and well experienced. There are currently 38 Radiation
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Protection Technicians (RPTs) and 6 foree:en.
No violations or deviations were identified.
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4.
Solid Radwaste and Transportation (IP 86750)
The inspectors reviewed the licensee's program for processing, storage, and shipping of solid radioactive waste (radwaste).
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Waste Generation and Processing
Primary waste streams included Dry Active Waste (DAW) from miscellaneous plant work, and wet waste consisting of filter media
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(powdered resin and fiber), bead resin, and waste oil.
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DAW is either baled or compacted onsite prior to shipment in l
55-gallon (208.3 liter) drums. As needed, DAW is also sent to offsite vendors for further processing (supercompaction, incineration, or decontamination)' prior to disposal.
Waste oil is processed onsite via a vendor decontamination
process, which chemically _ precipitates the radioactive contamination. The collected precipitate is shipped offsite for disposal, while the oil is reused in the plant.
The licensee was
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evaluating the onsite incineration of waste oil for future plant i
implementation.
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Spent resin was pumped directly into high integrity containers
(HICs), and dewatered onsite by a vendor.
Each HIC provides the means of drawing off water from the resin as it is being pumped in l
the container. Following dewatering, a blower / heater system
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cycles air through the resin for moisture removal.
Compliance l
with 10 CFR Part 61 waste form requirements was met via an-NRC approved topical report and by encasing the resin in an approved i
HIC (section 4b).
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The inspector
.lso reviewed the licensee's progress towards reducing res1 tse. A test using 20 ft' (0.6 m') of charcoal atop demineralizer iesin resulted in a 50% reduction in resin use and doubled run times, due to increased removal of total organic carbons (TOCs). Mer initiatives included future river'
i discharges of fis drain water (currently recycled in the plant)
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to reduce demineralizer TOC input, and replacing the current filter septa (which require a resin precoat) with. solid mechanical l
filters (no precoat needed) of the same removal efficiency.
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The inspectors toured the waste processing areas and observed the
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dewatering of reactor water cleanup (RWCU) resins; no problems
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were identified. The vendor operator demonstrated good system knowledge and maintained current procedures. The inspectors also
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noted that the licensee verified the vendor's performance in
accordance with station procedure QOP 2099-12, " Verification of
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Vendor's Process Control Program and Waste Processing Procedures."
b.
Waste Classification and Transportation Radwaste shipping responsibility is shared between the radiation protection (RP) and radwaste groups. The inspectors verified that individuals responsible for classifying waste shipments and
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certifying shipping papers received appropriate training.
The inspectors also reviewed the licensee's administrative and implementing procedures for the radwaste shipping program; no problems were identified. While the inspectors noted that copies of HIC certificates of compliance and burial and vendor site licenses were kept current, controlled copies of these documents were not kept in a central location. This was discussed with the licensee who agreed that the RP department would maintain controlled copies.
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Shipping papers were generated by the radiation protection
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department using the computer program WASTETRAK. An inspector reviewed selected shipping papers and observed the use of the WASTETRAK program; no problems were identified.
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An inspector reviewed the classification of spent resin and DAW.
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analyses of resin samples obtained during the dewatering process.
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These analyses are performed yearly by a contract vendor.
For DAW shipments, a dose-to-curie conversion was performed (via i
WASTETRAK) using conversion factors calculated from annual
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isotopic analyses of representative smears from the waste stream.
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The inspector calculated correlation factors for resin and DAW using current isotopic analyses, and noted good agreement with
historical results.
To date, there were 34 radwaste shipments comprising 15,848 ft'
(444 m') of radwaste. About 73% of the radwaste was shipped to
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offsite vendor processors, with the remainder going to burial. An inspector observed preparations for a shipment of RWCU resin to
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the Barnwell waste facility.
Both the shipping coordinator and RP technician displayed good knowledge of the transportation
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regulations and the inspector's radiological measurements agreed i
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with the licensee. The inspector also reviewed the shipping papers and verified that the waste was properly classified in accordance with 10 CFR part 61.
c.
Onsite Storage of Radwaste The inspectors reviewed the licensee's 10 CFR 50.59 review (safety review) for its Interim Radwaste Storage Facility (IRSF), which remained as described in Inspection Reports No. 50-254/92015(DRSS)
and 50-265/92015(DRSS); no problems were identified.
Another safety review is being conducted to allow storage of dewatered resin in polyethylene HICs and will be reviewed in a subsequent routine inspection.
No violations or deviations were identified.
5.
Audits ar Jaisals (IPs 83750 and 86750)
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The inspectors reviewed the licensee's auditing program, including
auditor qualifications and vendor audits.
The process control program (PCP) was formally audited biennially, and supplemented by periodic curveillances. Audit scope was based on
functional area performance, rather than a formal audit plan.
Of the
eight auditors, four were qualified as radwaste specialists based on
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their individual education and work experience. These qualifications
were primarily maintained via work performance and supplemented by
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review of industry events and as needed training. The inspectors I
reviewed recent audits of the radwaste program and auditor i
qualifications; no problems were identified.
Audits of vendor programs were performed triennially by the licensee's
corporate vendor auditing group and consisted of either direct j
observations by licensee staff or reviews of similar audits performed through the Nuclear Utilities Procurement Issues Committee (NUPIC).
NUPIC is an industry group that audits vendor programs using specialists
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drawn from member utilities. The inspectors reviewed selected vendor
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audits; no problems were identified.
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An inspector reviewed an off-site quality verification audit of the i
radiation protection (RP) program, including work practices and outage performance, radiation work permits, high radiation area controls, and j
procedure adequacy and implementation.
Except for minor findings'
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such as lack of attention to detail and proactive training concerning HRA controls, the audit found the RP program was effectively J
implemented.
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l An inspector observed a licensee auditor review a shipment of. spent
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resin. The auditor was knowledgeable of regulatory requirements and l
conducted activities in a professional manner.
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No violations or deviations were identified 6.
Control of Radioactive Materials and Contamination (IP 83750)
In a previous inspection (Inspection Reports No. 50-254/93014(DRSS) and 50-265/93014(DRSS)), an inspector discussed several instances of contaminated material found outside the Radiological Controlled Area-(RCA), but within the protected area. Recently, the licensee. identified additional examples, including a contaminated pump that was improperly -
transferred from a contaminated area indicating a continuing weakness in controlling contaminated material. Corrective actions included reducing the volume of material unconditionally released from the RCA, strengthening administrative limits, installing improved automated monitoring devices, reducing the number of exits from the RCA, changing the main release point to a lower radiation background area, and improving decontamination methods for equipment returned to non-contaminated areas. Additional actions discussed in the aforementioned inspection report will also be implemented in the near future. This matter was discussed at the exit meeting and will be reviewed in future inspections (IFI 50-254/93021-01(DRSS);
50-265/93021-01(DRSS)).
An inspector toured the reactor and turbine buildings and observed radiological controls and work practices. Radiological controls and:
housekeeping in these areas were adequate. Also inspected were the reactor building basements, including the torus, residual heat removal (RHR), high pressure coolant injection (HPCI), and core spray rooms for both units.
Contamination levels in these areas ranged from 1000 disintegrations per minute (dpm) to 20,000 dpm over 100 square centimeters. The one dressout in minimal protective clothes (booties and gloves) required to enter these areas did not inhibit operator rounds and surveillances.
Because an estimated 15 to 20 person-rem (0.15 to 0.2 person-Sv) would be expended to reclaim the area, station management has decided not to recover the area at this time.
No violations or deviations were identified.
7.
HEPA filter and Charcoal Adsorber System (IP 84750)
Diottylphthalate (D0P) tests for the high efficiency particulate air (HEPA) filters were reviewed by the inspectors.
The inspectors selectively reviewed surveillance test data and verified that the D0P tests met technical specification (TS) criteria for the control room heating, ventilation and air conditioning (HVAC), and standby gas treatment (SBGT) systems.
The inspectors also reviewed methyl iodide removal efficiency test
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results which are performed at 18-month intervals by a vendor. Although the control room HVAC absorbers met the test requirements, the SBGT adsorbers did not. On June 29, 1993, the licensee was informed by the vendor that the charcoal sample from the "A" train of the SBGT failed to meet TS requirements for methyl iodide efficiency. The licensee
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declared the "A" train inoperable and started the
"B" train to verify
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operability. Within two days, new charcoal trays which met the TS requirements were installed in the "A" train; the "B" train charcoal was also replaced as a conservative measure. A subsequent analysis of the old "B" train charcoal indicated it also failed to meet the required efficiency.
i Technical Specification 3.7.B.2.a.3 required laboratory carbon samples-
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from the SBGT system.to show greater than or equal to 90% methyl iodide removal efficiency when tested at 130'C and 95% relative humidity (RH).
The inspectors noted that the test criteria used during the June and July 1993 tests (30'C and 95% RH) differed from TS requirements, and were based on the results of an operability study performed after a recent licensee event report (LER) (Inspection Reports No.
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50-254/265-92025(DRP)). The criteria also reflected more conservative guidance contained in the revised American Society for Testing and
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Materials (ASTM 3803) standard. Although a subsequent calculation suggested the charcoal could have met the TS criteria, failure to
conduct the test in accordance with TS is a violation (Violation 50-254/93021-02(DRSS); 50-265/93021-02(DRSS)).
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The licensee submitted a TS revision to the NRC to allow the use of the more conservative 30'C and 95% RH criteria and is conducting an operability evaluation for the SBGT system.
This evaluation will include a dose projection based on the reduced charcoal efficiency and
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will be documented in an LER. The licensee's operability evaluation will be reviewed by the resident inspectors.
One violation was identified.
8.
Exit interview The scope and findings of the inspection were reviewed with the licensee i
representatives (Section 1) at the conclusion of the inspection on
July 27, 1993. The inspectors discussed closure of previous inspection
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findings, observations of the solid radwaste and transportation
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programs, and continuing problems associated with the control of i
contaminated material.
The violation concerning analyses of SBGT charcoal samples (section 7) was also discussed. No documents or processes discussed were identified as proprietary by the licensee.
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