IR 05000254/1999002
| ML20207D511 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/25/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207D504 | List: |
| References | |
| 50-254-99-02, 50-254-99-2, 50-265-99-02, 50-265-99-2, NUDOCS 9903090368 | |
| Download: ML20207D511 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lli
Docket Nos:
50-254;50-265
License Nos:
Report Nos:
50-254/99002(DRS); 50-265/99002(DRS)
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Licensee:
Commonwealth Edison Company
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Facility:
Quad Cities Nuclear Power Station Units 1 and 2
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Location:
22710 206th Avenue North l
Cordova,IL 61242
Dates:
January 25-29,1999 Inspector:
-K. Lambert, Radiation Specialist l
Approved by:
Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety
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9903090368 990225 PDR ADOCK 05000254
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EXECUTIVE SUMMARY
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Quad Cities Nuclear Power Station, Units 1 & 2 NRC Inspection Reports 50-254/99002; 50-265/99002
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This routine inspection of the radiation protection and chemistry program included the water
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chemistry control, instrument quality control and inter-laboratory comparison, the radiological
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environmental monitoring programs, and material condition of the process radioactive waste system.
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The staff's control of plant water chemistry continued to be good and was effective in
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i reducing corrosive impurities in reactor water. In addition, the licensee was planning to implement noble metal injection to enhance corrosion control and lower station dose
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rates (Section R1.1).
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The radiological environmental monitoring program was well implemented.
- Environmental sample results did not indicate any discernable environmental effects
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from plant operations (Section R1.2).
Surveillance and calibrations of the meteorological tower were properly performed. The
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meteorological equipment was maintained in good condition (Section R2.1).
Material condition of radioactive waste systems had improved. The implementation of
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the radioactive waste risk assessment procedure improved plant management's
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I awareness of radioactive waste system problems and the potentialimpact on plant
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operations (Section R2.1).
Chemistry technicians were knowledgeable regarding sampling and analysis procedures
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and demonstrated good sampling techniques. The chemistry technician training program was wellimplemented (Section R4.1 and Section RS.1).
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The instrument quality control program was well implemented, with evaluations and
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corrective actions performed when warranted. The station performance was good regarding the inter-laboratory cross check programs and effective evaluations were
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l performed for analysis discrepancies (Section R7.1).
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The audits and self-assessments were of sufficient depth to identify deficiencies and
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j areas where improvements could be made, and that corrective actions were appropriate (Section R7.2).
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Report Detti!g
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IV. Plant Support l
R1 Radiological Protection and Chemistry (RP&C) Controls
f Ri.1 Water Chemistry Control Procram i
a.
Inspection Scope (IP 84750)
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The inspector reviewed the licensee's water chemistry control program. This included discussions with cognizant individuals regarding chemical additions for corrosion
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Observations and Findinas
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The scope of the water chemistry control program was consistent with the Electric
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Power Research Institute (EPRI) boiling water reactor guide.!nes. The inspector
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reviewed selected trend records for January through December of 1998 which indicated i
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that plant water quality was very good, and minimized corrosive impurities in reactor water. The water chemistry parameters for reactor water were generally maintained '
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i well below EPRI Action Level 1 parameters. Twice in 1998, EPRI Action Level 1 parameters were exceeded and the station implemented appropriate actions to bring
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j the parameters to within acceptable levels, including documenting the excursions and causes. The inspector also reviewed reactor water isotopic analysis trend charts for
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January through December of 1998, which indicated there were no problems with fuel integrity.
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Zinc addition wa implemented on Unit 1 following the recent refueling outage in
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December 1998, and was implemented on Unit 2 following the 1997 refueling outage.
I Zine was being added to reduce personnel exposure by limiting the transport of cobalt-
60 from the fuel rod deposits to other reactor coolant components. Reliability of the i
zinc addition system has been good for both units. Hydrogen addition system i
availability was reviewed for the last several refueling cycles. Unit 1 hydrogen addition system availability between August 1994 and September 1998, was greater
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l than 90 percent. Unit 2 hydrogen addition system availability during the summer of 1997 was poor due to low oxygen in the off-gas system during main condenser flow direction changes causing numerous trips of the hydrogen addition system. To i
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compensate for these availability problems the licensee increased the air injection flow rate, which limited the numser and duration of system trips. A modification to the Unit 2
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system was planned for the future and is intended to buffer the excursions in offgas hydrogen concentrations that occur due to a hydrogen build-up in the main condenser
during flow reversals. This modification was in the approval process.. Hydrogen i
addition availability for both units during the last eight months averaged greater than 90 i
percent which was consistent with industry performance.
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Initiation of noble metalinjection was being planned for both units. Noble metal injection allows much lower hydrogen addition rates than currently used to obtain the same electrochemical corrosion potential for reducing the initiation and growth of intergranular stress corrosion cracking. The lower hydrogen addition would reduce the amount of nitrogen-16 carryover in the steam and lower drywell and shutdown dose rates, reducing overall station dose.
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Conclusions The staff's control of plant water chemistry continued to be good and was effective in reducing corrosive impurities in reactor water. In addition, the licensee was planning to implement noble metal injection to enhance corrosion control and lower station dose rates.
R1.2 Radioloaical Environmental Monitorina Proaram (REMP)
a.
Inspection Scope (IP 84750)
The inspector reviewed selected portions of the licensee's radiological environmental monitoring program (REMP) including the 1997 Annual Monitoring Report, the Off-site Dose Calculation Manual (ODCM), applicable procedures, interviews with cognizant individuals, and observed the collection of envMnmental air samples.
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Observations and Findinas The REMP program was implemented as described in station procedure QCAP 0610-01, Revision 4, " Environmental Monitoring Program " and in chapters 11 and 12 of the ODCM. The ODCM was recently revised to implement the corporate Unified Radiological Environmental Program (UREMP) during the first sampling period of 1999.
Because of the UREMP implementation, the number and location of environmental sampling locations were revised. The program was wellimplemented by a contract vendor and effectively overseen by the radiation protection staff.
The collection of environmental samples was performed by a contract technician. The inspector observed the collection of air particulate filter samples and noted that the instrumentation was operable, in good material condition, and was appropriately calibrated. During these observations, the inspector observed the contract technician
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conduct an air in-leakage test of the air sampling filter train. The inspector identified a l
problem with air in-leakage that was not apparent to the technician. The inspector observed air in-leakage of approximately 20 cubic feet per hour (CFH). The sampling procedure required that during the in-leakage portion of the test, the flow meter reading should be at approximately zero CFH or the flow indicator bouncing sporadically near zero CFH. During this part of the test, the technician incorrectly looked at the vacuum gage instead of the flow meter, and seeing an acceptable vacuum, assumed the test was acceptable. However, the amount of vacuum is not related to whether there is in-leakage. The amount of vacuum provides an indication of the condition of the pump.
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The sampling pump vacuum test was properly performed while the sampling train was removed to change the filter. The inspector discussed the in-leakage test with the
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technician, who indicated that i:e ' elieved the in-leakage was acceptable if the o
sampling pump developed a vacuum of approximately 20 inches of mercury (the acceptable vacuum measurement during the vacuum test). The inspector concluded that the technician did not possess a thorough knowledge of the sampling procedure.
Once the in-leakage was brought to the attention of the technician, appropriate steps were taken to reduce the in-leakage to an acceptable level. The in-leakage was identified as coming from the iodine cartridge holder. A licensee representative and the contract technician indicated that the O-rings on the iodine cartridge holder were stiff during the colder months and required additional pressure to obtain a good seal. The licensee representative, who also observed the air filter collection, indicated that during sample collection evaluations in July and October 1963, the air in-leakage was at an acceptable level.
In response to the inspector's observations, the licensee initiated problem identification form (PIF) Q1999-00317. Proposed solutions to the PlF included the following:
Notifying the contract vendor and requesting them to notify all Commonwealth
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Edison (Comed) sample collectors of the problem; Notifying the REMP point of contacts at all other Comed sites about the
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problem; Revising the assessment checklist used during performance evaluations to
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include checking the sampling train in-leakage, and whether the sampling procedure was followed; Requesting that the vendor and/or corporate health physics staff evaluate the
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iodine cartridge holder and 0-ring for possible attematives; Evaluating the procedure to determine if the in-leakage step is necessary;
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Meeting with the contract vendor to discuss expectations regarding sample
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collection and adherence to procedures; and Evaluating whether task qualifications were required for sample collectors.
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The inspector concluded that the proposed solutions were appropriate and that the in-leakage was of minor safety significance. The failure to ensure that air in-leakage was acceptable constitutes a violation of minor significance and is not subject to formal enforcement action.
The inspector reviewed the 1997 annual monitoring report and concluded that it complied with REMP and ODCM requirements. Environmental samples had been collected and analyzed, and sample anomalies and their corrective actions were documented. The land use census was performed as required. The environmental sampling data indicated no discemable radiological impact on the environment from the operation of the facility.
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Conclusions The radiological environmental monitoring program was well implemented.
Environmental sample results did not indicate any discemable environmental effects from plant operations.
R2 Status of Radiation Protection and Chemistry Facilities and Equipment R2.1 Meteoroloaical Monitorina Instrumentation a.
Inspection Scope (IP 84750)
The inspector reviewed the operability of the meteorologicalinstrumentation at the meteorological (met) tower. Specifically, the inspector reviewed instrument performance trends and calibration and maintenance records; discussed instrument performance with the cognizant radiation protection staff; and performed a walk-down of the met tower instrumentation.
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Observations and Findinas The licensee maintained a met tower south of the sight to provide weather information for the purposes of offsite doss projections and emergency response actionc. The met tower measured temperature, wind speed, and wind direction at 33,196 and 296 feet elevations. A contractor vendor implements the monitoring program and provides monthly data reports to the station.
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The vendor performs monthly visits to the met tower to gather data, review the condition of monitoring equipment, and conduct scheduled maintenance activities. The vendor performed quarterly in-place calibrations of the temperature, wind speed, and wind direction detectors. In addition to the vendor visits, station personnel visit the met tower monthly to eneck the housekeeping of the met tower building, lighting and heat in the building, and to check the diesel generator and battery. The inspector reviewed monthly vendor reports for 1998 and no problems were noted. Detector availability was greater than 90 percent. Logs at the met tower building were reviewed and indicated that visits, maintenance, and calibrations were performed at the required frequencies.
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Conclusions
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Surveillances and calibrations for the met tower were performed at the required frequency. The radioactive meteorological equipment was maintained in good condition.
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R2.2 Radioactive Waste Syste_.ms
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Inspection Scope (IP 84750)
The inspector reviewed the process control program (PCP) and procedures and.
discussed the material condition of radioactive waste (radwaste) systems with plant personnel.
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Observations and Findinas The PCP was revised in November 1998 to allow the shipment of radwaste to an intermediary processor for volurne reduction of resins and filter media before disposal.
In the past, resins and filter media were dewatered onsite and sent directly for disposal.
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The inspector reviewed the status of radwaste systems with the radwaste coordinator.
This individual indicated that the major processing systems were all operational, with the spare floor drain filter the only major piece of equipment out of service (OOS). The floor drain filter was OOS for an electrical modification, with engineering working on the design change. The backlog of radwaste work requests continued to be large, but the radwaste coordinator indicated there was not a major impact on equipment Most of the
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work requests were for leaking valves or abandoning old equipment that was not used.
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Radwaste maintenance work weeks were being planned into the station work schedule at approximately four week intervals.
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The station implemented procedure QCAP 0280-02,"Radwaste Operation Assessment of Risk," assessing the status of the primary radwaste systems to prevent plant operational restriction or unit shutdowns. The primary radwaste systems evaluated were the equipment and floor drains, chemical wastes, demineralizer backwash, and refueling operation. The radwaste shift supervisor reviewed each of these matrices daily and reported the status to the shift manager. The report includes the status of each matrix, a description of the concern and the action plans in effect. The report was included in the plan of the day package provided to station managers and significant issues were brought to the attention of the plant manager. The result of this assessment has been j
plant management's increased awareness of radwaste system problems and the
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potential impact on primary, secondary, and essential service water systems.
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Conclusions
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Material condition of radwaste systems had improved. The implementation of the
1 radwaste risk assessment procedure heightened plant management's awareness of radwaste system problems and the potential impact on plant operations.
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R4
- Staff Knowledge and Performance in Radiation Protection and Chemistry i
R4.1 Staff Performance Durina Sample Collection and Analysis I
a.
Inspection Scope (IP 84750)
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The inspector observed the collection of samples from the 2A and 2B cleanup filter
demineralizer outlets and the Unit 2 reactor water. The inspector also observed the
preparation of several samples in the chemistry laboratory.
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Observations and Findinas
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The chemistry technician observed collecting samples was knowledgeable of the i
procedures and checked off the procedure steps as they were completed in accordance with station expectations. The technician appropriately contacted the
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control room prior to and after obtaining each sample. The technician wore rubber
gloves and used good sampling techniques including rinsing the bottles before
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obtaining each sample. The inspector noted during sample collection, that the L
procedure book (kept in the sampling panel, a designated contaminated area)
straddled the contamination control boundary, because the contaminated area was too
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. narrow to keep the book within the boundary when opened. To prevent the spread of
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i contamination, items within contaminated boundaries should be treated as contaminated and should not straddle the boundary or be removed from the area l
without being properly surveyed or placed into an appropriate container. After the sampling was completed at each sampling panel, the technician wiped down the
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procedure book, replacing it in the contaminated area, wiped down the sampling panel
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counters, and then counted the wipe to determine if any radiological contamination was
present. The results of the surveys did not identify any contamination. The technician also discussed that if contamination was identified, the panel would continue to be -
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decontaminated until no contamination was detected. The inspector discussed with
j radiation protection management the inconsistency wi.th posting the panels as contaminated areas when the survey data did not identify any contamination.
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Radiation protection management indicated the panois were posted as contaminated
i areas as a precautionary measure, since the potential existed for the panels to become contaminated. However, radiation protection management indicated they would review
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i The inspector also observed, during a backwash of a sampling line, that hoses used -
during the evolution were carried back and forth across the contamination boundaries of the sample panel and storage cabinet without being surveyed or placed in a bag.
The inspector discussed the contamination control inconsistency with the radiation
protection management, who indicated that the issue would be evaluated. The
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inspector noted that a PIF was written to document the contamination control issues e
mentioned above.
The inspector observed and discussed the preparation of a sample from the make-up
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demineralizer trailer with a technician. The sample was being prepared to analyze for
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anions and for silica breakthrough. The technician followed the procedure and checked
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off steps as they were completed.
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Conclusions Chemistry technicians were knowledgeable regarding sampling and analysis
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procedures and demonstrated good sampling techniques.
R5 Staff Training and Qualification in Radiation Protection and Chemistry R5.1 Chemistry Technician Trainina
The inspector reviewed the training programs for newly hired technicians and i
continuing training. The new technician training consisted of training as a "B"
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technician and then training as an "A" technician. "B" Technician duties include collecting routine samples, preparing samples for analysis, performing inventories, and
cleaning glassware. "A" technician duties include collecting special samples, chemical analysis and special sample collections. The training program for "B" technicians was approximately 21 weeks and included five weeks of generic chemistry, five weeks of site specific chemistry and 11 weeks of on the job training. The training program for"A" technicians was approximately 15 weeks and included sample analysis training, plant systems training, and on the job training. The licensee's continuing training program was well established and included sessions on theory, sample analysis, and plant
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systems. Training records were reviewed for two recently trained technicians and randomly for other technicians. Records reviewed were complete and indicated that
training was provided in accordance with station procedures. The chemistry technician training program was well implemented.
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R7 Quality Assurance in RP&C activities
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R7.1 Laboratory and Instrument Quality Control Proarams
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Inspection Scope (IP 84750)
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The inspector reviewed the laboratory quality control programs, including programs for
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inter-laboratory comparison, analytical and radioanalytical instrumentation, and
instrument quality control.
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Observations and Findinas The inspector reviewed the radioanalytical instruments inter-laboratory cross check program results and noted 100 percent agreement with the reference lab for the quarterly results over the last two years. Samples included filters and liquids for
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gamma spectroscopy analysis, liquids and gases for gross alpha and gross beta analysis, and charcoal cartridges for iodine analysis.
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l quarterly samples. The station was in good agreement with the contract vendor's
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results and was outside the acceptable agreement twice during the last two years. The'
i station appropriately evaluated the discrepancies in accordance with station procedures
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and implemented corrective actions.
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i documented when instrument response was outside the control limits or when trends were identified.
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Conclusions
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The instrument quality control program was well implemented, with evaluations and
corrective actions performed when warranted. Station performance was good i
regarding the inter-laboratory cross check programs and effective evaluations were l
performed for analysis discrepancies.
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R7.2 Quality Assurance in Chemistry Activities i
l The inspector reviewed the results of audits and self-assessments of the chemistry j
and REMP programs conducted in 1998 and 1999. Two self-assessments of the
REMP program were performed, which concluded that the REMP program was
effectively implemented and no deficiencies were identified. Approximately seven i
audits and self-assessments were performed of the Chemistry program in 1998. These audits reviewed the effectiveness of self-assessments, the auxiliary chemistry program, j
sample collection and analysis, the material condition of chemistry equipment, and
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technician knowledge and performance. The audits identified several minor
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deficiencies and areas where improvements could be made. Corrective actions, in
response to the deficiencies, were being evaluated, implemented and tracked for timely
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completion. The inspector concluded that the audits and self-assessments were of
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sufficient depth to identify deficiencies and areas where improvements could be made,
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and that corrective actions were appropriate.
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X1 Exit Meeting Summary
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The inspector presented the inspection results to members of licensee management at the
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conclusion of the inspection on January 29,1999. The licensee acknowledged the findings L
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The licensee did not identify any information discussed as being proprietary.
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee E. Anderson, Radiation Protection Manager i
P. Behrens Chemistry Manager J. Dimmette, Jr., Site Vice-President T. Fuhs, Regulatory Assurance R. Hebler, Chemistry Shift Supervisor T. Kirkham, Radiation Protection Technical Support Supervisor T. Pierce, Station Manager D. Wozniak, Engineering Manager INSPECTION PROCEDURES USED -
IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None
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Qiscussed None
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LIST OF ACRONYMS USED CFH-Cubic Feet per Hour
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Comed Commonwealth Edison
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EPRI Electric Power Research Institute
MET Meteorological ODCM Offsite Dose Calculation Manual OOS Out of Service DRS Division of Reactor Safety PCP Process Control Program PDR Public Document Room PIF Problem identification Form radwaste Radioactive Waste-REMP Radiological Environmental Monitoring Program RP&C Radiation Protection and Chemistry UREMP Unified Radiological Environmental Monitoring Program
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s LIST OF DOCUMENTS REVIEWED
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j Problem Identification Forms
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j PlF Q1997-03782, Excessive trips of the U-2 Hydrogen addition system l
PlF Q1999-00317, Failure to Proper Leak Test During REMP Sample Collection I
Procedures
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QCAP 0280-02, Rev. 3, Process Control Program for Processing of Radioactive Wet Wastes at Quad Cities Nuclear Power: ttion j
QCAP 0280-02, Rev. O, Radwaste Operational Assessment of Risk
QCAP 0610-01, Rev. 5, Environmental Monitoring Program
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QCCP 0100-01, Rev. 8, Scheduling of Surveillance Requirements I
QCCP 0100-02, Rev.10, Laboratory Analysis Schedule QCCP 0800-01, Rev. 7, Counting Analysis Schedule
QCCP 0800-19, Rev. 3, Counting Room Quality Control Program
QCCP 0900-04, Rev. 5, Chemistry Analyses Quality Control Program QCCP 0900-05, Rev. 5, Chemistry Instrument Quality Control Program QCRP 6100-07, Rev.1, Meteorological Tower Inspection i
Sampling Procedures Manual, Rev. 2, Teledyne Midwest Laboratory i
I Audits
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Radiological Effluent Program, January 1999
Radiological Environmental Monitoring Program, December 1998
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Nuclear Oversight Assessment QAS 04-98-077, Line Management involvement with Training i
Assessment l
Nuclear Overcight Assessment QAS 04-98-071, Assessment of Station Self-Assessments and Corrective Action Effectiveness Within the Plant Support Departments Nuclear Oversight Assessment QAS 04-98-057, Chemistry Assessment Chemistry Department Self Assessment, July 1998, Auxiliary Systems Chemistry Chemistry Department Performance Review 3* Quarter 1998.
Miscellaneous Hydrogen Availability Graphs Hydrogen injection System Performance,1997 Inter-laboratory Comparison Data,1997 & 1998 Quad Cities Annual Radiological Environmental Operating Report,1997 Sample Collector Evaluation,7-24-98 & 10-3-98 Water Chemistry Control Data Graphs and Charts,1998 13