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Insp Repts 50-254/97-03 & 50-265/97-03 on 970203-05. Violation Noted.Major Areas Inspected:Effluent Radiation Monitoring Program,Records & Interviews W/Sys Engineering, Chemistry,Operations & RP Personnel
	ML20136F777
Person / Time
Site:	Quad Cities
Issue date:	03/07/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20136F720	List: ML20136F715; ML20136F747; ML20136F777;
References
	50-254-97-03, 50-254-97-3, 50-265-97-03, 50-265-97-3, NUDOCS 9703170051
	Download: ML20136F777 (11)
	v • d • e

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 111

Docket Nos: 50-254; 50-265

Licenses No: DPR-29; DPR-30

Reports No: 50-254/97003(DRS); 50-265/97003(DRS)

Licensee: Commonwealth Edison Company

Facility: Quad Cities Nuclear Power Station

Units 1 and 2

Location: 22710 206th Avenue North

Cordova, IL 61242

Dates: February 3-5, 1997'

Inspectors: N. Shah, Radiation Specialist

K. Selburg, Radiation Specialist

Approved By: T. J. Kozak, Chief

Plant Support Branch 2

Division of Reactor Safety

9703170051 970307

PDR ADOCK 05000254

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Reoort Details

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R1 Radiological Protection and Chemistry (RP&C) Controls

R1.1 Effluent Radiation Monitors

a. Insoection Scoce

The inspectors reviewed the licensee's effluent radiation monitoring program,

including observations of the operational condition of the monitors, a review of

applicable records and interviews with system engineering, chemistry, operations,

and radiation protection (RP) personnel,

b. Observations and Findinas

During plant walkdowns, the inspectors observed that the material condition of the

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monitors was good with few work request tags observed on the systems.

However, the inspectors observed a small sheet of paper with handwritten

instructions on a wire attached to the chimney high range monitor stating

" disconnect me in 30 seconds to clear stuck check source and maintenance alarm."

This paper had apparently been there for some time. The licensee removed the

paper and stated that this was from a previous problem with the system that had

since been re, solved and that using handwritten notes was not an accepted

communications practice.

The effluent monitor system engineer was knowledgeable of the system operation ;

and of the work requests open on the system. However, discussions with control l

room operators revealed a problem with the Eberline SPING microprocessor that the

inspectors determined the system engineer was not aware of. The operators stated I

that the microprocessor frequently locked up, after a switch in an efectrical bus or if I

there were mechanical nroblems with the printer. Although this problem did not

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affect the monitor's cz, abilities or alarm functions, the operators had to reboot the l

system after each occurrence, which caused the printer to become backdated to l

July 31,1988. Chemistry personnel believed that they were being contacted by

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operations every time this problem occurred in order to reset the date, but the

operators stated that this was not always the case. Occasionally, chemistry staff

performing routine walkdowns would reset the date without having been previously l

contacted by the operators. The inspectors identified that this problem had not '

been identified in a Problem identification Form (PlF), by either the operations or

chemistry staff, nor had corrective actions been taken. The licensee was

considering methods of resolving this problem and the inspectors considered it an

example of poor communication between the operations, chemistry, and system

engineering departments.

The inspectors also reviewed several selected calibration records and alarm

setpoints for the effluent monitors including applicable procedures; no problems

were noted. The monitor alarm setpoints were as described in the Offsite Dose

Calculation Manual (ODCM).

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c. Conclusions

Although the effluent monitors appeared to be in good material condiJon, there

were two examples of poor communication of system operability problems. In

particular, a problem associated with the Eberline SPING microprocessor had not

been identified via the licensee's problem identification process nor had it been well

communicated to the chemistry and system engineering staff.

R1.2 Radioactive Effluents

The inspectors reviewed the licensee's semiannual radioactive effluent reports from

January 1995 through June 1996, and the licensee's monthly effluent data from

July 1996 through December 1996. Through interviews, the inspectors noted that

the chemistry personnel responsible for generating the effluent reports were

knowledgeable of the process and were effectively tracking effluent activity

released. Additionally, the licensee was appropriately reporting abnormal releases

including a leak on the Unit 1 "B" RHR heat exchanger which was repaired in

February 1996, and a leak on the Unit 2 "A" RHR heat exchanger which was

repaired in March 1995. The total activity released in 1995 and 1996 remained

low and was well below applicable regulatory requirements.

In January 1996, the licensee was made aware (via the corporate office) of an error

in the computer software used to calculate dose from radioactive effluents.

Specifically, since January 1,1994, the software had been calculating dose using

only one non-noble gas pathway (i.e. through the ingestion of meat products). The

licensee has since corrected the software and recalculated the dose reports. In all

cases, the recalculated percentage was less than 0.5% of the applicable limit.

R2 Status of RP&C Facilities and Equipment

R 2.1 Radioloaically Protected Area insoections

a. Insoection Scooe (83750) ,

The inspectors reviewed the results of the licensee's annual inspections of I

infrequently entered areas and observed radiological controls and postings in the

radiologically controlled area (RCA).

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b. Observations and Findinas

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As required by station procedure OCRP 6020-03 " Radiological Surveys," the RP l

group has been performing annual surveys of infrequently entered areas since about l

December 1995. Specifically, the following areas were inspected: Unit 1 and 2

phase separator pump and tank rooms, waste sludge tank room, condensate phase

separator rooms, and the waste collector tank rooms. These tours were typically I

accomplished using a robot to maintain exposures ALARA. A review of licensee

inspections conducted since February 1996 identified no signs of recent leakage or

deterioration in the above rooms. However, in several of the rooms, there were l

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signs of poor housekeeping from previous work activities. The inspectors also

l reviewed recent radiological surveys of the Unit 1 "A" and "B" clean up pump

rooms and the Unit 2 clean up demineralizer valve alley. These rooms were not

part of the above annual survey as they were frequently entered, but the

components within the rooms were under frequent maintenance. No problems

were identified with these rooms.

During plant walkdowns, the inspectors observed several problems with the

licensee's control of contaminated areas and radiological postings. For example, in

i the Unit 2 "A" RHR room the inspectors observed a telephone for which the body

] wat .nside a contaminated area, but the head set was located outside the area and

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a testing apparatus that partially extruded from a contaminated area. The licensee

subsequently verified that these items were not contaminated and reestablished the

contamination boundaries. However, the inspectors also observed the following

examples of poor posting control:

2 e in the Unit 2 RCIC room, a hose, which v,as iabeled as contaminated,

stretched from a posted contaminated area into a drain, which was not

, labeled as contaminated;

e in the Unit 2 "A" RHR room, a drainage trough traversing an uncontaminated

area, but connecting two posted contaminated areas, was not posted as a

contaminated area as required by station procedure OCRP 5010-01; and

! e Radioactive material stickers for the radioactive check sources (licensed

material) on the service water and the radwaste effluent radiation monitors

did not legibly indicate dose rates, contamination levels, signature / initials of

! the surveyor or a description of the material / contents as required by station

. procedure OCRP 5010-01.

Although the licensee verified that the drain in the Unit 2 RCIC room was not

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contaminated, the labels on the check sources had been illegible for several years

and had not been identified by the licensee. The last two examples of poor posting

and labeling were considered a violation of Technical Specification (TS) 6.11, which

j required adherence to RP procedures (VIO 50-254/97003-01; 50 265/97003-01).

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c. Conclusions

f The licensee was effectively reviewing the status of infrequently entered areas per

procedure no. OCRP 6020-03. However, during plant walkdowns the inspectors

! identified several examples of poor control of contaminated areas and radiological

j postings which resulted in a violation.

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R2.2 Review of Area Radiation and Continuous Air Monitors

a. Lnapaction Scone

The inspectors reviewed the operability of the area radiation and continuous air

monitors (ARMS and CAMS), including: selected calibration and maintenance

records, in-field observations, interviews with applicable personnel, and the

applicable requirements in sections 11.5 and 12.3.4 of the Final Safety Analysis

Report (FSAR) and tables 3.2.A-1 and 4.2-A-1 of the Technical Specifications,

b. Observations and Findinas

The licensee maintained a fixed network of 71 ARMS and about 10 CAMS to

monitor plant radiologicallevels and provide early notification of possible adverse

events. The ARMS constitute a fixed,in-place network with each specific monitor

location and expected background radiation levels described in tables 12.3-3 to

12.3-5 of the FSAR. The CAMS were not similarly described in the FSAR and were

placed at the discretion of radiation protection or plant chemistry personnel.

Oversight of the ARMS and CAMS was maintained by the RP and chemistry groups,

respectively, with the instrument maintenance group performing routine

maintenance. The inspectors reviewed selected calibration and maintenance

records for the ARMS and CAMS; no problems were identified.

During plant walkdowns, the inspectors observed ARMS and CAMS in good

operating condition and evidence of routine surveillance activities (based on

chemistry technician notations on monitor charts and/or daily checklists) by plant

personnel. For selected monitors, the inspectors verified that the location,

background radiation levels and remote (control room) and local (if applicable)

indications were as described in the FSAR. However, during the tour, the

inspectors observed that an ARM Iccated near the Feedwater Heater Area (595'

elevation of the Unit 1 reactor building) was partially blocked by material stored in

the area potentially affecting the monitoring capability of the ARM. This material

had apparently been stored there for some time and had not been identified by the

licensee. This was discussed with the licensee who promptly moved the material.

While reviewing selected surveillance records and through interviews with

personnel, the inspectors identified several problems, including:

The licensee could not readily provide the basis for the monitor alarm

setpoints and had not verified (prior to the inspectors review) if the setpoints

met the basis. During the walkdown, the inspectors verified that the

setpoints for selected ARMS and CAMS were appropriate given their location

and the background radiation levels:

Station procedure 1200-05 (dated 10/27/95) "NMC AM-2D Continuous Air

Monitor" lists the required CAM surveillances that the chemistry department

performs, but did not list the weekly requirement for replacement of filter

papers. Although the chemistry group was performing this surveillance, this

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discrepancy had apparently existed for several years and had not been '

identified by the chemistry group;

o The inspectors identified several examples of missing data in CAM source

check and sample logbook entries from October - December 1996. For ,

example, on November 5,1996, the logbook did not contain the survey

results for the routine weekly filter changeout of the Unit 1 turbine building

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CAM. Although chemistry management was able to reproduce the missing

information, the missing entries were not identified during routine chemistry

managemont reviews nf the logbook; and

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e Station procedure 1200-04 (dated 9/28/95) "NMC Continuous Air Monitor

and Calibration" listed an equation that incorrectly calculated radioactive l

decay. Although the inspectors noted that radioactive decay was correctly ;

calculated in CAM calibration records, the incorrect equation had not been ;

identified by the chemistry technicians who performed the calibrations.

The licensee believed that the ARM alarm setpoints were based on data provided by

the architect / engineering (A/E) firm that designed the plant and was attempting to

obtain the information. The basis for the CAM setpoints was being developed by

chemistry. Additionally, the chemistry department was reviewing other logbook l

entries for missing information and will revise the aforementioned procedures. 1

c. Conclusions

A number of problems were identified, including: the licensee could not provide the

basis for CAM and ARM alarm setpoints and had not verified (prior to the

inspectors review) if the setpoints met the basis; the station procedure that listed

the required CAM surveillances did not list the weekly requirement for the changing

of filter papers; and there were several examples of missing data in CAM source

check and sample logbook entries from October-December 1996. Based on these

examples, the inspectors concluded that the oversight of the ARM sad CAM

program was in need of improvement.

R2.3 Review of Habitability Systems

The inspectors reviewed the licensee's results for the most recently performed

standby gas treatment (SBGTS) and control room emergency ventilation (CREVS)

systems tests, including inplace charcoal adsorber leak and charcoal canister iodine

absorption tests and in-place testing of the high efficiency particulate air (HEPA)

filters. The test results were within the Technical Specification (TS) limits and were

performed using proper industry standards. During plant walkdowns, the inspectors

noted that the above systems were maintained in good material condition and

observed selected portions of routine maintenance on the unit 2 SBGTS. No

problems were identified with the work on the SBGTS.

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R 2.4 Failure to Perform Reauired Surveillance on Main Steam Line Radiation Monitors

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a. Insoection Scone

The inspectors reviewed Licensee Event Report (LER No.96-019) regarding the

failure to perform the weekly functional test on the main steam line radiation

monitor (RT) on several occasions. Included in the inspection was a review of I

documentation and interviews with station personnel,

b. Observations and Conclusions

During a review of TS Interpretations (TSis), the licensee identified that the weekly

functional test of the RT system had not been performed during several Unit 1 l

outages since October 1992. However, the test had apparently been performed

during the Unit 2 outages and no problems with other similar surveillances listed on

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the TSI were identified by the licensee. Upon discovery, the licensee verified that

the weekly test had been performed for both units. i

The TSI was implemented to specify which TS requirements pertaining to the RT

system were not required during cold shutdown or refueling. Specifically, the TSI

concluded that the requirements listed in TS table 4.1-1 pertaining to the primary

containment isolation functions of the RT system were not applicable, as the main I

steam isolation valves were normally closed during the above plant conditions.

However, the TSI did not clearly address similar requirements (also in Table 4.1-1)

for the Reactor Protection System functions of the RT system that were applicable

whenever fuel was in the reactor vessel; this resulted in the missed weekly tests as

described above.

On September 23,1996, the licensee implemented revised TS which removed all

previous TSis and the aforementioned isolation and protection function surveillances ,

during the shutdown and refueling conditions. Through a selected review of I

records, the inspectors verified that this test had been performed since these TS

i were implemented. To prevent recurrence, a revision was made to station

procedure no. OCAP 2300-14 " Technical Specification Clarification Request" to

require (per step D.10(b)) that the Plant Operations Review Committee review and

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approve all future TSis.

Although the failure to perform the test was a violation of TS table 4.1-1

requirements, this licensee identified and corrected violation is being treated as a

Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy

(NCV 50-254/97003-02; 50-265/97003-02).

c. Conclusions

One non-cited violation was identified for the failure to perform a weekly functional

test of the RT system as required by TS.

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X1 ' Exit Meeting Summary i

j The inspectors presented the inspection results to members of licensee management ;

l (denoted by "*") at the conclusion of the inspection on February 5,1997. The licensee

acknowledged the findings presented. The licensee did not identify any of the documents

reviewed as proprietary. I

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'P. Beers, System Engineer i

i 'A. Chernick, Regulatory Assurance

"D. B. Cook, Operations Manager

! *S. Darin, Source Term Reduction Coordinator

l "T. Kirkham, Lead Technical Health Physicist

{ "D. McCullough, System Engineering / Auxiliary Group Lead

j "J. L. Morris, PEP supervisor

*C, Peterson, Regulatory Assurance

! 'G. Powell, Radiation Protection Manager

l 'W. Schmidt, ALARA Coordinator

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"R. G. Svaleson, Radiation / Chemistry Superintendent l

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PARTIAL LISTING OF DOCUMENTS REVIEWED

Offsite Dose Calculation Manual, Revision 1.8, June 1996, Chapter 10.

Problem identification Forms (PIF) No. 96-3371, "U 2 'B' Main Steam Line Radiation

Monitor"

Quad Cities Station Procedures:

OCCP 0300-03, Unit 1 (2), Revision 3, " Liquid Effluent Monitors Alarm Setpoints."

OCRP 5010-01, Unit 1 (2), Revision 4, " Radiological Posting & Labeling Requirements."

OCTS 0430-02, Unit 1/2, Revision 2, " Standby Gas Treatment System In Place DOP Leak

test of the HEPA Filters;"

OCTS 0430-03, Unit 1/2, Revision 2, " Standby Gas Treatment System inplace Charcoal

Adsorber Freon 11 Leak Test;"

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OCTS 0430-03, Unit 1/2, Revision 3, " Standby Gas Treatment System inplace Charcoal

Adsorber Freon 11 Leak Test;"

OCTS 0430-05, Unit 1/2, Revision 2, " Standby Gas Treatment System Removal of .

Charcoal Adsorber Test Canister " I

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OCTS 0430-05, Unit 1/2, Revision 3, " Standby Gas Treatment System Removal of I

Charcoal Adsorber Test Canister;"

OCTS 0440-01, Unit 1/2, Revision 1, " Control Room HVAC Air Filtration unit In-Place DOP

Leak Test of the Hepa Air Filters;"

OCTS 0440-02, Unit 1/2, Revision 2, " Control Room HVAC Air Filtration Unit inplace

Charcoal Adsorber Leak rate Test;"

OCTS 0440-03, Unit 1/2, Revision 3, " Control Room Emergency Filtration System l

Removal of Charcoal Adsorber Test Canister." '

OCCP 1200-05 "NMC AM-2D Continuous Air Monitor"

OCCP 1200-04 "NMC Continuous Air Monitor and Calibration"

OCAP 2300-14 " Technical Specification Clarification Request"

OCOS 5750-02 " Control Room Emergency Filtration System Monthly Test"

IP 96-0182 " Main Control Room Envelope Air in-Leakage Test"

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l OlP 0100-11 " Calibration of Instrument Used by Operations in Performing Their

i Surveillance Requirements"

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Licensee Event Report No.96-019 " Failure to Perform Required Surveillance on Main

i Steam Line Radiation Monitors"

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i Radioactive Effluent Reports: January through June 1995, July through December 1995,

i and January through June 1996.

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INSPECTION PROCEDURE USED

l IP 83750 OCCUPATIONAL RADIATION EXPOSURE

IP 84750 RADIOACTIVE EFFLUENT MONITORING AND RELEASE, PLANT WATER

CHEMISTRY AND RADIOLOGICAL ENVIRONMENTAL MONITORING

PROGRAMS

ITEMS OPENED, DISCUSSED or CLOSED

Open

50-254/265 97003-01 Violation for failure to follow RP procedures (section R2.1)

Discussed or Closed 1

One LER and one NCV were closed during this inspection:

LER No.96-019 " Failure to Perform Required Surveillance on Main Steam Line

Radiation Monitors" (Section R.2.4) ,

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NCV 50-254/265/97003-02 Non-cited violation for LER No.96-019 (Section R2.4)

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ML20136F777

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