IR 05000003/1978008

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IE Insp Repts 50-003/78-08 & 50-247/78-23 on 780620-22.No Noncompliance Noted.Major Areas Inspected:Program for QC of Analytical Measurements & Internal Audit Results
ML20050A073
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 07/05/1978
From: Kottan J, Stohr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20050A071 List:
References
50-003-78-08, 50-247-78-23, 50-3-78-8, NUDOCS 8203310084
Download: ML20050A073 (8)


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U.S. NUCLEAR REGULATORY COMMISSIOh j

t OFFICE OF INSPECTION AND ENFORCEMENT

Region I 78-08 porice Report No.

78-23

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50-03 as et '

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Docket No.

50-247 UFK-3

License No.

OPR-26 C

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Category

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Licensee:

Consolidated Edison Company of New York, Inc.

4 Irving Place

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New York, New York 10003 Facility Name:

Indian Point Nuclear Generating Units 1 and 2 Inspection at:

Buchanan, New York Inspection conducted:

June 20-22, 1978

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Inspectors:

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( J. J.

.ottan, Raoiation specialist date signed

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date signed care signed Approved by:

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Insoection Summary:

Inspection on June 20-22, 1978 (Report Nos. 50-03/78-08'and'55-2D/78-Zij'

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Areas Insoected:

Routine, unannounced inspection of the licensee's chemical and radiochemical measurements program using laboratory assistance provided by 00E Radiological and Environmental Services Laboratory.

Areas reviewed included:

program for quality control of analytical measurements; internal audit results; performance on radiological analyses of split actual effluent samples and spiked samples; and effluent control records and proceoures.

The inspection involved 20 inspector-hours onsite by one NRC inspector.

Results:

Of the four areas inspected, no items of noncompliance were identified.

Region I Form 12 (Rev. April 77)

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e203310004 780707 PDR ADOCK 05000003 O

PDR

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b DETAILS

1.

Persons Contacted Principal Licensee Employees

  • J. Makepeace, Technical Engineering Director
  • J. Higgins, General Chemistry Supervisor S. Profeta, Chemistry Supervisor S. Wisla, Chemistry and Radiation Safety Director The inspector also talked with and interviewed several other licensee employees including members of the chemistry and operations staff.
  • denotes those present at the exit interview.
  • 2.

Licensee Action on Previous Inspection Findings (0 pen)

Unresolved Item (50-247/77-12-01):

Sampling line loss test j

for R-ll and R-13 heat tracing evaluation.

The inspector noted that the licensee has completed the heat tracing evaluation but had not completed the evaluation of R-ll line loss test data.

This item remains open until the licensee completes the evaluation and

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it is reviewed by the inspector.

3.

Laboratory OC Program The inspector reviewed the licensee's program for quality control of analytical measurements in the following areas:

a.

Assignment of Authority and Responsib311ty to flanage and Conduct the QC Program

The licensee's laboratory QC program is detailed in Administrative

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Directive No. CAD 3, Revision 2, Quality Control of Radiochemical Analyses by the Chemistry Sub-Section.

This Directive assigns re-sponsibility for the program to the Station Chemistry Director, Chemistry General Supervisor and Chemistry Supervisor.

b.

Provisions for Audits / Inspections The licensee's laboratory QC program contains no provisions for audits of the program by the Station Chemistry Director, Chemistry

General Supervisor or Chemistry Supervisor.

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Methods for Assuring Deficiencies and Deviations in the Program are Recognized and Identified The inspector noted the licensee's QC program contains. provisions for recognizing results that do not meet acceptance criteria, d.

Methods for Taking Corrective Actions on Identified'Oeficiencies The inspector noted the licensee's'QC program contains provisions for taking corrective actions on identified deficiencies. '

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Method of Recording Audits / Inspections

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The licensee's laboratory QC pfogram contaids no prov'isicns for audits / inspections and therefore contains no provisions for re '

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cording the audits / inspections.

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Method of RepictNg Results of Audits /I'nspections to Supervicor for Review and Approval

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The inspector noted the licensee's iaboratory QC program contains no methods or. provisions'for reporting _results of audits /inspec2.

tions to supervisory personnel for review in that' the licensee's program requires that no audits be performed.

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Requirements'for Purchased or Contracted Services s

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The inspector noted the licensae's QC program contains management and procedural [contrors for purchased and/or contracted laboratory services.

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The inspector dhcussed laboratory QC with the licensee. The inspector also discussed viricus aspects of NRC Regulitary Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations) -

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Effluent Streams,,and the Environment. ~ The inspector noted the licen ~

see had no regulatory ~ requirements in the area of laboratory QC and had no further questions in this area.

No Items of'noncoSpliance -

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4.

Audit Results The inspector datermined that the licensee's effluent monitoring program was on the site Quality Assurance and Reliability (QA&R)

audit list.

The inspector determined the last audit of this area was performed in October, November and December, 1977 and was documented in Audit 77-G1 dated January 18, 1978.

The inspector had no further questions in this area.

No items of noncompliance were identified.

5.

Confirmatory Measurements During this inspection, certain capability test standards, prepared by the NRC reference laboratory (Department of Energy, Radiological and Environmental Services Laboratory (RESL)), were submitted to the licensee for analyses.

In addition, during this inspection, actual liquid and gaseous effluent samples were sent to RESL for analyses.

The analyses to be performed on the samples are:

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liquid waste to be analyzed for gross beta, tritium, strontium-89 and 90, and gamma iso. topic; and,

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b.

gas sample to be analyzed for gamma isotopic.

These results will be compared with the licensee's results when received at a later date and will be documented in a subsequent inspection report.

Joint analyses of actual effluent samples determines the licensee's capability to measure radioactivity in effluent samples.

The comparisons of the capability test standards indicate that all of the measurements were in agreement under the test criteria used for comparing results.

(See Attachment 1).

The results of the comparisons are listed in Table I.

6.

Pecords and Procedures The inspector reviewed the following records and procedures:

Gaseous effluent analysis data (January,1978 to May,1978).

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b.

Liquid effluent analysis data (January, 1978 to May, 1978).

Counter calibration and check records (January,1978 to fiay, c.

1978).

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Laboratory QC sample analyses (January,1977 to May,1978).

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The following procedures:

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IPC-020, Radiochemical and Chemical Sample Preparation for Discharge.

(2)

IPC-022, Radioactive Sampling Schedule for Eff1 dent Monitoring.

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IPC-030, Radiation Monitor - Calibration Factor Verification.

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IPC-039. Radioactive Airborne Release Calculations.

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(5)

IPC-046, Radioactive Airborne Sampling.

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IPC-050, Radioactive Liquid Release Calculations.

7.

Liquid Waste Discharge Analyses The inspector noted that since December 12, 1977 the licensee has been permitted by his Environmental Technical Specifications to perform a gross beta analysis on each ba'tch of liquid effluent, as per Appendix A. Section B.l.a of NRC Regulatory Guide 1.21, with a gamma isotopic

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analysis being performed on a weekly composite sample.

Prior to this date, the licensee was required to perfonn a gamma isotopic analysis on each batch of liquid waste.

The inspector noted that the licensee is performing the gross beta analyses because of the small size (1000 gallons) of the liquid effluent waste tanks and the amount of time re-quired to perform a gamma isotopic analysis as compared to a gross beta analysis.

The inspector noted the licensee had documented the operational limitation which precludes the gamma isotopic analysis and permits the gross beta analysis as required by Regulatory Guide 1.21. The inspector further noted that the licensee is in the process of installing a new liquid waste system with larger liquid effluent waste tanks which will permit a gamma isotopic analysis to be per-formed, as discharges of liquid waste will be less frequent and time will be available for the gamma isotopic analysis.

No items of non-compliance were identified in this area.

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Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on' June 22, 1978.

The inspector summarized the purpose and scope of the inspection and

the inspection findings.

t The licensee agreed to perform the analyses listed in paragraph 5 and report the results to the NRC.

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TABLE 1

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INDIAN POINT 1 AND 2 CAPABILITY TEST RESULTS SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON

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Charcoal Cartridge

  1. 21 Ba-133 (4.241920)E-2 (4.0219 06) E-2 Agreement Charcoal Cartridge
  1. 26 Ba-133 (6.5919 33) E-2 (5.63fp.08) E-2 Agreement Particulate Filter
  1. 41 Co-57 (1.0610.03) E-2 (9.1819 25) E-3 Agreement

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Cs-134 (1.5419 06) E-2 (1.201913) E-2 Agreement Cs-137 (7.819 3) E-3 (6.6919 21) E-3 Agreenent Co-60 (1.0219 05) E-2 (9.1519 24) E-3 Agreenent

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Attachment 1 Criteria for Comparing Analvtical Measurements This attachment provides criteria for comparing results of capability tests and verification measurements.

The criteria are based on an empirict1 relationship which combines prior experience and the accuracy

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needs of this program.

In these criteria, the judgement limits are variable in relatf?n to the

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comparison of the NRC Reference Laboratory's value to its associated uncertainty.

As that ratio, referred to in this program as " Resolution",

increases the acceptability of a licensee 's measurement should be more selective.

Conversely, poorer agreement must be considered acceptable as the resolution decreases.

LICENSEE VALUE RATIO = NRC REFERENCE VALUE Possible Possible Resolution Agreement Agreement A Agreement B

<3 0.4 - 2.5 0.3 - 3.0 No Comparison 4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5 16 - 50 0.75 - 1.33

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0.6 - 1.66 0.5 - 2.0 51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.66

>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33

"A" criteria are applied to the following analyses:

Gamma Spectrometry where principal gamma energy used for identificatici is greater than 250 Kev.

Tritium analyses of liquid samples.

"B" criteria are applied to the following analyses:

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Gamma Spectrometry where principal gamma energy used for identification is less than 250 Kev.

89Sr and 90Sr Determinations.

Gross Beta where samples are counted on the same date using the same reference nuclide.

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