IR 05000010/1975002
| ML19340A700 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/18/1975 |
| From: | Jorgensen B, Pagliaro J, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A696 | List: |
| References | |
| 50-010-75-02, 50-10-75-2, 50-237-75-03, 50-237-75-3, 50-249-75-03, NUDOCS 8009030704 | |
| Download: ML19340A700 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
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Report of Independent Measurements Inspection TE Inspection Report No. 050-010/75-02 IE Inspection Report No. 050-237/75-03 IE Inspection Report No. 050-249/75-03 Licensee:
Commonwealth Edison Company P. O. Box 707 Chicago, Illinois 60690 Dresden Nuclear Power Station License No. DPR-2 Units 1, 2, and 3 License No. DPR-19 Morris, Illinois License No. DPR-25 Category:
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Type of Licensee:
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Type of Inspection:
Routine, Announced
l Dates of Inspection:
January 27, 1975 Dates of Previous Inspection:
January 2, 3, 13 and 14, 1975 (REP)
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Principal Inspector:
B. Jo'rgensen
(Date)
Accompanying Inspectors:
None
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Other Accompanying Personnel:
G. Wright
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D. Ed (Bureau of Radiological Health, Illinois)
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/h7f SeniorEn{dto Reviewed By:
I. A. Pag
ronmental Scientist
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Environmental and Special
Projects Section
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SUMMARY OF FINDINGS
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Enforcement Action: None.
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Licensee Action on Previously Identified Enforcement Matters
No previously identified enforcement items within the scop; of this inspection.
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Unusual Occurrences: None within the scope of this, inspection.
Other Significant Findings A.
Current Findings l
This inspection consisted of an evaluation of the licensee's perfor-mance in analysis of several test samples and sample standards.
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The licensee's performance has resulted in 61% agreements or possible agreements and 39% disagreements with the results of the NRC reference laboratory.
B.
Status of Previously Reported Unresolved Items No previously reported unresolved items within the scope of this inspection.
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i Management Interview A management interview was held with Messrs. Butterfield, Adam and Bergen at the conclusion of the inspection on January 27, 1974.
The following items were discussed with the licensee representatives:
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A.
The inspector discussed the scope and intent of the independent measurements inspection program, including reporting of comparative results.
(Paragraph 2)
B.
The inspector provided the licensee with copies of the current criteria for comparison and discussed these criteria with the licensee representatives.
(Attachment 1)
C.
The inspector discussed instances of unacceptable comparisons between licensee and reference laboratory results.
The inspector i
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stated that remedial action would be required for charcoal cartridge
analyses. The licensee stated that the licensee calculational techniques had been adjusted ef fective November 1,1974, to yield results expected to be in agreement with those of the reference laboratory.
(Paragraph 5.d)
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The inspector stated that it is the licensee's responsibility to
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assure that analyses performed by a contractor are representative i
and accurate. The licensee responded that the contractor labora-
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tory would be required to document the ability and intent to meet licensee requirements for this program.
(Paragraph 5.a)
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REPORT DETAILS 1.
Persons Contacted
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D. Butterfield, Assistant Superintendent D. Adam, Admistrative Assistant G. Bergen, Plant Chemist R. Coley, Chemical Engineer (CE Technical Center)
2.
General The licensee is required to measure the quantities and concentrations of radioactive material in effluents from his facility to assure that they are within the limit specified in his license and NRC Regulations. This inspection consisted of a test of the licensee's measurements of radioactivity in actual samples of his effluents and in test s,tandards which approximate samples of actual radicactive effluents.
The test consists of comparing the licensee's measurements with those of the NRC's reference laboratory.
The two laboratories make measurements on the same samples, or on duplicates or splits of the same samples.
The measurements made by the NRC's laboratory are referenced to the National Bureau of Standards radioactivity measure-ments system by laboratory intercomparisons.
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3.
Analytical Results This inspection showed some of the licensee's measurements on these samples are acceptable under the test criteria used by the Office of Inspection and Enforcement for comparing measurements results (see the attachment).
However, some of the licensee's measurements are not acceptable under the test criteria.
The types of samples tested and the results of the measurements were:
a.
Type of Sample:
Liquid Waste (1/74)(8/74)
(Results in units of uCi/ml)
ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurement H-3 2.48 1 0.02 E-03 2.8 1 0.02 E-03 Sr-90 4.5 1 07 E-08
15 E-08
- Cs-137 3.7 1 0.1 E-95 3.1 1 0.1 E-05
'*Cs-134 9.2 1 0.9 E-06 8.6 1 0.4 E-06 Co-60 4.38 i 0.03 E-04 4.28 1 0.05 E-04-4-l
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ACCEPTABLE (Cont)
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Radionuclide NRC Reference Measurement Licensee's Measurement
- Cr-51 1.21 + 0.01 E-04 1.4 + 0.1 E-04
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- Ba-140 4.6
+ 0.3 E-05 3.1 + 0.2 E-05
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- Cs-134 6.0 3['O.3 E-06 7.4 3[ Oi.4 E-06
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- H-3 1.78 + 0.01 E-03 1.60 + 0.16 E-03
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- Second Sample (8/74)
NOT ACCEPTABLE i
j Radionuclide NRC Reference Measurement Licensee's Measurement t
Sr-89 8.2 + 0.2 E-07 4.3 + 0.5 E-06
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Ce-141 9.1 ][ 0.9 E-06 3.15 3[ 0.5 E-05 j
- I-131 5.47 j; 0.06 E-05 1.2 + 0.1 E-04
- Co-58 1.20 + 0.05 E-05 2.2 + 0.1 E-05
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- Co-60 6.10 3[ 0.07 E-05 1.3 3[ 0.1 E-04
- Sr-89 4.3 + 0.2 E-06 1.2 + 0.2 E-06 j
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- Sr-90 2.1 + 0.1 E-07 8.9 + 1.0 E-07 i
- Second sample (8/74)
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b.
Type of Sample:
Gaseous Waste (1/74)(8/74)
(Results in units of uCi/ml)
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ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurement i
- Xe-133 3.1 + 0.1 E-02 2.4 + 0.1 E-02
- Second sample (8/74)
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NOT ACCEPTABLE
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Radionuclide NRC Reference Measurement Licensee's Measurement Xc-133 1.13 + 0.01 E-02 2.16 + 0.02 E-02
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Type of Sample:
Particulate Filter (8/74)
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(Results in units of uCi/ sample)
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l ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurerent
I-131 3.2 + 0.3 E-04 2.83 + 0.26 E-04 Ba-140 2.18 + 0.09 E-03 1.81 E-03 Co-60 2.5 + 0.2 E-04 3.5 + 0.6 E-04 i
NOT ACCEPTABLE: None i
d.
Type of Sample:
Charcoal Adsorber (8/74)
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(Results in units of uCi/ sample)
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ACCEPTABLE:
None NOT ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurement I-131 2.69 + 0.04 E-02 1.88 + 0.12 E-02
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Type of Sample:
Particulate Filter Standard (2/74)
(Results in units of dpm/ sample)
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ACCEPTABLE i
Radionuclide NRC Reference Measurement Licensee's Measurement
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Ce-144 1.01 + 0.01 E+05 7.10 + 0.03 E+04 Cs-137 9.0 + 0.1 E+03 7.1 1 0.1 E+03 Sr-89 5.9 1 0.2 E+02 6.2 1 0.7 E+02 Sr-90 7.7 1 0.2 E+02 6.9 1 0.7 E+02 NOT ACCEPTABLE Radionuclide NRC Reference Measurement Licensee's Measurement Co-60 1.64 1 0.01 E+04 1.2 1 0.1 E+04
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Type of Sample:
Charcoal Adsorber Standard (2/74)
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(Results in units of dpm/ sample)
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ACCEPTABLE:
None NOT ACCEPTABLE Radionuclide AEC Reference Measurement Licensee's Measurement I-131 2.31 1 0.05 E+04 9.77 1 0.15 E+03 l
4.
Unacceptable Comparisons a.
Liquid Samples
Analysis of two liquid waste samples resulted in unacceptable
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comparisons for Sr-89 (twice), Sr-90 and for several gamma emitting nuclides.
Strontium analyses are performed for the licensee by a con-tractor laboratory.
Examination of the comparative data i
indicates that the contractor has not been consistent in performance of these analyses. Two of the " unacceptable" comparisons result from licensee reports of greater quantities
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of radio-strontium than were determined to be present by the NRC reference laboratory, while one results from the reporting of a lesser quantity.
The licensee reported " acceptable" results for the analysis of Sr-90 in one liquid sample and for j
both Sr-89 and Sr-90 on a particulate filter standard sample.
The inspector stated that it is the responsibility of the lic2nsee to assure that all results reported are complete and accurate.
The licensee stated that the comparative data would be provided to the contractor laboratory with a written statement of licensee requirements and a request for documentation of the contractor laboratory's capability and intent to meet those requirements. These items will be examined further during a subsequent inspection.
Licensee results on gamma analysis of liquid waste samples
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yielding unacceptable comparisons result from the licensee overreporting the quantity of contaminant in comparison to the i
NRC reference laboratory.
If these differences are genuine with respect to required routine analyses, the licensee may
have overreported releases of these nuclides near the times of these comparisons. The licensee has investigated the possibility of particulate setting during counting.
The NRC reference laboratory is continuing investigation of methods for improving i
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the representativeness of split samples and minimizing possible
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selective radionuclide losses during shipping ana handling.
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The licensee stated that the equipment used for this analysis is calibrated with commercially obtained standards on an annual basis.
This equipment was last calibrated on September 25, 1974, subsequent to the analyses reported here.
b.
Off-Gas Samples The licensee's analysis of off-gas for Xe-133 resulted in an unacceptable comparison on the first verification sampling. The licensee analysis on a subsequent sampling resulted in acceptable results.
The initial result is thus apparently not indicative of continuing problems with the analysis.
If the difference is assumed to have carried through several required routine analyses, the licensee may have overreported releases of Xe-
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133 in off-gas near the time of the initial comparison.
c.
Particulate Filter Samples The licensee's results on a particulate filter sample standard and a " live" plant filter yielded all acceptable results except for Co-60 on the sample standard.
The licensee reported Co-60 satisfactorily on the " live" sample, which was subsequent
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to the sample standard analysis.
The unacceptable comparison is thus apparently not representative of a continuing problem with the analysis.
The licensee value, which is 27% less than the value reported by the NRC reference laboratory, may have been an acceptable result but for the large " Resolution" values attached to specially prepared sample standards.
(See the Attachment)
d.
Charcoal Filter Samples The licensce's results on analysis of a charcoal adsorber standard and a " live" plant charcoal adsorber both yielded unacceptable comparisons.
Both results indicate the possibility of past underreporting of the quantities of I-131 released by the licensee.
The inspector examined daily I-131 release records for all of 1973 and the first half of 1974.
No instances were found in which increasing reported release rates by a factor suggested by these comparisons (less than 40%) could be demonstrated to show operation in excess of Technical Specific-arions release limits on 1-131.
The licensee stated that all release rates are calculated assuming all fans operating at maximum rated flow, while the actual flow rate is used for the charcoal adsorbers.
Detailed information on fan operation and flow is not available.
The inspector also examined licensee records on establishment of the methods used in counting charcoal cartridges and in-8-
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converting countrates to quantities of I-131.
These records
indicated that the equipment, procedures, and conversion factors were provided by the General Electric Company when Unit I was constructed. The conversion factors are now strictly empirical, based on a continuing series of comparisons with other laboratories' results. Adjustments in calculational technique have been made based on these comparisons.
The inspector informed the licensee during discussions held in October, 1974 that performance on analysis of charcoal cartridges for I-131 had yielded consecutive unacceptable results.
Examination of all comparative data to date shows the licensee to have underreported I-131 in each case compared to the Reference Laboratory. One of the earlier analyses was acceptable and one unacceptable under the current criteria for comparison.
The licensee stated during the currect inspection that a new
"re-calibration" of plant calculational methods had been performed using quantities of I-131 on the most recent samples reported by the reference laboratory as the standard This
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procedure was implemented November 1,1974, for all analyses of charcoal cartridges throughout the plant.
The inspector provided the licensee with a spiked " unknown" charcoal cartridge
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at the time c f this inspection.
The results for this spiked sample and for the actual cartridge taken from the plant at the time of this inspection visit will be examined at a subsequent inspection.
Attachment:
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Attachment 1
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ATTAC1DIENT 1
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....u CRITERIA FOR COMPARTMC ANALYTICAL MEASUREMEllTS
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This attachment provides criteria for comparing results of capability'
tests and verification measurements.
The criteria are based on an
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empirical relationship which combines prior experience and the a
REGION lli
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799 ROOSEVELT RO AD CLEN ELLYN, ILLINOIS 60137
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IE Inseection Report No.
050-010/75-02 IE Ins.ection Report No.
050-237/75-03 A.
IE Inspection Report No, n5n_9Ao/75_n3 Transmittal Date
- February 21. 1975 Distribution:
Distribution:
IE Chief, FS&EB IE Chief, FS&EB IE:HQ (5)
IE:llQ (4)
DR Central Files L:D/D for Fuels & thterials
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Regulatory Standards (3)
DR Central Files Licensing (13)
IE Files IE Files IE Chief, M&PPE L:D/D for Reactor Project
B.
IE Inquiry Report No.
Transmittal Date
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Distribution:
Distribution:
IE Chief, FS&EB IE Chief, FS&EB IE:HQ (5)
IE:HQ DR Central Files DR Central Files Regulatory Standards (3)
IE Files Licensing (13)
IE Files C.
Incident Notification From:
(Licensee & Docket No. (or License No.)
Transmittal Date
Distribution:
Distribution:
IE Chief, FS&EB IE Chief, FS&EB IE:llQ (4)
IE:llQ (4)
Licensing (4)
L:D/D for Fuels & Materials DR Central Files DR Central Files IE Files IE Files osuito,
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