IR 05000010/1978032
| ML19274D751 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/08/1979 |
| From: | Grant W, Januska A, Oestman M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19274D750 | List: |
| References | |
| 50-010-78-32, 50-10-78-32, 50-237-78-30, 50-249-78-30, NUDOCS 7902260012 | |
| Download: ML19274D751 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSIOS OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-10/78-32; 50-237/78-30; 50-249/78-30 Docket No. 50-10; 50-237; 50-249 License No. DPR-2; DPR-19; DPR-25 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Generating Stations 1, 2 and 3 Inspection At: Dresden Site, Morris, Il Inspection Conducted: October 31, November 1, 2, 3 and 29, 1978
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Inspectols:
M. J.,0estmann O )) lv LL%c c o h-'-
A.G.hanuska
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W. B. Grant p
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Approved By:
T. H. Essig, Chief ( 8 Environmental and Special Projects Section Summary Inspection on October 31 and November 1, 2, 3 and 29, 1979 (Report No.
50-10/78-32; 50-237/78-30; 50-249/78-30)
Areas Inspected:
Routine, unannounced inspection of (1) environmental protection program, including: management controls; internal audits; implementation of the radiological environmental monitoring program and (2) Confirmatory measurements program, including: discussion of results of comparative analyses of previous radiological effluent samples; and collection of samples for future comparative analyses.
The inspection involved 58 inspector-hours onsite by 3 NRC inspectors.
Results: No apparent items of noncompliance or deviations were identified.
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DETAILS 1.
Persons Contacted
- A.
Roberts, Assistant Station Superintendent, Dresden
- D. Farrar Tech Staff Supervisor, Dresden
- G. Bergan, Plant Chemist, Dresden
- G. Reardanz, Senior QA Inspector, Dresden
- T.
Schneider, Chemist, Dresden
- R. Stobert, QA Inspector, Dresden J. Golden, Staff Radioecologist and Administrator for Radiological Environmental Monitoring Programs, Production and Systems Analysis Department (PSA), CECO P. Hayes, Nuclear Technician, PSA, CECO B. Dionne, Radiation Protection Engineer, Dresden
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Significant Inspection Finding (10/78-19; 237/78-17; 249/78-19): Calibration of control room readout from m<teorological tower to correspond with readouts at the tower and in tie CECO Command Center. The readouts at the tower, control room, and command center now agree with one another.
The problem was traced to the electronics portion of the system. According to licensee representatives, a check of the agreement between the readouts is now a part of the Production and Systems Analysis Departments'
monthly surve.11ance checks of meteorological systems.
3.
Management coitrols_
The inspector examined management controls, including organizational structure, and assignment of responsibilities and authorities, and procedural controls of the environmental and radiological monitoring programs. It was noted that the licensee has maintained the same administrative functions relating to these monitoring programs as discussed in previous environmental inspections.
No apparent items of noncompliance or deviations were identified.
4.
Licensee Internal Audits The inspector reviewed licensee audits of the contractor who conducts the radiological environmental monitoring program. The inspector noted that the Production and Systems Analysis Department-2-
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performed an audit of the contractor in July of 1978. The audit traced the paperwork for 30 randomly selected samples from all Commonwealth Edison plants. The audit also reviewed logbooks and calibration procedures. No deficiencies were identified.
The licensee's Quality Assurance Department performed an audit by onsite personnel of the environmental monitoring program on June 12, 1978. The inspector reviewed the results of this audit. One discrepancy, a failure to complete the annual cilk census, was identified. On October 3 and 4, 1978, an audit by offsite quality assurance personnel reviewed the environmental monitoring program. A review of this audit report showed that the milk census noted in the previous audit had been completed.
No other discrepancies were noted.
No items of noncompliance or deviations were identified.
5.
Implementation of the Radiological Environmental Monitoring Program As stated in a previous inspection report 1/ the radiological environmental monitoring program underwent a significant change with the issuance of a Technical Specification amendment effective October 18, 1977. The inspector examined the monitoring results from Jaruary through October 1978 for compliance with the requirements of the revised Technical Specifications. No monitoring omissions or unusual trends were noted in the results.
Special sample collections and analyses were performed following increased effluent activity release rates associated with operational occurrences. Actions taken were found to be adequate and notification to the NRC timely and as described in the semiannual and annual reports. The inspector also examined the schedule for calibration and naintenance of monitoring equipment listed in the Eberline Field Samp.ing/ Analytical Procedures.
It was noted that the sampling, maintenance, and calibration had been completed as required.
The inspector toured several monitoring stations end found them all to be operable. Monitoring equipment is checke3 weekly by the contractor to assure equipment is operable.
No apparent items of noncompliance or deviations were identified.
l/ lE Inspection Report No. 50-10/78-19; 50-237/78-17; 50-249/78-19.
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6.
Confirmatory Measurements The inspector examined the licensee's analytical equipment used to measure reactor coolant and reactor plant effluent. Records of maintenance, calibration, and daily operations were reviewed and found to be satisfactory.
The RIII Radiation Measurements Van was used onsite during this inspection to perform radioanalytical analyses of Confirmatory Measurements Program samples in addition to the analyses performed by the NRC's Reference Laboratory.
a.
Results of Comparative Analyses The inspector reviewed the analytical results of gaseous and liquid wastes, particulate and charcoal absorber samples collected from Dresden Nuclear Power Station in June 1978. A summary of these results by sample type and isotope is presented in Table I.
The results of the licensee's and the NRC's Reference Laboratory's analyses were compared using the " Criteria for Comparing Analytical Measurements" (Attachment 1).
For 11 sample comparisons, the licensee's results yielded six agreements or possible agreements. The results were discussed with the licensee.
The licensee failed to properly quantify Xe-133 and Xe-133m and failed to detect Xe-135 in the analysis of gaseous waste. Regarding Xe-133 and Xe-133m, the licensee's reported results were 2.4 and 2.5 times higher than those reported by the NRC Reference Laboratory. If these results were real and representative, the licensee may have overestimated quantities or concentrations of radionuclides released at the time of sample collection.
The licensee had no explanation for the failure to quantify Xe-135, except that since the NRC Reference Laboratory and the licensee did not agree on any of the gaseous waste results, the samples may not have been homogenous. This result, which was in the non-conservative direction, would not have resulted in the effluent technical specifications being exceeded.
The licensee also failed to properly quantify Co-60 activity in the analysis of liquid waste. The licensee's reported result was 2.2 times higher than those reported by the NRC Reference Laboratory.
If this result was real and representative, the licensee may have overestimated quantities or concentrations of radionuclides released at the time of sample collection.
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The licensee also failed to properly quantify Ba-140 activity in an analysis of the particulate filter. The licensee could offer no explanation for the failure to properly quantify the Ba-140 result, which was approximately 60% of the NRC Reference Laboratory. This result, which was in the non-conservative direction, would not have resulted in the effluent technical specifications being exceeded.
No apparent items of noncompliance or deviations were ider.tified.
b.
Collection of Samples for Future Comparative Analyses The inspector collected samples of liquid and gaseous waste, a particulate filter and charcoal adsorber sample from the licensee for subsequent comparative analyses. Results of these analyses with particular emphasis on radioxenon, Co-60, and Ba-140, will be compared during a future inspection.
7.
Exit Interview The inspector met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on November 29, 1978. The inspector summarized the purpose and. the scope of the inspection and the findings.
Attachments:
1.
Table 1, Dresden Confirmatory Measurements Program 2.
Attachment 1, " Criteria for Comparing Analytical Measurements"
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SAMFLE ISCTOFF EESUL7 rfF0F RESULT E Rf 0t RATIC FEt I
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I 131 4 5F-33 1 9E-Oc 5 7E -3 3 1 0E-14 1 1 E + T r-2ecE+01 A
T TEST EESULTS:
t=/Ge[pyrNT DsDI S AGREE ME NT P =PO S S I ?L E A C F E r v r.1
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N=NO COMP A R I S0t.
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ATTACINENT 1
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CRITERIA FOR COMPARING ANALYTIC /.L MEASF"F':TS 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 accuru needs of this program.
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In these criteria, the judgment limits are variabic in relation to the comparison of the NRC Reference Laboratory's value to its associa cd one sigma uncertainty. As that ratio, referred to in thic program as
" Resolution", increases, the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement should be con-sidered acceptable as the resolution decreases.
The values in the ratio criteria may be rounded to fewer significant figures to maintain statistical consistency with the number of significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a
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narrowed category of acceptance.
The acceptance category reported ull!
be the narrowest into which the ratio fits for the resolution being used.
RESOLUTIOh RATIO = LICENSEE VALUE/NRC REFERENCE VALE Possible Possible A reement "A" Agrceable "D" Agreement J
<3 No Comparison No Comparison No Cct.parison
>3 and <4 d.4 -
2.5 0. 3
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3.0 No Compari san
>4 and <8 0.5
- 2.0 0.4
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2.5 0.3
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3.0 I8 and <16 0.6 - 1.67 0.5
- 2.0 0.4
- 2.5 Il6 and <51 0.75 - 1.33 0.6
- 1.67 0.5
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2.0
~551 and <200 0.80 - 1.25 0.75 - 1.33 0.6
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1.67
>200 0.85 - 1.18 0.80 -
1.25 0.75 - 1.33
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"A" criteria are applied to the following analyses:
Gamma spectrometry, where principal gau energy used for identifi-cation is greater than 250 kev.
Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Gamma spectroretry, where principal gamma energy used for identifi-cation is Jess than 250 kev.
Sr-89 and Sr-90 determinations.
Gross beta, where samples are counted on the same date using the same reference nuclide.
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0FF CAS XE 133 E. 0 E -C ?
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XE 133 t1 8 3E-qa 4 0F-15 2 0F-97 2.D E -J c 2 4E+CC 2 1 E + 01 J
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BETA 3 7C-96 1e3F-07 5.??-36 2 7 E -n ?
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CO 60 4-5C-06 2 3E-77 1 0E -0 5 1,0E-06 c.2E+00 2 0L +?1 D
P FILTEF CE 1 '1 3 2E-1C 4,7E -?-
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sA 140 4.LE-93 1. F E -E t 2rtr-03 14 C E -0 4 5 9E-01 2.. t + 31 I
CS 137 2 e 6 r -0 5 c.0F-06 3..M -05 Se0F-06 1s2E+0C
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CO 69 2 7E-94 2."F-95 2e6E-94 1 0E -0 5 v 6E
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C FILTFR I 131 4 5F-03 1 9E-nc 5 1E -3 3 1 9E-14 1 1E+00 2 ecE + C1 A
T TEST F.E S U L T S :
A=AGcEFMENT D -D I S A GRE E ME t;T P=POSSI9LE AGFE E ME NT N = tt0 C OMP A R I S0r.
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ATTACHMENT 1
CRITERIA FOR COMPARING ANALYTICAL MEASURD!ENTS This attachment provides criteria for comparing results of capability tests and verificatien measurements. The criteria are based on an
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empirical relationship which combines prior experience and the accurat needs of.this p.ogram.
In these criteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated one sigma 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 should be con-sidered acceptable as the resolution decreases.
The values in the ratio criteria may be rounded to fewer significant figures to maintain statistical consistency with the number of significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a
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narrowed category of acceptance.
The acceptance category reported will be the nacrowest into which the ratio fits for the resolution being used.
RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Possible Possible Agreement Ay,reement "A" Agreeable "B"
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<3 hlo Comparison No Comparison No Cct.parison 3.0 No Comparison
>3 and <4 0.4 - 2.5 0. 3
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,>4 and <8 0.5 -
2.0 0.4
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2.5 0.3
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3.0 T8 and <16 0.6 - 1.67 0.5
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2.0 0.4
- 2.5 T16 and <51 0.75 - 1.33 0.6
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1.67 0.5
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2.0 751 and <200 0.80 - 1.25 0.75 - 1.33 0.6
-
1.67 I200 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 identifi-cation is greater than 250 kev.
Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Camma spectrometry, where principal gamma energy used for identifi-cation is less than 250 kev.
Sr.-89 and Sr-90 determinations.
Cross beta, where samples are counted on the same date using the same reference nuclide.
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