IR 05000010/1982015
| ML20027C445 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/30/1982 |
| From: | Januska A, Nicholson N, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20027C442 | List: |
| References | |
| 50-010-82-15, 50-10-82-15, 50-237-82-19, 50-249-82-20, NUDOCS 8210150543 | |
| Download: ML20027C445 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-10/82-15(DEP0s); 50-237/82-19(DEPOS); 50-249/82-20(DEPOS)
Docket Nos. 50-10; 50-237; 50-249 Licenses No. DPR-02; DPR-19; DPR-25 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Generating Station, Units 1, 2 and 3 Inspection At: Dresden Site, Morris, IL Inspection Conducted: August 30 through September 3 and 9, 1982 Inspectors:
. G>.Januska k I #
2-w.s.6ddw p / J A # f2s N. A. Nicholson m.,6dedw L
Approved By:
M. C. Schumacher, Chief Independent Measurements and Environmental Protection Section Inspection Summary Inspection on August 30 through September 3 and 9, 1982 (Reports No. 50-10/82-15(DEPOS); 50-237/82-19(DEPOS); 50-249/82-20(DEPOS))
Areas Inspected: Routine, announced inspection of the confirmatory measure-ments program, the quality control program for analytical measurements, and the radiological environmental monitoring program (REMP). The Region III Mobile Laboratory was onsite to analyze samples collected and split with the licensee for. comparison. The inspection involved 84 inspector-hours onsite by two NRC inspectors.
Results: No apparent items of noncompliance were identified.
8210150543 821001 PDR ADOCK 03000010 G
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DETAILS 1.
Persons Contacted
- R.
Ragan, Assistant Superintendent, Operations
- D.
Farrar, Assistant Superintendent, Administration
- J.
Eenigenburg, Assistant Superintendent, Maintenance
- E. Wilmore, QA Superintendent
- J. Brunner, Technical Staff Supervisor
- S.
Harris, Technical Staff
- G. Myrick, Rad / Chem Supervisor
- S.
Mcdonald, Lead Chemist J. Schrage, Health Physicist D. Saccomando, Health Physics Co-op R. Stobert, QA Staff
- R. Coley, Supervisor, Chemistry and Radwaste Services - Nuclear Station Division
- Attended the September 3, 1982, exit meeting.
- Participated in telephone discussion September 9, 1982.
2.
Scope Four samples were collected and analyzed for gamma isotopic activity onsite with the Region III Mobile Laboratory. Results were compared with those of the licensee. Beta analyses will be completed by RESL (Radiological Environmental Services Laboratory), NRC's reference laboratory. The quality assurance program for the counting laboratory, including sampling, chemical, and analytical procedures, was reviewed.
No significant findings impacting the program were identified. The licensee's new standardized analytical software program - The Automated Analytical Instrumentation System (AAIS) - was reviewed and its cap-abilities discussed with licensee representatives.
3.
Sample Split A Waste Sample Tank liquid, Unit 2 recombiner gas, and Unit 2/3 chimney air particulate and charcoal adsorber were collected and analyzed.
Results of comparative gamma analyses are presented in Table I; compar-ison criteria are defined in Attachment 1.
All twenty four comparisons were classified as agreements or possible agreements. The Waste Sample Tank liquid will be analyzed for tritium,
Sr,
Sr, and gross beta (to be counted September 28, 1982, at 1:00 p.m. CDT) by the licensee and RESL; results will be compared in an addendum to this report.
In the liquid sample analyzed, only the iodines were greater than 10%
of 10 CFR 20, Appendix B unrestricted values, the threshold level for comparison as defined by I&E Manual Chapter 84711B. The licensee agreed to compare isotopic concentrations less than this threshold to minimize resampling and analysis time. The licensee's 181 I value on the in plant charcoal adsorber was greater than that of the NRC. This sample was forwarded to RESL for an independent analysis. Results
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appear in Table I; the licensee was in agreement with RESL. The licensse's and NRC's calibration standards were also forwarded to RESL-for verification. No issues were identified with the gas and liquid sampics.
4.
Analytical System Sofcware
.The licensee's Automated Analyticc1 Instrumentation System (AAIS) has a " Class 2 Peaks" and " Class 3 Peaks" section for peaks described as
"... suitable for qualitative identification." During the inspection l'1 the inspectors noted that 1 on a D 2/3 chimney charcoal adsorber and 18' Xe on a D-3 recombiner gas sample were reported in the Class 3 Peak section. The respective sample activities were approximately 0.06 and 100 pCi, well within the activity levels that should be quantifiable.
No written guidance on whether to or how to report nuclides as described above had been given to the station analysts. Although the AAIS printout implies that Class 2 and 3 Peaks are not suitable for quanitification, the Dresden Lead Chemist routinely reports values for these peaks as appropriate.
It also appeared that the analysts were unable to recall stored spectra for subsequent examination.
During a telephone call to the Supervisor, Chemistry and Radwaste Services (SCRS) the inspectors expressed their concern over the potential for failing to accurately and completely report radioactive releases and the lack of guidance to station personnel which would allow this situa-tion to exist. The SCRS agreed to provide written guidance, which he stated had already been provided verbally, to CECO station personnel on the operation of the AAIS.
5.
Laboratory QA/QC The licensee's QA/QC for the counting room and chemistry laboratories was examined.
QA audits were performed by (1) onsite auditors (12-81-56),-(2) offsite auditors assisted by a consultant (II-81-12), and (3) the Institute of Nuclear Power Operations (INPO). None of the findings, observations or open items reported affected regulatory performance. All items, except one, reported by INPO, have been satisfactorily closed.
In answering the recommendations made by INPO, the licensee committed to formalize the split sampling and quality control programs patterned after INPO Good Practice documents CY701 (Quality Control Program for Chemistry Instrumentation) and CY702 (Verification of Analytical Performance).
A revi2w of the licensee's Chemistry Procedures (DCP) revealed some minor errors which were brought to the attention of the licensee. The committment to INP0 will require a review of procedures which will result in corrections as necessary.
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The licensee maintains a QC program for chemical and equipment specified
' in DCPs. Records reviewed, observations of equipment and supplies and discussions with the licensee indicate that the program is being properly implemented.
The' licensee recently moved three additional counters into the. counting-room which will require a daily QC check. -The licensee ordered an addi-tional source,-for these counters, which will be permanently mounted on a planchette to achieve a reproducible geometry.
6.
Environmental Monitoring An inspector reviewed environmental monitoring reports for CY's 1980, 1981, and the first quarter of 1982. No anomalies. attributable to plant operations were identified. The-Radiological Environmental Monitoring Program (REMP) is conducted in accordance with Technical Specifications Table 4.8-1.
Six near and far field air sampling and TLD stations were inspected.
For those stations, all air samplers were operable; TLD's were in' place.
The inspector also reviewed selected weekly sampling worksheets to verify samples were collected according to schedule and air samplers were calibrated at a consistent frequency. TVo NRC TLD's colocated with-the licensee's at Prairie Park (08) and Channahoa (14) were' inspected;-
both were in place and the collection cannisters were in fairly good condition. The inspector reviewed an October 1981 audit lof'Hazelton Environmental Services, the licensee's environmental contractor, con-ducted by the licensee's QA department to assure compliance with the vendor contract..No findings affecting the collection or analytical program were identified. The QA department has scheduled an' audit for the fourth quarter of 1982'to assure the contractor's analytical and sampling procedures are in accordance with his' manual.
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The environmental coordinator accompanied the inspector during the sample station. tour and appeared to be unfamiliar.with program details, as he acknowledged. The coordinator should arrange to accompany the' sampler contractor periodically during his rounds to increase his familiarity _with sampling locations and techniques.
7.
Exit' Interview a.
September 3, 1982 s
The inspectors met with onsite licensee representatives denoted in i
Section 1 at the conclusion of the inspection. The inspectors j
summarized the inspection scope and findings.
In' response to the
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i inspectors' comments, the' licensee agreed to analyze the liquid j
sample for tritium,
'Sr,
Sr, and gross beta activities and submit
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results to Region III for comparison.
(0 pen item 50-237/82-19-01; i
50-249/82-20-01).
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- September 9, 1982 The need for written guidance to station analysta (n the operation of the AAIS was discussed by telephone with the Supervisor, Chemistry and Radwaste Services.
He-_ agreed to provide such guidance including instructions for managment intervention to quantify Class 2 and 3 Peaks, and instructions on system spectral recall capabilities.
These' instructions will be distributed to' appropriate CECO Station personnel by November 29, 1982.
(0 pen Items 50-237/82-19-02; 50-249/82-20-02)
Attachments:
1.
Criteria for Comparing Analytical Measurements 2.
Table I, Confirmatory Measurements Program Results, 3rd Quarter 1982-
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/.TTACl!ME';T 1 CRITERIA FOR COMPARING ANALYTICAL MEASURDiENTS 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 accuracy needs of this program.
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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
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" 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 narrowest into which the ratio fits for the resolution being used.
RESOLUTION
_ RATIO = LICENSEE VALUE/NRC REFERENCE VALUE
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Possible Possible Agreement Agreement "A" Agreeable "B"
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No Comparison No Comparison No Comparison
>3 and <4 d.4 2.5 0.3
- 3.0 No Comparison
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2.5 0.3
- 3.0 T4 and <8 0.5
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2.5 2.0 0.4 T8 and <16 0.6 1.67 0.5
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2.0 1.67 0.5 T16 and <51 0.75 - 1.33 0.6
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1.33 0.6
- 1.67 T51 and <200 0.80 - 1.25 0.75
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1.33 1.25 0.75 T200 0.85 - 1.18 0.80
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"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:
Gamma spectrometry, where principal gamma energy used for identifi-cation is less than 250 kev.
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Sr,-89 and Sr-90 determinations.
Cross beta, where samples are counted on the same date using the
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same reference nuclide.
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TABLE I U S NUCLEAR REGULATORY COMMIS$IDri DFFICE DF INSPECTIDil AND ENFORCEMENT CDriFIRMATDRY MEASUREMEtiTS PROGRAM FACILITY: DRESDEff FOR THE 3 QUARTER OF 1982
NRC-------
---LICENSEE-----
---L I C EriS E E : liRC----
iAMPLE ISDTOPE RESULT ERROR RESULT ERROR RATID RES T
OFF GRE KR-85M 6.5E-03 3.6E-05 6.6E-03 0.0E-01 1.0E 00 1.8E 02 H
KR-87 2.9E-02 2.3E-04 3.2E-02 0.0E-01 1.1E 00 1.3E 02 A
KR-88 2.3E-02 1.9E-04 2.4E-02 0.0E-01 1.0E 00 1.2E 02 A
XE-133 8.2E-03 6.9E-05 8.8E-03 0.0E-01 1.1E 00 1.2E 02 A
XE-135 3.4E-02 8.9E-05 3.6E-02 0.0E-01 1.1E 00 3.8E 02 A
XE-135M 1.0E-01 3.9E-03 1.2E-01 0.0E-01 1.2E 00 2.6E 01 A
XE-138 4.0E-01 1.1E-02 4.6E-01 0.0E-01 1.1E 00 3.6E 01 A
L WASTE CR-51 2.9E-06 6.8E-07 3.6E-06 0.0E-01 1.2E 00 4.3E 00 A
Mti-54 6.3E-07 6.9E-08 5.5E-07 0.0E-01 8.7E-01 9.1E 00 A
CD-60 2.8E-06 1.0E-07 1.9E-06 0.0E-01 6.8E-01 2.8E 01 P
I-131 2.0E-06 9.0E-08 2.3E-06 U.0E-01 1.1E UU 2.2E 01 A
I-133 6.2E-06 1.3E-07 5.1E-06 0.0E-01 8.2E-01 4.8E 01 A
MD-99 3.3E-06 3.9E-07 3.1E-06 0.0E-01 9.4E-01 8.5E 00 A
TC-99M 2.9E-06 1.2E-07 4.5E-06 0.0E-01 1.5E 00 2.4E 01 P
RU-103 3.2E-07 4.9E-08 2.6E-07 0.0E-01 8.1E-01 6.5E 00 A
CS-137 7.4E-07 7.1E-08 6.8E-07 0.0E-01 9.2E-01 1.0E 01 A
P FILTER Mri-54 8.8E-05 1.3E-05 1.1E-04 0.0E-01 1.2E 00 6.8E 00 A
CD-60 1.0E-03 3.6E-05 1.1E-03 0.0E-01 1.1E 00 2.8E 01 A
I-131 5.3E-03 3.7E-05 5.9E-03 0.0E-01 1.1E 00 1.4E 02 A
RU-103 9.0E-05 1.2E-05 1.4E-04 0.0E-01 1.6E 00 7.5E 00 A
CS-137 2.0E-04 1.7E-05 1.7E-04 0.0E-01 8.5E-01 1.2E 01 A
BR-140 1.9E-02 1.4E-04 2.2E-02 0.0E-01 1.2E 00 1.4E 02 A
CE-141 1.1E-03 1.6E-05 1.2E-03 0.0E-01 1.1E 00 6.9E 01 A
C FILTER I-131 3.5E-02 1.0E-03 3.9E-02 0.0E-01 1.1E 00 3.5E 01 A
T TEGT RESULTS:
A=AGREENENT D= DISAGREEMENT P=POSSIBLE AGREEMENT ti= tid COMPAPISDri
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