IR 05000213/1980022

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IE Insp Rept 50-213/80-22 on 801117-20.Noncompliance Noted: Chlorine Indicator Solution Carried Preparation Rather than Expiration Date on Bottle.Charcoal Cartridges Counted on Only One Side
ML20003G616
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 01/29/1981
From: Bores R, Kottan J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20003G606 List:
References
50-213-80-22, NUDOCS 8104300264
Download: ML20003G616 (12)
v • d • e


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-213/80-22 Docket No. 50-213 License No. OPR-61 Priority Category c

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Licensee:

Connecticut Yankee Atomic Power Comoany P. O. Box 270 Hartford, Connecticut 06101 Facility Name:

Haddam Neck Plant Inspection it:

Haddam Neck, Connecticut Inspection conducted:

Nov er 17-20, 1980-1 Inspectors: 7. -

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d-J. J. Kottarf,~ Radiation Laboratory Specialist date signed e

date signed date signed Approved by-I' U R.J. Bogs,Chieft 2nvironmental and date signed Special Projects Section, FF&MS Branch l

Inspection Summary:

Inspection on November 17-20, 1980 (Report No. 50-213/80-22)

Areas Inspected:

Routine, unannounced inspection of the licensee's chemical and radiochemical measurements program using NRC:I Mobile Radiological Measurements Laboratory and laboratory assistance provided by DOE Radiological and Envi On-mental Services Laboratory.

Areas reviewed included:

program for quality control l

of analytical measurements; audit results; performance on radiological analyses of split actual effluent samples; and procedure review.

The inspection involved 28 inspector-hours onsite by one NRC regionally based inspector.

Results: Of the four areas inspected, three items of noncompliance were identified in three areas.

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hion I Form 12

day. April 77)

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DETAILS 1.

Persons Contacted

. Principal Licensee Employees

  • R. H. Graves, Statf or. Superintendent
  • J. Ferguson, Station Services Superintendent M. Quinn, Chemistry Supervisor

"J. Wtters, Chemist

  • denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-213/77-03-01):

Contractor laboratory gamma analysis accuracy.

Analyses performed by the licensee's contractor labora-tory remain in disagreement with the same analyses performed by the licensee.

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The inspector noted that the licensee has not been able to resolve the discrepancy between his measurements and the contractor's measurements.

The licensee was using the contractor laboratory measurements for control-ling and reporting effluent releases for air particulate filters.

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licensee, however, is now using the larger of the analytical results in his effluent reports. The measurements comparison made during this inspection indicate that using Ge(Li) system number 2, the particulate filter measure-

ments were in agreement or possible agreement, and the particulate filter measurements using Ge(Li) system number 3 were in disagreement but high by a factor of approximately 2.

(See paragraph 5.) The inspector noted the licensee has not exceeded any effluent release limits using the higher values.

A comparison of a stack particulate filter analyzed by both the licensee and his contractor yields the following:

Stack Particulate Filter (11-8-79 to 11-15-79)

Isotope Licensee Results Contractor Results Cs-134 (6.12+22%)E-13 (6.91+3.73)E-14 Cs-137 (8.98T15%)E-13 (9.3972 56)E-15 Co-60 (7.71}19%)E-13

<4E-15 Tt,e data show the licensee's values were higher than his contractor 1. oratory values.

Thus by using the higher values the licensee is conserva-ttee in relation to his effluent release limits and this item is closed.

(Closed) Infraction (50-213/78-08-01):

Lack of procedures to carry out sampling, data recording and storage, instrument calibration, and release control of effluents.

The inspector determined that the procedures to carry out the above functions were written and italemented by the licensee.

(See paragcaph 6,)

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(Closed) Deficiency (50-213/78-08-02):

Liquid effluent sample counting

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i procedures. The inspector determined that the licensee has written and implemented a procedure for counting liquid effluent samples.

(See para-graph 6.)

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(Closed) Infraction (50-213/78-08-03):

QC program implementation. The

inspector detemined during this inspection that the licensee had not adhered to all of his QC procedures. This is a recurrent item of non-

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compliance.

(See paragraph 3.)

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3.

Laboratory QC Program i

The inspector reviewed the licensee's program for the quality control of analytical measurements. The licensee's quality control program is detailed in the following procedures: CHDP 1.1 - Chemical Analysis Quality Assurance

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Procedure, CHDP 1.7 - Dupicate Sample Analysis Program CHDP 2.0 - Quality

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Control of Counting Instrument Calibration and Operational Checks, and CHDP

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2.13 - Split Sample Program. The inspector noted that procedure CHDP 1.7 i

requires that quarterly duplicate sample analyses be perfomed by the chemistry technician. A review of the QC data indicated that the quarterly

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duplicate sample analyses had not been perfomed for the first three quarters

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of 1980. Also procedure CHDP 1.1 requires a wecily standard check of each j

of the licensee's Ge(Li) counting systems with the requirement that correc.

tive action be taken when the standard analysis result differs from the expected result by 10%. The inspector noted that Ge(Li) system number 1, on which a

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standard in a 500 ml polybottle was counted weekly, had Cs-137 values which differed from the standard value by greater than 10%. This difference i

greater than 10% first ;; curred on September 5,1980. However, the inspector

noted that the licensee had failed to take the required corrective action.

The inspector stated that failure to follow procedures CHDP 1.7 and CHDP

1.1 as required by Section 5.5.1 of the Environmental Technical Specifica-

tions was an item of noncompliance. The inspector further noted that this area was identified as an item of noncompliance in a previous inspection

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report (50-213/78-08-03) and thus is a recurring item of noncompliance (50-213/80-22-01). The inspector noted that the licensee had instituted a

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computer tracking system for QC requirements in order to ensure that future

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i required analyses would be perfomed.

l The inspectcc has no further questions in this area.

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Audit Results

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The inspector detemined that the licensee's effluent radiochemistry orogram

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was examined in an Environment 31 Review Board Audit during 1980. The

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inspector also reviewed the licensee's internal responses to the items identified during the audit. The inspector had no further questions in

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this area.

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No items of noncompliance were identified.

5.

Confirmatory Measure gn M During the inspection, actual liquid and airborne effluent samples were

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split between the licensee and NRC:I for the purpose of intercomparison.

The effluent samples were analyzed by the licensee using his normal methods and equipment, and by the NRC using the NRC:I Mobile Radiological Measure-ments Laboratory. Joint analyses of actual effluent samples are used to determine the licensee's capability to measure radioactivity in effluent samples.

Simulated charcoal cartridges and a particulate filter were

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submitted to the licensee for analysis because the stack charcoal cartridge

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and particulate filter contained less than detectable concentrations of radioactivity.

In addition, a liquid effluent sample was sent to the NRC reference labora-tory, Department of Energy, Radiological and Environmental Services Labora-tory (RESL), for analyses requiring wet chemistry.

The analyses to be performed on the sample are:

Sr-89, Sr-90, tritium, and gross alpha, The results will be compared with the licensee's results when receivt.d E

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later date, and will be documented in a subsequent report.

The results of the sample measurement intercomparisons indicated that all of the measurements were in agreement or possible agreement under the

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criteria used for comparing results (see Attachment 1) with the exception of the simulated particulate filter counted on Ge(Li) system 3 and the Ba-

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133 on a simulated charcoal cartridge counted on Ge(Li) system 3.

In both disagreements, the licensee's results were higher than the NRC results and were in a conservative direction and would not have resulted in the licensee exceeding any effluent release limits.

In addition, the licensee stated l

that he will review his particulate filter and charcoal cartridge calibration for Ge(Li) system 3.

At the time of the inspection, no reason for the disagreement could be found. The results of the comparisons are listed in Table I.

The inspector noted that the licensee counted liquid effluent samples in a 1000 ml poly bottle on his Ge(Li) systems 1 and 2.

However, the licensee's procedures did not specify a counting time for the liquid effluent samples.

The licensee's Technical Specifications, Table 2.4-1, requires that each batch of liquid waste be analyzed for each significant gamma energy photopeak to an MDA of SE-7 uCi/ml.

The inspector determined that the licensee could meet this MDA if the 1000 ml polybottle was counted for 2000 sec on Ge(Li) systems 1 and 2.

A review of liquid effluent data from January to November 1980 indicated that approximately one half of the liquid effluent samples were not counted for 2000 seconds.

Typical counting times for these samples were 1000 seconds and 500 seconds.

The inspector also noted that Sb-125 in a concentration greater than SE-7 uC/ml was pr6sent in the "B" Waste Test Tank sample which was compared during this inspection, and the Sb-125 was not identifiec by the licensee.

The licensee's

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radionuclide library did contain Sb-125, however, it was not identified L*crase one of the photopeaks used for identification was attributed to anotner radionuclide.

The licensee corrected his library and the Sb-125 result was in agreement with the NRC result.

The review of the liquid effluent data indicated that 7 liquid waste test tanks released during 1980 contained Sb-125 which was not identified and reported by the licensee.

The inspector stated that both the failure to meet the Technical Specifica-tion MOA on each batch of liquid waste, and the failure to identify and report the Sb-125 as required by Table 2.4-1 of the Technical Specifications was an item of noncompliance (50-213/80-22-02).

The inspector had no further questions in this area.

6.

Procedures The following procedures were reviewed by the inspector:

CHDP 2.1 Training of Chemistry Department Primary and Secondary Sample Points CHDP 2.10 Monthly Reporting Data Collection CHDP 2.15 Radiochemical Analyses Performed by Offsite Labs to Insure Compliance with Environmental Technical Specifications

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CHDP 2.33 Handling of Low Level Samples to be Sent to an Offsite Laboratory PM 9.4-1.5 Calibration of the Germanium-Lithite (GeLi) Detector

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PM 9.4-2.3 Cl Determination by Mercuric Nitrate Method PM 9.4-3.3 Radioactive Determination of Liquid, Gaseous and Particulate Samples SUR 5.4-22 Steam Generator Weekly Compositing and Analysis SUR 5.4-24 Main Stack Sampling and Compositing SUR 5.4-27 Test Tank Sampling and Analysis In viewing the above procedures, the inspector noted that:

(1) PM 9.4-2.3 required the expiratior, date on the indicator solution used for the C1 analysis, but as of November 20, 1980 the indicator solution bottle did not contain the expiration date; (2) PM 9.4-3.3 required counting the charcoal cartridges on both sides, but in fact the charcoal cartridges counted during this inspection were counted on only one side; and (3) CHDP 2.15 requires the use of contractor laboratory data in Semi-Annual Effluent Reports, but since July 1980 the licensee has been using the highest value (see

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paragraph 1), either his or his contracting laboratory's, in the Semi-Annual Effluent Reports.

The inspector stated that failure to follow the above procedures as required by Se: tion 5.5.1 of the Environmental Technical Specifications is an iten of noncompliance (50-213/80-22-03).

7.

Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on November 20, 1980.

The inspector summarized the purpose and scope of the inspection and the inspection findings.

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

The licensee stated that he would calculate the Sb-125 concentrations in the seven test tank releases in which Sb-125 was not reported and include these values in his effluent totals.

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TABLE 1

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CONNECTICUT YANKEE - VERIFICATION TEST RESULTS

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SAMPLE IS0 TOPE NRC VALUE LICENSEE VALUE COMPARISON

l RESULTS IN MICR0 CURIES PER MILLILITER Waste Gas Kr-85 (5.210.8)E-3 (6.2713%)E-3 Agreement

Decay Tank 0920 Hrs.

11-19-80 s

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"B" Waste Sb-125 (5.1+0.5)E-6

  • (4.61+23%)E-6 Agreement Test Tank Cs-134 (1.3E+0.03)E-5 (1.32T4.7%)E-5 Agreement 1030 it;s.

Cs-137 (2.20T_0.04 )E-5 (2.2713%)E-5 Agreement

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  • Calculated by licensee after modification of his radionuclide library.

Not reported initially.

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TABLE 1

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i CONNECTICUT YANKEE - VERIFICATION TEST RESULTS SAMPLE IS0 TOPE NRC VALUE

_ LICENSEE VALUE COMPARISON

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RESULTS IN MICR0 CURIES PER MILLILITER

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Reactor Coolant I-131 (1.5310.05)E-2 (1.50110%)E-2 Agreement 1135 Hrs.

11-18-80 I-133 (1.4910.01)E-1 (1.4012%)E-1 Agreement j

I-135 (2.10+0.04)E-1 (1.8914.5%)E-1 Agreement I-132 (5.8410.04)E-1 (6.4711.65%)E-1 Agreement

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Cr-51 (3.010.3)E-2 (3.65130%)E-2 Agreement Mn-54 (8.710,5)E-3 (8.85114%)E-3 Agreement Co-58 (3.3010.07)E-2 (3.2115.2%)E-2 Agreement Co-60 (4.413.4)E-3 (4.31125%)E-3 Agreement N -239 (2,010.2)E-2 (1.65119%)E-2 Agreement p

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TABLE 1

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CONNECTICUT YANKEE - VERIFICATION TEST RESULTS

_ SAMPLE ISOTCPE NRC VALUE LICENSEE VALUE COMPARIS0N

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RESJLTS IN MICR0 CURIES

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i Simulated Co-57 (6.310.2)E-4 Not Reported

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Particulate Filter Cs-134 (1.40+0.05)E-3 (2.93+12%)E-3 Disagreement i

3-8-79 Cs-137 (4.06TO.12)E-3 (9.00T4%)E-3 Disagreement (Comparison made Co-60 (2.13 0.06)E-3 (4.44_T9%)E-3 Disagreenent

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using licensee's Ge(Li) System #3)

t Simulated Co-57 (6.310.2)E-4 (8.32134%)E-4 Agreemnt Particulate Filter Cs-134 (1.40+0.05)E-3 (2.12+7%)E-3 Possible Agreement 3-8-79 Cs-137 (4.06T0.12 )E-3 (6.12T3%)E-3 Possible Agreement (Comparison made Co-60 (2.13[0.06)E-3 (3.2916%)E-3 Possible Agrennent using licensee's Ge(Li). System #2)

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i TABLE 1 CONNECTICUT YANKEE - VERIFICATION TEST RESULTS i

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l SAMPLE IS0 TOPE NRC VALUE LICENSEE Vf40E COMPAR_ISON RESULTS Ili F.ICR0 CURIES i'

Spiked Charcoal Ba-133 (1.73+0.05)E-1 (2.18+0.46%)E-1 Agreement Cartridge H Cs-137 (3.74TO.11)E-2 (4.71T1.2%)E-2 Agreement i

3-1-79 Co-60 (2.09T0.07)E-2 (2.62T2.4%)E-2 Agreement (Comparison made Cs-134 (1.32[0.04)E-2 (1.62T3%)E-2 Agreement using licensee's

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Ge(Li) System #2)

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l Spiked Charcoal Ba-133 (1.73+0.05)E-1 (1.60+.63%)E-1 Agreement Cartridge H Cs-137 3.74TO.11)E-2 3.62T2%)E-2 Agreement 3-1-79 Co-60 2.09TO.07)E-2 2.24T3.3%)E-2 Agreement (Comparison made Cs-134 1.32[0.04)E-2 1.20[5%)E-2 Agr.enment using licensee's Ge(Li) System #1)

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TABLE 1

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CONNECTICUT YANKEE - VERIFICATION TEST RESULTS

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,NRC VALUE LICENSEE VALUE COMPARISON RESULTS IN MICR0 CURIES

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Spiked Charcoal Ba-133 (5.03+0.13)E-2 (1.12+1%)E-1 Disagreement i

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Cartridge F Co-57 (2.4+0.1)E-3 (3.72+30%)E-3 Possible Agreement 3-1-79 Cs-134 (8.6TO.3)E-3 (1.18TS%)E-2 Possible Agreement (Comparison made Co-60 (1.36+0.05)E-2 (1.71T4%)E-2 Possible Agreement using licensee's Co-137 (2.48TO.08)E-2

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Ge(Li) System #3)

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(3.46T2%)E-2 Possible Agreement

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Spiked Charcoal Ba-133 (5. 03+0.'13 )E-2 (7.96+0.78%)E-2 Possible Agreement Cartridge F Co-57 (2.4+0.1)E-3 (2.90T26%)E-3 Agreement 3-1-79 Cs-134 (8.6T0.3)E-3 (9.12T4.4%)E-3 Agreement (Comparison made Co-60 (1.3H+0.05)E-2 (1.56T3%)E-2 Agreement using 1icensee's Cs-137 (2.48T0.08)E-2 (2. 72T1.6%)E-2 Ge(Li) System #2)

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I Attachment 1 Criteria for Comparing Analytical Measurements This attachment provid'

criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical 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 relation to the

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

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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 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 identification is greater than 250 Kev.

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Tritium analyses of liquid samples.

Iodine on absorbers

"B" criteria are applied to the following analyses:

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

895r and 90Sr Determinations.

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

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