IR 05000213/1985004

Insp Rept 50-213/85-04 on 850311-15.No Noncompliance Noted. Major Areas Inspected:Chemical & Radiochemical Measurements Program,Including QC of Analytical Measurements & Audits

ML20127N889
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/10/1985
From:	Cioffi M, Jang J, Shanbaky M, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127N857	List: IR 05000213/1985004 ML20127N854
References
50-213-85-04, 50-213-85-4, NUDOCS 8507020232
Download: ML20127N889 (13)

Text

.

.

>

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-04 Docket N License N DPR-61 Priority --

Category C Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddain Neck Plant Inspection At: Haddam Neck, Connecticut Inspection Conducted: March 11-15, 1985 Inspectors: II Richard K. Struckmeyerg7 ae_ 5'/7/f5

' date Radiation Specialist, DRSS W "1"/k 7k5 Jason C. Jang 47 '/ date Radiation Specialist, DRSS W "/~//<1 ?b5 M. Jean A. Cioffi /V date Radiation Specialist, DRSS Approved by: W. . dd Mohamed M. Shanbak9, ~Ctifef 5/' /cNf

' date PWR Radiological Safety Section, DRSS Inspection Summary:

Inspection on March 11-15, 1985 (Report No. 50-213/85-04)

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 Environmental Sciences Laboratory. Areas reviewed included: program for quality control of analytical measurements; audits; performance on radiological analyses of split actual effluent samples; and effluent control records and procedure The inspection involved 96 inspector-hours on-site by three NRC regionally based inspector PDR ADOCK 05000213 G PDR

. l

.

Results: Within the areas inspected, no items of noncompliance were identifie I

= 1

. 1 DETAILS Individuals Contacted Haddam Neck Plant

• J. Beauchamp, Quality Assurance Supervisor

• G. Bouchard, Station Services Superintendent

• R. Graves, Station Superintendent T. Lantry, Chemist

• S. Matthess, Chemist P. Pritchard, Training

• Quinn, Chemistry Supervisor U.S. Nuclear Regulatory Commission

• P. Swetland, Senior Resident Inspector

• Denotes those present at the exit interview on March 15, 198 This will be reviewed in a future inspection (50-213/85-04-03). Laboratory Quality Control Program The inspector reviewed the licensee's program for quality control of analytical measurements, which is covered in the following procedures: CHDP 1.3 - Split Sample Program CHDP 1.11 - Radio Chemical Analysis Performed by Vendor Labs CHDP 1.12 - Quality Control of Counting Instrument Calibration and Operaticaal Checks The licensee stated that it is revising the program for quality assurance and quality control. Several procedures have been revised but have not yet been approve A control chart was developed and is used for the liquid scintillation counter but control charts have not been instituted for the gamma counting systems using a Ge(Li) detecto The licensee is developing control charts for the calibrations and weekly performance checks of the gamma counting systems, for each of the various counting geometries. Approval of procedures and use of control charts will be reviewed in a future in-spection (50-213/85-04-01).

The licensee participates with other utilities in a split sample program through procedure CH0P 1.3. The inspector reviewed the records of split sample analyses, and found that these records were incomplete. In ad-dition, there was insufficient documentation to show that discrepant data had been reviewed and resolved. The inspector discussed this matter with the cognizant individual and determined that the split sample program was

.

.

i

being implemented in accordance with procedure CHDP 1.3, but the records and documentation were poorly maintained. The Chemistry Supervisor stated that the record keeping and documentation for the split sample program would be improve This will be reviewed in a future inspection (50-213/85-04-02).

The inspector reviewed the licensee's program for quality control of vendor laboratory analyses of effluent samples. Procedure CHDP 1.11 states that duplicate samples, spiked samples, and blanks will be sent to a vendor laboratory "when possible." The licensee stated that such samples were not being sent to its vendor laboratory. The inspector discussed with the licensee the necessity of assuring that its vendor laboratory analyses are accurate in order to ensure that Technical Specification limits are not exceede The Chemistry Supervisor stated that procedure CHDP 1.11 would be revised to include a requirement to send quality control samples to its vendor laboratory on a definite schedul No items of noncompliance were identifie . Audits and Appraisals The inspector reviewed audits of the chemistry and radiochemistry areas for 198 Three audits were performed by the Nuclear Review Board (NRB) and the Environmental Review Board (ERB). These audits examined the accuracy of the implementation of the Technical Specification effluent limits and the adequacy of and adherence to department procedures. No open items were identified by these audit Audits performed by American Nuclear Insurers and Institute of Nuclear Power Operations were examined and found to address programmatic weakness in the areas of radiochemistry and chemistr Discussions with licensee personnel indicated that attention is given to the audit findings by li-censee management and commitments have been made to resolve identified problem No items of noncompliance were identified in this are . Sample Collection The licensee's capabilities with respect to collection of liquid and gaseous effluent samples were reviewed. This review included:

--

Observation of sample collection from the "A" waste test tank, the waste gas decay tank, the reactor coolant sampling sink, and charcoal and particulate filters from the stack monito .

.

--

Review of the following sample collection procedures:

a .~ SUR 5.4-27, Revision 5, " Test Tank Sampling and Analysis." SUR 5.4-24, Revision 7, ." Main Stack Sampling and Compositing." SUR 5.4-23-D, Revision 5, " Waste Gas Decay Tank Sampling and Analysis." NOP 2.14-11, Revision 8, " Waste Gas Decay Tank Sampling." NOP 2.11-1, Revision 3, " Sampling System - Normal Operation."

' The inspector noted that procedure NCP 2.11-1, did not specify the recir-culation .and flush times for obtaining the reactor coolant sample. The licensee stated that this had been identified in a previous audit and the new procedure was being rewritten to include this informatio Within the scope of this review, no items of noncompliance were identifie . Confirmatory Measurements During 'the inspection, liquid, particulate filter, charcoal cartridge and gas samples were split between the licensee and NRC for the purpose of intercomparison. Where possible, the split samples were actual effluent and inplant samples normally analyzed by the licensee. Sample activities were below the minimum detection limits for air particulate filters and charcoal cartridges. In these cases, NRC standard sources having similar configurations were substitute The samples were analyzed by the li-censee using normal methods and equipment, and by the NRC using the NRC:I Mobile Radiological Measurements Laboratory. Joint analyses of actual effluent samples were used to verify the licensee's capability to measure radioactivity in effluent samples with respect to Technical Specification requirements and other regulatory requirement In addition, a liquid effluent sample was sent to the NRC Reference Laboratory, Department of Energy, Radiological and Environmental Services Laboratory (RESL), for analyses requiring wet chemistry. The analyses to be performed on the samples are: Sr-89, Sr-90, gross alpha, and tritiu These results will be compared with the licensee's results when received at a later date, and will be documented in a subsequent inspection repor The licensee agreed to analyse his portion of the sample for the same nuclide The results of an effluent sample split between the licensee and NRC:I during a previous inspection on June 20-24, 1983 (Inspection Number 83-18)

were compared during this inspection and are listed in Table 1. The re-sult of tritium was in agreement under the new criteria used for comparing results (See Attachment 1). The results of gross alpha, Sr-89, and Sr-90 were not compared due to low activitie Also, a simulated airborne particulate filter and a simulated charcoal cartridge were analyzed by health physics personnel using the health physics gamma spectroscopy syste .

i l 5 The results of the gamma isotopic measurements indicated that all of the measurements were in agreement under the criteria used for comparing re-sults (see Attachment 1). The results of the comparisons are listed in Table I.

l The initial comparison of results for Chemistry's analysis of a simulated particulate filter indicated a positive bias of approximately 25% in the licensee's results. Such a bias is conservative, and would lead to an overestimate of radionuclides in airborne effluents. The chemistry labora-tory normally analyzes particulate filters by placing them in contact with the detector, in order to reduce the counting time and to meet required sensitivity. The sample was re-analyzed using a source to detector dis-tance of five inches and a longer counting time. This technique elimin-ated the positive bias, and resulted in very close agreement for the long-lived nuclides (Cs-137, Co-60) in the source. Agreement was marginal for the short lived nuclides (Ce-144, Mn-54), for which the counting statistics are not as goo An additional simulated particulate filter sample was prepared by pouring a known quantity of reactor coolant through a filter in order to deposit activity from the coolant on the filte The comparison of results for this filter indicated close agreement between the licensee and the NRC: The licensee analyzed this sample at a distance of five inches from the detector. The sample activity was sufficient to provide good counting statistics. However, it was noted that the licensee's detectors are less l sensitive than the NRC's detecto The inspector discussed with the licensee the feasibility of analyzing particulate filters using a geometry away from the detector and using a longer counting time. The licensee stated that the activity on particulate filters is normally so low that it is difficult to quantify the activity, even when the source is in contact with the detecto The inspector stated that the calibration for this geometry should be improved in order to more accurately quantify the activity on particulate filter This will be reviewed in a future inspection (50-213/85-04-04).

The initial comparison of results for Chemistry's analysis of a simulated charcoal cartridge indicated a negative bias of approximately 30%. The chemistry counting laboratory normally analyzes charcoal cartridges by placing the air inlet side of the cartridge in contact with the detecto This procedure is followed because the licensee expects all of its char-coal cartridges in effluent and process sample streams to be face loaded.

l The radionuclides of the NRC standard charcoal cartridge are distributed homogenously, and the licensee had no calibration curve for this geometr The cartridge was re-analyzed by determining the activity on each side of the cartridge, and averaging the results. This resulted in a conservative estimate of the activity, which the inspector indicated was acceptable given the fact that the licensee had not calibrated his system for this geometr . - - - _ _ , - - - . - .., . _ _ . _

- - . _. -

.

.

The initial comparison of results for Health Physics' analysis of the simulated charcoal cartridge was also negatively biased. When reanalyzed by averaging the results for each side, the licensee's results were in agreement. Like Chemistry, the Health Physics counting laboratory nor-mally analyzes charcoal cartridges, and counts only the air inlet sid No items of non-compliance were identified in this are . Effluent Monitor Calibrations The licensee's effluent monitor calibration program was reviewed against criteria contained in:

(1) Regulatory Guide 4.15, " Quality Assurance for Radiological Moni-toring Programs (Normal Operation) - Effluent Streams and the Environment".

(2) SUR 5.4-15, " Radiation Monitor System Liquid Monitor Calibration".

(3) SUR 5.4-17-D, " Radiation Monitoring System Main Stack Gas Monitor".

The licensee's performance relative to these criteria was determined by review of completed procedures and results of the calibration of monitors R-18 and R-14 In reviewing monitor calibration results, the inspector was unable to verify the lower level energy discriminator setting for the liquid effluent monitor, because the licensee did not keep records of this informatio The inspector stated that the capability of the liquid effluent monitor to read low gamma energy radionuclides was questionabl In reviewing the noble gas monitor calibration data, the inspector noted that the licensee did not perform the plateau check to obtain the operating voltage setting on the GM tube. This check is necessary to verify the operability of the noble gas monito Procedures SUR 5.4-15 and SUR 5.4-17-D state that a sealed source is to be placed on this detector, and the count rate is to be determined using the ratemete Since there were no acceptance criteria for the results, the inspector was not able to determine the adequacy of the calibratio The inspector reviewed the calibration curves for the gas and liquid monitors. The calibration curve shows the count rate on a monitor versus the radiological activity levels (cpm vs uCi/cc). The licensee uses these curves to monitor the effluent radioactivity and the alarm setting. The inspector noted that the licensee did not statistically determine the slop _ - -

.- _ _ _ . _ _

.

.

,

Based on the above findings, the inspector stated that improvements in the following areas were needed:

(1) calibration procedures must be rewritten to incorporate acceptance criteria, (2) the energy discriminator setting for liquid monitors should be documented, (3) a plateau check for the gas monitor should be performed, and (4) a statistical method should be used to draw the final calibration curv The calibration frequency for the effluent monitors is on a quarterly basi The inspector reviewed the calibration results for 1984 dat The licensee stated that the calibration procedures would be evaluated and appropriate actions would be taken. This area will be reviewed during a subsequent inspection (50-213/85-04-05). Effluent Release Permits The inspector reviewed gaseous and liquid release permits for 1984. The release permits contained the total amount of radioactive material released and the dose calculations at each release. All releases met the Technical Specification limit No items of noncompliance were identifie . Training of Chemistry Personnel The inspector reviewed Chemistry Department procedure CHDP 1.1, Revision 2, " Training of Chemistry Department Personnel", and discussed training

)

with the Chemistry Superviso The procedure specified the equipment and methods used in radiochemical and chemical analyses but lacked lesson plans and methods to provide necessary and consistent information to all chemistry department personne A Chemistry Trainer was hired by the Connecticut Yankee Training Depart-

'

ment on March 4,1985, to establish a formal chemistry training progra The licensee stated that this individual will initiate a job analysis pro-gram for the Chemistry department and develop a training program to address the licensee's immediate and long-range needs. The training program is scheduled to be in place by September,1985. This item will be reviewed in a future inspection (50-213/85-04-06).

9. Exit Interview The inspector met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on March 15, 198 The inspector summarized the purpose and scope of the inspection and the inspection finding _ _ _ _ .

_ __

. _ - _ _ _ . - . - _ _

.

.

The licensee agreed to perform the analyses listed in Paragraph 5 and report the results to the NR _ _ _

,

,

.

TABLE 1 HADOAM NECK VERIFICATION TEST RESULTS'

SAMP(( ISOTOPE NRC VALUE LICENSEE VALUC COMPARISON-RESULTS IN MICROCURIES PER MILLILITER

"A" Waste Co-60 (1.51 1 0.13)E-07 (2.1 1 0.5)E-07 Ag reement Test Tank 1335 Hrs. Cs-134 (6.0 1 0.9)E-07 (5.7 1 0.6)E-07 Ag reement 3-12-85 Cs-137 (1.4 1 0.1)E-06 (1.02 i O 07)E-06 Ag reement

"A" Waste gross a lpha (7.8 t'O.8)E-09 <6. E-08 No compa rison Test Tank H-3 (5.09 i 0.02)E-02' (5.03 1 0.50)E-02 Ag reement 1220 hrs. S r-89 (417) E-09 <3. E-08 No comparison 6-21-83 Sr-90 (7 1 4)E-09 <1. E-08 No comparison Reactor 1-131 (3.68 1 0.03)E-02 (3.71 i O.10)E-02 Ag reement Coolant I-132 (6.70 1 0.14)E-02 (7.2 1 0.4)E-02 ' Ag reement 0830 hrs. 1-133 (2.21 1 0.03)E-02 (2.3 1 0.1)E-02 Ag reement 3-13-85

"C" Waste Xe-131m (7 1 2)E-03 <4.58 E-03 No comparison Cas Decay Xe-133m (2.4 i O.4)E-03 (1.8 1 0.6)E-03 Agreement Tank Xe-133 (5.56 0.02)E-01 (6.49 i 0.02)E-01 Ag reement 1425 hr I

_ _ - - _ . _ _ _ _ - . _ - _ _ - - - _ _ . -

.

TABLE 1 HADDAM NECK VERIFICATION TEST RESULTS * *

SAMPLC ISOTOPE NRC VALUE- LICENSEE VALUE COMPARISON RESULTS IN TOTAL MfCROCURIES NRC Standard Ce-144 (3.46 i 0.02)E-02 14.3 1 0.2)E-02 Ag reement Pa rt icu la te Cs-137 (1.50 1 0.02)E-02 (1.89 i 0.04)E-02 D i sag reement*

F i l te r

1200 Mn-54 (1.47 1 0.02)E-02 (1.88 i 0.10)E-02 Di sag reement*

hrs

2-22-84 Co-60 (2.68 1 0.02)E-02 (3.2 1 0.1)E-02 Ag reement j (Analysis by i Chem i st ry)

i 1st Count i

e NRC Standa rd Ce-144 (3.46 1 0.02)E-02 (2.7 1 1.0)E-02 Ag reement*

lJ Pa rt i cula te Cs-137 (1.50 1 0.02)E-02 (1.43 1 0.09)E-02 Ag reement Filter i

'

1200 Mn-54 (1.47 1 0.02)E-02 (1.1 1 0.2)E-02 Ag reement*

hrs.

j 2/22/84 Co-60 (2.68 i 0.02)E-02 (2.7 1 0.2)E-02 Ag reement (Analysis by

,

chem i st ry)

, 2nd count

. NRC Standa rd Ce-144 (3.46 1 0.02)E-02 (3.76 i 0.18)E-02 Ag reement

!

Pa rt icu la te Cs-137 (1.50 1 0.02)E-02 (1.80 1 0.04)E-02 Ag reement Filter 1200 hrs Mn-54 (1.47 1 0.02)E-02 (1.84 1 0.07)E-02 Ag reement 2-22-84 Co-60 (2.68 1 0.02)E-02 (3.06 i 0.07)E-02 Ag reement (Analysis by ,

Health Physics)

4 NRC Standa rd Cd-109 (3.42 i q.05)E-02 Not detected No compa rison

-

Cha rcoa l Cs-137 (9.74 1 0.05)E-03 (6.7 i 0.3)E-03 Di sag reement

! Ca rt ridge Co-60 (9.84 1 0.05)E-03 (7.2 1 0.5)E-03 Di sa g reement

+

1200 hrs 5-10-83

'

(Analysis by 1 chem i st ry)

i l~st count -

intet facing

<

detector only i NRC Standa rd Cd-109 (3.42 1 0.05)E-02 (3. i 1.)E-02 Ag reement

Charcoal Cs-137 (9.74 1 0.05)E-03 (1.25 1 0.04)E-02 Ag reement*

I Ca rt ridge Co-60 (9.84 i 0.05)E-03 (1.28 1 0.06)E-02 Ag reement" i

'

1200 hr (Analysis by Chemi st ry)

2nd count -

Average or both sides

facing detector

• See Pa rag ra ph 5

,!

!

b t

'

i I I

.

.

.

TABLE 1 HADDEM NECK VERIFICATION TEST RESULTS SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON RESULTS IN TOTAL MICROCURIES NRC Standa rd Cd-109 (3.42 1 0.05)E-02 Not detected No comparison Cha rcoa l Cs-137 (9.74 1 0.05)E-03 (4.5 1 0.2)E-03 Di sag reement Ca rt ridge Co-60 (9.84 1 0.05)E-03 (4.5 i O.3)E-03 Disagreement 1200 hrs 5-10-83 (Analysis by Health Physics)

1st count -

inlet racing detector only NRC Cd-109 (3.42 0.05)E-02 (3. i 1.)E-02 Ag reement Standard Cs-137 (9.74 1 0.05)E-03 (1.25 i 0.04)E-02 Ag reement*

Ag reement*

Cha rcoa l Co-60 (9.84 1 0.05)E-03 (1.28 1 0.06)E-02 Ca rt ridge 1200 hrs 5-10-83 (Analysis by Health Physics)

2nd count - average of both sidet racing detector

• See Pa ragraph 5 RCS Filter C r-51 (9.7 1 0.2)E-01 (1.04 1 0.10)E-01 Ag reement 2130 hr Mn-54 (3.5 1 0.2)E-02 (3.7 i 0.8)E-02 Ag reement 3-13-85 Co-58 (2.10 1 0.01)E+00 (2.20 1 0.03)E+00 Ag reement (Analysis Co-60 (2.34 i 0.04)E-01 (2.4 1 0.1)E-01 Ag reemen t by chemistry Mo-99 (5. i 1.)E-02 (5.2 1 0.7)E-02 Ag reement Tc-99m (1.86 1 0.05)E-01 (1.9 1 0.2)E-01 Ag reement I-131 (4.82 1 0.04)E-01 (5.08 1 0.15)E-01 Ag reement No compa rison**

1-132 (1,52 1 0.07)E+00 Not Detected I-133 (2.03 i O.05)E-01 (1.8 i 0.2)E-01 Ag reement Cs-134 (4.6 i O.2)E-02 (6. i 1.)E-02 Ag reement Cs-137 (3.5 1 0.2)E-02 (4. i 1.)E-02 Ag reement

• • Delay between sample collection and analysis was 15) hours, or nearly seven ha lf-lives of l-13 .

.

l

.

.-

l l

ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides 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 needs of this progra In these criteria, the judgement limits are variable in relation to the com-parison of the NRC Reference Laboratory's value to its associated uncertaint As that ratio, referred to in this program as " Resolution", increases, the ac-ceptability of a licensee's measurement should be more selective. Conversely, poorer agreement must be considered acceptable as the resolution decrease Resolution = i'RC REFERENCE VALUE Ratio = LICENSEE VALUE REFERENCE VALUE UNCERTAINTY NRC REFERENCE VALUE Resolution Agreement

<3 0.4 - .5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25-

> 200 0.85 - 1.18