IR 05000213/1988013

Insp Rept 50-213/88-13 on 880822-26.No Violations Noted. Major Areas Inspected:Radiochemical Measurements Program, Including Confirmatory Measurements,Program for Qa/Qc of Radiological Measurements & Mgt Controls

ML20207K934
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/06/1988
From:	Joseph Furia, Kirkwood A, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207K921	List: IR 05000213/1988013 ML20207K918
References
50-213-88-13, NUDOCS 8810170085
Download: ML20207K934 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 88-13

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Docket N License No. DPR-61 Priority -

Category _B_

Licensee: Connecticut Yankee Atomic Power Company PT O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddam Neck Plant Inspection At: Hadda b Connecticut Inspection Conductec a st 22-26, 1988 i

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Inspectors: .

A. Kirk' wood, Radiction Specialist

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. Fv71a, Radiation Specialist

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Approved by: k y t Jo ? ,SS W. J.(FJasciak, Chief Effluents da w

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Radiad on Protection Section

Ingection Summary: Inspection on August 22-26, 1933 (Inspection Report q ho. 50-21F8FF3)

Areas Inspected: Routine, unannounced inspection of the licensee's radio-chemical measurements prog am using the NRC:I Mobile Radiological Measurements Laboratory and laboratory assistance provided by DOE's Radiological and Environ-eental Sciences Laborato y. Areas reviewed included: confirmatory measure-

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' ments; program for the cuality assurance / quality control of radiological measurements, including procedures, records and sampling; management controls, including audits and resporise to NRC initiative Results: No violations were identified, khdol g85881006 Q M 05000213 PNU

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DETAILS 1.0 Individuals Contacted 1.1 Principal Licensee Employees

• E. OeBarba, Station Services Superintendent

• Bouchard, Unit Superintendent

• Quinn, Chemistry Supervisor i *H. Clow, Health Physics Supervisor

• G. Concarous, Chemist l *L. Silvia, Health physicist

• P. Heffernan, Assistant Chemistry Supervisor 1.2 Northeast Utilities Service Company Employn s

• Heinig, Quality Services Specialist l

• Hornyak, Quality Services Technologist  !

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] 2.0 Confirmatory Measurements L

j 2.1 Split Sample Results During this part of the inspection, liquid, particulate filter, charcoal cartridge, and gas samples were split between the licensee

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j and NRC for the purpose of intercomparison. Where possible, the -

i split samples arc actual effluert samples or implant samples which

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duplicated countir.; neometries used by the licensee for effluent ,

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i sample analyses. In addition, spiked charcoal cartridge standards

were submitted to the licensee for analysis because racioiodine was j not present on any effluent charcoal cartridge samples. The samples I and standards were analyzed by the licensee using normal methods and j equipment, and by the NRC:1 Mobile Radiological Measurements Labora-j tory. Joint analyses of actual effluent samples are used to verify l

) the licensee's capability to measure radioactivity in effluent L i samples with respect to Technic 01 Specifications and other regulatory j requirements.

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) In addition, a liquid effluent sample was sent to the NRC reference i laborat ory, Department of Energy, Radiological and Environmental Sciences Laboratory (RESL), for analyses requiring wet chemistr !

The analyses to be performed on the sample are Sr-89, Sr-90, Fe-55, gross alpha, and tritiu The results will be compared with the

, licensee's re:ults when received at a later date and will be

documented in a subsequent inspection report. The results of an !

effluent sample split between the licensee and NRC:I, during a

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. previous inspection on March 11-15,1985, (Inspection Report ,

l No. 50-213/85-04) were compared during this inspectio !

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The results of the sample measurements comparison indicated that all of the measurements were in agreement under the criteria used for comparing results, (See Attachment 1.) with one exception. The results of the comparisons are listed in Table The one exception occurred during the March, 1985, sample split for the Sr-90 analysi Licensee results were approximately two and a half times higher than NRC results. Since this is more conservative, no Technical Specifi-cation or regulatory requirements would have been underestimated. In addition, Sr-90 intercomparison results since that time have been in agreement during routine quality control checks with other lab Both Radiation Protection (RP) and Chemistry use gamma spectrometry system The RP system is used to anelyze airborne and swipe samples principall During the comparisons of the NRC spiked charcoal cartridge with uniformly distributed activity, both RP and Chemistry gamma results were 30 to 40% lower than NRC. The licensee stated that they do not calibrate their systems for this situation since normal air sampling flow rates of 1 to 2 cfm are used, and under this condition a charcoal cartridge would be face loaded with a collection efficiency close to 100%. The inspector discussed the use of air samplers under other than normal use with both RP and chemistry personnel. At flow rates greater than 2 cfm, such as under emergency sampling conditions, when results are needed rapidly, cartridge loading becomes more uniform and collection efficiencies signifi-cantly decrease. Thus the combined losses due to calibration for face loaded activity rather than uniformly distributed activity and losses of measurement accuracy attributable to decreases in charcoal cartridge collection efficiency can result in underestimation of airborne radioactivity concentrations. During the inspection both RP anc Chemistry reca'ibrated for this geometry, and subsequent measure-ments were in agreement with the NRC, uniformly distributed, spiked charcoal cartridge. The need to routinely calibrate for this geometry and use variable collection efficiencies dependent on flow rates will be investigated jointly by RP and Chemistry, as discusse The results of this investigation will be reviewed during a subse-quent inspectio ;

2.2 Laboratory QA/QC The licensee's laboratory QA/QC program is described in procedures designated by CHDP (Chemistry Department Procedures). Calibration procedures are designated by PMP (Preventive Maintenance Procedurts).

The inspector reviewed the following licensee procedures with respect to radiochemical measurements-l

• CHDP 1.2, Rev. 5, Duplicate Sample Analysis Program CHDP 1.3, Rev. 13, Split Sample Program l

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• CHDP 1.11, Rev. 6 Radiochemical Analysis Performed by Vendor Laboratorie 'CHDP 1.12, Rev. 11, Quality Control of Counting Instrument Calibration and Operational Checks

• CHDP 1.20, Rev. 3. Preparation and use of Control Standards and Standard Check Performance

'CHDP 1.40, Rev. 3, Quality Assurance Control Charts

'CHDP 3.31, Original, Startup and Calibration of the Computer Based Gamma Spectroscopy System

• PMP 9.4-1.5, Rev. 8 Calibration of the Germanium-Lithium Detector

• PMP 9.4-1.6, Rev. 3, Operation and Calibration of Beckman LS1800 Scintillation Counter The review was performed with respect to criteria contained in the following:

• Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring programs (Norr.;al Operations) - Effluent Streams and the Environment"

• ANSI N42.15-1930, Performance Verification of Liquid-Scintillation Counting Systems

• ANSI N42.14-1978, Calibration and Usage of Germanium Detectors for Measurement of Gamma-Ray Emission of Radionuclide ' Principles of Quality Assurance of Chemical Measurements (National

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Bureau of Standards) NBSIR S5-3105 Within the areas reviewed the following observations and concerns were note The use of blanks, especially with the liquid scintil-lation samples, inikes and duplicates at specified frequencies are an essential part of a radiological measurement quality assurance l program. The inspector suggested that the licensee consider the use i of blanks. CHDP 1.12, Rev. 11. Q.C. of Counting Instrument Calibra-tion, does not specify the frequency or scope of supervisory review of quality control data. Consideration should be given to specify a l review frequenc CHDP 3.31, Calibration of the Computer Based Gamma

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Spectroscopy System does not detail a method of efficiency calibra-tion (this system has been in operation less than one year).

Efficiency calibration methodology should be incorporated in the

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procedure. PMP 9.4-1.5, Calibration of the Geli Detector, does not

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specify a minimum number of counts for each full energy peak such as recommended by ANSI N42.14-1978. PMP 9.4-1.6, Calibration of LS1800 ,

Liquid Scintillation Counter, does not specify a minimum number of '

counts for determination of counting efficiency as recommended by ANSI N42.15-1980. Minimum number of counts should be established for '

instrument calibratio Improvements to Chemistry Department Procedures and QA program will be reviewed on a subsequent inspectio Various records related to laboratory QA/QC were also reviewed with respect to the previously mentioned criteria. The following records were reviewed:

' Background and ef ficiency p'ots for the LS1800, liquid scintillation counter dated August 1-23, 198 'Interlab split samples and vendor crosschecks for 1985, 1986, 1987 and first quarter 1988. Also results from the October 1986 ECNE/NSC Chemistry Subcommittee crosscheck dated April 20, 198 Control charts are well maintained and have tighter statit.tical limits than industry standard practic The inspector r,ad several l observations related to documentation of quality controt activitie Disagreements on interlaboratory splits indicated follow'ap would occur in the subsequent quarter. Comments suggested a possible cause, but no further documentation indicating continued follow-up, prior to the next quarter, was include Furthermore, results from the next quarter, though acceptable, were not noted as resolving the prior quarters disagreemen Consideration should be given to clarifying the resolution of problem The inspector also noted that the Split Sample Radiochemical Analysis result record sheets do not

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typically show the error associated with the stancard used for I

comparison analysis. This precludes verification of acceptance criteria and thus inhibits thorough review of data. Another concern the inspector had was that the frequency of supervisory review of 1 measurement data and the documentation of data review was not outlined in the QC program. Actions on QC program disagreements and data review will be reviewed during a subsequent inspectio The inspector observed the performance of the routine gamma spectro-scopy and liquid scintillation counter daily performance checks, done l on August 23, 1938, during the offshift. The inspector also observed the sampling of a liquid effluent sample for split analysis between the NRC Mobile Laboratory, the licensee, and the NRC reference Lab

,(RESL). Tne of f shif t chemistry technician accomplished the daily

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instrument performance checks in a minimal amount of time, recorded results accurately and was knowledgeable of the purpose of the check I

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and of actions to take should a disagreement occur. Sampling of the liquid ef fluent was accomplished with consideration of flush time, plateout, volume and contamination contro No violations were found in the above area .0 Management C_ontrols 3.1 Sta t fi ngdupe rvi sion Staf fing is adequate for the needs of the chemistry pro 9 ram. One s contract employee supplements the normal staff. The Chemistry Supervisor, who reports directly to the Station Services Superinten-dent, who in turn is responsible to the Station Superintendent, is assisted by two chemists and one first line supeavise The first line supervisor is directly responsible for seven technician .2 Facilities /Eqaipment Chemistry has acquired a state-of-the-art gamma spectroscopy system within the past yea Also a majority of its detectors have been replaced with high efficiency intrinsic germanium. Separate facilities have been provided for low activity / low background samples. A temperature control problem in the lab his kept an older, GeLi system inoperabl .3 Audits Two audits were reviewed by the inspector:

. Audit A25002, "REMODCM" (Radiation Ef fluent Monitoring),

conducted by NUSCO (Northeast Utilities) from May 5 through June 17, 195 ,

• Audit No. A25019, "REMODCM," by NUSCO from December 21, 1987 through January 23, 198 The inspector noted that two items previously addressed in 1 A25002 were still found to be unresolved in the subsequent j Audit, A25019. Finding F02 appears to have mistakenly been s routed to a supervisor not having responsibility for corrective action. The second item, VOI-6, (Unresolved Open Item) was ;

i given a Project Assignment that was later canceled. The licensee needs to address the shortcomings of their management control system that did not alert responsible managers to audit findings that were not progressing in a timely manne I

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3.4 Response to NRC Initiatives The inspector reviewed licensee response to previous NRC assessment '

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and inspection concerns. It was noted that during Inspection N /85-04, March 11-15, 1935, split sample records were found to '

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l have insufficient documenta ion to show that discrepant data had been

reviewed and resolv.)d. Thi same omission has been observed during ,

j the current inspection, as taentioned in Section Also during j 1 inspection 50-213/85-04, it was noted that procedure NO P2.11-1, did

not specify flush times. This has now been addressed in Revision 6

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of this procedure. Noted in Inspection No. 50-213/87-17, July 27-31, i 1987, was the introduction of a fornal chemistry requalification

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i program expected in 1988. This also has been accomplished. A review of the current requalification. schedule (Sept SS) appears to address I topics necesssry for maintaining technical competence. Mentioned in '

the SALP of March 1, 1956 through March 31, 1937 was the need to

! perform functions manually because of lagging software development.

l The inspector was shewn computerized gas set point calculations (SUR i 5.4-30, Rev 8) dated February 13, 1987, which was the item which l initiated the SALP commen It was also noted that computerized ODCM i calculations are done quarterly.

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No violations were found.

4l 4.0 Exit Interview i The inspector met with the licensee representatives (denoted in Section i

) 1.0 by *) a+ the conclusion of the inspection on August 26, 1938 and ,

Summarized the scept and findings of the inspection. One Inspector !

] follow-up Item (50-213/88-13-01) will be used to review two subitems in a j subsequent inspectio The items are ,

1 t j An evaluation of the significance of charcoal cartridge usage with .

respect to activity distributions and collection efficiency [

corrections relative to gamma isotopic analyse !

3 Quality Assurance Program improvements related to instruments and i

improvements to those aspects of the Chemistry Quality Control !

l Program, related to corrective actions on interlab and intralab !

measurement sample comparisons, that result in disagreement l l

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ATTACHMENT 1 CRITERIA FOR CCMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurement 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 comparison of the NRC Reference Laboratory's value to its associeted uncertainty. As that ratio, referred to in this program as "Resolution",

increases the acceptability of a licensee's measurement should be more selectiv Conversely, poorer agreement must be considered acceptable as the resolution decrease Resolution 1 Ratio For Agreement:

<3 No comparison 4-7 0.5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25

>200 0.85 - 1.18 Resolution = (NRC Reference Value/ Reference Value Uncertainty)

2 Ratio = (License Value/NRC Reference Value)

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TABLE 1

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HADOAM NECM VERIflCATIOM TEST RESULTS .

SAMPLE ISOTOPE RESULTS IM MICROCURIES/MILLtLITER COMPARISO4 NRC VALUE LICENSEE VALUE Rad Waste Li Mn-54 (6.8810.08)[-05 (7.3910.12)E-05 Agreement Dete: 8/23/88 Time: 13:45:00 00-58 (3.6910.06)[-05 (4.0910.07)[-05 Ag reement 1000 ml Co-60 (7.6510.08)E-05 (8.1610.06)E-05 Ag raement 1-131 (7.5010.50)E-06 (8.09fo.29]E-06 Ag reement Cs-134 (1.21510.OO9)E-04 (1.2910.02)E-04 Agreement Cs-137 (2.51610.013)[-04 (2.7910.05]E-04 Ag reement l

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Waste Gas Kr-85m (2.9610.51)E-04 (3.6210.32)f-04 Agreement t tank Dote: 8/24/88 Kr-85 (4.220.3)E-02 (3.2110.53)E-02 Ag reement Time: 10:00:03 33cc xe-133m (6.8310.19)E-03 (6.7410.4310-03 Ag reement Xe-133 (7.79010.007)E-01 (8.5010.53)E-01 Agreement Xe-135 (i.11610.006)E-02 (1.0410.04)E-02 Agreement l

Recctor Coolant 8-131 (2.5010.05)E-02 (2.1910.13)E-02 Ag reement Date: 8/23/88 Time: 08:26:00 3-132 (8.3310.04)E-02 (7.6010.33]E-02 Ag reement I tal l (diluted to 50m1) 6-133 (9.8410.10)[-02 (9.1310.40)E-02 Ag reement 8-135 (1.3610.05)E-01 (1.1210.02)E-01 Agreement Cs-137 (2.3910.33)E-03 (2.1310.15)E-03 Agreement l

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HADDAM NECA VERiflCATf04 TEST RESULTS .

SAMPLC I SOT OPE PESULT5 tN TOTAL MfCROCUR1ES COMPARf50'4 WRC VALUE LfCENSEE VALUE

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Cha rcoa 8 Ca rtrid9 e 00-57 (1.7010.16)E-03 (1.0310.03)E-03 Agreement Date: e/23/88 Time: 12:00:00 Co-60 (6.7910.10)E-02 (4.5720.03)[-02 Di sag reement*

Chemistry Lab

1. 17636-145 Cd-109 (3.6510.06)E-01 (2.20to.09)E-01 D i sag reement*

(Uniform)

Cs-137 (9.06t0.09)[-02 (6.1520.12)E-02 Di sag reemen t*

CharcosI Co-57 (1.5610.12)E-03 (9.3610.31)E-04 Agreement Ca rt ridge Date: 8/23/88 Co-60 (6.6110.10)E-02 !4.3610.03)[-02 Di sag reement*

Time: 12:00:00

1. 17636-145 Cd-109 (3.5610.06)E-01 (2.26to.03)E-Of Di sag reement*

Uniform HP Lab Cs-137 (8.9120.10)[-02 (5.5910.03)E-02 Disagreement *

RESULTS IN MfCROCURfES/ MILL 8LfTER Particulate Co-58 (3.2210.23]E-05 (4.18to.22)E-05 Agreement Date: 8/23/88 Teme: 09:30:00 Co-60 (2.0610.21)E-05 (2.0210.13)E-05 Ag reement Chemistry Lab t-131 (1.6410.03)C-04 (1.8810.08)E-04 Agreement 1-133 (3.2820.20)E-05 ( 3.8010.18 ) E-05 Agreement Particulate 1-131 (1.6410.03)E-04 (1.6910.04)[-04 Agreement Date: 8/23/88 Time: 09:30:00 I-31 ( 3.28 tO.20 )E-05 (2.9810.17)E-05 Agreement HT Lab

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MADOAM NECM VERfFICATIOM TEST RESULTS

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$ AMPLE 150TOPf PESULTS IN TOTAL MICf(0 CURIES COMPARISOM NRC VALUE LfCENSEE VALUE

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Cha rcoa l Ca rt ridge Co-57 (1.5620.12)[-03 (1.44to.11]E-03 Ag reement Octe: 8/23/88 Time: 12:00:00 Co-60 (6.6110.10)E-02 (6.8310.11)E-02 Ag reement Ctemistry Lab *

1. 17636-145 Cd-109 (3.5620.06)C-01 (3.0410.13)E-01 Ag reement (Unirorm)

Cs-137 (8.9110.10)[-02 (8.5120.24]E-02 Ag reement Cha rcoa l Co-57 (1.7820.19)[-03 (1.3610.04)E-03 Agreement CottriCge Date: 8/23/88 Co-60 ;6.4910.13)[-02 (5.9210.04)E-02 Agreement Time: 09:30:00

1. 17637-145 Cd-109 (3.5610.07)[-01 (2.9520.12)E-01 Ag reement (face)

Cronistry Lab Cs-137 (8.85to.12]E-02 (8.10to.16]E-02 Agreement Cha rcom I Ca rt ridge Co-57 (1.5610.12)E-03 (1.27t0.25)E-03 Ag reement Date: 8/23/88 Time: 12:00:00 Co-60 (6.6120.10]E-02 (6.43t0.16)E-02 Ag reement Hf' L ab'

1. 17636-145 Cd-109 (3.5620.06)E-01 (3.1710.16)E-02 Agreement (Uniform)

Cs-137 (8.9120.10)f-02 (8.5710.18)E-02 Ag reement Cha rcoa l Co-57 (1.78tO.19)E-03 (1.3310.05)E-03 Agreement Ca rt ridge Date: 8/23/88 C0-60 (6.4910.13)E-02 (5.7010.05)[-02 Ag reement Time: 09:30:00

1. 17637-145 Cd-109 (3.5620.07)[-01 (3.1520.05)E-01 Agreement (Toce)

HP Lab Cs-137 (8.8510.12)E-02 ( 7. 7610.05 ) E-02 Ag reement ,

oaf ter Reca t ibration for Uniform Geometry

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HADDAM NICK VERaf1 CATION TEST RESULTS SAMPLE ISOTOPE PESULTS IN MICP.0 CURIES /MILLittT[R COMPARISON hRC VALUE LICENSEE VALUE Haddam Me9k Liquid Rad. Waste H-1 (4.9710.07)[-2 (5.1327)[-2 Ag reement Date: 3/12/85 Time: 13:35:00 Gross Alpha (3.410.5)E-9 (4.527)E-10 Ag reement SR-90 (2.220.5)E-8 (5.8817)E-8 Disagreement *

Cont racto r H-3 (4.9710.07)E-2 (5.127)E-2 Ag reement l Cross Alpha (3.420.530-9 (<7t?)E-8 No comparison l

Sr-90 (2.210.5)E-8 (<217)[-8 No Compa ri son l

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