IR 05000219/1987026

Insp Rept 50-219/87-26 on 870824-28.No Violations or Deviations Noted.Major Areas Inspected:Radiochemical Measurements Program & Radiological Environ Monitoring Program,Including Mgt & Program Organization

ML20236B975
Person / Time
Site:	Oyster Creek
Issue date:	10/05/1987
From:	Jang J, Pasciak W, Stuckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236B972	List: IR 05000219/1987026 ML20236B970
References
50-219-87-26, NUDOCS 8710260442
Download: ML20236B975 (15)

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U. S. NUCLEAR REGULATORY. COMMISSIONS.' '

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License N DPR-11 Priority --- <

Category C

, Licensee: GPU Nuclear Corporation- '

P. O. Box 388 <

Forked River, New 7ersey 08731 ',

b Facility Name: OysterCreekNuclearGeneratingStatfpg, ,

Inspection At: Forked River, New-Jersey d' .}' [ /

Inspection Conducted: August _24-28_,11987

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Inspection Summary: Inspection on August 24-28, 1987 (Inspection Report N /87-26)

Areas Inspected: Routine, unannounced inspection.of the licensee's radiochemical measurements program and radiological environmental monitoring- '

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program. The NRC Region I Mobile Radiological Measurements Laboratory was l used, and laboratory assistancp was provided by the D0E's' Radiological'and .,

Environmental Sciences Laboratory. ; Areas reviewed included management and V organization of each program, radioactive sample confirmatory measurements, \

laboratory QC, implementation of' ttie REMP, environmental .dosimety),

meteorological monitoring, and audrt / g e

k j Results: No violations or deviitions were identifie (/

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1.0 Individuals Con _tacted_ ..

• D. Cafaro Manger, Environmental' Controls i B,, Durham, Environmental Scientist j 7 S. Molello, Radiological Programs Manager

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/y'!?.', Schwartz,EnvironmentalScientist

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,X. Washburn, Environmental Scientist d; 'D. Weigle, Environmental Engineer

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• S. Fuller, Manager, Operations QA .

• P. Fiedler, V.P. & Director of Oyster Creek

• R. Hillman, Chemist-

>4 * D. Moore, Environmental Licensing Engineer

• J. Roger, Nuclear Licensing Engineer K. Wolfe, Radiological Engineering Manager >

)( *DenotesthosepresentattheexitinterviewonAuguAt 29, 198 o j ,

'7 The inspector also contacted other licensee personnel during the inspections 2.0 Radiologirjil_ Environmental Monitoring Program

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2.,1 Management Controls ,

p The inspector reviewed the licensee's. management controls for-the f

radiological environmental monitoring program, including assignment of responsibility and program audit j

, s I, Assignment of Responsibility The inspector determined that management of the radiological .

environmental monitoring program (REMP) remains essentially the H same as it was at the time of the last inspection in this are H I '

The Manager of Environmental Controls at the Oyster Creek Site reports to the GPUNC Director of Safety and Environmental Control. This individual reports'to the GPUNC Vice President of the Radiological and Environmental Control Divisio Audits The inspector reviewed the following audit reports for the

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Radiological Environmental' Mcnitoring Program (REMP) performed 7d i by the Oyster Creek Site Avdtt Group,' and audits of the 4~ . >'g contractor laboratory performed by; licensee:

ui t A 4( S-0C-85-07, REMP, May 23, 1985 - August 6, 1985 S-0C-85-19, REMP, November 6 6, 1985 - January 31, 1986

.S-0C-86-06, REMP, May 20,' 1986 - July 15, 1986 S-0C-86-07, REMP 3 May 27,1986. -, August 7, 1986-a L 1 st y

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J S-0C-87-05,REMP,May18,$987-Jane 26,1987 0-COM-84-06, Teledyna isotopes, March 1-2, 1984 '

0-COM-85-07, Teledyne isotopes, November 6-7, 1985 9420-86~0167, Teledyne isotopes, March 27, 1986 0-CDS87-01, Teledyne Isotopes, February 2f-27,1987 .

The inspector noted that the above referenced audits were very i thorough, and audit-identified deficiency followups were excellen The audits were performed by a VJalified lead auditor,2nd appeared to be quite thorough and of sufficient technical #epth to adequately 1 assess the contractors' capabilities and performanc p i

The inspector noted that the GPU Environmental Radioactivity . /

Laboratory (Commerce Park, PA) will assume the responsibili'.y to'

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analyze all environmental samples in the future. The licensee

< audited the laboratory to assess the adequacy of programs in complying with the guidelir.es established in Regulatory Gt.1de 4.1 The inspector reviewed this audit report: GPUNC QA Audit N f-87-03,EnvironmentalRadioactivityLaboratory, i April 6-8, 1987. The inspector noted this audit was very thorough and of sufficient techrical depth to adequately assess capabilities and performance of the Laborator .2 LicenseeProgramforQualityControlofAnalyticalMbasurements

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The licensee described the QC programs conducted by 'its contractors ,

Teledyne Isotopes. Teledyne Isotopes participates in the EPA QC crosscheck progra d The inspector ( diewed selected samples of quality control data submitted to 8.G licensee by its contractor.- These data indicated, withfrgexceptions'.,agreementbetweenEPAspikesamplesandthe cor: tractors' results. . Where discrepancies were fouad, reasons for

' the differences were investigated and satisfactory *1y resolve "

The inspector reviewed quality control data of scurce check and background for gamma spectrometry, liquid scintillation counter, and proportional counter ir;Miing ' control charts submitted to the licensee by Teledyne Isdebes, Teledyne Isotopes submits quality cont 701 data to the licen'see edery two month <

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Theinspactorreviewedthelicensee'sQAProcedure;941d40M-4500.07, kof fologice; Environmental Monitoring Prograrn;-Quality ,

Assuranc Th;; crocedure.will be in effect in the nbar futur j Tiis procedure cChien 3 not only the acceptance cri,tiWla f6r comparison but illso the corrective actions to iduntify y d solve possible causes d problem q The in6pector had no fcether questions in this area 4t this tirq ,

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2.3 Implementation of the REMP

The inspector examined selected environmental monitoring stations including air samplers for iodines and particulate, and TLDs for direct radiation measurement. All equipment at these stations was operational at the time of the inspection. The inspector reviewed calibration of the air samplers and vacuum gauges, and found that these calibrations were performed as require The inspector reviewed Semiannual Effluent Release Reports for 1984 ,

and 1985. The licensee had new radiological environmental '

) surveillance requirements as of November 21,1986(Amendment 108).

The licensee, therefore, is now required to submit an annual report rather than semiannual-reports for the REMP. The' inspector reviewed the annual report for-1986 regarding sample media, sampling i I

frequencies, sampling stations and analytical results. The inspector noted that these report.s cover a greater number and variety of environmental samples than is required by the Technical Specification. There were no anomalous analytical results in these report /

2.4 Environmental Dosimetry The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitoring Network is operated by the NRC (Region I) to provide continuous measurements of the ambient radiation levels around nuclear power plants (71 sites) throughout the United States. Each site is monitored by arranging approximately 30 to 50 i thermoluminescent dosimeter (TLD) stations in two concentric rings ]

extending to about five miles from the power plant. The monitoring j results are published in NUREG-0837 quarterl j

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One of the purposes of this program is to serve as a basis of I comparison with similar programs conducted by individual utilities which operate nuclear power plants. Therefore, four NRC TLDs are collocated with each licensee's TLD station The licensee monitors the environmental radiation levels monthly and quarterly (2 TLDs each station) using a Teledyne TLD System (CaS0 :

. Dy). The inspector reviewed both monitoring results and stated tAat comparisons between monthly and quarterly results for each station would be of benefit in evaluating the TLD system. The licensee agreed to review these results in the futur During this inspection the monitoring results of collocated TLDs were compared and the results are listed in Table'1. Although there are some differences between the NRC and the licensee's programs, (suchasstartingdateofquarter),resultsaregenerallyin agreemen %

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2.5 Meteorological Monitoring

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The inspector noted that the licensee had discontinued using the charts for meteorological parameters in the control room. The licensee is now using a computerized display for all parameters; wind speed, wind direction, temperature, dew point, and delta-T in the control room. . The control room _ personnel copy these parameters every thirty minutes in the log book,-because the licensee does not have a method to print the parameters. Meteorological parameters can be printed out at the meteorological tower station and the 1 Environmental Controls computer terminal on site. Therefnre, the inspector. verified all meteorological- parameters at three terminals; control room, tower station, and the Environmental Controls'

terminal, and found there were no disagreements between the control room and the other The inspector also reviewed Procedures'for calibration of wind speed, wind direction, and temperature. The inspector reviewed calibration records for 1986'and 1987 and found that calibrations were performed as schedule .0 Confirmatory Measurements 3.1 Management Controls The inspector reviewed the licensee's management oversight for radiochemistry and radioactive effluent releases, including assignment of responsibility and program audit ! Assignment of Responsibility i

The organization of the Chemistry group remains essentially j unchanged since the last inspection in this area. The Plant ~

Chemistry Manager reports to the Plant Operations Director, who- .

reports through the Deputy Director to the Director - Oyster Creek. Within the Chemistry group, there are three senior ;

level staff in addition to the manager, plus two foremen and fifteen technicians. Although the. Plant Chemistry Manager position is currently vacant, the group appeared to be functioning smoothly and professionally at the time of this inspectio Audits The inspector reviewed an audit of the Chemistry Program, number S-0C-86-10, conducted August 1 - October 17, 1986. This audit, which covered chemistry and radiochemistry, appeared to be reasonably thorough and complete. Areas covered included-training and _ qualification of technicians, document control, instrument calibration, surveillance schedules, sampling and analysis, quality control, control of materials, and review of

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INP0 findings. This audit produced three recommendations, and no major findings. The auditor concluded that the chemistry '

programs were adequately and effectively implemente ,

3.2 Laboratory QC Program The inspector reviewed the Chemistry program for the. quality control ]

of analytical measurements, including procedures,: data, and control )

charts. Control charts have been established for the gamma j spectroscopy systems covering instrument efficiency at 661 and 1332 l key. The control charts are computer-generated, with " limits" at 1 plus and minus five percent of the difference in net counts per f second. The licensee's control charts for most other. types of  :

analyses are statistically based, with warning limits of plus and >

minus two sigma, and control limits of plus and minus.three sigm !

The inspector discussed these differing methods of control chart-construction with the licensee representative, and pointed out that the five percent limits applied to the gamma spectroscopy system control charts do not indicate whether the instruments are.in a state of statistical control. The inspector also stated that it is common industry practice to use statistical control charts for gamma spectroscopy. The licensee representative stated that these control charts would be revised to include two-and tnree-sigma limits, and to eliminate the five percent limit The licensee representative also stated that these control charts would be initially constructed !

by repeated measurements of its check source to" establish .the two-and three-sigma limits. The inspector stated that approximately 20 (or more) such measurements would suffice for this. purpose.,

Other aspects of laboratory QC were discussed, including (1) checks of performance on various non-radiological chemistry samples, and (2) checks for the in-house and vendor laboratories' ability to correctly analyze for radionuclides for which quantification is rcquired by technical specification The licensee maintains control charts for in-house analyses of non-radiological duplicate and spiked chemistry samples. These charts indicate which technician performed each analysis, so it is possible to determine whether a given technician exhibits any bias 'l in results relative to the other technicians who perform that j analysi l A cross-check program has been established among the licensee's radiochemistry laboratory, its vendor laboratory, and another laboratory which supplies QC sample:: for analysis. This program provides checks of frequently used c.ounting geometries in the licensee's radiochemistry laboratories, using samples spiked at j levels similar to those normally encountered in the daily operations ;

of the facility, and also provides checks on the ability of the vendor laboratory to properly analyze samples required by technical specifications. The inspector noted that iron-55 was not included

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among the nuclides for which analyses were performed in this l

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program, although this nuclide is one specifically required to be analyzed according to the licensee's new Radiological Effluent Technical Specifications, which went into effect in November 198 The licensee stated that iron-55 would be included in this program as soon as arrangements could be made with the supplier of the QC sample .3 Confirmatory Measurements

During this inspection, samples were split between the licensee and !

NRC for the purpose of intercomparison. .These consisted of liquid, gas, particulate filter, and charcoal cartridge samples. - To the extent possible, the split samples are. actual effluent samples, or inplant samples that duplicate counting geometries used by the licensee for effluent sample analyses. Samples supplied by the NRC were also analyzed by the licensee's radiological controls group on its gamma spectroscopy equipment. The samples were analyzed by the licensee using normal methods and equipment, and by the NRC:I Mobile Radiological Measurements Laboratory. Joint analyses'of actual effluent samples are used to verify the licensee's capability to measure radioactivity in effluent samples with respect to Technical Specification and other regulatory requirement In addition, a liquid effluent sample was sent to the NRC reference laboratory (Department of Energy, Radiological and Environmental ,

Sciences Laboratory) for analyses requiring wet chemistry. The

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analyses to be performed on the sample include Sr-89, Sr-90, gross alpha, tritium, and Fe-55. The results will be compared with the licensee's when received at a later date, and will be documented in a subsequent inspection repor The results of an intercomparison between the licensee and NRC:I during a previous inspection on June 4-8, 1984 (Inspection Report !

No. 50-219/84-17), were also compared during this inspectio The results of the sample measurements comparison indicated that all y but one of the measurements by chemistry were in agreement under the j criteria used for comparing results (see Attachment 1). Two l a n eurements by the licensee's vendor laboratory were not in i a,reement, as well. Results of the intercomparisons are summarized I in Table l I

The comparison of the reactor coolant sample that was split between the licensee and NRC:I during this inspection indicated a disagreement in the measurement of Y-92. The licensee's result was about 1.7 times larger than the NRC result, which is conservative, and only slightly out of agreement considering the large amount of uncertainty in the NRC result. The comparison of the results for tritium (H-3) indicated that the licensee's vendor laboratory determined a value which was about one-half that of the NRC value,

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and therefore not in agreement. The licensee had noted another instance in its own QC program in which the. vendor . laboratory's l tritium results were incorrect, but subsequent QC analyses resulted in 1 agreement. The vendor laboratory's gamma spectroscopy result for i

Mn-54 was about one-fourth of the NRC value, and not in agreemen <

However, the licensee normally performs gamma spectroscop )

measurements in its own in-house laboratory, and does not rely upon the vendor to perform these analyses; thus this result _ is of _little significance with regard to licensee effluent measurements. .Another ,

comparison will be made on a similar sample taken during this ]

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The licensee's radiation controls group analyzed three samples j supplied by the.NRC. These included a simulated particulate ~ filter,, '

and two simulated charcoal cartridges, one face-loaded and one a containing essentially a uniform distribution of radioactivity.- The j

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analysis of the face-loaded cartridge indicated good agreement with the known values. However, the analysis of the uniformly-loaded q cartridge was not in agreement. The explanation for the l disagreement is that the radiation controls group calibrates its j detector only for a face-loaded geometry. The inspector stated that j calibration for a uniformly-loaded charcoal cartridge should also be j performed in order to deal with accident situations in which a i cartridge could become saturated. Although chemistry did not I analyze the NRC cartridge, the licensee stated that chemistry )

l calibrates for a " post-accident" charcoal cartridge, which may be a j uniformly-loaded geometry. The licensee stated that this matter  :

would be examined further, and that if necessary, a calibration for

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a uniformly-loaded charcoal cartridge would be performe .4 Effluent Monitor Calibration Procedures and Records The inspector reviewed procedures and records for calibration of the following effluent radiation monitors: stack gas channels A and B, offgas building vent, and turbine building sump 1-5.. These calibrations appeared to have been performed in accordance with procedures. The inspector noted that calibrations and functional tests are generally being performed more frequently than required by technical specifications. Other monitors required by technical specifications, including the radwaste _ effluent line, reactor i building service water effluent line, and turbine building vent, were not in operation at the time of_this inspection. The licensee is using alternative means permitted by technical specifications to track effluents via these pathways, i.e., sampling and analysi .5 Effluent Release Records The inspector reviewed Semiannual Effluent Release Reports for 1986, and found no instances of non-compliance with Technical Specification requirements. The analyses presented in these reports indicated that no regulatory or Technical Specification

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limits were exceeded for releases of liquid or. gaseous effluents' J e during the perio , Exit Interview The inspectors-met with the: licensee represen.tatives denoted-in' Paragraph 1 at the conclusion of the inspection on August'28, 1987. The inspectors'- -

summarized the purpose and scope _of.the-inspection and discussed the-results. L At no time during-this inspection,was written ' material supplied to.the licensee by the_ inspector I

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ATTACHMENT I-CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS-l 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 thi <

progra 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 (

uncertainty. As that ratio, referred to in this. program as " Resolution"' , -

increases, the acceptability of a licensee's measurement should be more' l selective. Conversely, poorer agreement must be considered acceptable.as the ;j resolution decrease Resolution = NRC REFERENCE'VALUE Ratio = LICENSEE VALUE REFERENCE VALUE UNCERTAINTY NRC REFERENCE VALUE Resolution Agreement  ;

i 43 0.4 - .5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25

> 200 0.85 - 1.18 NOTE: Applies only to Table .

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