IR 05000220/1987015
| ML20235J152 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/14/1987 |
| From: | Kirkwood A, Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235J133 | List: |
| References | |
| 50-220-87-15, 50-410-87-24, NUDOCS 8710010326 | |
| Download: ML20235J152 (11) | |
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I'7 U.S.' NUCLEAR REGULATORY COMMISSION
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REGION I
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50-220/87-15 Report Nos.
50-410/87-24 50-220/87-15 Docket Nos. 50-410/87-24
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DPR-63-License Nos. NP F-54 Priority Category C
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Licensee:
Niagara-Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 l
Facility Name:
Nine Mile Point Units 1 and 2 Inspection At:
Scriba, New York 1)
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Inspection Conducted: August 3-7, 1987 j
Inspectors:
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R. K. Struckmeyer, RaWiation Specialist
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A.S.Kykwood,RadiationSpecialist date-j
Approved by.
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iE~J.gRadiation Protection Section
/ dpe asciTE, Chief, Effluents
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Inspection Summary:
Inspection on August 3-7, 1987 (Combined Inspection
Report Nos. 50-220/87-15; 50-410/87-24)
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Areas Inspected:
Routine, unannounced inspection of the licensee's radiochemical measurements program.
The NRC Region-I Mobile Ra'diological Measurements Laboratory was used and laboratory assistance was'provided by the
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DOE's Radiological and Environmental Sciences Laboratory. Areas reviewed
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included:
licensee actions on previous inspection. findings; chemistry management and organization; and radioactive sample confirmatory measurements,
' laboratory QC and audits.
Results: No violations were identified.
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i DETAILS-
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1.0 Individuals Contacted
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- J. Blasiak, Chemistry Unit 1 Supervisor J. Coates, Chief. Technician, Unit 1 Chemistry
- J. Duell, Supervisor, Chemistry and Radiochemistry
- T. Egan, NC&V Engineer
- T. Roman, Station Superintendent
- A. Ross, Chemistry Unit 2 Supervisor
- K. Snyder, Generation Engineer - Nuclear Chemistry Unit 1 C. Stuart, Superintendent., Chemistry & Radiation Management
- L. Wolf, Site Licensing Engineer The inspector also contacted other licensee personnel during the
inspection.
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- Indicates those attending exit meeting on August 7, 1987.
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2.0 Status of Previously Identified Items 2.1 (Closed) Inspector Folicsup Item (410/85-20-01) Complete review of liquid radwaste pre-operational testing:
The. licensee has completea the review
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and approval of the test procedure for this system. The licensee's Joint
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Test Group approved the test results in its meeting number 86-141 on j
August 7, 1986, and operational acceptance was given in SORC meeting l
number 86-85 on August 8, 1986.
2.2 (Closed) Inspector Follesup Item (220/85-20-02) Review licensee
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pre-operational' testing of solid radioactive waste processing system:
Two systems were involved, the Waste Solidification System, and the Radwaste
Backup Handling Facilities. The licensee has completed the review and.
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approval of the test procedures for these systems. The' licensee's Joint Test Group approved the test results for the Waste Solidification System in its meeting number 87-08 on January 15, 1987, and operational accep-tance was given in SORC meeting number 87-12 on January 30, 1987.
The Joint Test Group approved the test results for the Radwaste Backup Handling Facilities in its meeting number 86-88 on May 14, 1986, and operational acceptance was given in SORC meeting number 86-44 on May 15, 1986.
2.3 (Llosed) Inspector Followup Item (410/86-17-01) Calibration of counting equipment: The licensee has decided to use its laboratory gamma spectro-scopy equipment to analyze effluent samples collected by the GEMS, rather than rely on direct analysis by the GEMS itself.
This enables the licensee to perform required analyses in spite of problems identified with calibration of the GEMS detectors.
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- 2.4 (Closed) Inspector Followup Item (410/86-35-01) Include LCOs in radwaste procedures:
The inspector reviewed procedure N2-CSP-4V, for liquid wtste sampling, and found that this procedure now specifically references the LCO in section 3.3.7.10 of the Unit 2 Technical Specifications.
Similarly, procedure N2-CSP-7V, for reactor coolant leakage detection, now specifi-cally references the LC0 in section 3.4.3.1.
Furthermore, these proce-dures provide for measurement of radiation level and flow rate during discharges, which fulfills the intent of these LCOs.
2.5 (Closed) Inspector Followup Item (410/86-49-02) Review procedure S-CRIP-1: This procedure became effective on November 7, 1986.'
The inspector's review of this procedure did not reveal any significant problems or omissions.
2.6 (Closed) Inspector Followup Item (410/86-49-03)
Review simulated dirty filter air capacity tests:
The licensee generated deficiency reports covering the unsatisf actory tests of three ventilation systems - Post Accident 5ampling (2HVW FN 13/FLT 101), Liner Filling Hood Exhaust (2HVW
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FN 4/FLT 8), and Train B of the Radwaste Equipment Exhaust (2HVW FN 3 A&B/FLT 4 A&B).
These are non-Technical Specification, non-safety related l
systems. They were retested to ensure that flow rates at the design dirty l
filter differential pressure could be met.
In the csse of the Liner i
Filling Hood Exhaust, it was necessary to open the inlet damper (2HVW-DMP 6) to achieve a flow rate within 10% of the design flow rate. The Post Accident Sampling ventilation system was initially tested at a flow rate j
of about 26 cfm instead of the design flow rate of 40 cfm.
The in place
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HEPA and cherccal filters were tested at the lower flow rate, but were not l
retested after increasing the flow to near the design rate.
The tests at
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the lower rate are somewhat conservative relative to the higher rate; thus retesting was not considered necessary.
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3.0 Management Controls The inspector reviewed the licensee's management oversight for l
radio-chemistry and radioactive effluent releases, including assignment of I
responsibility and program audits.
3.1 Assignment of Responsibility The Chemistry and Radiation Protection department has been reorganized since the last inspection in this area.
There continue to be separate Chemistry supervisors for each unit; however, management above this level has been reorganized. Each chemistry supervisor now reports through the Supervisor, Chemistry and Radiochemistry, to the Superintendent, Chemistry i
and Radiation Management.
This position is at the same level of manage-ment as the Station Superintendent.
Both positions report to the General Superintendent, Nuclear Generation.
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3.2 Audits
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In a previous inspection of the Unit 1 effluents program during April, 1987, the inspector reviewed an audit conducted under the cognizance of the Safety Review and Audit Board by Radiological and Environmer tal-Services, Inc.
This audit was conducted December 15-19, 1986, and covered Chemistry and Effluent Monitoring at both units 1 and 2.
This tudit appeared to be reasonably thorough and complete; it addressed both acceptable and unacceptable findings, and corrective actions as appro-priate.
4.0 Laboratory QC Program The inspector reviewed the Unit 2 Chemistry program for the quality control of analytical measurements, including procedures, data, and control charts. The program is essentially similar to the Unit I program, reviewed in inspection report number 50-220/87-06.
Control charts have been established for the gamma spectroscopy systems covering instrument efficiency at 122 and 1173 kev, and background and resolution at 1173 kev.
The inspector reviewed the licensee's Quality Assurance procedure (N2-CSP-15V). This procedure provides for the use of a two-sigma warning level and a 15 per cent " control 1imit".
The two-sigma limits are based on the statistical variation observed when a known source is analyzed repeatedly, e.g. 20 to 30 times, and the mean and standard deviation of these analyses are calculated. The 15 per cent limit is based on a single result, i.e., the result of the analysis obtained at the time of calibra-tion of the instrument.
Because each of these limits'has a different basis, the midpoint (mean) based on the statistically based two-sigma analysis may or may not coincide with the midpoint (single value) of the calibration result.
Therefore, the result of a daily source check could be outside of the two-sigma warning limit and well within the 15 percent limit, or outside the latter limit, depending on how closely the midpoints of the two methods coincide.
In actual practice, the 15 percent limit is much broader than the two-sigma limit, and most QC results fall within the two sigma limit. The procedure specifies actions to be taken if too many measurements fall outside the two-sigma range, or if there appears.to be a l
trend toward repeated positive or negative results. A review of the
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licensee's control charts for these instruments indicated that the daily
source checks were generally within the two-sigma warning limit, and l
virtually always within the 15 per cent " control limit." (The latter limits are so broad that it would be very unusual for a measurement to exceed them.) The inspector discussed with the licensee the desirability
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of establishing the two-and three sigma levels as the principal check of proper instrument performance, and pointed out that this is standard industry practice. The inspector also noted, however, that the current method was acceptable as long as the two-sigma limits fall within the 15 per cent limits, and specific controls are applied to deal with trends and/or excessive numbers of results outside the two sigma limits.
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i Other aspects of laboratory QC were discussed, including (1) periodic j
checks of frequently used counting geometries in the licensee's radio-
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chemistry laboratories, using samples spiked.at. levels similar to those i
I normally encountered in.the daily operations of the facility, and (2)
sending spiked samples to the contractor laboratory to check its ability to correctly analyze for radionuclides for which quantification is
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required by technical specifications. These issues were discussed in l
relation to Unit 1 in report number 50-220/87-06. The licensee stated i
that efforts to develop such a program were not yet complete, but that it would apply to both Unit 1 and Unit 2.
l 5.0 Confirmatory Measurements
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i 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
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possible, the split samples are actual effluent samples, or inplant
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samples that duplicate counting geometries used by the licensee for effluent sample analyses.
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 l
regulatory requirements.
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 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 wi'll be documented in a subsequent inspection report.
The results of an effluent sample split between the licensee and NRC:I during a previous inspection on October 22 - 26, 1984 (Inspection Report No. 50-220/84-24), were also compared during this inspection.
The results of the sample measurements comparison indicated that all but
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one of the measurements were in agreement under the criteria used for comparing results (see Attachment 1). The results of the comparisons for Unit I are listed in Table 1, while the results for Unit 2 are contained in Table 2.
Because Unit 2.has been operating only a short time, very little radioactivity has built up in its liquid or gaseous effluents.
Thus, samples taken from Unit I were analyzed on equipment in the Unit 2 laboratory.
The comparison of the Waste Collector Tank that was split between the licensee and RESL during the previous inspection indicated a disagreement in the measurement of gross alpha.
The licensee's result was about an order of magnitude below that of RESL. Therefore, another comparison will be made on a similar sample taken during this inspection.
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No violations or concerns were identified in this area.
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6.0 Effluent Release Procedures and Records The inspector reviewed procedures for control of effluents, including i. hose for sampling and analysis, and found them to be very detailed and generally accurate.
This review primarily covered Unit 2 effluents, since Unit I had been reviewed recently (Inspection 50-220/87-06, April 20 - 24, 1987).
Records of releases of liquid and gaseous discharges were gener-ally complete and well-documented, with one exception: A gaseous discharge was made on May 31, 1987, and a sample of the gas was seat to l
the licensee's vendor laboratory for tritium analysis. A license; cepre-sentative stated that the results of this analysis.had been received on
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June 29, 1987.
Procedure N2-CSP-7V provides a form (Figure '8-V) on which
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the results of the tritium analysis are to be recorded; however, at the time of this inspection, this form had not yet been completed.
The licensee indicated that a time limit for entering the vendor data on figure 8-V had not been established, but that records are reviewed prior to issuance of the semiannual effluent release report, and that this
oversight would have been caught et that time.
The inspector stated that l
it would be preferable to establish a method to ensure that such data is
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recorded in a more timely fashion, in order to avoid the possibility of overlooking.a required analysis in the future.
The inspector reviewed. Semiannual Effluent Release Reports for 1986, and l
found no instances of non-compliance with Technical Specification requirements. 'The analyses presented in these reports indicated that no regulatory or Technical Specification limits were exceeded.for releases of liquid or gaseous effluents during the period.'
7.0 Exit Interview i
The inspector met with the licensee representatives denoted in Paragraph I at the conclusion of the inspection on August 7, 1987. The inspector
.j summarized the purpose and scope of the inspection and the #indings.
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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 program.
In these criteria, the judgement limits are variable in relation to the com-parison 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 selective.
Con-versely, poorer agreement must be considered acceptable as the resolution
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decreases.
Resolution = NRC REFERENCE VALUE Ratio = LICENSEE VALUE I
REFERENCE VALUE UNCERTAINTY NRC REFERENCE VALUE
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l Resciution Agreement
<3 0.4 - 2.5 4-7 0.5 - 2.0 8 - 15 0.6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25
>200 0.85 - 1.18
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