IR 05000244/1987014

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Insp Rept 50-244/87-14 on 870517-22.No Violations Noted. Major Areas Inspected:Licensee Radioactive Liquid & Gaseous Effluents Program.Need for Improvement in Radiochemistry Lab QC Identified
ML17261A526
Person / Time
Site: Ginna Constellation icon.png
Issue date: 06/08/1987
From: Pasciak W, Struckmeyer R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17261A525 List:
References
50-244-87-14, NUDOCS 8706250447
Download: ML17261A526 (12)


Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report,No.

87-14 Docket No.

50-244 License No.

DPR-18 Priori ty Category C

Licensee:

Rochester Gas and Electric Cor oration 49 East Avenue Rochester New York 14649 Facility Name:

R.

E. Ginna Nuclear Power Plant Inspection At:

Ontario New York Inspection Conducted:

Ma 18-22 1987 Inspectors:

Richard K. Struckmeyer, diation Specialist I

/

Approved by:

. d P

i1,,.

alter J.

Papciak, Chief, Effluents Radiation Pr'otection Section, EPRPB d te da e

Ins ection Summar:

Ins ection on Ma 18-22 1987 Ins ection Re ort No. 50-244/87-14

'reas Ins ected:

Routine, unannounced inspection of the licensee's radioactive liquid and gaseous effluents program.

Areas reviewed included:

radioactive effluent release records, effluent control instrumentation, effluent control procedures, Offsite Dose Calculation Manual and dose calculations, Semiannual Effluent Release Reports, reactor coolant chemistry, and v'enti lation systems.

Results:

Within the areas inspected, no violations were identified.

A need for improvements in radiochemistry laboratory quality control was identified.

8706250447 870605 PDR ADOCK 05000244

PDR

DETAILS 1.0 Individuals Contacted 2.0

'D. Filion, Radiochemist

"D. Fi lkens, Manager, Health Physics and Chemistry R. Gasper, Chemistry and Health Physics Technician

"M. Klueber, Health Physics Foreman G. Joss, Foreman, Results and Test Department J. Loria, Engineer T. Meyer, Superintendent, Ginna Support F. Mis, Health Physicist

"B. Snow, Superintendent, Nuclear Production S. Spector, Superintendent, Ginna Production J. St. Martin, Liaison Coordinator C

The inspector also contacted other licensee personnel during the inspection.

"Indicates those attending exit meeting on May 22, 1987.

Status of Previously Identified Items (Open) Inspector Followup Item (84-20-02)

Ability of TLD system to properly measure and record environmental radiation:

The licensee stated that a final value had been chosen for the photon correction facto setpoint, but did not have the documentation available at the time this issue was discussed.

The inspector reviewed the unofficial results of the licensee's participation in the Eighth Inter'national Environmental Dosimeter Intercomparison Project.

According to these results, the licensee's values were in fairly close agreement with those stated by the project's sponsors.

Documentation for both matters will be reviewed as

'soon as it is available from the licensee.

(Open) Inspector Followup Item (84-20-04)

Document training for environmental technician and provide specific training and job description for this position:

A job description had=not yet been completed as of this inspection.

A request for'ormal training (to be provided by ORAU)

was recently written, but has not yet received management approval.

This item will'remain open until the formal job description has been written and approved, and until the technician has completed the requested training.

3.0 Management Controls The inspector reviewed the licensee's management oversight for radiochemistry and radioactive effluent releases, including assignment of responsibility and program audit A S

3. 1 Assignment of Responsibility Responsibility for effluent control is held by the Health Physics and Chemistry Section.

The radiochemist is responsible for laboratory quality control, as,.well as calculation of offsite dose due to effluents and preparation of Semiannual Effluent Release Reports.

This individual reports to the Manager of the Health Physics and Chemistry Section, who reports to the Superintendent, Ginna Production.

Filter testing is conducted under the cognizance of the Results and Test Supervisor, who reports through the Technical Manager to the Superintendent, Ginna Support Services.

Both superintendents report to the Superintendent, Nuclear Production.

3.2 Audits The inspector reviewed audit number 86-59:OB conducted by guality Assurance between Oecember 10-17, 1986.

This audit covered. Chemistry and Effluent Monitoring, as well as the Radiological Environmental Monitoring Program and Health Physics.

This audit appeared to 'be reasonably thorough and complete; it addressed both acceptable and unacceptable findings, and corrective actions as appropriate.

4.0 Laboratory gC Program The inspector reviewed the licensee's program for the quality control of analytical measurements, including procedures, data, and control charts.

Control charts have been established for the gamma spectroscopy system covering instrument efficiency and background.

The inspector reviewed the licensee's quality control procedure (HP-10. 1), which provides for daily source checks of the gamma spectroscopy system.

The procedure provides for the use of a two-sigma warning level and a three-sigma control limit.

The limits are based on" the statistical variation observed when a

known source is analyzed repeatedly, e.g.

20 times, and the mean and standard deviation of these analyses are calculated.

A review of the licensee's control charts for these instruments indicated that the daily source checks were generally within the two-sigma warning limit, and virtually always within the three-sigma cont~ol limit, although there did appear to be a small amount. of negative bias in the results.

The inspector noted that although the licensee uses a mixed (multi-energy)

check source, only one peak is used for gC checks.

The inspector -discussed with the licensee

,the value of using two or three different peaks to check the system over a

range of energie The inspector stated that it is standard industry practice to perform periodic checks of commonly used counting geometries; for example, particulate filter, reactor water, and off-gas sample.

Such samples should be spiked at levels similar to those normally encountered in the daily operations of the facility.

Gas samples are frequently simulated by solid sources prepared in the geometry normally used for counting the gas.

The licensee stated that it participates in a program sponsored by the Northeast Nuclear Chemists Association (NENCA) that provides quality control samples twice yearly, primarily for non-radiological chemistry, and includes one sample for analysis by gamma spectroscopy.

The inspector stated that one sample of this type will provide.little information about the ability of the gamma spectroscopy equipment to accurately quantify radionuclides in the various geometries that must be analyzed for effluent control purposes.

A program of periodic independent checks of the equipment should be a part of a quality control program in order to provide a means to detect errors in calibration and other sy'stematic errors that normally cannot be detected by the use of daily source checks.

The licensee stated that an attempt was made to participate in a program that provides quality control samples for radiological chemistry, but that participation in this program was turned down by the president of RG&E.

The licensee stated that another attempt would be made to participate.

The inspector discussed with the licensee the importance of checking the accuracy of analyses performed by chemistry technicians through the use of spiked, split, and blank samples.

Such samples might be prepared by the'adiochemist or his designate, and analyzed without the technicians'nowledge of their gC status.

A program for such analyses should be established, covering several different type's of samples and counting geometries.

The licensee's technical specifications require quantification of Fe-55, Sr-89, Sr-90, and gross alpha in liquid effluents.

These analyses are normally performed by a contractor'laboratory.

The inspector determined that the licensee does not routinely send spiked samples to its contractor laboratory to check its ability to correctly analyze for these radio-nuclides.

The inspector stated that this aspect of quality control. is also important to ensure that the licensee accurately quantifies its effluents, and is generally considered to be a good industry practice.

The licensee stated that a program to include such periodic checks on its contractor laboratory, using spiked samples and/or audit of the labora-tory's participation in an independent gC check program, will be developed.

The inspector stated that the licensee's improvements to its gC program will be reviewed in a future inspection.

The current status of the radiological quality control program is technically sound but not sufficiently thorough.

The program could be significantly improved by the addition of the aspects of gC discussed abov.0 Procedures for Control of Effluents and Radiochemistry The inspector reviewed procedures for control of effluents, including those for sampling and analysis, and for determination of monitor setpoints.

The procedures were found to be detailed and well written.

The licensee also maintains controlled and well written procedures for calibration of effluent monitors.

However, these procedures cover calibration both of the detectors and their associated electronics, and many of the procedures cover two or more channels of a particular monitor.

The inspector noted that it has been common practice to use only a portion of a given procedure (e.g.

to calibrate 'the electronics of one channel, perform maintenance on another, etc.), while the remainder is marked N/A (not applicable).

Generally, no indication is made as to the reason for performing the procedure.

However, a review of the licensee's records indicated that the calibrations have been performed within the required intervals.

The inspector reviewed the licensee's procedures for obtaining

.

and analyzing a primary reactor water sample, and observed the acquisition of the sample and part of the analysis by a technician.

No problems were noted with either aspect.

6.0 The licensee records the results of its chemical and radiochemical analyses in a log book, which is microfilmed for archival purposes.

The licensee stated that this is the official log of the results of analyses required by technical specifications.

The inspector reviewed the log and determined that required analyses apparently have been performed and that results have generally been within limits, but that the log itself does not indicate whether these requirements have been fulfilled.

The inspector stated that this informal method of record keeping may hinder the licensee's own review of results to ensure that technical specification requirements have been met.

The inspector discussed with the licensee the value of improving its records in this area.

Effluent Release Records The inspector reviewed Semiannual Effluent Release Reports for 1985 and 1986, and found them to be in. 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.

The inspector also reviewed selected results of offsite dose assessments included in the semiannual report, and performed calculations to check the licensee's results.

The semiannual report summarized the maximum offsite doses due to liquid and gaseous effluents from Ginna and demonstrated that doses are within the ALARA guidelines of 10 CFR 50 Appendix I, and also in compliance with 40 CFR 190 for total dose from all uranium fuel cycle facilitie.0 Tests of HEPA and Charcoal Filters The inspector reviewed the results of tests of HEPA and charcoal filters performed in 1987 and 1986, for the Control Room Emergency Air Treatment System, the Spent Fuel Pit System, the Containment Recirculation System, and for the Post Accident System, all of which are required by the licensee's technical specifications.

These systems met the technical specification requirements for filtration efficiencies; i.e., at least 99K removal of DOP by the HEPA filters and of halogenated hydrocarbon by the charcoal adsorbers for the in-place test, and at least 90% removal of radioactive methyl iodide by a carbon sample in the laboratory.

(The Containment Recirculation System has no requirements for testing of charcoal filters, and no test of HEPA filters is required for the Post-Accident System or the Spent Fuel Pit System.)

8.0 Exit Interview The inspector met with the licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on May 22, 1987.

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

At no time during the inspection was written material provided to the licensee by the inspector.