IR 05000244/1987017
| ML17261A592 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/19/1987 |
| From: | Kottan J, Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261A591 | List: |
| References | |
| 50-244-87-17, NUDOCS 8709020440 | |
| Download: ML17261A592 (26) | |
Text
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U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.
50-244/87-17 Report No.
ON 50-244 License No.
OPR-18 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:
Jul 13-17 1987 Inspectors:
R.
K. Struckmeyer, Radiat n Specialist d
e J. J. Kottan, Radiation oratory Specialist te Approved by
. J.
P sciak, Chief, Effluents Radiation Prot tion Section, DRSS E
Ins ection Summar:
Ins ection on Jul 13-17 1987, Ins ection Re ort No. 50-244/87-17 date f
(1) radiochemical measurements program using the NRC I Mobile Radiological Measurements Laboratory and laboratory assistance provided by DOE, Radiological and Environmental Sciences Laboratory; (2) bioassay whole body counting program; and (3) radioactive waste processing, packaging and shipping.
Results:
- Within the areas inspected, no violations were identified.
PDR gD~40 870826 87090204 DOCK OS000244
'PDR
'
Individuals Contacted DETAILS C. Anderson, Manager, Quality Assurance
"J. Bodine, Nuclear Assurance Manager D. Bryant, QA Auditor
- D. Fi lkins, Manager, Health Physics and Chemistry D. Filion, Radiochemist R. Gasper, Radiation Protection Technician
'W. Goodman, Health Physics Foreman M. Harrison, Radiation Protection Technician
- T. Meyer, Superintendent, Ginna Support Services
- F. Mis, Radwaste Supervisor, Health Physics
"K. Nassauer, QC Inspection Supervisor F.
Puddu, Radiation Protection Technician W. Stiewe, QC Engineer
"S. Warren, Health Physicist Indicates personnel present at exit meeting on July 17, 1987.
2.0 Sco e of Ins ection The purpose of this inspection was threefold:
( 1) to review the licensee's ability to properly measure the levels of radioactivity in effluents from the plant, (2) to assess the licensee's ability to detect and quantify those radionuclides normally encountered in routine whole body courting operations, and (3) to evaluate the radioactive waste processing, preparation, packaging, and shipping program as implemented between August, 1986 and July, 1987.
3.0 Previous Identified Items (Closed)
Unresolved Item (50-244/84-20-02).
Ability of TLD system to properly measure and record environmental radiation.
The inspector reviewed the licensee's documentation pertaining to the photon correction factor setpoint and to the eighth International Environmental Dosimeter Intercomparison Project.
The photon correction factor setpoint is acceptable.
The results of the intercomparison showed reasonably good agreement with those stated by the project's sponsors.
(Closed) Violation (50-244/86-15-01).
Failure to identify iron-55 on shipping papers:
The inspector reviewed records of shipments made in the past twelve months and determined that iron-55 has been included on the shipping manifests as required.
4.0 Confirmator Measurements 4.1 S lit Sam le Results During this part of the inspection, liquid, particulate filter, charcoal cartr'idge and gas samples were split between the licensee and NRC for the purpose of intercomparison.
Where possible, the
split samples are actual effluent samples, or inplant samples which 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 regulatory requirements.
In addition, a liquid effluent sample was sent to the NRC reference laboratory, Oepartment of Energy, Radiological and Environmental Sciences Laboratory (RESL), for analyses requiring wet chemistry.
The analyses to be performed on the sample are Sr-89, Sr-90, gross alph'a, 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 report.
The results of an effluent sample split between the licensee and NRC: I during a previous inspection on October 7-11, 1985 (Inspection Report No. 50-244/85-22)
were also compared during this inspection.
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.)
The results of.the compari-sons are listed in Table I.
The comparison of the waste holdup tank sample results indicated that the licensee's results, although in agreement under the comparison criteria, appeared to be consistently biased low by approximately 12-13%.
At the time of this inspection the licensee was recalibra-ting his gamma spectroscopy system, and the efficiency values-for the Waste Holdup Tank counting geometry differed by approximately. 12-13%
from the 1986 calibration to the 1987 calibration.
Based on discus-sions with licensee personnel, it appears that the change in the efficiency values and the corresponding bias of the results compari-son were due to a change to a slightly different container for sample counting after the,1986 calibrations had been performed.
The inspec-tor noted that the new calibration would correct the low bias.
The inspector had no further questions in this area.
No violations were identified.
4.2 Procedures The inspector reviewed the following selected licensee effluent sampling and analysis procedures:
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PC-1.5, Operation of the TN-4000 Gamma Analyzer
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HP-10.5, Efficiency Calibration of Gamma Spectrometers
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HP-10. 1, guality Control of Counting Systems
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RD-6, Gas Decay Tank Releases
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RD-7, Liquid Waste Release The inspector also reviewed calibration data and selected 1987 QC data generated by Procedure HP-10. 1.
The inspector noted that the licensee's laboratory QC program was recently reviewed in detail during a previous NRC inspection on May 18-22, 1987, (Inspection Report No. 50-244/87-14).
This review discussed improvements that could be made to the licensee's laboratory QC program in order to make it a sufficiently thorough program.
During this inspection, the inspector inquired as to which improvements had been implemented or were planned for implementation.
The licensee stated that, to date, no changes had been made to the laboratory QC program, and a review of the program improvements was still underway..
The inspector noted that one of the suggested improvements, an interlaboratory QC program, would have identified the low bias results identified by the NRC during this inspection.
(See Section 4.0.)
The licensee's improvements to its QC program will be reviewed during a future inspections No violations were identified in this area.
i 5.0 Whole Bod Countin Pro ram This part of the inspection assessed the capability of the licensee to adequately perform radiological bioassay using a whole body counting system.
A whole body counting phantom containing radioactive sources traceable to the National Bureau of Standards (NBS) was submitted to the licensee for analysis.
The phantom duplicated the nuclides and the organ burdens that the licensee might encounter during normal operation.
The phantom was analyzed using the licensee's routine methods and equipment.
5. 1 Com arison of Results The licensee uses a Helgeson whole body counter which consists of a stationary bed and a moveable detector.
A terminal printer at the whole body counting facility provides an interim output of whole body counting results.
Whole body counting results of record, using a
more complete algorithm, are provided by Helgeson periodically in a written report.
The compari son results for the lung are based on an average of five measurements and the GI tract results are based on an av'erage of two measurements.
Table II contains the results of the intercomparison.
Based on these results, no violations were identified in this area.
5.2.
Procedures and Data The following procedures for the operation and calibration of the whole body counting system were reviewed:
HP.2. 1, Whole Body Counting Guide HP-2.2',
Whole Body Counter Operation HP-2.2. 1, Whole body Counter Source Check HP-2.2.2, Whole Body Counter Calibration Verification These procedures include periodic source checks and the maintenance of a quality control chart to trend changes in detector response.
Periodic background counts are taken and quarterly calibration checks, with specified acceptance limits, are performed.
Within the scope of this review, no violations were identified.
6.0 Radioactive Materials Handlin and Trans ortation Between August 1986 and June 1987, the licensee made approximately
shipments of all kinds of radioactive materials, a third of which were radioactive waste for disposal.
Selected records of shipments of various types were reviewed relative to the licensee's Technical Specifications, radwaste generator requirements in
CFR 20.311 and 61.55-57, and radioactive materials shipper requirements in 10 CFR 71 and
CFR 170-189.
1'he licensee's actions regarding previously identified items were also reviewed (See Section 3.0).
The inspector reviewed the organization of the health physics group, which handles radioactive shipments, as well as the quality assurance (gA) and quality control (gC) groups, which have responsibility for audits and checks of this area.
The Radwaste Supervisor is a health physicist who reports to the Manager of Health Physics and Chemistry.
The Manager reports through the Superintendent, Ginna Production, to the Superintendent, Nuclear Production.
The guality Control group is part of the Nuclear Assurance section, which is located onsite.
The Manager, Nuclear Assurance reports to the Superintendent, Nuclear Production.
This organizational structure gives gC a measure of independence'from the operations of the plant.
The guality Assurance Manager and auditors are located at the corporate office, and report to the Vice President, Engineering and Construction.
6.2 Procedures The inspector reviewed selected licensee and vendor procedures for processing, preparation, packaging and shipping of radioactive materials with respect to criteria provided in 10 CFR,
CFR and the licensee's Technical Specifications.
Procedures have been developed to handle classification of radioactive waste and to cover shipments using various packagings.
The procedures appeared to'dequately address regulatory requirements and to be properly implemented.
Radwaste shipping procedures contain numerous holdpoints for gC review of activities.
Procedures were also implemented for gC checks on receipt of packagings and on incoming vehicles to be used fot transporting radwast.3
~Tnainin The inspector'eviewed records of training, including course 'syllabi and attendance records for those health physics and quality control personnel involved in radioactive materials shipments.
The training was also attended by.the gA auditor who performed the 1987 audit and participated in the 1986 audit of this area.
Training has been provided on a biannual basis for these personnel since 1984.
However, no requirement for regular retraining is specified by procedure.
The scope of the training appeared to be adequate for the needs of the program.
6.4 ualit Assurance/ ualit Control In accordance with Technical Specification 3.9.2.7 the licensee is required to operate its solid radwaste treatment system in accordance with a Process Control Program (PCP) to process wet radwaste materials to meet shipping and disposal requirements.
Specific quality control requirements are also mandated by 10 CFR 20.311 to assure compliance with 10 CFR 61.55-56.
The establishment of a quality assurance program for the packaging and transportation of radioactive materials is required by 10 CFR 71, Subpart H.
A Commission approved quality assurance program which satisfies the applicable criteria of 10 CFR 50, Appendix B and which is established, maintained and executed for transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H.
The licensee elected to apply the currently established
CFR 50 Appendix B quality assurance program to packaging and shipping activities.
The inspector reviewed corporate gA audits of solid waste transport-ation activities conducted in 1986 (audit No. 86-17:CK) and 1987 (87-31:DB).
The station had responded to three of four findings in the 1986 audit and these have been closed.
The remaining finding will not be closed until a
new computer system has been acquired and methods for evaluation of vendor data concerning waste classification are incorporated into software for this computer.
The licensee expects to complete this by January 1988.
The 1987 audit report had not been written at the time of this inspection as the audit had just been completed.
The inspector reviewed the audit checklist and determined that it provided a comprehensive overview of activities pertaining to radwaste shipping, including ( 1) classification of radioactive wastes, (2) drumming, solidification and shipment of liquid and solid wastes, (3) packaging and shipping of licensed transport packages and (4) quality assurance activities.
A fifth area covering the Process Control Program was not performed during this audit because the Technical Specifications require auditing of this area once every two years.
The 1986 audit covered.the PC.4.1 Waste Classification A/ C Pro ram The licensee's quality assurance/quality control program to ensure proper classification under
CFR 61.56 was reviewed.
The inspector noted that:
Samples from the licensee's various radwaste streams were taken and sent to a contractor for analysis.
~
Scaling factors for determining the activities of difficult-to-measure radionuclides were determined by the contractor and incorporated into the classifica-tion methodology.
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The gC inspectors verify that radwaste has been classified, but do not regularly perform independent calculations to assure that the classification was properly performed.
The gC inspection supervisor stated that this was occasionally done, but the inspector did not see any written verification of this activity.
No instances of improper classification were noted.
Nevertheless, the inspector stated that gC should perform independent calculations to verify classification on a regular basis in order to preclude the possibility of improper classification in the future.
The inspector noted that virtually all classifications are accomplished by the radwaste supervisor who was very knowledgeable in this area.
The need for increased gC involvement in this activity might become more. apparent in the event that the current radwaste supervisor could not perforln the classification.
~
The (}uality Assurance auditor performed'ndependent calculations to verify proper classification of a few shipments during the 1987 audit.
~
The licensee performed test solidification of samples as needed when sample stream composition changed, and maintained control of key process parameters (e.g.,
pH and mixing speed during cement addition).
gC provided verification of final solidified waste form and independent inspection at designated hold points during solidification of actual waste.
The licensee appeared to have implemented a generally adequate process control program for waste classification and waste form quality contro.5 Radwaste Generator Re uirements Between August 1986 and June 1987, the licensee made ten shipments of radioactive waste, most of which consisted of drums of solidified evaporator residues plus one or more boxes of low specific activity (LSA) waste.
Only two shipments were made in HICs during this period consisting of dewatered resins.
The inspector reviewed selected records of these shipments, including both HICs, against the following radwaste generator requirements:
Waste manifests under 20.311(b),
(c) and (d) (4);
Waste classification under
CFR 20.311(d)(l)
and
CFR 61.55;
~
Waste form and characterization under
CFR 20.311(d)(1)
and
CFR 61. 56;
~
Waste shipment, labeling under
CFR 20.311(d)(2)
and
CFR 61.55 and 61.57; Tracking of waste shipments under
CFR 20.311(d)(8), (e)(6),
(f)(9) and (h)(2);
~
Disposal site license conditions for the Barnwell site.
Within the scope of this review, no violations were noted.
6.6 Radwaste Shi in Re uirements The inspector reviewed selected shipments including radwaste and other radioactive materials against criteria contained in 10 CFR 71 and
CFR 170-189 to determine if transportation requirements had been met.
6.6. 1
~
Procurement and Selection of Packa es The licensee's selection of packages for shipments of radioactive materials was reviewed with respect to requirements in 49 CFR 173 and
CFR 71. 12.
The licensee's performance relative to these criteria was determined by discussions with the radwaste supervisor and with gC personnel as well as by review of documents including shipping records.
Within the scope of this review, no violations were identified.
6.6.2 Pre aration of Packa es for Shi ment The licensee's preparation of packages for shipment was reviewed with respect to the requirements of 49 CFR parts
172 and 173,
CFR 71.87 and Technical Specifications.
The licensee's performance relative to these criteria was determined by interviews of licensee personnel as well as
'y review of procedures, shipping records and other documents.
Within the scope of this review, no violations were identified.
6.6.3 Deliver of Packa es to Carriers The licensee's delivery of packages to carriers was reviewed relative to criteria contained in:
~
CFR 71.5(a)(1)(iii), "Placarding";
~
CFR 71.5(a)(1)(vi), "Shipping papers";
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CFR 71.5(a)(2)(iv), "Public Highway";
The licensee's performance relative to these criteria was determined by review of procedures and shipping records, as well as by discussions with licensee personnel.
6.6.4.
Trans ortation Incidents The licensee stated that no transportation problems had been noted and no violations or warnings had been received from state regulatory agencies regarding the shipments during the period reviewed.
7.0 Exit Interview The inspector met with the licensee representatives denoted in Section 1.0 at the conclusion of the inspection on July 17, 1987.
The inspector summarized the purpose and scope of the inspection and the inspector's finding '
ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICALMEASUREMENTS 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 compari son of the NRC Reference Laboratory'
value to its associated uncertainty.
As that ratio, refer red to in this pro'gram as "Resolution",
increases the acceptability of a licensee's measurement should be more selective.
Conversely, poorer agreement must be considered acceptable as the resolution decreases.
Resolution'atio For A reement'3 4-7 8-15 16 - 50
200
>200 0.4 - 2.5 0.5 - 2.0 0.6 - 1.66 0.75 1.33 0.80 1.25 0.85 1.18
'Resolution
= (NRC Reference Value/Reference Value Uncertainty)
'Ratio
= ( License Value/NRC Reference Value)
SAMPLE ISOTOPE TABLE I
GINNA VERIFICATION TEST RESULTS NRC VALU LICENSEE VALUE COMPARISON RESULTS IN MICROCURIES PER MILLILITER Waste Holdup Tank 1000 Hours 7/15/87
"A" Gas Oecay Tank 7/15/87
"A" Gas 0925 Hours 7/16/87
- Containment Gas 1130 Hours 7/15/87 Reactor Coolant II8ll Loop 7/15/87 1st Count Reactor Coolant fl8iI Loop 0827 Hours 7/15/87 2nd Count Reactor Coolant Crud Filter 0700 Hours 7/9/87 Mn-54 Co-58 Co-60 Ag-110m I-131 Cs-134 Cs-137 Kr-85 Xe-133 Kr-85 Xe-133 Ar-41 Xe-133 Xe-135 1-134 Cs-138 I-131 I "132 I-133 I-134 I-135 C r-51 Mn-54 Co-58 Fe-59 Co-60 Zr-95 Ru-103 Te-132 (2. 1+0.3 )E-5 1. 89i0. 04 ) E-4 2. 46+0. 05 ) I--4 4.0+0.3)E-5 9+3)E-6 4.70+0.06)E-4 1. 119+0.008)E"3 (9+2)E-4 ( 1.78+0.03 )E-4 (8. 1+1. 3 ) E-4 (1. 61+0. 02) E-4 1.9+0.2)E-6 2.03+0.02)E-5 1.7+0.02)E-7 (1.10+0.02) E-1 (1.01+0.02) E-1 (3.0+0.2)E-3 (6.0810.08) E-2 (3.64+0.03)E-2 ( 1. 06+0. 08) E-1 (6.96+0. 15)E-2 (4.04t0.09)E-5 3.7+0.04)E-7 ( 1.64+0.02)E-5 5.0+0.8)E-7 (1. 19+0.07) E-6 3.70+0.14)E-6 (3. 110. 7) E-7 ( 1. 05+0. 14 ) E-6 ( 1. 71+0. 09) E-5 ( 1.63+0.02)E"4 (2. 17+0.03)E-4 (2.94+0. 14)E-5 (6.0+1.3)E-6 (4.0710.02)E-4 (9.64+0.04)E-4 (9.8+1.5)E-4 ( 1.62+0.03)E-4 (5.3+1.5)E-4 (1.7120.04) E-4 (2. 35+0. 13 ) E-6 (2.2910.02)E-5 (2. 1+0.2) E-7 (1. 11+0.02) E-1 ( 1. 01 10. 03 ) E-1 (2.59+0.08)E-3 (5.9210.04) E-2 3. 0010. 02 ) E-2 1.0110.02) E-1 6. 1+0.2)E"2 (4. 6110.06) E-5 (4.6+0.3)E-7 (1.8210.02) E-5 (6.6+0 ~ 9)E-7 (1.17+0.04) E-6 4.3+0.2)E-6 3.6+0.5)E-7 (1.24+0
~ 09) E-6 Agreement Agreement Agreement Agreement Agreement Ag reement Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement, Agreement Agreement Ag reemen t Agreement Ag reemenr.
Agreement Agreement Agreement Ag reement Agreement Agreement Agreement Agreement Agreement Agreement Waste Holdup Tank 1440 Hours 10/8/85 H-3 Gross a I pha Sr-89
'Sr-90 2.90+0
~ 04)E-1 7.6+0.8)E-8 6.7+0.3)E-6 1.09+0.06)f~6 ( 3.2310. 15) E-1 (522)E-8 (7.4+0.4)E-6 (1.13+0.05) E-6 Agreement Agreement Agreement Agreement
SAMPLE
'ISOTOPE TABLE I
GINNA VERIFICATION TEST RESULTS
~NRC VA UE COMPAR I SON RESULTS IN TOTAL MICROCURIES Containment Charcoal Cartridge 1347 IIours 7/14/87 l-131 I-133 Br-82 (3.3010. 14)E-3 (6.7+0.9)f-4 (5.4+0.2)E-3 (3.27+0.07)E"3 (5.3+0.5)E-4 (4.96+0. 11)E-3 Agreement Agreement Agreement-2-
TABLF II WHOI.E BODY COUNTING PHANTOM TEST RESULTS PRELIMINARY RESULTS
~IOOTOP ORGAN NRC KNOWN VALUE LICENSEE RESU T
LICENSEE RESULT NRC VALUE Co-60 Cs-137 Co-60 Cs-137 Lung Lung Gl Gl 64+8 92+12 58+8 83+11 78.0+0.7 110. 4+1. 1 91.5+0.7 121. 0+2 1. 22+0. 15 1.2+0.2 1.6+0.2 1.5i0.2 FINAL RESULTS ISOTOPE ORGAN NRC KNOWN VALUE LICENSEE RESULT LICENSEE RESULT NCR VALUE Co-60 Co-137 Co-60 Cs-137 Lung Lung Gl Gl 64+8 92+12 58+8 83+11 71. 2+1. 1 109.2+0.5 89+0 132+4 1. 1110. 14 1.2+0.2 1.5+0.2 1.6+0.2-3-