IR 05000245/1980020

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IE Insp Repts 50-245/80-20 & 50-336/80-22 on 801105-07. Noncompliance Noted:Failure to Identify Gamma Emitting Radionuclide in Liquid Effluent Sample
ML19345F682
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 12/05/1980
From: Bores R, Kottan J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19345F672 List:
References
50-245-80-20, 50-336-80-22, NUDOCS 8102190033
Download: ML19345F682 (9)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

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Region I 50-245/80-20 Report No. 60-336/80-22 50-245 Docket No. 50-336 DPR-21 C

License No. DPR-65 Priority

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Category C

Licensee:

Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name:

Millstone Nuclear Power Station Inspection at:

Waterford, Connecticut Inspection conducted:

November 5-7, 1980 Inspectors: T T

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/2 - 2. - 80 J. J. Kottan', Radiation Laboratory Specialist date signed date signed date signed Approved * :

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R. J. Bores,' Chief, Environmental and date signed Special Projects Section, FF&MS Branch Inspection Summary:

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Inspection on November 5-7. 1980 (Combi.ed Inspection Report Nos. 50-245/80-20 and 50-336/80-22)

Areas Inspected:

Routine, unannounced inspection of the licensee's chemical and radiochemical measurements program using NRC:I Mobile Radiological Measure-ments Laboratory and laboratory assistance provided by DOE Radiological and Environmental Services Laboratory. Areas reviewed included:

program for quality control of analytical measurements; audit results, and performance on radio-logical analyses of split actual effluent samples.

The inspection involved 30 inspector-hours onsite by one NRC regionally based inspector.

Results:

Of the four areas inspected, no items of ncncompliance were identified in three areas.

One item of noncompliance (Infraction - failure to identify a gamma emitting radionuclide in a liquid effluent sample) was identified.

Region I Form 12 (Rev. April 77)

8102190033

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DETAILS 1.

Persons Contacted Principal Licensee Employees

  • E. C. Farrell, Station Services Superintendent
  • A. G. Cheatham, Radiological Services Supervisor
  • J. P. Kangley, Chemistry Supervisor
  • R. H. Langer, Unit 2 Chemistry Foreman The inspector also interviewed other licensee employees including members of the chemistry and oialth physics staffs.
  • denotes those present at the exit interview.

2.

Laboratory QC Program The inspector reviewed the licensee's program for the quality control of analytical measurements.

The licensee's QC program is detailed in procedure CP 800/2800, " Chemistry Quality Assurance Program." This procedure includes training, equipment calibration, intralaboratory and interlaboratory compari-

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sons, and preparation of laboratory standard solutions.

The inspector reviewed records of chloride, fluoride, boron and radioactivity QC samples j

including splits and spikes for interlaboratory comparison and intra-l laboratory duplicate analyses for the period March - November 1980.

The I

inspector also reviewed the licensee's chemistry training program which l

included formal lesson plans and a written examination for new employees

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and periodic performance observation for other employees.

The inspector (

determined that the licensee was implementing his QC program.

The inspector I

had no further questions in this area.

No items of noncompliance were identified.

3.

Audit Results The inspector determined that the licensee's effluent analyses and QC program were examined by an internal corporate audit conducted by the Environmental Review Board.

The inspector reviewed Environmental Review l

Board Audit 80-1 dated July, 1980 which covered effluent releases, labora-l tory QC and training.

The inspector had no further questions in this area.

No items of noncompliance were identified.

4.

Confirmatory Measurements During the inspection, actual liquid, airborne particulate and charcoal, and gaseous effluent samples were split between the licensee and NRC:I for the H

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purpose of intercomparison.

The effluent samples were arealyzed by the licensee using his normal methods and equ.'pment, and by the NRC using the NRC:

Mobile Radiological Measurements Laboratory.

Joint analyses of acttul effluent samples are used to determine the licensee's capability to measure radioactivity in effluent samples.

A simulated off gas standard was submitted to the licensee for analysis because Unit I was shutdown for refueling and this type of effluent sample was not available.

In addition, a liquid effluent sample was sent to the NRC reference labora-l tory, Department of Energy, Radiological and Environmental Services Labora-i tory (RESL), for analyses requiring wet chemistry.

The analyses"to be performed on the sample are:

Sr-89, Sr-90, gross alpha, gross beta, and tritium.

These results will be compared with the licensee's results when l

received at a later date, and will be documented in a subsequent inspection report.

The results of the sample measurement intercomparisons indicated that all of the measurements were in agreement or possible agreement under the cri-l teria used for comparing results.

(See Attachment 1.) The results of the comparisons are listed in Table I.

l The comparison of the Unit 2 WMT "A" radwaste sample indicated that Sb-125 I

was identified by the NRC and not identified by the licensee.

This sample l

analysis was used by the licensee for Discharge Permit No. 2279.

Sb-125

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has the following photo peaks and corresponding gamma abundances:

176 kev-6.7%, 427 kev-29.5%, 463 kev-10.3%, 600 kev-17.6%, and 636-11.3%.

All of these photo peaks were identified by the NRC in a 600 second count of a 500 ml sample in a polybottle.

The 427 kev, 463 kev, and 636 lev photo peaks were identified by the licensee's peak search routine for a 30 minute count of a 1000 ml polybottle.

Although the photo peaks were identified by the licensee's peak search program, Sb-125 was not identified because it was not in the licensee's radionuclide library.

Table 2.4-1 of the licensee's Technical Specifications requires that the licensee report principal gamma i

l emitters present in the sample in concentrations greater than SE-7 uCi/ml.

Section 2.1.4.3 A and B require that each batch of liquid waste be analyzed for each significant gamma energy photo peak in accordance with Table 2.4-1.

The inspector stated that failure to identify the Sb-125, which was present in a concentration greater than SE-7 uCi/ml, was an item of non-compliance (50-245/80-20-01, 50-336/80-22-01). The inspector noted that the concentration of Sb-125 in the sample was less than the 10 CFR 20 Appendix B, Table II, Column 2 values and therefore, the licensee would not l

have exceeded any effluent release limits.

The inspector noted that the

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licensee could meet his Technical Specification MDA of SE-7 uCi/ml with a 30 minute count of a 1000 ml polybottle.

The licensee " hand" calculated the Sb-125 concentration in the sample and the result was in agreement with

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the NRC result.

The inspector reviewed the licensee's liquid effluent l

release records from January,' 1980 to November, 1980 and noted that Sb-125 l

photo peaks were present in some, but not all, of the samples.

The inspector l

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discussed the licensee's Technical Specification MDA of SE-7 uCi/ml for liquid radwaste and the MDA definition contained in NRC Regulatory Guide 4.15 with the licensee.

The inspector had no further questions in this area.

5.

Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on November 7, 1980.

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

The licensee agreed to perform the analyses listed in Paragraph 4 and report the results to the NRC.

In addition the inspector also discussed the licensee's Technical Specifi-cation MDA of SE-7 and the definition of MDA as stated in Regulatory Guide 4.15.

The licensee stated that he would review the previous liquid rad-waste discharge permit results and report any Sb-125 which met his Tech-nical Specification reporting requirement.

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TABLE 1

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MILLSTONE 1 AND 2 - CAPABILITY TEST RESULTS

SAMPLE IS0 TOPE NRC VALUE LICENSEE VALUE COMPARISON RESULTS IN MICR0 CURIES PER MILLILITER Unit 2

"A" WMT Co-60 (7.310.3)E-6 6.0910.40E-6 Agreement 1510 Hrs.

Co-58 (3.1+ 0. 2 ) E-6 (2.27+0.26)E-6 Agreement 11-5-80 Sb-124 (4.4TO. 5 )E-6 (6.13T0.39)E-6 Agreement Sb-125 (7.7TO.5)E-6 Not lieported

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  • (6.8210.60)E-6 Agreement Unit 2 Vent.

I-131

    • 1.410.6E-13 (6.61411.380)E-14 Agreement Charcoal

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Cartridge I-131

      • 1.1+0.2E-13 (6.614+1.380)E-14 Agreement
  • Hand Calculated by licensee after being identified by NRC.
    • Using homogeneous distribution calibration factor.,(NRC only)
      • Using face loaded distribution calibration factor.

(NRC only)

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TABLE 1 (continued)

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MILLSTONE 1 AND 2 - CAPABILITY TEST RESULTS

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SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON

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RESULTS IN MICR0 CURIES PER MILLILITER Unit 2 Waste Gas Xe-133 (3.24+0.10)E-4 (4.154+0.013)E-4 Agreement Surge Tank Xe-135 (1.1+0.3)E-5 (8.552TO.122)E-6 Agreement 1155 Hrs.

Kr-85 (5.0TD.5)E-3 (4.692[0.053)E-3 Agreement 11-7-90

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Unit 2 Reactor I-131 (1.79+0.01)E-3 (1.898+0.012)E-3 Agreement Coolant I-133 (4. 73[0. 04 )E-3 (5.575[0.039)E-3 Agreenent 0400-Hrs.

Co-60 (3.13+0.09)E-4 (3.772+0.074)E-4 Aareement 11-5-80 Co-58 (3.28TD.09)E-4 (3.594TD.066)E-4 Agreement Mn-54 (9.6+6.7)E-5 (9.408TD431)E-5 Agreement W-187 (3.15+0.08)E-3 (3.326TD.055)E-3 Agreement Na-24 (1.74T).05)E-3 (2.130TD.04)E-3 Agreement Ce-144 (1.42[0.06)E-3 (1.082[0.032)E-3 Agreement

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TABLE 1 (continued)

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MILLSTONE VERIFICATION TEST RESULTS s

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SAMPLE ENERGY (KEV)

NRC VALUE LICENSEE VALUE

_ COMPARISON RESULTS IN GAMMAS PER MINUTE NRC Simulated

2.75E46%

3.03ES+3%

Agreement

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Off Gas Sample *

303 1.5ES+7%

1.83ES+9.8%

Agreement 346 2.7E6+6%

2.71E6+1.1%

Agreement

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356 4.5E5t7%

5.19ES+3.2%

Agreement 779 1.3E6+7%

1.14E6+2.4%

Agreement 964 1.4E6+6%

1.25E6+2.4%

Agreement 1408 3.3E6+8%

1.92E6+2.0%

Possible

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Agreement

  • At the time of the inspection, the licensee's facility was shut down for refueling, and, therefore, no offgas sample was available.

An NRC simulated offgas sample was given to the licensee.

The results for the various photo peaks in the spectrum were compared in ganoms per minute emitted from the sample.

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TABLE 1 (continued)

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MILLSTONE 1 AND 2 - CAPABILITY TEST RESULTS

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SAMPLE IS0 TOPE NRC VALUE LICENSEE VALUE COMPARISON f

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RESULTS IN MICR0 CURIES PER MILLILITER Particulate Co-60 (2.31+0.02)E-4 (2.609+0.025)E-4 Agreement Filter of Co-58 (2.45Tb 02)E-4 (2.613TO.022)E-4 Agreement Unit 2 Mn-54 (1.45TO.07)E-5 (1.452TO.095)E-5 Agreement Reactor Coolant W-187 (2.67TO.06)E-4 (2.514TO.051)E-4 Agreement 0400 lirs.

Cr-51 (2.65Tb.05)E-4 (2.787TD.079)E-4 Agreement

I-131-(2.4+6.5)E-6 (3.572TD.933)E-6 Agreement Zr-95 (3.68+0.13)E-5 (3.623TO.163)E-5 Agreement Nb-95 (3.62TO.08)E-5 (3.648TD.109)E-5 Agreement

La-140 (9.5+0.9)E-6 (6.086TO.579)E-6 Agreement Ba-140 (1.3TO.3)E-5 (1.063[0.329)E-5 Agreement

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Attachment 1 Criteria for Comoaring 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

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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 selective.

Conversely, poorer agreement must be considered acceptable as the resolution decreases.

LICENSEE VALUE RATIO = NRC' REFERENCE VALUE

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Possible Possible

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Resolution Agreement Agreement A Agreement B

<3 0.4 - 2.5 0.3 - 3.0 No Comparison 4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5

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16 - 50 0.75 - 1.33 0.6 - 1.66 0.5 - 2.0 51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.66

>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33

"A" criteria are applied to the following analyses:

Gaana Spectrometry where principal gamma energy used for identification is greater than 250 Kev.

f Tritium analyses of liquid samples.

Iodine on absorbers

"B" criteria are applied to the following analyses:

Gamma Spectrometry where principal gamma energy used for identification is less than 250 Kev.

89Sr and 90Sr Determinations.

Gross Beta where samples are counted on the same date using the same reference nuclide.

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