IR 05000250/1981006
| ML17341A183 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/16/1981 |
| From: | Montgomery D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17340B316 | List: |
| References | |
| 50-250-81-06, 50-250-81-6, 50-251-81-06, 50-251-81-6, NUDOCS 8106100182 | |
| Download: ML17341A183 (20) | |
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UNITEDSTATES NUCLEAR REGULATORY COIVIIVIISSION REGION I I 101 MARIETTAST., N.W., SUITE 3100 ATLANTA,G EORG IA30303 r
E Report Nos. 50-250/81-6 and 50-251/81-6 Licensee:
Florida Power and Light Company P. 0. Box 529100 Miami. FL 33152 Facility Name:
Turkey Point 3 and 4 Docket Nos. 50-250 and 50-251 License Nos.
DPR-31 and DPR-41 Inspection at Tu ke Point Site, Homestead,'Florida rrre r ery ~
Inspector:
Fu('.
. Montgom Accompanying Personn C. Mc hail SUMMARY Inspection on March 17-20, 1981 Approved y:.
t J.
ilip to
,
E S Branch Chief ate igned Date Signed Areas Inspected
'This routine unannounced inspection involved 45 inspector-hours on site in the areas of quality control and confirmatory measurements including; review of the labo'ratory quality.- control program, review of chemistry and radiochemistry procedures, review of quality control records and logs, and comparison of the results of split samples analyzed by the licensee and the NRC..RII Mobile Laboratory.
Results Of the four areas inspected, no items of noncompliance or. deviations were identi-fied in three areas; two violations were found in one area (failure to document and approve temporary changes to an approved procedure and failure to follow guality Assurance procedure for calibration of M&TE).
Persons Contacted DETAILS
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Licensee Empl oyees H. E. Yeager, Site Manager J. Hays, Plant Manager
"J. S. Made, Jr., Nuclear Chemistry Supervisor
"E. LaPierre, Radiochemist
"R. D. Leineke, Counting Room Supervisor
"D. W. Jone,. gC Supervi sor
.
"J. E. Moore, Operations Superintendent
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Other licensee employees contacted included four technicians.
NRC'esident Inspectors
"A. Ignatonis
"W. C. Marsh
"Attended exit interview Exit Interview The inspection scope and findings were summarized, on March'20, 1981 with those persons indicated in Paragraph 1. above.
The licensee representati've acknowledged the violations and agreed to perform the analyses referred to in paragraph 8.b.
The inspector stated that a dedicated area with appro-priate. power was needed for the NRC Van for emergency response and routine inspections.
A licensee representative agreed to provide the necessary facilities by August 1, 1981.
3.
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Licensee Action on Previous Inspection Findings (Open) Infraction (250/80-08-01 and 251/80-08-01) Failure to have and follow written procedures for radiochemistry counting equipment.
The inspector reviewed the procedure for efficiency calibration of the gamma spectroscopy system and liquid scintillation counter, and the daily control checks for the gas flow proportional counter.
The inspector noted that corrective action for the noncompliance associated with the daily control checks had been implemented.
The licensee completed corrective action as stated in their response to the item of noncompliance dated May 19, 1980; however, the inspector noted that the gamma spectroscopy calibration procedure did'ot have adequate detail regarding the preparation of standards for charcoal cartridges, particulate filters, and gas geometries.
Licensee representa-.--
tives agreed to address this area.
This item will remain open until necessary procedure revisions have been complete.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may.involve noncompliance or deviations.
A new unresolved item identified during this inspection is discussed in paragraph 6c.
5.
Laboratory guality Control Program
/
The inspector reviewed the licensee's quality control. program for chemical and radiochemical measurements in the. following areas:
a.
Assignment of Responsibility and Authority to Manage and Conduct the gC Program.
The quality control program for chemistry and radiochemistry is detailed in the plant Nuclear Chemistry procedures.
The Chemistry Supervisor has been assigned the responsibility to develop and imple-
,
ment procedures covering all aspects of, the chemistry program including
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quality control and testing methods.
The Chemistry Supervisor q.iso serves as the guality Control Coordinator for the.Radiochemistry Department.
b.
Provisions for Audits/Inspections Administrative Procedure 0190.73,
"gC Surveillance of Nuclear Safety Related. Activities" provides for quality control surveillance to assure
'hat plant systems and components are tested, operated, controlled and maintained in accordance with requirements as specified by applicable plant procedures.
The guality Control Supervisor is responsible for scheduling, carrying out, and reviewing surveillances.
C..
Methods for Assuring Deficiencies and Deviations in the 'Program are Recognized, Identified, and Corrected.
The Chemistry Supervisor is responsible for identifying and correcting deficiencies that are identified in the guality.Control "program..
The guality Control inspectors are also responsible for ensuring that open surveillance items are resolved in a timely manner.
The nuclear, chemistry procedures specify various performance checks and acceptance criteria for chemistry and radiochemistry instrumentation.
6.
Review of Chemistry and Radiochemi stry Procedures a
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The inspector reviewed the following procedures:
(1)
(2)
NC;6, "Sample System Normal Operation", January 22, 1981..
NC-18,
"LS-100 Liquid Scintillation Detector Daily..Response Check," April 10, 1980.
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'L'3)
(4)
(5)
NC-25B,
"Gamma Spectrometer Efficiency Calibration,.for",Various Geometries Using Radioactive Standards," April 10, 1980
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NC-26A, "Calibration of the ND 680/66 System,"
December 31; 1980.
NC-45,
"Determination of Tritium Activity for Liquid Release Composites,"
February 11, 1977.
(6)
NC-52,
"Sampling and Analyses, Preparation arid Documentation of Gas Decay Tank Releases,"
February 11, 1977..
(7)
NC-50,
"Exchange of Plant Vent and Unit 3 Spent Fuel Pit Parti-culate and 1odine Filter Cartridges, Analyses and Dbcumentation of'esults'."
The procedure review was discussed with licensee representatives as.
discussed in paragraphs 6b - 6d.
b.
C.
The inspector noted that a controlled copy of NC-52,
"Sampling and Analysis, Preparation and Documentation of Gas Decay Tank Rel~ayes,"
was being. used in the laboratory and had been changed-by penciling in changes to step 4.4.
This step provides instructions as to the'.switch position for the gas analyzer and the mode of operation (manual or automatic).
The inspector was informed that this change had been made after modification of the gas analyzer, but the procedure had not been officiallychanged.
The exact date of the unofficial procedure changes could not be determined, but licensee representatives indicated that they had been in effect for at least several'onths.
The inspector noted that Technical Specification 6.8.3 requires that temporary changes be reviewed by two members of the plant management prior to implementation and that the Plant Superintendent and Plant Nuclear Safety Committee'eview the changes within fourteen days after imple-mentation.
The inspector informed licensee representa'tives that failure to initiate a temporary procedure.
change was a violation of Technical Specification 6.8.3 (250/81-06-01, 251/81-06.-01).
Licensee representatives acknowledged the violation arid stated that the
. sampling procedure would, have been valid with either.-the approved procedure or the 'procedure with unauthorized changes.
A licensee repre-sentative informed the inspector by telephone on March 27, 1981 that temporary changes per Technical Specification 6.8.3 had been completed for the previously unauthorized changes.
The inspector informed the licensee representative that formal response to the violation would still be necessary even though corrective action had been taken.
C The inspector noted that the flow rate for sampling radioiodine in the plant vent (NC-50)
was 7.5 cfm with 2 aux fans and 1 purge fan in -.--
. operation.
The inspector
'expressed concern about the.collection efficiency for radioiodine, especially organic species, at such high, ';
flow rates.
Licensee representatives stated that a 50 per cent collec-
'
f tion efficiency was used, but this factor was apparently.
based on studies conducted when the flow rates were lower and the 'dallection efficiency for organic iodine had not been specifically addressed.
This item shall remain unresolved pending further investigation by the licensee to determine the collection effi'ciency of the charcoal cart-ridges under current operating conditions (250/81-06-.02, 251/81-06-02).
Licensee representatives agreed to finish these tests by July 1, 1981.
This finding will be carried as an inspector followup item and will be reviewed during a subsequent inspection.
d.
The inspector noted that Procedure NC-45 for determination of-tritium in liquid waste release composites did not provide for distillation of all samples to separate the tritiated water from interferences nor did the counting procedure monitor potential interferences from other radionuclides.
The inspector stated that'this could lead to over-reporting of tritium concentrations and that some control should be initiated to prevent this situation from occurring.
A licensee repre-sentative agreed to revise Procedure NC-45 and include distillation of the sample prior to counting (250/81-06-03, 251/81-06-03)
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finding will be. carried as an inspector followup item and will;,be reviewed during a subsequent inspection.
t 7..
Review of Records and Logs a.
The inspector reviewed the following records and logs:
(1)
Ge(Li) Calibration Records for following geometries:
(a)
1-litet Marinelli, 11-16-79.
(b)
100-cc gas bomb, 3-4-80.
(c)
2-inch planchet, 2-5-80.
(d)
1-liter bottle; 1-.28-80.
(e)
100-cc gas bomb 9 3.2 cm, 2-26-80.
(f): glass tritium vial, 2-26-80.
(2)
Daily. Resolution and Energy Checks for Ge(Li) Detectors, 2-3-81 to 3-20-81.
(3)
Daily Efficiency Checks for Ge(Li) Detectors, 2-3-81 to 3-20-81 (4)
Daily Checks for pH, Boron, and Fluoride, February, 1981 (5)
Daily Performance Checks for Gas Flow Proportional Counter, January - March, 1981.
(6)
Daily Performance Checks for Liquid Scintillation Counter, --
January -'ebruary, 1981.
p (7)
Liquid waste Release Spectra, January - Feburary 1981.-
b.
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'L'8)
Plant Vent Particulate Filter and Charcoal Cartridge. Sp'ectra, January - February, 1981.
'l The inspector discussed the review of records and logs with licensee representatives as noted in paragraph 7b.
Procedure QP'. 12.1 of the Florida Power and Light Quality Assurance Manual requires that a complete listing of all M&TE within the scope of the procedure be compiled by the responsible organization and that a
documented system for assuring that M&TE and reference standards are calibration checked and, if required, maintained and calibrated at prescribed intervals shall be implemented.
The inspector determined from licensee representatives that an up to date listing of M&TE for tPe Chemistry Department was not available.
The inspector also determined that the flow rate meter for the waste gas decay tank
,sampling system had not been calibrated since it was installed and was not. on any calibration schedule.
The-accurary of the flow rate meter directly affects the accuracy of the effluent measurements for parti-culate radioactivity and radioiodine associated with releases from the waste gas decay tanks since the integrated flow -is determined frog the product of the measured flow rate and the sample time The i'nspector noted that failure to calibrate or check. the accuracy of the flow meter would not have resulted in inaccurate measurements of total plant effluents since the plant vent monitor is sampled to determine total plant releases for particulate radioactivity and radioiodine.
The inspector informed, licensee representatives that failure to have an up to date list of M&TE equipment with a calibration schedule and failure'o calibrate or check the calibration of the.flow rate meter was a
violation of Technical Specification 6.8. 1 for failure to follow QA Manual Procedure, QP 12.1, "Calibration and Control of Measuring and Test Equipment (250/81-06-04, 251/81-06-04)..
8.
Confirmatory Measurements C
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The results of, H-3, Sr-89, and Sr-90 analyses of a sampl'e collected on March 26, 1980 and results of licensee analyses of a spiked sample were discussed with the license'e.
The results are presented in Table 3. and show agreement for H-3 in the liquid waste sample.
The radiostrontium concentration was too low for a valid comparison so a spiked liquid sample was provided for analysis.
The Sr-89 results were in agreement but the Sr-90 results were significantly'ower and in possible agree-ment.
The inspector stated that this was apparently due to the efficiency calibration technique used by the licensee which does not involve the preparation of separate standards for Sr-89',
Sr-90, and Sr-90/Y-90 'in the same physical geometry as the separated sample.
This was previously identified by the inspector as a potential problem-.-
(250/80-08-02, 251/80-08-02),
and the spiked samples were,pravided to determine the validity of the licensee's method. Since'he results for.-, ",,
analyses of spiked samples were-marginally acceptable, the,.i,inspector informed licensee representatives that the validity of the 0,'fficiency determination would have to be demonstrated or that an acceptable
'lternative efficiency calibration would have to be developed.
The previously identified item will remain open pending licensee investi-gation of this item.
Liquid and gaseous samples were collected during: this inspection and counted by the licensee and the NRC RII Mobile. Laboratory to verify the licensee's capability to measure radionuclides in effluent and reactor coolant samples.
Samples were analyzed by gamma ray spectroscopy and included:
a liquid waste holdup tank sample, reactor coolant sample, crud filter sample, waste gas decay tank sample and -a charcoal cartridge sample.
The crud filter was counted in lieu of a particulate filter since a particulate filter with sufficient activity for analysis was not. available.,
An al.iquot of the liquid sample was sent to the NRC coritract laboratory for tritium and radiostrontium analyses.
The results will be compared to licensee results in a subsequent inspection report. This finding will be carried as an inspector followup item and will be reviewed during a subsequent inspection (250/81-06-05, 251/81-06-05).
The comparisons of licensee and NRC results are presented in Table
with acceptance criteria in Attachment 1.
The results show agreement for all samples except the waste gas decay tank sample and crud filter sample.
The results for Cs-137 associated with the crud filter were not in agreement due to overestimation of the area under the Cs-137 662 KeV photopeak.
This would result in licensee.over reporting for this
.instance.
The licensee is in the process of replacing the current computer-based multichan'nel analyzer system with a "state of the art" system that should correct this problem.
The analysis of the first gas sample showed disagreement for Xe-133, the main constituent in the sample, and a second sample was analyzed.
The results'rom the second sample were in agreement; however, a licensee representative determined that "the -peak search parameters used for analysis of the first sample
'ere different from those normally used for routine counting.
The change in parameters would normally result in oyerestimation of, radio-nuclide concentrations.
The inspector expressed concern that the assignment of parameter s was not controlled to ensure that the appro-priate values were used.
Licensee representatives indicated that. the new system did not require adjustment of parameters to the same degr'ee and that the new procedure would ensure that parameters are properly set.
The inspector noted that gas"standards were not used for calibration of gas geometries and that simulated gas samples were prepared.
The-.-
inspector stated that NBS gas samples were available and.,that when available, NBS Standards 'or NBS relatable standards should-be utilized'.,
for calibrations.
This finding will be carried as an inspector followup'tem (250/81-06-06, 251/81-06-06).
A licensee representati've agreed to implement the use of gas standards as soon as practicable.
This item will be reviewed during a subsequent inspectio d.
During operation of the waste -gas decay tank sampling system; the inspector noted the inadequacy of the flow measuring device.",. The flow meter was mounted on the pump and excessive vibration during sampling made flow measurements difficult to measure.
The inspector noted that this problem was related to the failure to cal'ibrate the flow meter which was a violation as discussed in paragraph 7b.. If the system had been calibrated or calibration checked while operating, this problem would probably have been identified.
A licensee representative indicated that the sampling system; will be modified with a new pump that had previously been'purchased for this purpose.
The licensee agreed to complete modifications of the waste gas decay sampling systems by September 1,
1981 and to correct. the excessive vibration problem associated with the flow meter by April 21, 1981.
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RESULTS OF CONFIRMATORY MEASUREMENTS AT TURKEY POINT, March 1980 CONCENTRATION, MICROCURIES/CC
~aam le
~CBB artson
, Liquid Waste 3-26"80 NRC Spiked II-3 Sr-89 Sr-90 Sr-89 1.6 f"2 2 E-8 C2.8 E-9 3.4 E-3
. ~RC 1.58 k 0.01 E"2 0%1 E-8 OX3 E-9 3.09 i.12 E"3 Ratio Te/PT R G 1. 01 1. 10
~RBBO la lOll 158
Agreement NC NC Agreement Liquid Sample Sr-90 3.7 E-4
'6.2 k 0.'2 E-4
.60
Possible Agreement
'TABLE 2 RESULTS OF CONFIRHATORY HEASUREHENTS AT TURKEY POINT, Harch 1981 CONGE TRATIO HICROCURIES CC Ratio
~eam le QRC ae/pTRO Qeeso le loo
~com artso Waste Holdup Tank 3-19-81 6 0845 Reactor Coolant 3-19-81 6 0850:00 I-131 Co-58 Co-60 Cr-51 Cs-1311 Cs-137 Sb" 124 Sb-125 I-131 1-132 I "133'-134, I-135 Br-84 Cs" 134 Cs-138.
Na-24 4. 6io. 6 E-5 1.3010.02 E'-3 8.010.2 E"4.
2.110.5 E-4 1.7%0
~ 1 E-4 2. 4%0. 1 E-4 1.3fOe1 E-4 1.1%0.2 E-4 1.752.01 E-3 1. 4910. 06 E-2 1.06+0.02 E"2 2.410.2 E-2 1.46%0.08 E-2 5.810.3 E-1 2.0 k 0. 1 E"3 811 E-1 8. 510. 3 E-3 4.3%0.5 E-5
' 1 e 1410. 02 E-3 6. 710. 2 E"4 9.3%3.6 E-5 1.5510.09 E"4 1.9ioa1 E"4 1. 010.5. E-4 1. 010. 4 E"5 1. 44K. 08 E-3 1.302.08 E-2 9. 910. 2 E-3 ND 1.6%0.2 E-2 ND 1.610e1 E-3 ND 7.210.2 E"3 1. 15 1. 14 1.19 2.26 1.10 1.26 1. 30 1. 10 1. 22 1.15 1.07 NC
.91 NC 1. 25 NC 1.18 8.6
33.5 2.6 17.2
22.5
16 49.5
16
Agreement Agreement Agreement Agreement Agreement
'Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement Agreement
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~CUO ariaoo
, Crud Fi I ter 3-20"81 Hn-54 Cr-51 Co-58 Co-60 Zr-95 Nb"95 Tc-99 Te-132 Cs-134 Cs-137 4.6i0.3 E-7 7.5i.2 E-6 2. 6i. 01 E-5 3.9i.07 E"6.
5.3i.09 E-6 3.8i.05 E-6 6.7i".1 E-7 '.
2.4i.1 E-7 1.2i.04 E-6 6.7i.09 E-6 IiRC 4.1i.7 E-7 8.1i.8 E-6 2.6i.03 E-5 4.4i.1 E"6 5.3i.2 E"6 3;7i.1 E-6
'.6.1i,4 E"7 2.3i.5 E"7 1.6i.l E-6 1. 9i. ) E"6 Ratio
~TP NRC 1.12
.92 1.88 1.0 1.02 1. 09 1.04
.75 3.52
~RBBOI U lail 5.9 10. 1 86.6
26.5
15. 25 4.6
19 Agreement Agreement Agreement Agreement Agreement Agreement Ag reement Agreement Agreement
'isagreement Charcoa I
I-131 Car tridge I-133 Plant Vent 3-19-81 0 15.00 3.38K.02 E-4 1.0i0.2 E-4 3. 26i. 01 E-4 6. 5il. 7.E"5 1. 04 1.5 326 3.8 Agreement Agreement Waste Gas Decay Tank
.Sample No.
Xe-133 Kr-85 Kr-85m Xe-131m Xe-133m Xe-135 2.03i.03 E-2 1.3i0.2 E-3 9.7i1.8 E-6 7. 6io. 3 E-4 4.1i0.4 E"5 1. 31io. 07 E-5 1.42i.004 E-2 7 1i312 E-4 ND 5. 1i3.7 E-4 4. 3io. 6 E-5 8.4i0.9 E-6 1.43 355 1.86 2;22 NC 1.49 1.4
.95
'.56
D I sag reement Agreement NC Agreement Agreement Agreement Waste Gas Decay Tank 3-20-81 Sample No.
Xe-133m Xe-133 Xe-135 3.2i0.4 E-5 3.2i0.8 E-5 1.40i0.01 E"5'.29i.004 E-5 5.4i0.5 E-6 3.7i1.2 E-6 Xe-131m 2.42i0.06 E-3 4.4i0.4 E-4
.55
1.0
1. 09
1.46 3.1 Possible Agreement Agreement Agreement Agreement ND - Not Detected, NC - No Comparison
Attachment
CRITERIA FOR COMPARING ANALYTICALMEASUREMENTS
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This attachment provides criteria for tests and verification measurements.
empirical relationship which combines needs of this program.
comparing results of capability The criteria are based on an.
prior experience
'and the accuracy In these criteria, the judgment limits are variable in relation to the 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 NRC REFERENCE VALUE Resolution (34-7 8 15 16-50 51 200
'200
~Areement 0.4 - 2.5 ;0.66 0.75 1.33 0.80 1.25 0.85 1.18 Possible A reement A
0.3 3.0.5.0 0-6 1.66 0.75 1.33 0.80 -- 1.25 Possible A reement B
No Comparisdn 0. 3 3.0.
0.4 2.5.0 0.6 - 1.66 0.75 1.33
"A" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used is greater than 250 Kev.
Tritium analyses of. liquid samples.
for jdentification
"B" criteria. are applied to the following 'analyses:
Gamma Spectrometry where principal gamma energy used is less than 250 Kev.
for identification.
Sr and Sr Determinations.
Gross Beta where samples are counted on the same date using the same reference nuclide.
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