IR 05000250/1982019

IE Insp Repts 50-250/82-19 & 50-251/82-19 on 820412-16. Noncompliance Noted:Failure to Continuously Sample for Radioiodines & Particulate Activity at Condenser Air Ejector Exhaust

ML20055A021
Person / Time
Site:	Turkey Point
Issue date:	05/14/1982
From:	Evans C, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20055A010	List: IR 05000250/1982019 L-82-255, Responds to NRC Re Violations Noted in IE Insp Repts 50-250/82-19 & 50-251/82-19.Corrective Actions: Sampling Sys Installed to Continuously Monitor Air Ejector Exhausts When Primary to Secondary Leaks Occur ML20055A009 ML20055A017 ML20055A018
References
50-250-82-19, 50-251-82-19, NUDOCS 8207150397
Download: ML20055A021 (10)

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<,9 o UNITED STATES 8 '1 NUCLEAR REGULATORY COMMISSION g a REGION 11 o, 101 MARIETT A ST., N.W., SUITE 3100 b[ ATLANTA, GEORGIA 30303

• • • • • j Report Nos. 50-250/82-19 and 50-251/82-19 Licensee: Florida Power and Light Company P. O. 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 Tufr ey Po nt sit 9 nsh Homestead, FL Inspector:_

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C. . Evan's

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/f fi~Date Signed Accompanying Personnel: P. McPhail Approved by: h . jy1 EL' m h/// )

Dat'e Signed D. M. Montg6merg, ChiqJ, IM&EP Section EPOS Division SUMMARY Inspection on April 12-16, 1982 Areas Inspected This routine, unannounced inspection involved 37 inspector-hours on site in the areas of quality control and confirmatory measurements including; review of the laboratory quality control program, review of chemistry and radiochemistry procedures, review of quality control records and logs, review of airborne effluent accountability and sampling techniques, and comparison of the results of split samples analyzed by the licensee and the NRC RII Mobile Laborator Results Of the five areas inspected, no violations or deviations were identified in four areas; one violation was found in one area (failure to continuously sample for radioiodines and particulate activity at the Condenser Air Ejector Exhaust, paragraph 7c).

8207150397 820707 PDR ADOCK 05000250 G PDR L

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REPORT DETAILS Persons Contacted Licensee Employees

• H. E. Yaeger, Site Manager

• J. K. Hays, Plant Manager - Nuclear

• S. M. Feith, QA Operations Supervisor

• D. W. Jones, QC Supervisor

• D. W. Haase, Operations Superintendent

• J. S. Wade, Chemi stry Supervisor

• E. R. Lapierre, Radiochemi st

• F. J. Schmitt, Counting Room Technician

• Attended exit interview Exit Interview The inspection scope and findings were summarized on April 16, 1982, with those persons indicated in paragraph 1 above. The inspector stated that the absence of a continuous sampling device for particulate activity and radio-iodines at the Condenser Air Ejector (CAE) Exhaust would be an unresolved item pending further interpretation of regulatory requirements by the regional staff. On April 29, 1982, Dr. D. M. Montgomery of NRC:RII notified the Nuclear Plant Manager by telephone that failure to sample continuously for particulate activity and radioiodines at the CAE exhaust was a violation rather than an unresolved item. The Nuclear Plant Manager acknowledged the violation and stated that an appropriate response to the Notice of Violation would be mad . Licensee Action on Previous Inspection Findings (0 pen) Infraction (250/81-06-04, 251/81-06-04) Failure to follow Quality Assurance Procedure QP.12.1 for calibration of M&T The inspector noted that the Chemistry Section was in the process of finalizing a procedure documenting and scheduling calibrations of all M&TE within the scope of the i

Chemistry Sectio Licensee representatives indicated that the procedure

should be approved before June 1, 1982. This item will remain open pending implementation of the procedur (Closed) Unresolved (250/81-06-02, 251/81-06-02) Determination of the collection efficiency of the charcoal cartridges under operating condition The inspector noted that the licensee had changed to TEDA impregnated charcoal cartridges which have a F ;gh efficiency for organic iodine specie The charcoal cartridges are also batch tested by the vendor for collection ef ficiency versus flow rat From the results of the batch testing, the licensee is able to use a collection efficiency factor which is representa-tive of the actual sampling conditions for the process ven _ ___. . _ _ - . - ._ .-. - . _ _ _ _ _ . _. - ._ _

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i (Closed) Infraction (250/80-08-01, 251/80-08-01) Failure to have and follow

! written procedures for radiochemistry counting equipment. Tne inspector I

reviewed the procedure for performance checks and efficiency calibration of t the gamma spectroscopy system. The inspector noted that daily performance i

checks and annual ef ficiency calibrations were being implemente . Unresolved Items Unresolved items were not identified during this inspectio ,

5. Laboratory Quality Control Program The inspector reviewed the licensee's quality control program for chemical and radiochemical measurements in the following areas: Assignment of Responsibility and Authority to Manage and Conduct the QC *

Progra ,

The quality control program for chemistry and radiochemistry is detailed in the plant Nuclear Chemistry procedure The Chemistry '

Supervisor has been assigned the responsibility to develop and implement procedures covering all aspects of the chemistry program including quality control and testing method The Chemistry Supervisor also serves as the Quality Control Coordinator for the Radiochemistry Departmen ' Provisions for Audits / Inspections Administrative Procedure 0190.70, "QC Surveillance of Nuclear Safety

, Related Activities" provides for quality control surveillance to assure

that plant systems and components are tested, operated, controlled and maintained in accordance with requirements as specified by applicable plant procedure The Quality Control Supervisor is responsible for

scheduling, carrying out, and reviewing surveillances.

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) Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Corrected.

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The Chemistry Supervisor is responsible for identifying and correcting deficiencies that are identified in the Quality Control program. The Quality Control inspectors are also responsible for ensuring that open surveillance items are resolved in a timely manne The nuclear chemistry procedures specify various performance checks and acceptance ,

criteria for chemistry and radiochemistry instrumentatio Quality Control of Purchased and Contracted Analyses No chemical or radiochemical analyses are contracted to outside ,

vendor Analyses of liquid ef fluent samples for radiostrontium are performed in plan i

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3 . Review of Chemistry and Radiochemistry Procedures l The inspector reviewed the following procedures:

(1) NC-45, " Determination of Tritium Activity for Liquid Release

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Composites", 7-30-8 l (2) NC-71, " Sampling and Analysis of Radionuclides Discharged Through  ;

The Condensor Air Ejector System", 10-23-8 '

(3) NC-70, " Primary to Secondary Leak Detection", 8-7-7 (4) NC-132, " Determination of Total Hardness - EDTA Titration",

3-28-81.

, (5) NC-52, " Sampling and Analysis Preparation and Documentation of Waste Gas Decay Tank Releases", 4-2-8 l

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(6) NC-20, " Instrumentation Performance Evaluation", 11-30-7 t (7) NC-258, " Gamma Spectrometer Efficiency Calibration for Various Geometries Using Radioactive Standards", 4-10-8 (8) NC-6, " Sample System - Normal Operation", 3-4-82.

(9) NC-21A, "N06620 System Turn On to Full Shutdown",1-21-8 ;

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t (10) NC-41, Determination of Sr-89/90 Activity in the Monthly Liquid Release Composite", 7-30-8 (11) NC-53, " Exchange of Plant Vent and Unit 3 Spent Fuel Pit  !

Particulate and Iodine Filter Cartridges, Analysis and i Documentation of Results", 7-30-8 ;

l The procedure review was discussed with licensee representatives as f j discussed in paragraph ' The inspector noted that Procedure NC-45 for determination of tritium in liquid waste release composites had been changed to provide for '

distillation of all samples to separate the tritiated water from interfering radionuclides. This closes a previously identified item ,

(50-250/81-06-03. 251/81-06-03).

7. Review of Records and Logs The inspector reviewed the following records and logs:

(1) Geometry Efficiency Curves (a) 100cc - Gas Chamber, April 7,198 . .

(b) CP-100 Charcoal Cartridge, April 4,198 (c) 1-liter Marinelli, April 1,198 (2) Daily Performance Checks for Geli Detectors; March 15 - April 13, 198 (3) Steam Generator Composite Samples Unit 4; July, 1981 to April 198 (4) Condenser Air Ejector (Noble Gas, Particulate, Iodine) Release Permits; July 1981 to Apri1 198 (5) Containment Purge No. 4 Release Permit,198 (6) Geli Detector No. 2 Background; March 15 - April 13,198 The inspector discussad the review of records and logs with licensee representatives as noted in paragraphs b- The inspector reviewed recent Geli detector backgrounds and noted that Co-60 was present above acceptable levels in the detector shield. The inspector discussed with licensee representatives the need for decontamination of the shield. A licensee representative indicated that they would attempt to decontaminate the shield with a chemical solution in the near futur This area will be reviewed in a subsequent inspection (50-250/82-19-01, 251/82-19-01) . The inspector noted that the Condenser Air Ejector Exhaust (CAE) was sampled for radiciodine and particulate activity by taking a 10 minute grab sample once a week when secondary coolant activity indicated primary to secondary leakage. The grab sampling technique consisted of holding a particulate filter and charcoal cartridge sampling device attached by a mop handle to the exhaust of CA The inspector noted that weekly grab samples would not be representative of the effluent discharged from the CAE Exhaust. Review of the CAE sampling log revealed that the licensee had taken 22 grab samples during the period of April 1981 to April 1982. The inspector noted that several of the CAE charcoal grab sample analyses showed concentrations of I-131 in the range of 4 to 6 E-10 microcuries/cc and that the steam generator composite samples showed concentrations of I-131 as high as 1 E-05 microcuries/cc. The inspector noted that Technical Specification 3.9.2.i requires that sampling and analysis be performed in accordance with AEC Safety Guide No.21, " Monitoring and Reporting of Effluents from Nuclear Power Plants", which specifies that releases which potentially contain particulate activity and radiciodines should be sampled continuously through a particulate filter and charcoal cartridge sampling devic The inspector informed licensee repre-sentatives that failure to continuously sample for radiciodines and particulate activity at the Condenser Air Ejector Exhaust was a violation of Technical Specification 3.9. (250/82-19-02, 251/82-19-02).

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5 The inspector examined the modifications made by the licensee to the Waste Gas Decay Tank sampling system. The modifications consisted of the relocation and replacement of the rotameter to permit more accurate flow measurements. The inspector noted that the new rotameter had been designed with a short vertical tube and scaled for large flow rate The use of this rotameter for WGDT sampling is inappropriate because of the poor accuracy for measurement of flow rates normally i

used for sampling. The inaccuracy of the rotameter could result in 20 percent error in the total volume sampled. The inspector expressed concern at the lack of quality control exhibited in the seleccion of the rotameter, and the effect that the rotameter inaccuracy might have on measuring release A licensee representative agreed to review this area of concern. This area will be examined during a subsequent inspection (250/82-19-03, 251/82-19-03) .

8. Confirmatory Measurements 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, containment gas sample, and a containment charcoal cartridge. The crud filter was counted in lieu of a particulate filter since a particulate filter with sufficient activity for analysis was

.not availabl The compa ri son s of licensee and NRC results are presented in Table 1 with acceptance criteria in Attachment The results show agreement for all samples except the containment charcoal cartridge and containment gas which are discussed in paragraphs 7b and 7c respectively. An aliquot of the liquid sample was sent to the NRC

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contract laboratory for tritium and radiostrontium analyse The results will be compared to licersee results in a subsequent inspection report (250/82-19-04, 251/82-19-04). The results of the two charcoal cartridge comparisons showed that the licensee values were approximately 50 percent higher than the NRC results for all identified radioiodines. The inspector examined the last two efficiency curves and noted that the data points for Hg-203 and Sn-114 of the mixed gamma calibration standard where higher in percent efficiency than would have been expected by the linear relationship of the other nuclide data point The inspector noted that little detail was recorded on the preparation of the charcoal cartridge calibration standard and that some questions existed as to the exact technique used for its preparation. Licensee representatives agreed to revise the calibration preparation procedure to include more detail on how the standards are prepared. Possible causes of the l

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higher values by the licensee may be attributable to the volatilization of Hg-203 and the depth of spiking into the charcoal cartridge with the calibration standard. Licensee representatives indicated that they would prepare another charcoal calibration standard and recalibrate the GeLi detectors as soon as possible. The inspector requested that the licensee dynamically load a charcoal cartridge with radiciodine from containment and analyze the cartridge by gamma ray spectroscopy after recalibration of the GeLi detectors; and that the loaded charcoal cartridge and the licensee's results be sent to NRC:RII for comparison (250/82-19-05, 251/82-19-05). The results of the two containment gas sample comparisons showed that licensee results were approximately 25 percent higher than NRC results for all identified noble gases. During the previous inspection, the inspector had identified the need for calibration of gas geometries with gas standards. The inspector noted that the licensee had recently received a NBS mixed gas standard of Kr-85, Y.e-127, and Xe-131; and that recalibration of the GeLi detectors with gas standards was in progres The gas calibrations will be reviewed in a subsequent inspection (250/81-06-06, 251/81-06-06). The inspector reviewed licensee results for H-3, Sr-89 and Sr-90 analyses of a spiked sample prepared by the NRC contract l aborato ry .

The comparison of licensee results with the values of the spiked sample are given in Table 2, with acceptance criteria in Attachment The comparisons show " agreement" for H-3 and Sr-90, but "possible agree-ment" for.Sr-89. The inspector noted that the efficiency determination in Procedure NC-41, "Determinatin of Sr-89/90 activity in the Monthly Liquid Release Composite", did not involve the preparation of separate standards for Sr-89, Sr-90, and Sr-90/Y-90 in the same geometry as the separated sample. A licensee representative agreed to revise the efficiency determination in the procedure, and to analyze another spiked sample to be provided by the NRC. This was a previously identified item and will remain open pending licensee completion of the revised procedure and results from the spiked sample (250/80-08-02, 251/80-08-02).

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TA8LE 1

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RESULTS Of CONflRMATORY MEASUREMENTS AT TURKEY POINT, APRIL 15, 1982 CONCENTRATICN, MICROCURIES/C *

SAMPLE NUCLIDE LICENSE 1 NPC RATIO RESOLUTION COMPARIS0y Containment I-131 5.05 E-8 3.38 i .04 E-8 1.49 77 Disagreement Cha rcoa l Cartridge 1-133 5.33 E-9 .2 E-9 1.44 20 Possible Agreement Containment 1-131 5.21 E-8 3.37 .03 E-8 1.54 99 D i sa g reemen t Cha rcoa l Ca rt r i dge 1-133 5.58 E-9 3.7 1 E-9 1.50 16 Possible Agreement Containment cas Xe-133 2.122 E-03 1.74 1 0.01 E-03 1.21 871 Possible Agreement 1260 ML Ma rinell i Xc-133m 2.288 E-05 1.73 i .05 E-05 1.32 32 Ag reemen t Xe-135 2.249 E-05 1.59 .01 E-05 1.41 113 D i sag reement Containment Xe-133 2.11 E-03 1,73 i .01 E-03 1.22 192 Ag reement Gas 25cc vo Xc-135 2.33 E-05 1.79 i .08 E-05 1.30 22 Ag reemen t Xe-133m 2.215 E-05 1.9 i .4 E-05 1.16 Ag reemen t C rud Co-58 2.70 E-5 2.36 i .03 E-7 1.14 7 Agreement Co-60 4.60 E-6 4.3 i .1 E-6 1.07 4 Ag reemen t Z r-95 4.06 E-6 3.6 i .1 E-6 1.11 3 Ag reemen t Mn-54 4.85 E-7 5.4 i .5 E-7 .90 1 Ag reemen t 1-13 1.30 E-5 1.05 i .05 E-5 1.23 21 Ag reemen t Cr-51 2.76 E-5 2.2 i .1 E-5 1.27 2 Ag reemen t Cs-137 1.17 E-6 .8 E-7 1.27 1 Ag reemen t RCS Cs-137 8.97E-4 1.2 i .2 E-3 .75 6 Ag reemen t Cs-138 1.02 E-1 1.1 i .1 E-1 .92 11 Ag reemen t 1-131 8.30 E-2 8.82 i .09 E-2 .94 98 Ag reement 1-132 4.43 E-2 4.93 i .09 E-2 .89 54 Ag reemen t 1-133 1.60 E-1 1.65 i .01 E-1 .96 165 Ag reement 1-135 8.10 E-2 7.7 i .2 E-2 1.04 38.65 Ag reement Liquid Effluent Co-58 3.86 E-4 3.90 i .09 E-4 .98 43 Ag reement Co-60 1.90 E-3 1.86 i .02 E-3 1.02 93 Ag reement Cs-137 1.69 E-4 1.65 i .07 E-4 1.02 2 Ag reemen t 1-131 5.98 E-4 6.03 i .08 E-4 .99 75 Ag reement I-133 2.31 E-4 2.19 i .06 E-4 1.05 3 Ag reement

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RESULTS OF CONilRMATORY MEASUREMENTS AT TURKEY POINT, 4/15/82 CONCENTRATION, MICROCURIES/C ,

SAMPLE NUCLIDE LICEt4SEE f1RC RATfD REsotUTION COMPARISON Spiked Sample H-3 S.50 E-03 6.22 i .06 E-03 0.88 103 Ag reemen t from NRC S r-89 4.80 E-03 7.38 .008 E-03 0.65 92 Possible Agreement Con t ra c t La bo ra to ry Sr-90 6.60 E-04 S.87 i .24 E-03 1.12 25 Ag reement

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Attachment 1 CRITERIA FOR COFfPARING ANALYTICAL MEASUREMENTS This attachment provides .riteria 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 progra In these criteria, the judgment limits are variabic in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertaint 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 decrease *

LICENSEE VALUE SRC REFERESCE VAlUE Possible Possible Resolution Agreement A3 reement A Agreemen t B

<3 0.4 - .3 - No Comparison 4-7 0.5 - .4 - .3 - .6 - 1.66 .0 0.4 - .75 - 1.33 .66 0.5 - .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:

Gamma Spectrometry where principal gamma energy used for identification is greater than 250 Ke Tritium analyses of liquid sample "B" criteria are applied to the following analyses:

Gamma Spectrometry where principal gamma energy used for identification is less than 250 Ke 'Sr and '8Sr Determination Gross Beta where samples are counted on the same date using the same reference nuclide.