IR 05000261/1980001
| ML14184A209 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 02/22/1980 |
| From: | Jenkins G, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14184A205 | List: |
| References | |
| 50-261-80-01, 50-261-80-1, NUDOCS 8004140480 | |
| Download: ML14184A209 (8) | |
Text
_ o5 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report No. 50-261/80-1 Licensee:
Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: H. B. Robinson 2 Docket No. 50-261 License No. DPR-23 Inspection at Robinson site near Hartsville, South Carolina Inspector:
0.,A, c
D. M. Montgomery Da e Signed Accompanying Personn : P. C. McPhail Approved b P4
.
nkins, Section Chief, FFMS Branch Date Signed SUMMARY Inspection on February 4-7, 1980 Areas Inspected This routine, unannounced inspection involved 34 inspector-hours onsite in the areas of quality control and confirmatory measurements: including review of the laboratory quality control program; audit results; review of chemical and radio chemical procedures; and comparison of the analyses of split samples analyzed by the licensee and the NRC Region II Mobile Laborator Results Of the four areas inspected, no apparent items of noncompliance or deviations were identified in three areas; one apparent item of noncompliance was found in one area (Infraction - failure to have and follow written approved procedures for radiochemical measurements (261/80-01-61, paragraph 7b)).
80 04140
DETAILS Persons Contacted Licensee Employees
- R. B. Starkey, Jr., Plant Manager
- S. Zimmerman, Manager, Technical and Administration
- D. S. Crocker, Environmental and Radiation Control Supervisor
- J. A. Eaddy, Senior Generation Specialist
- W. L. MacCready, Health Physics Engineer W. T. Ritchie, RCT Foreman C. Bethea, Training Supervisor W. Garrison, Quality Assurance Supervisor Other licensee employees contacted included six technician *Attended exit interview Exit Interview The inspection scope and findings were summarized on February 7, 1980, with those persons indicated in Paragraph 1 abov The Plant Manager acknowledged the item of noncompliance and stated that procedures would be written or updated to meet the requirement The licensee agreed to perform the analyses referred to in Paragraph 9 and report the results to NR.
Licensee Action on Previous Inspection Findings Not inspecte.
Unresolved Items Unresolved items were not identified during this inspectio.
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 Program The quality control program for chemistry and radiochemistry is detailed in Volume 8 of the Radiation Control and Protection Manual, Appendices II and III. The overall responsibility for laboratory quality control is assigned to the Environmental and Radiation Control (ERC) superviso The ERC supervisor has the responsibility for instructions and reviews necessary to ensure implementation of the procedure The Radiation Control and Test Foremen are responsible for implementation of the
-2 specific quality control procedures in their respective area In addition, the Quality Assurance Supervisor is responsible for assuring that the plant's program meets regulatory codes, standards, and corporate QA requirement Provisions for Audits/Inspections The inspector noted that there are no specific procedures or require ments for audits or inspections by the E&RC Superviso Technical Specification 6.5.4 requires audits of the plant activities by Corporate Quality Assurance, but there are no specific frequency requirements for chemistry and radiochemistr In addition, surveillance activities are carried out by the Operations Quality Assurance to ensure that procedures are being followe Methods for Assuring Deficiencies and Deviations In The Program Are Recognized, Identified, and Corrected The specific quality control checks for laboratory equipment are detailed in Appendices II and III of Volume 8 of the Radiation Control and Protection Manua The acceptance criteria for particulate counters and the Ge(Li) gamma spectroscopy systems are given, but there are no specific requirements to ensure that corrective actions are taken other than contacting the RC&T Forema d. Requirements For Purchase or Contracted Services There are no purchased or contracted services for laboratory analyses in the chemistry and radiochemistry area.
Audit Results The inspector reviewed the results of Corporate Quality Assurance audits, QAA/20-16 and QAA/20-19, which were dated July 1978 and November 1979, respectivel The inspector noted that corrective action had been initiated for deficiencies identified in the audits and that the audit results and corrective actions were reviewed and approved by the Plant Manager and QA Superviso The results of Operation QA Surveillance Reports, QAS-78/20 (October 4, 1978) and QAS-79/35 (June 18, 1979) were reviewe The inspector had no further question.
Review of Radiochemical Procedures The inspector reviewed the following procedures:
(1)
Chemistry Procedure P-4400, "Quality Control", Rev. 10-26-7 (2)
Chemistry Procedure P-4404, "Measurement of Conductivity", 1-5-7 (3)
Chemistry Procedure P-4412-B,
"Chloride Determination In High Purity Water", Rev. 8-15-7 (4)
Chemistry Procedure P-4410, "Boron Determination", Rev. 10-26-7 (5) Chemistry Procedure P-4430, "Determination of Dissolved Oxygen by Indigo Carmine", Rev. 12-16-7 (6)
Chemistry Procedure P-4503, "Radioiodine", Rev. 3-20-7 (7) Chemistry Procedure P-4504, "Radiogases", Rev. 8-26-7 (8) Procedure P-5102, "Determination of Absolute Particulate Activity",
10-16-7 (9) Procedure P-5201,
"Preparation of Samples For Counting In The Liquid Scintillation Counter", 10-16-7 (10)
Procedure P-5202, "Counting A Sample In The Liquid Scintillation Counter", 10-16-7 (11)
Procedure P-5301,
"Gamma Spectrometer Activity Determination",
10-16-7 (12)
Procedure P-5401, "Standard Source Preparation", 10-16-7 (13)
Procedure P-5404,
"Determination of General Efficiencies of Particulate Counters", 10-16-7 (14) Calibration of Packard Liquid Scintillation Counter, Procedures P-5407 - P-5410, 10-16-7 (15)
Procedure P-5501,
"Quality Control For Particulate Counters",
10-16-7 (16)
Procedure P-5502, "Determination of System Reliability", 10-16-7 (17)
Procedure P-5503, "Determimation of Chi-Square", 10-16-7 (18)
Procedure P-5504, "Quality Control for the Gamma Spectrometer",
10-16-7 (19) Environmental Surveillance Procedure ES-3, "Liquid Waste Release Procedure", Rev. 12-18-7 (20) Environmental Surveillance Procedure ES-4,
"Gaseous Effluent Accountability", Rev. 12-18:7 The inspector reviewed the licensee implementation of procedures for the analysis of liquid and gaseous effluent Based on discussions with licensee representatives on February 5, 1980, it was determined that the following approved procedures were not being adhered to:
P-4503, Radioiodine; P-5102, Determination of Absolute Particulate
-4 Activity; and P-5202, Counting a Sample in the Liquid Scintillation Counter. Licensee representatives stated that the procedures were not being followed because new instrumentation or measurement techniques had replaced approved procedures, but new procedures had not been implemented. The inspector also noted that there was no written and approved procedure for operation of the Ge(Li)
gamma spectroscopy syste The inspector informed licensee representatives that this constituted an item of noncompliance with Technical Specification 6.8.1 that requires written procedures and administrative policies be established, implemented, and maintaine Licensee representatives acknowledged the item of noncompliance and stated that procedures would be written and implemented to correct the identified deficiencies (261/80-01'-01). The inspector noted that a chemical reagent had been changed in Proce dure P-4416, "Silica By Heteropoly Blue" without review and approval by the responsible individua The change had been noted in the Chemistry laboratory copy with no indication of approval or concurrenc A licensee representative acknowledged that changes should not be made without approval and that the laboratory personnel would be instructed to adhere to the written procedure The inspector had no further questions regarding this ite The inspector noted that the calibration program for laboratory equip ment does not meet the requirements of Chapter 6 of the Corporate Quality Assurance Manua This was identified by the licensee in a Quality Assurance Audit, QAS-79/28B and identified as an open item in IE Report No. 261/79-09, dated October 1979. Licensee representatives stated the calibration procedures are being written and will be completed by March 31, 198 The inspector verified that certified standards were used for calibration of Ge(Li) detectors, particulate counters, and the liquid scintillation counte The inspector had no further questions regarding this item at this tim The inspector noted that the Liquid Waste Release Procedure, ES-3 did not include instructions regarding the preservation or handling of liquid effluent samples to ensure the integrity of the samples during the time between sample collection and analyse The Gaseous Accounta bility Procedure, ES-4 did not have any provisions for documenting sampling times and flow rates to ensure that the proper sample volume was used in calculation The inspector was informed that these concerns would be addressed in their response to the item of noncompliance, paragraph 7b (261/80-01-02). Review of Instrument Records and Logs The inspector reviewed selected sections of the following records and logs: Gaseous Waste Release Permits (December 1978 - December 1979).
-5 Liquid Effluent Permits (December 1978 - December 1979). Quality Control Records for Beta and Alpha Counters, P-5501 (January 1978 - December 1979). Gamma Spectrometer Quality Control Records, P-5504 (January 1978 December 1979).
e. Particulate Instrument Quality Control Monthly Report (January 1978 December 1979).
The inspector verified that liquid and gaseous permits had been approved by the ERC Supervisor and Shift Foreman as required, and had no further question.
Confirmatory Measurements Liquid and gaseous effluents samples were collected during this inspec tion and counted by the licensee and the NRC Region II Mobile Laboratory to verify the licensee's capability to measure radionuclides in effluent samples. Samples were analyzed by gamma ray spectroscopy and included a liquid waste tank, primary coolant, waste gas decay tank, charcoal cartridge, and particulate filte An aliquot of liquid waste sample was also sent to the NRC Contract Laboratory for H-3, Sr-89, SR-90, and gross beta analyse The results will be compared to licensee measurements in a later inspection repor The comparison of the licensee and NRC analyses by gamma spectroscopy are given in Table 1 with the acceptance criteria in Attachment The results show agreement for all analyses except Xe-133 in the Waste Gas Decay Tank Sampl The licensee's analysis was significantly higher than the NRC valu The licensee's calibration for gases utilizes a liquid standard with no correction for attenuation which would result in overestimation of gaseous radionuclides with low energy gamma ray The inspector informed a licensee representative that the disagreement was apparently due to the method of calibration and that the level of accuracy for measurement of Xe-133 was unacceptabl The inspector also noted to a licensee representative that their method for measuring of H-3 in liquids may overestimate the H-3 concentration since the tritium sample was not prepared by distillation and no correc tions were made for other radionuclides in the sampl A licensee representative informed the inspector that the gas calibration method and tritium procedure would be reviewed and corrected (261/80-01-03).
Attachment I
CR1TERIA FOR COMPARTNG ANALYTICAL MEASUREMENTS This attachment providen criteria for comparing results of capability tests and verification measurement The criteria are based on an empirical relationship which ombines prior experience and the accurney'
needs of this progra in these criLteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory'E value to its associated uncertaint As that ratio, referred to in this program as "Resolution",
increases, the acceptabitl y of a licensee's measurement should be more selectiv Conversely, poorer agreement must be considered acceptable as the resolution decrease RATIO -- LICENSEE VALUE NRC REFERENCE VALUE Possible Possible Resolution Agreement Areement A Areement B
<3 0.4 -.3 - No Comarison 4 -
0.5 -.4
-.3 -.6 -
1.66 0.5 -.4 -.75 -
1.33 0.6 -
1.66 0.5 -.80 -
1.25 0.75 -
1.33 0.6 -
1.66
>20-0 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:
Gaima Spectrometry where principal gamma energy used for identification is less than 250 Ke Sr and 90Sr Determination Gross Beta where samples are counted on the same date using the same reference nuclid TABLE 1 Results of H. B. Robinson Confirmatory Measurements, February 4-7, 1980 Concentration, pCi/cc Sample Isotope Robinson NRC Robinson/NRC Comparison Liquid Waste H-3 6.16+0.02E-2 NR1 No Comparison 2-5-80 Co-60 1.23+0.15E-5 1.00+0.06E-5 1.23 Agreement
&
in Coolant Xe-135 4.0+l.4E-4 ND2 No Comparison 2/7/80 @
1-134 9.0+0.3E-3 8.5+0.5E-3 1.06 Agreement 8:06 Cs-138 7.2+0.9E-3 9.1+0.7E-3 0.79 Agreement 1-132 4.5+0.2E-3 5.3+0.2E-3 0.85 Agreement 1-133 3.09+0.15E-3 3.8+0.lE-3 0.81 Agreement 1-135 6.8+0.5E-3 6.6+0.6E-3 1.03 Agreement CO-58 3+1E-4 ND No Comparison Na-24 1.29+0.02E-2 1.30+0.01E-2 0.97 Agreement Charcoal Cartridge 1-131 8.4+2.3E-11 7.4+0.9E-11 1.14 Agreement 2/6/80 @ 13:45 1-133 2.5+0.5E-10 2.4+0.2E-10 1.04 Agreement Particulate Filter Cs-138 2.8+0.06E-10 ND No Comparison 2/6/80 @ 15:50 1-133 8.5+4.8E-11 7.5+1.6E-11 1.13 Agreement Na-24 3.01+0.15E-9 4.0+0.lE-9 0.75 Agreement Waste Gas Decay Tank Xe-133 4.18+0.08E-4 2.15+0.02E-4 1.94 Disagreement 2/6/80 @ 15:50 Notes:
1 Not reported, sample will be analyzed for H-3 and reported at a later dat Not Detected, the detection limits for analyses varied between NRC and licensee due to differences in counting time and sample geometry.