IR 05000261/1981020

IE Insp Rept 50-261/81-20 on 810721-23.Noncompliance Noted: Failure to Review & Approve Changes in Procedure for Calibr of Germanium (Lithium) Counting Sys

ML14176A673
Person / Time
Site:	Robinson
Issue date:	08/10/1981
From:	Evans C, Montgomery D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14176A669	List: IR 05000261/1981020 ML14176A671
References
50-261-81-20, NUDOCS 8109290577
Download: ML14176A673 (8)

Text

o UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report No. 50-261/81-20 Licensee:

Carolina Power and Light 411 Fayetteville Street Raleigh, North Carolina 27602 Facility Name:

H. B. Robinson 2 Docket No. 50-261 License No. DPR-23 Inspection at Robinson Site near Hartsville, South Carolina Inspectors:

2.-

D. M. Mon omery Date Signed C. D. Evans Date Signed Accompanying Personn :

C. McP ail S Approved/

X,'r J Philip hr, EPOS Branch Chief D'ate Signed SUMMARY Inspection on July 21-23, 1981 Areas Inspected This routine, unannounced inspection involved 36 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 radiochemical 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 violations or deviations were identified in three areas; one violation was found in one area (failure to review and approve changes in procedure for calibration of Ge(Li) counting system, paragraph 7e).

8109290577 810924 PDR ADOCK 05000261 G

PDR'

REPORT DETAILS 1. Persons Contacted Licensee Employees

• H. S. Zimmerman, Acting General Manager

• D. S. Crocker, Manager Environmental and Radiation Control

• C. L. Wright, Specialist-Regulatory Compliance

• J. A. Eaddy, Jr., Environmental and Chemistry Supervisor

• B. J. Sanza, Associate Engineer

• H. F. Watkins, Foreman, Environmental and Chemistry J. M. Hill, Technician

• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 23, 1981 with those persons indicated in paragraph 1 above. A licensee representative acknowledged the item of noncompliance and agreed to perform the analyses referred to in paragraph 9 The inspector requested that the licensee provide an area with power receptacles for the NRC Mobile Laborator A licensee representative agreed to provide the requested services by October 1, 198.

Licensee Action on Previous Inspection Findings Closed infraction (80-01-01) Failure to have a written approved procedure for operation of the Ge(Li) system and failure to follow approved procedures for radiochemical analyses. The inspector reviewed the approved procedure for operation of the Ge(Li) system and noted that new procedures had also been written and implemented for radiochemical analyses associated with effluent release This item is close. Unresolved Items were not identified during this inspectio.

Laboratory Quality Control Program a. Assignment of Responsibility to manage and conduct the QC Progra The inspector reviewed changes in the organization since the previous inspection. The inspector determined from discussions with licensee representatives that the Environmental and Radiation Control Organization is being reorganized and that the new organization will provide for additional manpower in this are Overall responsibility

will rest with the Environmental and Radiation Control Manage The Environmental and Chemistry Supervisor will have the responsibility for management of the environmental monitoring and plant chemistry progra The quality control program is detailed in Volume 8 of the Radiation Control and Protection Manual, Appendices II and II The Environ mental and Chemistry Foreman is responsible for implementation of the specific quality control procedures to ensure the validity of chemical and radiochemical analyse The inspector determined from procedure review and discussions with licensee representatives that the reorganization will provide an equivalent or higher level of management control than the previous organizatio b. Provisions for Audits/Inspections The inspector noted that there are no provisions for audits or inspec tions of this area by Environmental and Radiation Control Managemen Technical Specification 6.5.4 requires audits of 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 plant Quality Assurance staff to ensure that procedures are being followe Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Correcte Specific quality control checks for laboratory and counting equipment are detailed in Appendices II and III of Volume 8 of the Radiation Control and Protection Manual., Acceptance criteria for the quality control checks are provided with corrective actio Malfunction of equipment is documented as necessary in procedure RCP-16, "Instrument Nonconformance Reports."

d. Requirements for Purchased or Contracted Services There are no purchased or contracted services for laboratory analyses in the chemistry and radiochemistry progra Analyses of radioactive liquid effluents for Sr-89 and Sr-90 are provided by the Harris Environmental Center which has a quality assurance program for radiochemical analyse. Audit Results The inspector reviewed QA Surveillance Report, QAS-81/1 This report identified the lack of procedures for calibration of flow meter The inspector verified that corrective action has been initiated to provide for calibration of the air flow meter.

Review of Radiochemical Procedures The inspector reviewed the following procedures and discussed the review with licensee representatives as noted in paragraphs 7b -

7 (1) CP-1 "Chemistry Monitoring Program", Rev. 0, 8-27-81 (2)

CP-2, "Calibration Control", Rev. 0, 2-28-80 (3)

CP-3, "Systems Sampling Procedure", Rev. 1, 9-2-80 (4)

CP-5,

"pH Determination", Rev. 0, 1-31-80 (5)

CP-6, "Mettler Balance Procedure", Rev. 0, 2-28-80 (6)

CP-7 "Boron Determination", Rev. 0, 2-28-80 (7)

CP-8, "Chlorides by Mecuric Nitrate Titration", Rev. 0, 10-9-80 (8)

RCP-1. "Calibration of GeLi Spectroscopy System", Rev. 5, 1-22-81 (9) RCP-17, "Operation of Nuclear Data GeLi Spectroscopy System", Re, 1-22-81 (10) RCP-14, "Tritium Sample Preparation and Analysis", Rev. 0, 3-4-81 (11) ES-3, "Liquid Waste Release Procedure," Rev 3, 5-15-81 (12) ES-4, "Gaseous Effluent Accountability", Rev 6, 3-24-81 b. The inspector noted that procedures ES-3 and ES-4 for liquid waste and gaseous effluent accountability had been revised to address sample integrity for liquids and documentation of sampling time and flow rates for gaseous samplin This closes a previously identified item (261/80-01-02),

c. The inspector identified the following areas of concern regarding the procedures for operation and calibration of the Ge(Li) counting system:

(1) the performance tests are conducted Monday through Friday and do not provide assurance of operability when in use on weekends and holidays; (2) background checks are not specified in operating proce dures. (3) resolution *checks are not specified in operating procedures; (4) operating procedures do not limit dead time to preclude pulse pileup losses which affect the accuracy of measurements; and (5) the calibration procedure does not provide for calibration of the detector at various distances from the detector surface to accommodate higher activity levels that may be encountered in nonroutine application Licensee representatives agreed to review these items and revise procedures as needed. This will be carried as an inspector followup item (81-20-01).

d. The inspector noted that Procedure CP-8, "Chlorides by Mecuric Nitrate Titration", does not provide a mechanism for recording of the standardization, blank, or sample data as required by the procedur Licensee representatives agreed to review and address this area of concern which will be carried as an Inspector Followup Item (81-20-02).

e. The inspector discussed the calibration procedure for gaseous samples with licensee representatives. The inspector reviewed the correction factors used for efficiency data as specified in Step 3.2.2.4 of RCP-1 and the referenced memo to file, File 2-0-6-J, September, 198 A licensee representative stated that the procedure has been changed and the correction factors had not been used with the most recent gas calibrations on January 14, 198 A licensee representative also stated that the referenced change had not been reviewed by the PNSC and approved by the General Manager prior to implementation. The inspector informed licensee representatives that failure to review and approve the change in the Ge(Li) calibration procedure prior to implementation was a violation of Technical Specification 6.8.2. (81-20-03). The inspector determined from discussions with licensee representatives that the charcoal cartridges used for radioiodine sampling (MSA 44135 and CESCO #81-70SC727) were not TEDA impregnated and may not be as efficient for organic radioiodine specie The inspector noted that collection efficiencies for cartridges in use should be tested or docu mented for the radioiodine species actually released or expected to be released. Licensee representatives indicated that they had intended to use the TEDA-impregnated cartridges; however, the other cartridges had been substituted due to a mixup in the procurement process. Licensee representatives stated that they would initiate action to use TEDA-impregnated cartridge This will be carried as an Inspector Followup Item (81-20-04).

g. The inspector discussed the need for an interlaboratory crosscheck program in the radiochemistry are Licensee representatives stated that a crosscheck program is under development through the CP&L Technical Services Department. The status of the crosscheck program will be reviewed during a subsequent inspectio (81-20-05) The inspector noted that details of sample preparation and radionuclide analysis for reactor coolant samples and other non effluent samples such as spent resin were not specifically addressed in the chemistry or radiochemistry procedure Licensee representatives agreed to review the need for additional procedural guidance in this area. This will be carried as an Inspector Followup Ite (81-20-06)

i. The inspector noted that the procedure for tritium analysis, RCP-14 had been modified to include distillation of sample This was included to provide decontamination from other radionuclides present in sample This closes a previously identified item (261/80-01-03)

5 The inspector reviewed selected portions of the following records and logs: Proportional Counter Performance Data sheet, 10-11-80 to 12-26-80 Ge(Li) System Daily Performance Checks, 11-17-80 to 1-4-81 c. Ge(Li) System Efficiency Forms, 12-2-80 to 12-3-80 Reactor Coolant Liquid and Gas Analyses, 7-7-80 to 7-31-81 Steam Generator Blow Down Analyses, 6-1-80 to 6-29-80 Daily Chemistry Reports, 8-1-80 to 8-30-80 Ge(Li) Calibration Standard Certificates, June 1, 1981 for Charcoal Cartridge, particulate filter, 125 cc bottle, 500 cc bottle, 100 cc gas vial, 1-L Marinelli Beake.

Confirmatory Measurements a. The inspector reviewed licensee results for tritium analysis of a liquid waste sample that was collected during a previous inspectio The licensee reported a concentration of 5.72 +/- 0.02 E-2 microcuries/cc compared to the NRC concentration of 6.16 + 0.02E-2 microcuries/c The ratio of the licensee's valve to the NRC valve was 1.0 This constitutes agreement in accordance with the acceptance criteria in Attachment b. Liquid and gaseous effluent 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 sample The samples were analyzed by gamma-ray spectroscopy and included samples from: a liquid waste holdup tank, the primary coolant, and a waste gas decay tank. A spiked particulate filter and charcoal cartridge were counted by the licensee since samples with sufficient activity for comparison were not available during the inspection. An aliquot of the liquid waste holdup tank sample was sent to the NRC contract laboratory for H-3, Sr-89, and Sr-90 analysis. The results will be compared to licensee results in a subsequent inspection report (81-21-07).

The comparison of licensee and NRC analyses by gamma-ray spectroscopy are given in Table 1 with the acceptance criteria in Attachment The results show agreement for all analyses except the waste gas decay tank sample where the licensee's reported concentration was 1.42 times the NRC concentration. Based on the acceptance criteria this constitutes

"possible agreement". The inspector noted to licensee representatives that the method for calibration of the1.detector for gases would overestimate the concentration since they did not include attenuation corrections as discussed in Paragraph 7 A licensee representative stated that mixed gamma-ray gaseous standards had been ordered for

direct calibration of the Ge(Li) detectors and that recalibration of gas geometries would be initiated as soon as possibl This will be carried as an Inspector Followup Item. (81-20-08).

TABLE 1 RESULTS OF CONFIRMATORY MEASUREMENTS AT H. B. ROBINSON, JULY 21-23, 1981 CONCENTRATION, MICROCURIES/CC RATIO SAMPLE ISOTOPE H. B. ROBINSON NRC HBR/NRC RESOLUTION COMPARISON Reactor 1-132 4.3 +/- 0.1 E-3 5.7 +/- 0.3 E-3

.75

Agreement Coolant 1-133 2.8 +/-.06 E-3 3.7 +/- 0.2 E-3

.76

Agreement 7-21-81 1-134 8.5 +/- 0.2 E-3 8.8 +/- 0.7 E-3

.97

Agreement

@ 15:45 1-135 4.4 +/- 0.2 E-3 3.7 +/- 1.3 E-3 Agreement Mn-56 5.9 +/- 0.1 E-3 4.9 +/- 0.3 E-3..16 Agreement Na-24 4.24 +/- 0.03 E-2 4.37 +/-.07 E-2

.97

Agreement Ru-106 5.5 +/- 0.6 E-3 6.2 +/- 1.7 E-3

.89 Agreement Waste Gas Xe-133 1.72 +/-.02 E-4 1.21 +/-.01 E-4 Possible Agreement Decay Tank Liquid Na-24 2.01 +/-.02 E-4 1.64 +/-.05 E-4 Agreement Waste Co-58 1.32 +/-.01 E-4 1.25 +/-.03 E-4 1.05

Agreement Holdup Co-60 1.17 +/-.01 E-4 1.16 +/-.03 E-4 Agreement Tank Sb-124 1.86 +/-.02 E-4 1.68 +/-.04 E-4 1.10

Agreement 1-133 1.55 +/-.08 E-5 2.2 +/- E-5

.69

Agreement Cs-137 2.70 +/-.01 E-4 2.42 +/-.04 E-4 1.11

Agreement Spiked Co-57 7.9 +/- 1.2 E-4 6.3 +/- 0.2 E-4 1.25

Agreement Filter Cs-134 1.5 +/- 0.1 E-3 1.40 +/-.03 E-3 1.09

Agreement Cs-137 5.24 +/- 0.09 E-3 4.06 +/-.12 E-3 1.29

Agreement Co-60 2.8 +/- 0.1 E-3 2.13 +/-.06 E-3 1.31

Agreement Spiked Ba-133 7.7 E-4*

7.6 +/- 0.2 E-4*

1.01

Agreement Charcoal Cartridge

• gamma s/minute