IR 05000261/1986019
| ML14175B412 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/18/1986 |
| From: | Kuzo G, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B411 | List: |
| References | |
| 50-261-86-19, NUDOCS 8609080124 | |
| Download: ML14175B412 (11) | |
Text
REG(,4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 AUG 2 0 1986 Report No.: 50-261/86-19 Licensee:
Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DPR-23 Facility Name: H. B. Robinson Inspection Conducted: July 28, 1986 - August 6, 1986 Inspector: ___
199 G. e Signed Accompanying Personne * G Froemsdo f Approved by:
/__
__
P. G. St 'ddrt, Sectiofi Chief Date Signed Division of Radiation Safety and Safeguards
SUMMARY Scope:
This routine, unannounced inspection involved onsite review of the chemistry, radiochemistry and counting room laboratories in the areas of quality control and confirmatory measurements including review of the laboratory quality control program; review of procedures; review of quality control records and logs; review of counting room and chemistry laboratory facilities; and review of split sample results analyzed by the licensee and the NRC Region II Mobile Laborator Results:
No violations or deviations were identifie a0124 860820 PDR ADOCK 05000261 G
REPORT DETAILS 1. Persons Contacted Licensee Employees
- R. E. Morgan, General Manager
- R. M. Smith, Environmental & Radiation Control Manager
- J. M. Curley, Regulatory Compliance Supervisor
- J. A. Eddy, Environmental & Chemistry Supervisor
- H. J. Young, Quality Assurance/Quality Control Director
- S. Griggs, Regulatory Compliance Aide
- J. L. Harrison, Environmental & Chemistry Project Specialist
- J. M. Hill, Environmental & Chemistry Technician
- H. F. Watkins, Environmental & Chemistry Foreman Other licensee employees contacted included engineers, technicians, and office personne NRC Resident Inspectors
. Krug
- R. M. Latta
- Attended exit interview 2. Exit Interview The inspection scope and findings were summarized on August 1, 1986, with those persons indicated in Paragraph 1 above. Two inspector followup items concerning improvements in the analytical laboratory quality control program (Paragraph 3) and licensee evaluation of gamma spectroscopy analyses of Co-58 in liquid samples (Paragraph 7.a) were discusse One unresolved item*
concerning gaseous effluent measurements was discussed (Paragraph 7.a).
Following receipt of additional gaseous effluent cross-check results, the inspector informed cognizant licensee representatives during a telephone conference on August 6, 1986, that the problems associated with gaseous effluent measurements had been resolve Licensee management representatives acknowledged the inspector's comments and expressed no contrary opinion The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspectio *Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviation. Laboratory Quality Control Program (84725)
a. The inspector reviewed selected portions of the radiochemistry, chemistry, and counting room Quality Control/Quality Assurance (QA/QC)
program with cognizant licensee representatives and determined that organizational structure and program management had not changed since the previous inspection (IE 50-261/85-17).
The inspector noted that program implementation for analytical measurements met the general guidance of Regulatory Guide 4.15 "Quality Assurance for Radiological Monitoring Programs," with respect to the radioactive effluent monitoring progra The inspector discussed with licensee representatives their QC program following review and discussion of the confirmatory measurement analyses (Paragraph 7).
Licensee representatives stated that they were evaluating the following change o Maintain performance trend charts incorporating longer review periods and keeping the QC charts with each instrument. Presently data are detailed on monthly charts and stored in a fil o Improve the review of QC trend data by both supervisory personnel and all technicians utilizing the instrumentatio o Conduct systematic QC comparison and review of analyses among gamma spectroscopy detectors within the counting room, utilizing as many of the standard geometries as practicabl In general these comparisons are being performed; however, not all of the licensee's geometries are utilized nor are the results systematically retaine Improvements in the interstation cross check program, i.e.,
utilization of additional geometries for comparison The inspector informed licensee representatives that review of these QA issues would be considered an inspector followup item and would be reviewed during subsequent inspection (50-261/86-19-01).
(Opened) 50-261/86-19-01 (IFI) Review Changes to the Analytical Laboratory QA Program No violations or deviations were identifie. Audits (84725)
Technical Specification (TS) 6.5.3 states audits of plant activities shall be performed under the cognizance of the Manager, Corporate Quality Assurance, encompassing conformance of facility operations to provisions contained within the TS's and applicable license conditions at least once per 12 months; the Radiological Environmental Monitoring Program and the results thereof at least once per 12 months; the Offsite Dose Calculation
Manual and implementing procedure at least once per 24 months; and the performance of activities required by the quality assurance program to meet the criteria of Regulatory Guide 4.15, December 1977, at least once per 12 months. The inspector reviewed the following audit reports:
QAA/XX20-85-04, Quality Assurance Audit of HBR Operations, May 1, 198 QAA/0020-86-04, Quality Assurance Audit of Robinson Nuclear Project
- Operations, June 4, 198 The inspector noted that chemical and radiological measurements program areas were audited against applicable sections of the Technical Specifications and approved plant operating manuals. The audits reviewed the Environmental and Radiation Control (E&RC) administration, calibration, surveillance, and environmental monitoring program The inspector noted that audits addressed implementation of the chemical and radiochemical measurements but did not evaluate the accuracy of the data collected. No significant adverse findings regarding the analytical laboratory programs were noted in the audit report No violations or deviations were identifie * 5. Procedures (84725)
a. Technical Specification 6.8.1 requires written procedures to be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Rev. 2, February 1978; Radiological Environmental Monitoring Program, the Offsite Dose Calculation Manual; and the Quality Assurance Program for Effluent and Environmental Monitoring (using the guidance in Regulatory Guide 4.15, December 1977).
The inspector reviewed selected portions of the following procedures:
(1) CP-12 Standards and Reagents Preparation, Rev. 1, December 6, 198 (2) RCP-101 Preparation of Effluent and Noneffluent Samples, Rev. 1, May 16, 198 (3) RCP-105 Unsealed Source Accountability, Rev. 0, September 10, 198 (4) RCP-110 Gross Alpha/Beta Sample Preparation and Analysis, Rev. 2, August 3, 198 (5) RCP-120 Tritium Sample Preparation and Analysis, Rev. 1, October 21, 198 (6) RCP-121 Calibration of the Packard Model 460 Liquid Scintillation Spectrometer, Rev. 2, October 15, 198 (7) RCP-130 Calibration of the Nuclear Data Gamma Spectroscopy System, Rev. 5, May 16, 198 (8) RCP-134 Radioactive Standard Preparation for Calibration of Gamma Spectrometers, Rev. 1, May 16, 198 (9) RCP-135 Nuclear Data ND6685 Generic Operational Procedure, Rev. 2, May 16, 198 The inspector noted that procedures were being reviewed and approved in accordance with established administrative polic Results of the procedure review were discussed with cognizant licensee representatives as follow In the procedure for preparation of liquid samples for H-3 analysis, corrections should be included to account for dilution if any additional liquids, e.g. reducing agents, are adde Details for comparison between new and old instrument efficiency values needed clarification for selected procedure Clarification of required data to be included on labels for laboratory chemical bottles, i.e., different requirements needed for standards prepared daily, for standards maintained for extended time period, and for carrier solution Licensee representatives agreed to clarify and/or improve the applicable procedures and all changes were completed or in progress prior to completion of the inspectio No violations or deviations were identifie. Records (84725)
a. The inspectors reviewed selected portions of the following records:
(1) Packard 460 Liquid Scintillation Counter Quality Control Logs for January - July 1986 including:
i. Background Data & Quality Control Charts ii. Efficiency Data iii. Performance Response Data (2) Ge(Li) Detector Systems Nos. APTEC 1299, PGT-1452, and ORTEC 1602 Quality Control Logs for January - July 1986, including:
i. Peak Response Data ii. Instrument Response Data & Quality Control Charts iii. Resolution Response Data & Quality Control Charts iv. Background Data (3) 1984, 1985 and 1986 Efficiency Calibration Data for Gamma Spectroscopy Detectors Nos. APTEC 1299, PGT-1452, and ORTEC 1602 including the following geometries:
125 ml Bottle, 1 L Liquid Marinelli, Faceloaded Charcoal Cartridge, 100 cc Gas Bomb, 1260 cc Gas Marinelli, and 47 mm Millipore Filter (4) Standard Radionuclide Source Certificates and Inventory Records
(5)
1985 Round Robin Crosscheck Results for Gamma Spectroscopy Analyse (6) Gas Waste Release Permits, January - July 198 (7) Liquid Waste Release Permits, January - July 198 (8) Unsealed Source Signout Records, January - July 198 Results of the record review were discussed with cognizant licensee representative The inspector noted that records were maintained as required and readily availabl No violations or deviations were identifie. Confirmatory Measurements (84725)
a. During the inspection, reactor coolant and selected liquid and gaseous plant effluent process streams were sampled and the resultant sample matrices analyzed for radionuclide gamma-ray spectroscopy systems. The purpose of these comparative measurements was to verify the licensee's capability to measure radionuclides accurately in various plant system Analyses were conducted utilizing as many of the licensee's gamma spectroscopy systems as practicable. Sample types and licensee counting geometries included the following:
reactor coolant sample (RCS) - 125 ml bottle; liquid waste - 1 L marinelli; and gaseous waste
- 100 cc gas bomb (waste gas decay tank) and 1260 cc marinelli (gaseous effluent).
As a result of low nuclide activities in the liquid waste and gas effluent process systems, simulated samples were analyzed using diluted reactor coolant and waste gas decay tank samples -for the 1L liquid marinelli and 1260 cc gas marinelli geometrics, respectivel Spiked particulate filter and charcoal cartridge sample types were provided for analyses in lieu of licensee samples which did not have sufficient levels of activity for analysis. Comparison of licensee and NRC results are listed in Table 1 with the acceptance criteria listed in Attachment 1. Results were in agreement for the reactor coolant, particulate filter, charcoal cartridge, and 100 cc bomb geometrie Observed biases and differences between the licensee and NRC for selected geometries were discussed as follow (1) Although all nuclides for the reactor coolant geometry (125 ml bottle) were in agreement, the inspector noted a difference greater than 20% for Co-58 results between gamma spectroscopy system Nos. APTEC 1299 and ORTEC 160 This difference was not observed for the other isotopes within the sample. In addition, this large difference for Co-58 analyses between licensee's detectors was noted for an additional reactor coolant sampl Review of the licensee's gamma spectroscopy analyses details and calibration records did not resolve the noted difference Furthermore, this "between detector" difference was not noted for Co-58 results reported for the liquid waste geometry comparison (2) For the liquid waste geometry (1L marinelli) Co-58 results were in disagreement with NRC values using Detector Nos. APTEC 1299 and ORTEC 160 A review of the licensee's gamma spectroscopy analyses and calibration records did not resolve the noted differences between the licensee and NRC's measurement (3) For all gamma spectroscopy systems both Xe-133 and Xe-135 were in disagreement with NRC values for analyses using the 1260 cc marinelli beake All nuclide data were biased low (15 - 35%
below NRC values).
The inspector reviewed and discussed previous calibrations of this geometry with cognizant licensee representative No significant changes in calibration efficiencies were noted between successive year Furthermore, the inspector noted that previous confirmatory measurements analyses were in agreement for this geometry (IE Report No. 50-261/85-17).
The inspector discussed the observed findings with cognizant licensee representatives. From review of results obtained during subsequent sampling the inspector noted that the observed trends and disagreement were consistent and most likely not the result of non-homogeneous or contaminated samples. Licensee representatives agreed to evaluate the "between detector" differences and disagreements noted for the Co-58 analyses. The inspector informed licensee representatives that this item would be considered an inspector followup item and would be reviewed during subsequent inspections (50-261/86-19-02).
Licensee management committed to complete a cross check analysis for the 1260 cc gas marinelli geometry between the H. B. Robinson plant and Brunswick Steam Electric Plant (BSEP)
using a solid marinelli standar Although the analysis of this sample by the gaseous effluent geometry efficiencies would not result in accurate data, it would provide a relative corroboration of the adequacy of H. B. Robinson's gaseous effluent efficiency calibratio At the time of the exit interview, the inspector informed licensee representatives that the noted difference in effluent gas measurements would be considered an unresolved item pending review of the cross check data with BSEP. Results of the comparison were forwarded to the NRC Region II Office August 5, 1986, and all results showed agreement. The inspector informed licensee representatives during a telephone conversation on August 6, 1986, that their effluent gas measurements appeared adequat Furthermore, the inspector noted that the differences observed may have resulted from problems with NRC gamma spectroscopy calibration for gas geometry, and thus the initial differences noted would not be considered an unresolved ite b. The inspectors noted that the licensee was provided with a simulated liquid waste sample by the NRC contract laboratory and was requested to complete radiochemical analyses for H-3, Fe-55, Sr-89, and Sr-90 concentration The inspector noted that results of these comparisons were sent to the licensee in a letter from NRC Region II to Carolina
Power and Light Company dated February 11, 198 Results were in agreement for all analyse (Opened)
50-261/86-19-02 (IFI)
Review of licensee's evaluation of Co-58 results in reactor coolant and liquid waste analyse No violations or deviations were identifie. Tour of the Chemistry and Counting Room Facilities (84725)
a. The inspector toured the chemistry and counting room facilitie The inspector noted adequate cleanliness and organization in the laborator The inspector reviewed and discussed storage of unsealed calibration sources used for the instrumentation. Presently unsealed calibration source materials were stored in an unlocked cabinet within the counting room with inventory control maintained using log books and/or signout sheets. Licensee representatives informed the inspector that facilities were being made available in the immediate future to maintain all unsealed source materials within locked cabinets to be located in the counting room. The inspector had no further questions regarding the laboratory area No violations or deviations were identifie. Inspector Followup Items (92701)
a. (Open)
50-261/86-14-01, IFI 1985 Semi Annual Report - Typographical Error Changes, Total Error Analysis; Demonstration of LLD Value Licensee representatives stated that changes to the Semi-annual Report have not been complete b. (Open)
50-261/IN-42, IFI Review of Information Notice 86-42 Improper Maintenance of Radiation Monitoring System The licensee had not completed an evaluation of the notice at the time of the inspectio *TABL*
RESULTS OF CONFIRMATORY MEASUREMENTS AT H. B. ROBINSON NUCLEAR PLANT JULY 27 -
AUGUST 1, 1986 Sample Isotope Concentration (uCi/Unit)
Resolution Ratio Comparison (Geometry)
Licensee NRC Licensee/NRC (1)Reactor Coolant Co-58 6.37 E-6 7.47+/-0.91 E-6
0.85 Agreement (125 ml Bottle)
1-131 9.03 E-6 9.95+/-0.78 E-6
0.91 Agreement 1-133 9.58 E-5 9.17+/-0.15 E-5
1.04 Agreement 1-135 7.41 E-5 9.14+/-0.65 E-5
0.81 Agreement (2)Reactor Coolant Co-58 7.51 E-6 7.47+/-0.91 E-6
1.00 Agreement (125 ml Bottle)
1-131 1.05 E-5 9.95+/-0.78 E-6
1.06 Agreement 1-133 9.49 E-5 9.17+/-0.15 E-5
1.03 Agreement 1-135 6.86 E-5 9.14+/-0.65 E-5
0.75 Agreement (3)Reactor Coolant Co-58 8.24 E-6 7.47+/-0.91 E-6
1.10 Agreement (125 ml Bottle)
1-131 1.02 E-5 9.95+/-0.78 E-6
1.02 Agreement 1-133 9.64 E-5 9.17+/-0.15 E-5
1.05 Agreement 1-135 7.96 E-5 9.14+/-0.65 E-5
0.87 Agreement (1)Liquid Waste Co-58 4.35 E-5 5.54+/-0.09 E-5
0.78 Disagreement (1 I Marinell i)
Tc-99m 1.73 E-6 1.62+/-0.23 E-6
1.07 Agreement Sb-124 8.64 E-6 8.95+/-1.00 E-6
0.96 Agreement 1-131 5.93 E-6 6.30+/-0.48 E-6
0.94 Agreement 1-133 2.93 E-5 3.05+/-0.07 E-5
0.96 Agreement (2)Liquid Waste Co-58 4.34 E-5 5.54+/-0.09 E-5
0.78 Disagreement (1 1 Marinelli)
Tc-99m 1.73 E-6 1.62+/-0.23 E-6
1.07 Agreement Sb-124 9.35 E-6 8.95+/-1.00 E-6
1.04 Agreement 1-131 5.93 E-6 6.30+/-0.48 E-6
0.94 Agreement 1-133 3.00 E-5 3.05+/-0.07 E-5
0.98 Agreement (3)Liquid Waste Co-58 4.42 E-5 5.54+/-0.09 E-5
0.80 Agreement (1 I Marinelli)
Tc-99m 1.85 E-6 1.62+/-0.23 E-6
1.14 Agreement Sb-124 7.81 E-6 8.95+/-1.00 E-6
0.87 Agreement 1-131 6.35 E-6 6.30+/-0.48 E-6
1.01 Agreement 1-133 3.00 E-5 3.05+/-0.07 E-5
0.98 Agreement (1)Particulate Mn-54 2.01 E-3 2.45+/-0.12 E-3
0.82 Agreement Filter Cs-137 1.26 E-2 1.36+/-0.02 E-2
0.93 Agreement (47 mm filter)
Ce-144 3.80 E-3 4.48+/-0.19 E-3
0.85 Agreement (2)
Particulate Mn-54 2.01 E-3 2.45+/-0.12 E-3
0.82 Agreement Filter Cs-137 1.23 E-2 1.36+/-0.02 E-2
0.90 Agreement (47 mm filter)
Ce-144 3.80 E-3 4.48+/-0.19 E-3
0.88 Agreement
TABLE 1 t
RESULTS OF CONFIRMATORY MEASUREMENTS H. B. ROBINSON NUCLEAR PLANT JULY 27 -
AUGUST 1, 1986 Sample Isotope Concentration (uCi/Unit)
Resolution Ratio Comparison (Geometry)
Licensee NRC Licensee/NRC (3) Particulate Mn-54 2.11 E-3 2.45+/-0.12 E-3
0.86 Agreement Filter Cs-137 1.27 E-2 1.36+/-0.02 E-2
0.93 Agreement (47 mm filter)
Ce-144 3.83 E-3 4.48+/-0.19 E-3
0.85 Agreement (1) Charcoal Ba-133 4.52 E-2 3.98+/-0.03 E-2 133 1.14 Agreement Cartridge (Face Loaded)
(2) Charcoal Ba-133 4.42 E-2 3.98+/-0.03 E-2 133 1.11 Agreement Cartridge (Face Loaded)
(3) Charcoal BA-133 4.70 E-2 3.98+/-0.03 E-2 133 1.18 Agreement Cartridge (Face Loaded)
(1) Waste Gas Xe-133 6.34 E-4 7.20+/-0.07 E-4 103 0.88 Agreement (100cc Gas Bomb)
Xe-135 1.71 E-5 1.70+/-0.09 E-5
1.00 Agreement (2) Waste Gas Xe-133 6.11 E-4 7.20+/-0.07 E-4 103 0.85 Agreement (100cc Gas Bomb)
Xe-135 1.61 E-5 1.70+/-0.09 E-5
0.95 Agreement (3) Waste Gas Xe-133 6.29 E-4 7.20+/-0.07 E-4 103 0.87 Agreement (100cc Gas Bomb) Xe-135 1.57 E-5 1.70+/-0.09 E-5
0.92 Agreement (1) Gas Vent Xe-133m 7.28 E-6 8.85+/-0.67 E-6
0.82 Agreement (1260cc Xe-133 5.54 E-4 8.38+/-0.02 E-4 419 0.66 Disagreement Marinelli)
Xe-135 3.75 E-6 5.19+/-0.13 E-6
0.72 Disagreement (2) Gas Vent Xe-133m 7.95 E-6 8.85+/-0.67 E-6
0.90 Agreement (1260cc Xe-133 5.60 E-4 8.38+/-0.02 E-4 419 0.67 Disagreement Marinelli)
Xe-135 3.69 E-6 5.19+/-0.13 E-6
0.71 Disagreement (3) Gas Vent Xe-133m 7.60 E-6 8.89+/-0.67 E-6
0.85 Agreement (1260cc Xe-133 5.83 E-4 8.38+/-0.02 E-4 419 0.70 Disagreement Marinelli)
Xe-135 3.69 E-6 5.19+/-0.13 E-6
0.71 Disagreement (1) Analyzed Using Gamma Spectroscopy System No. APTEC 1299 (2) Analyzed Usign Gamma Spectroscopy System No. P6T SN 1452 (3) Analyzed Using Gamma Spectroscopy system No. ORTEC 1602A
ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This enclosure 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 progra In these criteria, the judgement limits denoting agreement or disagreement between licensee and NRC results are variable. This variability is a function of the NRC's value relative to its associated uncertainty. As the ratio of the NRC value to its associated uncertainty, referred to in this program as "Resolution"'
increases, the range of acceptable differences between the NRC and licensee values should be more restrictive. Conversely, poorer agreement between NRC and licensee values must be considered acceptable as the resolution decrease For comparison purposes, a ratio 2 of the licensee value to the NRC value for each individual nuclide is computed. This ratio is then evaluated for agreement based on the calculated resolution. The corresponding resolution and calculated ratios which denote agreement are listed in Table 1 belo Values outside of the agreement ratios for a selected nuclide are considered in disagreemen t
=NRC Reference Value for a Particular Nuclide w
1Resolution =
Associated Uncertainty for the Value Licensee Value 2Comparison Ratio NRC Reference Value TABLE 1 -
Confirmatory Measurements Acceptance Criteria Resolutions vs. Comparison Ratio Comparison Ratio for Resolution Agreement
<4 0.4 -.5 -.6 -
1.66 16 -
0.75 -
1.33 51 -
200 0.80 -
1.25
>200 0.85 -
1.18