IR 05000263/1976005
| ML20125B351 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/28/1976 |
| From: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20125B294 | List: |
| References | |
| NUDOCS 9212090324 | |
| Download: ML20125B351 (1) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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RtGION lli
tot noostvtLT noAo CLEN ELLYN lLLINOIS $0137 April 28, 1976 L. B. Higginbotham, Chief, Safety and Environmental Programs Branch Office of Inspection and Enforcement, Headquarters
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NORTHERN STATES POWER COMPANY (MONTICELLO)
LICENSE NO. DPR-22 (DOCKET No. 50-263)
Attached is a copy of the Monticello Environmental Protection and Confirmatory Measurements Inspection Report No. 050-263/76-05 on the March 15-17, 1976 inspection.
The following items in the report should be noted and brought to the attention of the Of fice of Nuclear Reactor Regulation, as appropriate:
1.
Elevated I-131 Concentration Levels in talk (Item G, thnagement Interview and Paragraph 5.d of Report De tail s)
Technical Specification 6.7. A.2.h(2) does not provide a clear indication of the number of sampics or the time period af ter which the licensee is required to perform and report the estimates of the likely exposure to individuals or population groups and assumptions upon which the estimates are based.
It seems clear that when continuous IcVels are greater than those corresponding to the concentrations in Appendix B, Table II, Part 20, action is required.
The uncertainty exists for intermittent or short duration consecutive high levels.
It should (
be noted that the Prairic Island Technical Specifications (Docket Nos. 50-282 and 50-306) contain an identical section, as do the Kewaunee (Docket No. 50-305) specifications and
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possibly others.
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2.
Meteorological Data Reporting (Item H of Management Interview and Paragraph 5.b of Report Details)
The licensee is not required by the Technical Specifications to report the meteorological data being acquired, and does not adhere to the criteria for reporting of such data in accordance with Reg Guides 1.21 and 4.8.
Thus, no meteorological data are being provided to NRC at this time.
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UN1110 $1 Alts
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NUCLCAR HCGULATORY COMMISSION l
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REGION III==
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Report of Environmental Monitoring Inspection and Confirmatory Measurements
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IE Inspection Report No. 050-263/76-05 g.
Liegnsec:
Northern States Power Company
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414 Nicollet Mall Minneapolis, Minnesota 55401
}!onticello,Melcar Cencrating Plant License No. DPR-22; Monticello, }!innesota Category:,C
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Type of Licensec:
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Type of Inspection:
Routine, Unannounced
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Dates of Inspection:
March 15-17, 1976
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Principal Inspector:
M.
. Oestmnn (Datc)
h h, A, c J-O
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7b Accompanying Inspector:
. L. Jo gensen
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Other Accompanying Perso nel: Nonc
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Reviewed By:
. A. Pag ro, Chief
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Environmental and Special (Dat e)
Projects Section
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SUMMARY OF FINDINGS
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innpcetion' Summary Unannounced routine Environmental Protection and Confirmatory Heasurements inspections conducted on Fbrch 15-17 (76-05):
Reviewed environmental program conduct and management controls; examined program results; diccussed and reviewed programs for
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quality control in sampic collections and laboratory raddonnaly/ and followed up items from the previous environmental inspection;1
discussed results of confirmatory measurement effluent sampics previously taken on January 12-13, 1976.
Enforcement 7tems
None.
i 1dcencee Action on Previously Identified Enforcement Items No previously identified enforcement items within the scope of this inspection.
Other Significant items A.
Systems and Components
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The licensee has not followed through with their plans f or
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installation and operation of remote meteorological recording equipment in the pp;nt control room as described in a previous
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inspection report.-
The licensec has been obtaining meteoro-
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logical data fron its 330-foot meteorological tower but the data have not been reported to the NRC as requested by regula-tory guides.
The licensee has taken the position that it need not provide NRC with any additional meteorological data beyond that provided in the pSAR and FSAR.
(Paragraph 5.h., Report Details)
B.
Facility Items (Plans and Procedures)
No significant items were identified within the scope of this inspection.
C.
Managerial Items
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Responsibilitics for accomplishing, managing, and auditing environ-mental programs have been reorganized within the Engineering Vice
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Presidential staff, resulting in.n new Environmental-Covernmental Activitics Department (ECAD) and limited transfer of personnel and
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RO Innpection Report No. 050-263/74-11.
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responsibilitics to the Nuclear Support Servicen Department (HSS).
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The agreement with the Minnenota Department of Health (HDll) to
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perform the radiological environmental monitoring program was terminated on January 1, 1976.
The radiologica] environmental sample collection and delivery will continue to be conducted by ECAD and the samples will now be analy, zed by Nalco (Industrial Bio-Test Laboratories) of Northbrook, Illinois.
(Paragraph 3.b.,
' Report Details)
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One unreso]ved item was identified pertaining to the necessity for the licensee to perform and report on an evaluation of a
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few instances wherein I-131 concentrations in the mjJk samples a
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exceeded 2.4 pC1/1 in September, 1975.
(Paragraph 5.d., Report i
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Details)
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Noncompliance Items identified and Corrected by Licensec
None.
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E.
Deviations
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None.
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F.
Status of Previously Reported Unresolved Items
No previcusly reported unresolved items within the scope of
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this inspection.
Management Interview
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A management intervic.w was conducted on March 17, 1976, with L. O. Hayer, s
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Manager of NSS, and E. C. Ward, Manager, Nuclear Environmental Services
(NSS).
The following items were discussed with the licensec representativer A.
The NRC inspectors discussed the scope and intent of this specific inspection.
(Paragraph 2, Report Details)
B.
The inspectors and the licensec discussed the environmental monitoring program management.
(Paragraph 3, Report Details)
C.
Licensee programs for quality control of analytical measurements were discussed.
The licensee currently uses a two sigma action,
criterion.
The licensee and Nalco are discussing alternative criteria and arc developing procedures to define what_ action would be taken if the analytical results were in excess of these criteria.
(Paragraph 4, Report Details)
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D.
The licennec stated that the carbon-impregnated filtern utilized for airborne radiofodinc monitoring are being replaced with carbon cart ridges.
(Paragraph $.c., Report Details)
E.
The licensec discussed the arrangements for calibration of portabic flow meters to datormine air particulate sampic volumes.
(Paragraph 4, Report Details)
F.
The licensec and inspectors also discussed the status of develop-incnt of the Appendix 11 Technical Specifications, particularly those impicmenting the ecological programs.
(Paragraph 5.f.,
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Report Details)
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C.
The unresolved item pertaining to evaluation and reporting of Icycir. of I-131 in milk above 2.4 pC1/1 was dit. cussed.
(Paragraph 5.d., Report Details)
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11.
The incpectors discussed the reporting and recording of results of the incteorological program.
(Paragraph 5.h., Report Details)
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rep 0RT DETA11.S
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Persons contacted Pernons contacted, in addition to those identified in the Hanagement Interview Section of the Summary of Findings were as follows:
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B. W. Clark, Administrator, Radiation Environmental Monitoring (NSS)
J. L.11echthold, Administrator, Environmental Sciences, Environmental-
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Covernmental Activitics Department (ECAD)
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C. D. Ueberling, Jr., Supervisor, Ecological Studies (Monti/Sherco),
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(ECAD)
D. J. Johnson, Environmental Aide (Sherco) (ECAD)
L. Elinson, Radiation Protection Engineer R. Jacobson, Plant Chemist 2.
Cencral The Environmental Protection portion of this inspection consisted of an_. examination of the licenr.ec's environnental monitoring
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activit.les including sampling techniques and procedures, sampic co11cetion_cquipment_and locations, and program results.
Manage-ocnt control aspects including organizational otructure, assignment of responsibilitten and authoritics, and administra-tive procedures and control, vere also examined. The licensee's
' technical specifications were utilir.ed as the primary inspection criteria.
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This inspection also included an examination of the ifconsee's
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program and practicos to assure quality control of sampic co11cetion, handling, and shipment and of analytical measurements.
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Although the licensec has conducted a non-radiological monitoring program since 1968, the technical specifications do not contain non-radiological requirements; such specifications are expected
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to be issued later this year. The non-radiological portion of the licensec's environmental monitoring program will be examined in detail during an inspection conducted subsequent to the isruance of the Appendix B Technical Specifications.
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The Confirmatory Heasurements portion of this inspection consisted
- of comparison of the licensco's measurement of radioactivity to those of the NRC's refercuce laboratory.
The tvo laboratories performed measurements on the same campics or on duplicates or
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split sampics.
The measurenients modo by the NRC laboratory are referenced to the National llureau of Standards Radioactivity Hensurements System by laboratory intercomparisons.
The inspectors and licensee will continue to determine the basis
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for diff erences in analytieni results which will be examined at a subsequent confirmatory measurements inspection.
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3.
)tanagement controls
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The licensec's' administrative and procedural controls for
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impicmentation of the environmental monitoring program were I
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c,xamined.
This examination included a review of assignments of responsibilitics and authorities for program management and impicmentation.
a.
Mananmnent Ornanization Sincethetg7eofthepreviousEnvironmentalProtection inspection -, the licensee has engaged in a reorganira-tion of certain management and audit functions s
relating to the conduct of the radiological and nonradio-
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logical environmental monitoring program.
Functions pre-viously assigned to the Engineering Vice-Presidential Staff are now vested in a new Environmental-Governmental Activitics Departnant (EGAD) and in the Nuclear Support Services Departinent (NSS).
ECAD has responsibilitics for placement of monitors, collections, shipping and delivery of the radiological environmental sampics to the contractors for radionnayiscs, for operation and maintenance of the
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meteorological field equipment and data co11cetion svstem, s
and for the development and conduct of the non-radiological
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environmental monitoring program, including collection and delivery of non-radiological environmental samples to the contractor.
EGAD also maintains cognizance of the aquatic biota protection conditions, reports-to NSS when the pro-tection conditions are exceeded, and will produce other reports which will be required by the Appendix B Technical Specifications.
The NSS Department has administrative responsibilitics for contract management for analysis of the radiological and non* radiological samples, for production of certain routine and nonroutino reports, for reduction and computer processing of the meteorological program results and development of suitab3c calculational procedures f or dose pathway reporting to the NRC, and for conduct of independent audits of environ-
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mental program activitics.
NSS also maintains cognizance of plant radwaste effluent and ' environmental radiation Icvels.
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Contractor Channes
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Tho if censco's agreement for perf orming the radionnalytical environmental monitoring program with the Minnesota Department of Ilcalth van terminated on January 1,, 1976. The licensee
, has retained Nalco (Industrial Bio-Test Laboratories),
Northbrook, Illinois to carry out this function. The licensec's EGAD is responsibic to place and replace the environmental monitors and collect sampics and prepare them for shipment to Halco, i
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The scope of the environmental f f 3m badge monitori6g *
program with Landauer of Glenuood. Illinois, has been reduced.
Starting on October 26, 1975, the number of film badges exposed for a four-veck period was reduced in number from 47 to 22 badges at 14 locations.
This-change is within the Technical Specification requirements.
In addition, a contract that furnished a set of 30 environmental film badges was cancelled.
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1:cview and Audit
As noted in 3.o., above, the NSS has been assigned revicu
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and audit recponsibilitics for areas to be covered by the Appendix B Technical Specifications, procedures for auditing and recording results of audits and inspection of the radiological environmental monitoring program content
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have been prepared.
procedurcu for audit of the analytical
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quality control program to be carried out by Halco are not
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now prepared but will be prepared by another contractor for
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future impicmentation.
A computer system exists for reporting results of program audits and incpections to supervision and management for their review.
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d.
Criteria for Corrective Action
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The licensec's contractors have been using a two sigma action criterion in the analysis of radiological environmental sampic results. She licensee is provided immediate notification and explanation of missed samples and if results exceed the
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tbo sigma criterion.
The licensee will be responsibic to evaluate the significance of the results and to issue addi-tional instructions ao necessary.
4.
_ Quality Control of Analytical Measurement
The licensec's contractor for the radiological environmental monitoring program will maintain a laboratory quality control program for radioanalysin.
The contractor han provided the
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licensco with a general program description and is now working
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w'ith the licensee to customize the program to the licenoce's contract specifications.
The licensee has not yet approvd the quality assurance program but expects to give formal approval
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in the near future when the program meets contract specificatiev e The contractor participates with the Envir,onmental protecth.
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Agency in cross referencing stardard sampics, j
The licensec through EGAD will perform sampic collect':%
field treatment, packaging and shipment to the contru. w ha accorrlance with quality control procedures which arc M 'r j
develc. ped by the contractor in consultation with the licwpp,
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- A number of these sampling and shipping procedures det'ckped t>y-y the contractor have been revir. icd and appt oved by the afcensce.
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l procedures for the action criterion mentioned in Section. 3.d., above, are heing developed between the licensee and the contractor. The analyt.ical procedures and lower limits of detection given in llAS1c300 are a contractual requirement of the ifcensee's environ-mental nonitoring contractor.
The inspectors reviewed the records of the quality cont.rol program
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carried out -by the previous contractor (!!Di!) and found that Jthe -
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previous contractor provided the ifcer.sce with accuracy and
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proef sion control charts monthly.
Sciccted followup actions taken<
on identified deficiencies in analytical results were reviewed and t.hc inspectors foupd that except for radioiodine-131 in milk as discussed below in Section 5.d., variations were within
normal statistics.
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The licensec has revised its sample co11cetion and calibration
s procedures to reficct a change in the method of determining the
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airparticulatesaglevolumeinresponse.totheprevious
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inspection report.-
Another contractor'is hired for instrument calibration of the portable flovmeter used but no formal pro-cedures = for calibration nor-frequency of-checking the calibra-
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tion has been established by the licensee.
This item will be examined further in a subsequent inspection.
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Implementation and nesults of the Environmental tiens torinn Pronrams
The imiplementation and results of-the licensco'sTradiological environbental monitoring program for the second half of 1974, and the full year of 1975 were selectively examined for compliance with the monitoring and reporting. requirements and for corrective
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actions on identified deficiencies. The installation and operability
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of onlected radiological environmental monitoring stations were also examined.. - Chango 15 to - the-Appendix A -Technical Specifications.
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contains. the existing environmental radiological monitoring-program requirements.
On October 15, 1975 and'on } larch 1,:1976,.
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the-licensee submitted to the Office of Nuclear Henctor Regulation
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a revised monitoring program which has not yet baen put into of fect.
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Environtnental_ Honi torinn Report s Except for several milk samples co'ntaininn identifiabic quantities of iodine-131, no unusual results or treads were noted in the inspectors' review cf the radiologica) environmental monitoring resulta. The licensee reports in its nemiannual operating
. reporth those instances identified where sampics were missed or vero not obtained or sampics not analyzed. The licensco has innplemented arrangements with its new contractor to continue to identify and obtain such missed sarapies or analyses and to justify each event.
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b.
A,vailability__ of Clamn The inspe/ctors noted, on discussed in the previous inspection report.d. a continued f ailure to collect clam sampics through the last half of 1974 and through 1975.
The licensoc has stated that efforts to acquire these sampics, in areas of the river which might serve as an indicator of the !!onticello llucicar Generating Plant radiological effects, have not been successful.
The Ifeencec believco the program han value and plans to continue _ this program.
The inspectors discussed
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the Icvel of effort and number of at tempt s taade bef ore tbc licensee concludes clams are not availabic.
This item will be examined in a subsequent inspection, c.
_ Air Samplers
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The licensco has purchased new air samplers to replace.the
older air samplers.
These new camplers utilize charcoal s
cartridges rather than carbon-impregnatcJ filters. This change is responsive to the discussion of this ite:a in the previous inspection report.!d The new air samplers will also be provided with portabic flovmeters.
A procedure for an annual calibration of-the flowmoters in the new air samplers has been prepared.
The downtime of previous air samplers has been kept to a minimum.
Spare parts are available at the site.
All the routine maintenance of air samplers including preventive maintenance is donc through ECAD.
d.
Radiof odino Levels in Milk TI,m licensee has been previously co11ceting milk sampics from dairy cows located at farms in four different regions surrounding the plant but at 1 cast 5.6 miles away.
Since
)tarch 1975, milk nampics have been obtained from four farms 5/
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within two-three miles from the plant.
The inspectors
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examined the analytteni results, particularly of radio-todine-131 in milk tnken from these nearby farms.
The licensee had noted that since tby 1975, the milk campics from nearby f arms began to show increased levcis of radio-iodine-131.
The inspectors examined.the licensee analysis of the correlation between plant vent releases and
. the Icvels observed in milk from iby through July 1975.
The licensoc concluded that a close correlation existed between plant vent releases and Icvels of I-131 found in milk fron
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nearby farms during this period. When considered by overating
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on a semi-annual basis with previously o' served concentrations,
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these Icvels (which were below 2.4 pCi/1) represent only a fraction of 1% of the doso 3cvels corresponding to 10 CFR 20, Appendix B Tabic 11 concentrations.
llowever, three milk
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sampics taken from the two nearest farms on September 2, 9, and 16, 1975, showed iodine-131 concentrations in excess of 2.4 pCi/1 The licensee reported in its semiannual operating report the icyc1 of 4.7 pC1/1 of fodine-131 as the highest icyc1 found in the second half of'1975. The licensee concluded in its semiannual report !!o.10 that "the f odine-131 3 cvols det ceted
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arc equal or greater than those observed at other locatione during this six month period but are consistent with Icycls
observed during 1974."
The inspectors discussed the earlier (1973 and 1974) results for this analysis in followup on the previous inspection.1/
The licensec stated that their review of these earlier results,
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for which I-131 concentrations greater than 2.4 pCi/1 werc reported, had found them not to be typographically in error.
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Ilovever, due to the greater statistical uncertainty of the analytical method used at that time, the licensee does not belicue that the earlier results represent positive indications.
The 1975 results, on the other hand, are not considered to be compromised by statistical uncertainty.
- Technical Specification 6.7.A.2.h(2) requires the licensee to provide estimates of likely exposures to individuals and population groups, and the bases for these estimates, when the environmental monitoring program results indiente
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tpc likelihood of intakes in excess of 1% of those that could result from continuous exposure to the concentration valuca of Appendix 11, Tabic 11, l' art 20.
Although concen-trations of I-131 in milk grtqter then 2.4 pC1/1 appear to meet this clitorion, the licenco did t.ot provide the cotimates and bases discussed above for the sampics of'
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Septe ber 2, 9, and 16, 1975.
Since the referenced especification
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is unc1 car concerning the number of sampico or the duration of the period after which these actionn are required, this item is considered an unrcoolved item at this time. This matter y
'wijl he reicrred to the Of fice of Nuclear Reactor Itogulation and will be examined further at a subsequent inspection.
Elevated Thermoluminescent Detector (TLD) Results_
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The inspectors noted that the licensec contacted the !!Dil laboratory concerning the reported TLD network results SI showing elevated Icycis during 1974 similar to those for
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1973.
The MDil laboratory maintains the position that the results show that the plant effluents contributed to the
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elevated radioactivity background Icvel surrounding the plant.
A figure in the 1974 semiannual operating report shows a close correlation between the TLD Icvelt, and of f-gas release rates from the plant.
Witn the operation of the augmented off-gas system starting in October 1975, a reduction in the contribution of the plant ef fluents to the background Icycle around the plant is expected.
This item will be examined in a subsequent inspection.
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Sampic Monitoring Stationn The inspectors examined sc1cett d radiological environmental sampling stations and found them to be operabic and located
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as specified.
The licensee has just received new air samplers which will be placed in operation with the next
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several days,
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i The inspectorn noted the records kept by ECAD for collecting and shipping sampics were in order.
This information is supplied in the semiannual operating reports, including justification for missed campics.
g.
Non-radiolonical Effluents and Monitoring pronram No Jimits on release of non-radiological effluents nor ecological programs are required in the Technical Specifica-t.f ons. The licensec has been working with the Office of
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Nuc1 car p.cactor Regulation to preparc and finalize Appendix B Technical Specifications.
The ecological
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programs are managed through ECAD and are carried out with the assistance of personnel f rom St. Cloud State University.
The incpectots also visited a building containing fishing gear and boats which are used for the ecological sampling
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program.
An inspection of the non-radiological monitoring (
program vill be carried out subsequent to the issuance of the
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Appendix B Technical Specifications.
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Hetcorological Monitorinn pronram A meteorological tower complying with recommendations contained in Regulatory Guide 1.23 is currently operabic.
The inspectors observed the present 330-foot meteorological tower and tho
, equipment used for recording wind speed, direction, dowpoint, temperature and temperature dif ferentials at 33,140 and 330-foot cicvations.
The cquipment is calibrated by a con-tractor on a quarterly basis.
Checks are made daily to assure equipment is operabic.
A computer printout is y
availabic but not in use.
The licensee stated that it does a
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not plan to put this remote recording equipment in.the plant
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control room as discussed in the previous inspection report.g7 The licensee niso stated that since one year of meteorological data has aircady been provided 1 RC in the pSAR, it did not believe it was necessary to supply the NRC with any additional matcorological data as requested in Regulatory Guides 4.8 and 1.21.
This item will be ref erred to the Office of >Huc1 car Reactor Ecculation and will be examined further during a subsequent inspection.
- 6.
Confirmatory licasurements
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The Confirmatory Measurements portion of this inspect ion consisted of a test of the licensce's capabilitics f or measurement of radio-
' activity in actual plant effluent sampics.
In addition, changes acorrectiontodataprovidedinapreviousreporLEpiquidsand in a licensee procedure for analysis of tritium in were discussed.
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Analytical Result _s_
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This inspection showed some of the licensec's measurements on these sampics arc acceptabic ur.Jer the test criteria
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used by the Of fice of Inspection and Enforcement for comparing
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measurement results (ace the attachment). llowever, one of the licensec's measurements did not yicid an acceptabic com-parison in that the licensee did not identify the presence of Xc-133m in waste gas as did the NRC reference laboratory.
The types of sampics tested and the results of measurements were as follows:
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1E In,spection Report No. 050-263/76-01
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(1)
Type of Sampic:
Off-cas (1/76)
(Results in units of Aici/ml).
ACCT.PTABLE Radionuclide NRC Ref erence liensurement Licensco Measurement
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Xc-133 4.4 i 0.1 E-03 4,99.! 0.07 E-03 NOT A_C,CEPTABLE
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C Radionuclide NRC Reference Hennurement Licennee Mea surer.e'n Xc-133m 7.01. 0.9 E-04 Not detected (2)
Type of Sample:
Liquid Standard (4/75)
(Results in units ofj. sci /ml)
ACCEP_TADi.E Radionuclide NRC kef erence l'easurenent Lic ennee Ifea surer.e*
11 - 3 7.871 0.09 E-03 8.23 r 0.08 E-
NOT ACCEPTAl'LE :
Nonc
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(3)
Type of Sample:
Particulate Tilter (1/76)
(Results in units of pCi/sampic)
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ACCEPTABLE
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NRC Ref erence tiensurement Licensen ?!casurerer Radionuclide
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Ba-140 7.9 I 0.2 E-02 5.43 0.12 E-02 Cc-137 7.7 1 0.5 E-04 5.80 1 2.28 E-04 NOT ACCEPTABLE:
None (4) Type of Sampic: Charcoal Adcorber (1/75)
(Results in units ofj.ici/sampic)
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ACCEPTAB1.E
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Radionuclide NRC Reference Measurement Licennee Measurener I-131 3.97 I 0.13 E-02 4.19 1 0.15 E-02
NOT ACCEPTAli1.E: Nonc
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)_0_/ This valuo corrects that prevjously reported - see Paracrngh 6.c.
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Hectinn Acceptanen Critcria b.
Sainples Hat t
The analysis for Xc-133m in an of f-gas sampic did not meet
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the acceptanco critoria in that the licensec did not d(tect
this nuclide while it was detected and reported by the NRC reference laboratory.
Subsequent examination of the records t
by both laboratories did not disclose any basis in the counting
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analysis, calculations or transcription of results f or the
noted disparity. The licensco program did scarch for Xc-133m, and reported less than the minimum detectabic activity of 8.2 E-05 uCi/ml for the geometry and counting time used.
In i
discussions with the licensee, a licensee representativo noted
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that there is a potential for this nuclide to be masked by
other short-lived nuclides if the sample is counted soon af ter
it. in taken, as the licensee did.
It was agreed that arrange-ments would be made at the next comple split for the licensee
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to hold the sampic for a few days before analysis.
This
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item will then be re-examined at a subsequent inspection.
For the purpose of relotting releases of Xc-133m and demonstrating compliance with technical specification conditions, the licensee utilizes colculational models based on analyses for other, more readily quantifiable nuclides, including Xc-133m and five short-lived isotopes.
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Thic program was examined by the NRC staff and is part of the basis for the technical specifications themocives.
The
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licensee stated that counting analysis has rarely identified
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Xc-133m directly, and that no comparison of measured and enl-
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culated values has been performed by the licensee.
On the basis of this information, the licensec's failure to identify
Xc-133n by direct count does not have implications with respect s
to reporting and deronstrating compliance.
c.
goality Control in Radionnalysis _ Tritium The licensco program for quality control in radio-analysis was examined and reported during a previous
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ins pec t i on..l.3./
The referenced inspection report identified an or.alysis f or tritium in a standard sampic as yiciding an unacceptabic comparison.
On further examination, the licensco found and reported that radioactive decay of the tritium
,atandard used for determination of equipment ef ficiency had
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not boon taken into account.
The corrected value determined
by the licensec is identified in Paragraph 6.a.(2) of this report and yicided an acceptabic comparison. The licensec's
actual original and corrected calculations were examined by the inspectors during the inspection.
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11/ lE. Inspection Report No. 050-263/76-01.
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In addf Lional discussions concerning analysis f or tritium, the
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ifcensec stated that a new tritium utandard was prepared in
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January 1976 and that a program has' been developed and impic-J monted to automatically adjust for radioactive decay of the ntandard.
Further, the licensee plann to add a program segment which will automatically flag calculated of ficiency changes greater than three percent on sequential standard counts.
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