IR 05000267/1981017

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IE Insp Rept 50-267/81-17 on 810810-14.No Noncompliance Noted.Major Areas Inspected:Sample Collection,Sample Treatment & Analysis,Lab Instrument Calibr & QC
ML20040G867
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 01/26/1982
From: Murray B, Nicholas J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20040G865 List:
References
50-267-81-17, NUDOCS 8202160556
Download: ML20040G867 (14)


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U. S. NUCLEAR REGUtATORY COMMISSION

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REGION IV

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Docket:

50-267/81-U License:

DPR-34

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PublicServjceCompanyofColorado Post Office' Box 840

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Denver, Colorado 80201

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Facility:

Fort St. Vrain Nuclear Generating Station Inspection at:

Platteville, Colorado

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Inspection Conducted:

August 10-14, 1981 d!f2.-

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Inspector:

_.Nicho'as,'RapiationSpecialist

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A Blaine Murray, Chief, Facility Radipfion

/ Dati Protection Section V

Inspection Summary:

Inspection conducted during the period of August 10-14, 1981

(Report No. 50-267/81-17)

Areas Inspected:

Routine, announced inspection of the licensee's radiochemistry measurement program including sample collection, sample treatment and analysis, chemistry analytical procedures, laboratory instrument calibration and quality controls of analytical measurements, licensee audits of radiochemistry activities,_and independent confirmatory measurements using the Region IV mobile counting laboratory _for onsite comparisons of split sample results.

The inspection involved a total of 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> onsite by one NRC inspector.

Results:

No violations or deviations were identified.

C8202160556 820127 PDR ADOCK 05000267 O-

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DETAILS 1.

Persons Contacted Public Service Company of Colorado (PSCO)

  • D. W. Warembourg, Manager, Nuclear Production
  • E. D. Hill, Station Manager

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  • M. McBride, Tech..ical Services Manager H. W. Hillyard, Administrative Services Manager
  • T. Borst, Radiation Protection Manager
  • J. W. Gahm, Quality Assurance Department Manager
  • L. W. Singleton, Superintendent, QA Operations
  • T. E. Schleiger, Health Physics Supervisor
  • V. J. McGaffic, Chief Radiochemist B. Husted, Quality Assurance Engineer R. E. Reiss, Quality Assurance Engineer

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D. Miller, Radiochemistry Laboratory Assistant M. Prochownik, Radiochemistry Laboratory Assistant NRC Resident Inspectors

  • M. W. Dickerson, NRC Senior Resident Inspector, Fort St. Vrain Station
  • G. L. Plumlee, NRC Resident Inspector, Fort St. Vrain Station
  • Denotes those present during the exit interview.

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2.

Licensee Action on Previous Inspection Findings (Closed) Open Item (76-06/2):

This item was discussed in Inspection Report No. 50-267/76-06 and involved establishing calibration frequencies for the laboratory counting instruments.

A review of procedure RCP-28 indicated that calibration frequencies and performance check frequencies for nuclear measurement instrumentation have been established and records maintained by the staff Chief Radiochemist.

This item is considered closed.

3.

Open Items this Inspection (0 pen) Open Item (50-267/81-17/1):

Quality Control of Water Chemistry Laboratory Instrumentation and Analyses:

The licensee's internal audit program has identified some areas of concern which need resolution.

(See paragraph 6).

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4.

Scope of Inspection The purpose of this inspection was to. review the licensee's radio-chemistry instrument calibration and quality control programs for the period October 1, 1978 through August 1, 1981, radiochemistry staff training, and perform confirmatory measurements on selected plant radioactive effluent samples.

The previous quality control inspection of analytical measurements and confirmatory measurements was performed during October 16-19, 1978.

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5.

Radiochemistry Organization and Training The NRC inspector reviewed the PSCO organization and Fort St. Vrain plant staff assignments of chemistry and radiochemistry responsibilities.

The following diagram shows the present structure and~ assigned individuals as reported by a licensee representative.

O. R. Lee Vice President - Electric Production D. W. Warembourg Manager - Nuclear Production E. D. Hill F. J. Borst Manager - Fort St. Vrain Site Manager - Radiation Protection M. L. Block T. E. Schleiger V. J. McGaffic

Superinentdent - Operations Supervisor - Health Physics Chief Radiochemist l

V. A. Lucero W. E. Woodard D. Miller l

Chief Water Chemist Plant Health Physicist M. Prochownik Radiochemistry Laboratory Assistants l

Laboratory Techs.

H. P. Techs.

The NRC inspector reviewed the training and qualification records for the I

radiochemistry staff.

A training and review program has been established l

for-the radiochemistry staf f.

Training records were reviewed for the l

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Chief Radiochemist, Vern McGaffic, and the two radiochemistry laboratory assistants, Don Miller and Mike Prochownik.

All training has been documented on Form HPC-1 for the radiochemistry laboratory personnel and was found in order.

No violations or deviations in the radiochemistry staff training were identified.

6.

Licensee's Internal Audits

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-The NRC inspector discussed audits of the water chemistry and

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radiochemistry programs with a member of the QA staff and reviewed reports of audits conducted in this area during the period from August 1978 through August 1981.

The following audits were reviewed for scope and timely follow-up action of problem areas identified during the audit:

(a) QASP-601-78-01 Attachment 6.6, QA Surveillance Checklist Water Chemistry and beneral Chemistry, Water Chemistry Laboratory, June 2, 1978.

(b) QASP-601-78-02, Attachment 6.6, QA Surveillance Checklist Water Chemistry and General Chemistry, Water Chemistry Laboratory, September 20, 1978.

(c) QASP-601-80-01, Attachment 6.6, QA Surveillance Checklist Water Chemistry and General Chemistry, Water Chemistry Laboratory, July 29, 1980.

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(d) QASP-601-78-01, Attachment 6.7, QA Surveillance Checklist Radiochemistry, Radiochemistry Laboratory, March 20, 1978.

(e) QASP-601, Attachment 6.7, for the year 1979 was replaced by QAA-601-79-01, Water Chemistry and Radiochemistry, August 14, 1979.

(f) QASP-601-80-01, Attachment 6.7, QA Surveillance Checklist Radiochemistry, Radiochemistry Laboratory, June 2,1980.

(g) QAA-601-81-01, Water Chemistry and Radiochemistry, July 20, 1981.

It was noted that a QAMM-P1-3 audit on water chemistry is scheduled for October 1981 and a QAMM-Pl-4 aucit on radiochemistry is scheduled for December 198 _.

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The NRC inspector noted that responses and appropriate corrective actions have been either completed or scheduled for most deficiencies identified during the audits.

No major problem areas are identified in radiochemistry.

However, several areas of concern have been identified by the licensee's internal audit program in the water chemistry department without adequate resolution being accomplished or documented by the licensee to the inspector's satisfaction.

These items are:

(1) Water chemistry laboratory personnel do not have a documented training program or retraining schedule.

(2) NPDES permit requirements are not properly followed.

(3) Water chemistry laboratory equipment calibration list was incomplete and standards used for calibration are not properly maintained.

(4) Water chemistry laboratory cross-check program has not been implemented with the EPA.

The above four items are considered to be open item (50-267/81-17/1) pending further inspection of the water chemistry laboratory program.

No violations or deviations regarding the licensee's audit program in radiochemistry were identified.

7.

Quality Control of Radiological Analytical Measurements The NRC inspector reviewed the program for quality control of radiological analytical measurements and cross-check comparisons of analytical results between Colorado State University (CSU), Colorado State Department of Public Health (CSDPH), Environmental Protection Agency (EPA), and Fort St. Vrain station (FSV).

Monthly data from CSU, CSDPH, and FSV for tritium, gross alpha, and gross beta in environmental water samples were reviewed for the period January 1981 through July 1981 and the results were found to be in good agreement.

Fort St. Vrain analyzes quarterly samples as a participant in the EPA cross-check program which include, on a rotating basis, sample analysis types such as tritiuminurine,gggmascanofwgger,ggrossalpha/grossbetainwater, ljpwater, Sr-Sr in water, and gross alpha, tritium in w grossbeta,gger, y

Sr, and Cs on an air particulate filter.

All results _

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were in order, however, the NRC inspector noted that FSV has difficulty meeting the sensitivity required for analyzing the low activity spiked samples for gamma isotopic identification using their germanium-lithium detector.

Also the sensitivity of the FSV strontium procedure just approaches the low levels of strontium spiked in the EPA samples making it very difficult to compare results.

For good cross comparisons the activity levels of the spiked samples should be at least an order of magnitude higher.

However, based on the results of the cross-check comparisons between CSU, CSDPH, NRC, and FSV, it is determined by the inspector that the licensee has an adequate QC program for radiological analytical measurements.

The NRC inspector examined the licensee's radiochemistry QC procedures, instrument calibration data, and instrument performance check data.

Data for the period January 1981 through July 1981 was reviewed for the Beckman LS-100 Lignid Scintillation Spectrometer, Harshaw TASC-12 Low Background Alpha / Beta Proportional Counter, and Canberra Gamma Spectrometer.

The licensee's records indicated that an adequate QC program is maintained.

The NRC inspector has no further questions in this area at this time.

No violations or deviations in the radiochemistry quality control program were identified.

8.

Analytical Measurements a.

Confirmatory Measurements Confirmatory measurements were performed on the following samples in the mobile laboratory at Fort St. Vrain Nuclear Station during the inspection:

(1) Stack Charcoal Cartridge (2) Stack Particulate Filter (3) Liquid Radwaste Effluent (4) Laboratory Liquid Waste (5) Primary Coolant (6) RESL Charcoal Cartridge Standard (7) RESL Particulate Filter Standard i

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(8) NBS Gas Bulb Sphere Standard The confirmatory measurements test consists of comparing measurements made by the licensee, NRC's mobile laboratory, and NRC's reference laboratory, Radiological and Environmental Sciences Laboratory (RESL) in Idaho Falls, Idaho.

RESL's and the NRC's mobile laboratory measurements are referenced to the National Bureau of Standards by laboratory intercomparisons.

Confirmatory measurements are made only for those nuclides identified by 1ie mobile laboratory or RESL as being present in concentrations greater than 10% of the respective isotopic values for liquid and gas concentrations as stated in 10 CFR Part 20, Appendix B, Table II, and above the Lower Limit of Detection (LLD) for stack samples.

Stack charcoal cartridge and stack particulate filter comparisons are based on established Lower Limits of Detection (LLD) for total activity per sample.

Attachment No. 1 contains the criteria used to compare results.

Attachment No. 2 lists "he LLO's for stack samples, b.

Results The following tables show the various sample comparison results:

(1) Stack Charcoal Cartridge (Collected 09:45 MDT, August 11, 1981)

No significant nuclide concentrations greater than the lower level of detectability were identified by the licensee or by the Region IV mobile laboratory.

No comparison is made.

(2) Stack Particulate Filter (Collected 09:45 MDT, August 11, 1981)

No significant nuclide concentrations greater than the lower level of detectability were identified by the licensee or by the Region IV mobile laboratory.

No comparison is made.

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(3) Liquid Radwaste Effluent (Collected 06:45 MDT, August 11, 1981)

NRC Result PSCO Result PSC0/NRC Nuclide (uCi/ml)

(uCi/ml)

Ratio Decision Possible tritium 7.7910.04E-01 9.98 0.01E-01 1.28 Agreement gross 2.80 0.20E-07 7.83E-07 2.80 Disagreement beta 895r (1)

<5.49E-09

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(2)

90Sr (1)

<3.61E-09

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S (1)

8.85E-07

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(2)

No significant gamma emitting nuclide concentrations greater than 10% of the isotopic value as stated in 10 CFR Part 20, Appendix B, Table II were identified by the licensee or by the Region IV mobile laboratory.

(1) Analytical results had not been received from RESL at time of report.

Formal documentation of these analyses results will appear in the next radiological inspection report.

(2) Analytical results were not available at time of report; therefore, no comparison is made.

(4) Laboratory Liquid Waste (Collected 10:00 MDT, August 12, 1981)

NRC Result PSCO Result PSC0/NRC Nuclide (uCi/ml)

(uCi/ml)

Ratio Decision 57Co 1.5110.03E-05 1.66 0.04E-05 1.10 Agreement 8Co 4.6310.42E-06 4.16 0.75E-06 0.90 Agreement 59Fe 4.98 0.93E-06 5.65 1.92E-06 1.13 Agreement 60Co 4.35 0.02E-04 4.66 0.02E-04 1.07 Agreement Y

7.5710.54E-06 7.94i0.31E-06 1.05 Agreement

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95Nb 5.6310.42E-06 6.5810.72E-06 1.17 Agreement 95Zr 2.1310.65E-06 3.29 1.21E-06 1.54 Agreement 109Cd 6.7810.08E-04 8.0110.10E-04 1.18 Agreement 113 Sn 3.8010.53E-06 4.9810.84E-06 1.31 Agreement 134Cs 8.5410.08E-05 9.1510.07E-05 1.07 Agreement 137Cs 4.5810.01E-04 4.97 0.01E-04 1.08 Agreement 139Ce 2.3810.24E-06 2.44 0.35E-06 1.02 Agreement (5)

Primary Coolant (Collected 12:45 MDT, August 13, 1981)

NRC Result (1) PSCO Result PSC0/NRC Nuclide (uCi/ scc)

(uCi/ scc)

Ratio Decision 85mKr 5.1310.03E-04 5.56 0.16E-04 1.08 Agreement 87Kr 1.04i0.01E-03 1.0910.07E-03 1.05 Agreement Kr 1.50 0.01E-03 1.08 0.04E-03(2) 0.72 Disagreement

133 Xe 2.74 0.03E-04 2.63 0.18E-04 0.96 Agreement 135Xe 8.1910.04E-04 8.4910.17E-04 1.04 Agreement (1) NRC results are corrected for gas calibration using the attenuation coefficient ratio between water and air.

(2) Licensee used a branching ratio of 37.8% in calculating the result.

Upon recalculation of the isotopic data using a branching ratio of 26.3%, which was used by the NRC mobile laboratory, the analysis result of 1.55 0.06E-03 uCi/ scc was in agreement.

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(6) RESL Charcoal Cartridge Face Loaded Stand ud No. 80-06 (Standardized 09:00 CST, March 19, 1980)

NRC Result (2) PSCO Result (3) PSC0/NRC Nuclide (uCi/ sample)

(uCi/ sample)

Ratio Decision 5700 5.8110.03E-03 6.9510.16E-03 1.20 Agreement 60Co 4.4310.02E-02 5.3610.06E-02 1.21 Agreement 88Y 7.4710.28E-02 9.0310.53E-02 1.21 Agreement 113 Sn 1.4710.06E-02 2.101039E-02 1.43 Disagreement 137Cs 3.2910.13E-02 4.2910.04E-02 1.30 Agreement 241Am 8.1510.33E-03 3.1410.05E-02 3.85 Disagreement (1) The activity on the actual stack charcoal cartridge was less than the LLDs listed in Attachment No. 2.

Therefore, a prepared cartridge standard was analyzed by the licensee.

(2) Results are taken from the standard certificate supplied with the standard as prepared by RESL and traceable to the National Bureau of Standards.

(3) Licensee's results are based on a detector efficiency curve established using a face loaded cartridge standard which was counted with the deposited activity face of the standard facing the detector during the entire analysis count.

The RESL face loaded cartridge standard analysis was performed by the licensee in the same manner.

In comparison, RESL and the Region IV mobile laboratory rotate the cartridge during analysis and flip the cartridge at the midpoint of the analysis count, respectively.

This may account for the higher results obtained by the licensee.

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(7) RESL Particulate Filter Standard No. 80-8 (Standardized 09:00 CST, March 19, 1980)

NRC Result (2) PSCO Result PSC0/NRC Nuclide (uCi/ sample)

(uCi/ sample)

Ratio Decision 5700 1.1510.05E-02 1.0410.02E-02 0.90 Agreement 60Co 8.7910.36E-02 8.4810.07E-02 0.96 Agreement 88Y 1.4910.06E-01 1.4010.01E-01 0.94 Agreement 113Sn 2.9310.12E-02 2.7310.42E-02 0.93 Agreement 137Cs 6.5710.26E-02 6.2810.04E-02 0.96 Agreement 241Am 1.6310.07E-02 2.0210.03E-02 1.24 Agreement (1) The activity on the actual stack particulate filter was less than the LLDs listed in Attachment No. 2.

Therefore, a prepared filter standard was analyzed by the licensee.

(2) Results are taken from the standard certificate supplied with the standard as prepared by RESL and traceable to the National Bureau of Standards.

(8) NBS Gas Bulb Sphere Standard,$RM-43090-29 (Standardized 12:00 EST, October 1, 1980)

NBS Result (2) PSCO Result (3)

PSC0/NBS

Nuclide (uCi/ sample)

(uCi/ sample)

Ratio Decision 127Xe 5.5110.11E+01 5.8910.06E+01 1.07 Agreement (1) To test the validity of the water to gas calibration correction factors used at Fort St. Vrain Nuclear Station, the licensee made measurements on a water filled gas sphere standard prepared by RESL and traceable to the National Bureau of Standards supplied by the NRC inspector.

An efficiency curve for the gas bulb sphere sample geometry was established.

The correction factor based on water /airattenuationcoefficgtratiowasappliedto measurements made on the NBS Xe gas bulb standar __.

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(2) Result is taken from the standard certificate supplied with the standard as prepared by the National Bureau of Standards.

Licensee'sresultisg9kenfromtheprincipalgammaray (3)

i line 202.84 kev for Xe.

The result is within 17% error of the known standard activity.

Therefore, the validity of the water to gas calibration correction factors used at Fort St. Vrain Nuclear Station was proven.

No violations or deviations in the confirmatory measurements

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portion of the inspection were identified.

9.

Facilities and Equipment The NRC inspector visited the radiochemistry laboratory and nuclear counting facility.

The laboratory area and nuclear instrumentation were found acceptable and adequate.

10.

Exit Interview At the conclusion of the inspection on August 14, 1981, the inspection findings were discussed with the individuals denoted in paragraph 1.

The NRC inspector summarized the scope of the inspection, discussed the inspection findings, and informed the licensee of the agreement between PSCO and NRC on measurements performed on various intercomparison samples.

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ATTACHNINT NO. 1

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Criteria for Comparing Analytical Measurements The following are the criteria used in comparing the results ot capability tests and verification measurements.

The criteria are based on in empirical relationship established through prior experience and this program's analytical requirements.

In these criteria, the judgement limits vary in relation to the comparison of the resolution.

Resolution = NRC Value NRC Uncertainly Ratio = Licensee Value NRC Value Comparisons are made by first determining the resolution and then reading acrcss the same line to the corresponding ratio.

The following table shows the acceptance values.

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RESOLUTION RATIO Possible Possible Agreement Agreement A Agreement B

0.4 - 2.5 0.3 - 3.0 No comparison l

4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 l

8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5 l

16 - 50 0.75 - 1.33 0.6 - 1.66 0.5 - 2.0 51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.66 l

200 0.85 - 1.18'

O.80 - 1.25 0.75 - 1.33 l

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"A" criteria arc applied to the following analyses:

l Gamma Spectrometry where principal gamma energy used for identification is greater than 250 Kev.

Tritium analyses of liquid samples.

Iodine on adsorbers.

"B" criteria are applied to the following analyses:

Ganaa Spectrometry where principal gamma energy used for identification is less than 250 Kev.

90 5r and Sr Determinations.

Gross Bets where samples are counted on the same date using the same reference nuclide.

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ATTACHMENT NO. 2

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LLDs for Nuclides on Particulate and Charcoal Filters

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Cr 54Mn 1.5E-05 58 Co 1.5E-05

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134Cs 2E-05 137 Cs 2E-05

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Ba 2E-05 140La 4E-05

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Ce 2E-05 144

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