IR 05000267/1990010
| ML20056A362 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 07/25/1990 |
| From: | Baer R, Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20056A361 | List: |
| References | |
| 50-267-90-10, NUDOCS 9008070122 | |
| Download: ML20056A362 (30) | |
Text
{{#Wiki_filter:. -
-, w
.g .1
.
.,
s-APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV ; NRC Inspection Report: 50-267/90-10 Operating License: DPR-34 'f Docket: 50-267
::
Licensee: Public Service Company of Colorado (PSC) P,0.--Box 840
' - - Denver,. Colorado 80201-0840-
Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)
. Inspection At: FSV Site, Weld County, platteville, Colorado l
, Inspection Conducted: June 11-15, 1990 l 1
I Insta irs: !' ' RC. E. Baer, Radiation Specialist, Facilities f Dhte l Radiological Protection Section ] l FM o L J.'B. Nicholas, Senior Radiation Specialist Date Facilities Radiological Protection Section Approved: in /l./n @&/ E. Murray, Ch11T, Fact ties Radiological Date' b r Protection Section~" g l l Inspection Summary
. .
Inspection' Conducted June 11-15, 1990 (Report 50-267/90-10)
. Areas Inspected: Routine,-unannounced inspection of the licensee's radioactive
,
' material transportation program, liquid and gaseous radioactive waste L management programs including radiological effluent releases, water chemistry and radiochemistry programs including water chemistry and radiochemistry confirmatory measurements, and the radiological environmental monitoring program (REMP).
Results: The' licensee had implemented a radioactive material transportation program in accordance with NRC and Department of Transportation (DOT) , regulations. The organizational structure, management controls, staffing , i 9008070122 900731 POR C' ADOCK 05000267 ,
'
PDC
. _ . _
.
t.; r y .. . P q
~2-
,
.
!
. levels, and management support for the transportation of material-. appeared adequate. The licensee had completed three radioactive material shipments by
~
exclusive.use vehicia to a low level radwaste burial site during 198 .i In The 1.icensee's' radicartive waste effluent program (RWEP) was implemented in
.accordance with~ the Radiological Ef fluent Technical Specifications (RETS) and the Offsite Dose: Calculation Manual (00CM). The licensee had performed-v 22811guid batch re' esses and 220. gaseous batch releases during 1989. The Lquantities of radionuclides released in.the radioactive waste. effluents were within the limits spucified in the RETS. Offsite doses had been calculated using methods specified in the 0 0 and were within Technical Specification (TS) limits. The licensee had no unplanned radiological liquid ,
releases during 1989. Seven abnormal radiological gaseous batch releases were made in 1989 from the primary coolant system and the helium storage system-
.through the reactor building exhaust ventilation system. One unplanned .
radiological gaseous release-from 1A waste gas surge tank resulted in Licensee Event Report 89-12. No TS limits were exceeded. 'The licensee had made a
' design. change to the radioactive gaseous. waste system. The licensee had made approved changes'to the ODCM. The licensee had submitted their. semiannual effluent release reports for 1989 as par TS requirement The licensee had implemented a water che:mistry program and radiochemistry program in accordance with NRC requirement.:. The water chemistry and radiochemi_stry programs were being conducted in accordance with TS -
requirements. The licensee's water chemistry and radiochemistry staffs had-been reduced by 50 percent following: the-decision to decommission the plan . The results of the water chemistry confirmatory measurements indicated 89 percent agreement. _This was a significant-improvement over the previo'us
- 64 percent agreement in the water chemistry laboratory during the NRC inspection conducted in. April 1988. The licensee's radiological ~ confirmatory measurements results=were in 100 percent agreement with the NRC results. The
'
'
. licensee's performance in the area of. radiological confirmatory measurements u '
remained at the high level of.100 percent. agreement _ achieved during th < April 1988 NRC inspection'. - The . licensee had submitted their Radiological Environmental Monitoring Program- ? Annual Summary Report for 1989 as per TS requirements. The 1989 annual land-D .use census had been conducted and the results documented per TS requirement ,
~ Quality assurance (QA) audits and monitoring reports had been performed as 1 required and were technically comprehensive and performance based. Audit findings had-been resolved in a timely manne F Within the areas inspected, no violations or deviations were identified. One violation and four previously identified open items were closed in paragraph '
.-
. . ' ;,: + ,
s' , a; ,y ) 3; 1
,
*
'
-3-g
'
DETAILS
,
i
.
I '. Persons Contacted q: PSC i
*A. C. Crawford, Vice President,. Nuclear Operations *C. H. Fuller, Manager, Nuclear Production H.-E.lAdamski, Senior. Chemist- * L. Block, Manager, System Engineering *F J. Borst, Manager, Nuclear Training and Support-
'
*H L. Brey, Manager, Nuclear Licen. sing- . > :J..C. Brungardt, Senior Chemist S. L. Chambers, Senior Radiochemist i *M.-- Deniston, Superintendent of Operations - 4 y *D.;W. Evans, Manager, Operations / Maintenance t ' *M. J. Ferris, Manager, QA Operations D.-L. Fettercif, Senior Chemist *J. M. Gramling, Supervisor, Nuclear Licensing *L. C. Hutchins, Health. Physicist (HP)
lN *G. E. Krajewski, QA-Engineer u M. P. Mcdonald, Training Instructor
. .. *B. M. McDowell, QA Technician
*D.'D.' Miller, Supervisor, Water Chemistry and Radiochemistry-P.LF. Moore, Supervisor, QA Technical Support-S. K.; Piepenbrink, Supervisor, Maintenance Quality Control .(QC) i S..G. Poet, Senior. Radiochemist- *M. J. Raymond, Supervisor, Technical l Training-J *D. Rodgers, Manager, Nuclear Computer Services *T.-E. Schleiger. Superintendent, Chemistry and Radiation Protection S. S. Sherrow, Coordinator, Radioactive Waste Program- '*P. F. Tomlinson, Sr., Manager, QA ,
3m >;. l h Others
; *D. C.' Cummin, HP, Impell . *R!.E.'Farrell, Senior. Resident Inspector, NRC l * Denotes those individuals present during the exit interview on June 15, 199 ,
The inspectors also interviewed other licensee employees including
,
radiation protection, maintenance, operations, QA, and document contro L
,, )
i i
y,
:,n ;g: .- . .
R -4-w
' -
s ':l
.2. Licensee = Action on Previously Identified Inspection Findings
'
(Closed) Violation (267/8817-01): Qualifications of the Superintendent of Chemistry and Radiation Protection - This violation was discussed in NRC Inspection Report 50-267/88-17 and involved the-licensee's failure to complete an' evaluation and verification of the qualifications of the-
'
'
.
individual assigned to the position of superintendent. of chemistry and . radiation protection as required by station procedures. The' licensee had completed the necessary evalcation:and the assignee met the requirements-
of Regulatory Guide 1.8 - 1975. The licensee's corrective actions concerning this violation were considered adequat '
(Closed) Open Item (267/8817-07): Hot Particle Program - This item was discussed in NRC Inspection ~ Report 50-267/88.-17 and involved-the lack of.a-documented hot particle -program and lack of employee training on the nuclear power industry hot particle problems. The licensee had documented ,
a hot particle program in Station Procedures HPP-110 " Routine Survey Intervals and Survey Documentation," Revision 4, January 17, 1990;
, HPP-120, " Surface Radioactive Contamination Survey," Revision 2, January. 17, 1990; and HPP-125, " Establishing and Posting Controlled ~
Areas," R9 vision 3, January 17, 1990; and had included training of. hot particle problems in General Employee, GE-019, lesson plan for General Employee Training Class II and III trainin (Closed) Open Item (267/8913-02): Labeling of Containers of Radioactive
' Material. - This item was discussed in NRC, Inspection Report 50-267/89-13 1
and invol/ed the lack of labeling of containers of solid radioactive waste in accordance with 10 CFR 20;203(f). The containers were stored in a locked . facility with _ strict control of the key required for access. .The
~
.
-licensee had labeled the waste-containers that were stored-in the locked facility and had checked other areas within the plant for other containers which should be similarly marke (C1osed) Open Item (267/8914-02): Airborne Radioactivity Analysis For >
Errors - This item was discussed in NRC Inspection Report 50-267/89-14 and involved, the computerized printout of airborne radioactivity- sample W analysis which did'not provide sufficient information to allow the reviewer to verify the results .as recorde The licensee had revised the computer printout depicted in Procedure HPP-130; " Portable Air Sample Collection and Analysis," Revision 4, February 28, 1990,
' Attachment HPP-130A, to include, in addition to other pertinent data, the-counting instrument efficiency, background counts, and background counting i time. There appeared to be sufficient information on the new form to verify the analgic41 result (Closed) Open Item (267/8809-02): Water Chemistry Confirmatory Measurements - This item was identified in NRC Inspection '
Report 50-267/88-09 and involved the licensee's high percentage of disagreement rescits in the confirmatory measurements analyses of the water chemistry standards. During this inspection, a new series of standard chemical solutions was provided to the licensee for confirmatory I i g
b . 0 .
:. - - *Ft
. . u: .
;
-5- 1
?
l
- - ;
measurements analyses. The licensee's analyses results showed 89' percent agreement. .This was a marked improvement over the 64 percent agreement achieved during the previous inspection of this area conducted in
: ' April 198 ~ Organization and Management Controls
__The inspectors reviewed the licensee's organization and staffing of the water chemistry.section (WCS) and radiochemistry sectio ,RCS) to . determine-agreement with commitments in Chapter 12 of the Updated Final
'
.J'ety- Analysis _ Report (VFSAR) and compliance with the requirements in Sect.'in 7.1 of the T '
The inspectors verified that ti, organizational structures of the_WCS and RCS were as defined in the UFSx., and TS. The inspectors reviewed the_FSV '! management control procedures and position descriptions for the assignment of 'cesponsibilities_for the_ management and implementation of the FSV water > chemistry and radiochemistry programs. - The inspectors verified that the: administrative control responsibilities specified by the FSV_ procedures
. were being implemente The inspectors reviewed the staffing of the WCS and RCS, Since the previous NRC water chemistry / radiochemistry inspection conducted'in April 1988, .the WCS had lost the chemistry supervisor arid had reduced the ..t water chemistry technical staff sto three senior chemists and the RCS had reduced the radiochemistry technical staff lto three senior radiochemists.- "
The' inspectors discussed the water chemistry / radiochemistry staff ; stability'and morale'in view of the fact 1that the facility was no longer ,
-operating and plans were under way for decommissioning and the licensee .,
was looking for areas where _they could reduce staffing. The water
~
chemistry / radiochemistry staff morale appeared to be good and the staff l appeared to conduct their work activities in a professional manne : However, it was observed that.due to the decrease in staff, the water-chemistry / radiochemistry workload appeared to be at .the maximum capacity of:the current staff and:further reduction;in staff could impair the
. performance of water chemistry / radiochemistry TS requirements and water
; chemistry / radiochemistry activities associated with decommissionin No . violations or deviations were identifie , Qualifications
'
~The inspectors reviewed the qualifications of WCS and RCS personnel to
' determine agreement with commitments in Chapter 12 of the UFSAR and compliance with the requirements in Section 7.1 of the T i l
!
!
s .
us; 1
), v1E '
a p', t
, " ',E 4 3 < ,
H-
..
-6-
,
.The inspectors reviewed'theLeducation and experience backgrounds-of the present water chemistr; and radiochemistry staffs and determined that'all personnel met the qualifications specified in the.UFSAR, TS, and
'
ANSI N18.1-197 ' No violations deviations were identifie ' Audits The inspectors reviewed thi licensee's QA audit program for radioactive
~
waste management, radiological effluent releases, transportation of
,' radioactive material, radiological environmental monitoring, and the water J chemistry' and. radiochemistry programs to determine compliance with the requirements of 10 CFR Parts 20, 61, and 71; Department of Transportation (D0T) 49 CFR Parts 171-178; Section 7.1.7.8c of.the TS; and- ,
,
'
commitments in the UFSA " The inspectors reviewed QA manuals, audit procedures, audit checklists, Laudits,'and monitoring reports conducted during the. period January 1988 to ,, May:1990 in the above areas. The' inspectors also reviewed audit findings, corrective action tracking and responses to findings, and auditors'
'
L qualifications. The specific audits reviewed are listed in Attachment 6 , to this report. The licensee had initiated QA Audit ENPR-90-01 on June 1, ; 1990, and the audit was still in progress at the time of this inspectio The inspectors noted that-the transportation of radioactive material L -program had been reviewed in 1989 as part of QA Audit ENPR-89-01, .
" "
R Environmentel- Protection Plan." This QA audit included reviews of th l . ODCM and radioactive effluent release report doses, the radiological and-
.nonradiological environmental monitoring programs, radioactive gaseous and: .;
liquid effluent releases, process control and low-level radioactive waste-
' -program, meteorology program, semiannual radioactive effluent release ' reports, and the reactor; exhaust filter and adsorber system. This QA ,
audit: appeared to be a comprehensive evaluation of the programs reviewe , Deficiencies that'were noted had been resolved in a timely manne ~ J - ' >
'No violations or deviations were identifie . . Radioactive Material Transportation Program ,
The inspectors reviewed the licensee's radioactive material transportation program for compliance with the requirements of 10 CFR Part 71, 49 CFR, Parts 171 through.178, NRC IE Bulletin 79-19; agreement with commitments in Chapter 11.1.1.1 of the UFSAR; and the recommendations of NRC Regulatory Guides'7.1 through 7.1 '
,
- l +
_ __ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ - _- __ - _ - _ _ _ - _ _ _ - _ _ -
,f - , v g;
1, - :s
[5L
<
.
-7-- !
!
: a .~ QA Program 4
" '
.The inspectors determined that the licensee had submitted a QA ,
program for approval to the NRC to comply with 10 CFR Part 71, i Subpart He .The licensee had received NRC Form 311, " Quality Assurance Program Approval," Approval No.-71-0346, indicating an
.exp.iration date of December 31, 199 Procurement and Selection of Packages j 't The inspectors reviewed the licensee's procurement of DOT and NRC certified packages. The inspectors noted that the licensee normally ,
ships low-specific activity (LSA) waste in steel boxes as ' strong-tight containers or,in steel drums manufactured in accordance I with DOT Specification 17H for shipment of LSA radioactive wast * The inspectors determined that the licensee maintained current' i documents'on<the manufacturer's design, use, maintenance, testing, and NRC' Certificate of Compliance for all casks-the licensee was- ; registered to us ' , L The inspectors noted the licensee had used a DOT Specification 55 L -container to ship a plateout probe to a Department of Energy (DOE) l -contractor. The.plateout probe contained approximately 0.24 millicuries of radioactive material. The? licensee used the-Specification 55 container as a strong-tight. containe ' Preparation of Packages for Shipment It, . . . h, The' inspectors verified. that the licensee-had established procedures - i and checklists for the preparation:of radioactive material shipment These procedures included requirements for a visual inspection of-the package > prior to loading the package, instructions for closing and sealing the package, marking requirements of the package's weight and
.
curie content,:.labelhg requirements for the appropriate type of-package, and determining the radiation and contamination 1imits of' , the package The 1.icensee routinely ~used QC hold or= check' points
- during the preparation of the' package Discussions with' licensee personnel' indicated that individuals involved in transportation of ,
. radioactive material activities possessed a working knowledge.of-the- -
related procedures sufficient to ensure that the aspect's of DOT.and~ NRC regulations pertaining to the p' reparation of packages for .; y shipment lwere being me ; L The inspectors'noted that the licensee used detailed procedures for the loading and handling of cask-type shipments. During a review of ' a fuel handling procedure work packet (FHPWP), the inspectors noted that the. licensee, at a QC witness point, identified the torque-wrench and final torque valve but that the calibration due date for
.
I l
,j(# . ..
p, 7 1
> '
k ,
.
.
-8-the' wrench was not required to be recorded on the FHPWP. This-information was occasionally recorded on the FHPWP following the torque wrench identification number.. This information was available-on the QC-inspection report form, Delivery of Completed Packages to Carriers The inspectors compared the licensee's procedures with the DOT and NRC requirements to determine if all requirements were included. The review of-licensee's records and shipping paper documentation indicated that the licensee had prepared appropriate shipping papers'
in accordance with approved procedures and that the shipping papers included the necessary information to comply with regulatory requirements. Discussions with licensee representatives. indicated that the' licensee had-routinely used exclusive use-~ vehicles for the transport of radioactive material. The licensee used checklists to
~
ensure that the radiation levels were within.the required limits, the transport vehicle was properly placarded, removable surface
- contamination on packages was within regulatory limits, and blocks -
and/or braces.were within/on the transport vehicle in_such a manner.-
-as to prevent damage or shift of load under conditions normally encountered in transit. The licensee- took several photographs of the - vehicle JustLprior to shipmen Receipt of Packages The inspectors reviewed the licensee's program for receipt of packages-containing radioactive material to determine compliance with 10-CFR Part 20.20 The4 licensee's activities for receipt of radioactive materials were . covered by Procedure HPP-175, " Receiving Radioactive Materials,"
Revision 1,' March 27, 1989. The inspectors reviewed this procedure for consistency-with regulatory requirements-and determined that,it covered.all aspects of the work being performe Transportation Incidents The inspectors determined, by discussions with licensee representatives,_that none of the FSV radioactive material or_ waste shipments had been involved in an accident or incident. Also, no
, ' 4 reported. violations had been noted on any shipment received by
another licensee, Records, Reports, and Notifications The inspectors reviewed the records of 19 selected radioactive material shipments made by the licensee since the last radioactive
:
y.; , . -
. . i-. ..
_ '
.
waste / transportation inspection. These shipments had been adequately , documented to meet the NRC and 00T requirement [ Spent Fuel' Shipments The inspectors reviewed toe licensee's program for the shipment of irradiated reactor fuel. The licensee has maintained a spent-fuel-shipment capability within the technical services department for the tracking, loading, and preparation for shipment of spent fuel. _The _ , HP department had increased the transportation activities awareness . through.the employment of a contractor employee with considerable experience in the development of programs for and the shipment of
. radioactive materia ! .The FSV spent. fuel shipping casks.had been returned to their original '
as built licensed configuration as discussed in paragraph 4 of NRC l Inspection Report 50-267/89-23. The licensee had implemented detail , records for all: maintenance, periodic testing requirements and j changes made to these cask '
; -The licensee's program for the shipment of irradiated fuel satisfies -'
the requirements of TS 4.7.4 and appears to be adequate to ensure i that shipments are made in accordance with NRC-and DOT requirement ; No violations or deviations were identified.
l 7. Radioactive Waste Classification and Characterization I, The inspectors reviewed the licensee's radioactive waste management L program for waste classification, characterization, and tracking of waste I shipments to comply with the requirements of 10 CFR Parts 20.311, 61.55, l . and 61.56.
y The inspectors reviewed the licensee's radioactive waste shipment manifest _, ' form that accompanies each shipment of radioactive waste. The licensee - had not_made a shipment of radioactive waste directly to a burial sit ~
,
! Shipments had been made to a radioactive waste-broker who processed and repackaged the waste material. The inspectors determi,ed that the licensee's radioactive waste management program was be ng conducted in-such a manner that the requirements of 10 CFR Parts 20 snd 61 appeared to_ > be satisfie .!
!
No violattons or deviations were identifie L 8. Radioactive Liquids and Gaseous Waste System The inspectors reviewed the licensee's liquid and gaseous radioactive waste effluent programs to determine agreement with the commitments in Chapter 11 of 1.he UFSAR and compliance with the requirements in Sections 8.1.1, 8.1.2, 8.1.3, and 8.1.5 of the T + t
. - _ _
1c t; ,
.. , . . - . .
i a
' .
l k -10- l
, ,
#
T
.The inspectors _ reviewed the licensee's implementation of the RETS and 0DCM to ensure agreement with analysis sensitivities, reporting limits,- .
y analytical results, sampling requirements, RWEP operating procedures, and - offsite dose results from effluents. Selected documents and records
,
listed in Attachment 6 to this report were reviewe l The inspectors reviewed current approved revisions to FSV-procedures governing the release of liquid and gaseous radioactive waste. These ' effluent release procedures provided for the following: sampling of ? radioactive waste; radionuclide analysis; calculation of effluent release
'
rate, projected offsite radionuclide concentrations, and. projected offsite
-
doses prior to release; calculation and verification of effluent radiation monitor setpoints; and verification of discharge and dilution flow rates and effluent volume discharge , The inspectors reviewed a representative number of liquid and gaseous [ batch release' permits and gaseous continuous release permits for the r p3riod January 1989 through May 1990. It was determined that quantities
'
of radioactive nuclides released in the liquid and gaseous effluents were witt:in the ' limits specified in the RETS. Offsite doses had been calculated according to the ODCM and were within the TS limits. The inspectors determined that processing, sampling and analysis, and approval t and performance of the radioactive effluent releases were conducted in ; accordtnce with FSV procedure The. inspectors determined that no design changes had been made to the liquid radioactive waste system since=the previous NRC inspection of the d radwaste activities conducted.in June 1989.' The inspectors noted that # Change Notice 2939, issued October 12,-1989, modified the radioactive gas ' waste syste The modification provided a flow path for the purge vacuum
. pumps to discharge.directly to the reactor plant exhaust system rathe ,
than through the normal discharge path to the low activity header of the
'
gas waste system. This design change was made to' decrease the time , required to pump down the fuel handling machine or auxiliary transfer cask and expedite the defueling process. The inspectors reviewed the licensee's evaluation of the design modification and found it - satisfactor L No violations or deviations were identified.
g Reports of Radioactive Effluents
,
The inspectors reviewed the licensee's reports concerning radwaste systems I ef and effluent releases to determine compliance with the requirements of
.
10 CFR Part 50.36(a)(2) and Section 7.5.1.e of the I The inspectors reviewed the licensee's semiannual effluent release reports for the periods January 1 through June 30, 1989, and July 1 through December 31, 1989. These reports were written in the format described in NRC Regulatory Guide 1.21, Revision 1, June 1974, and contained the
-
_
- --,mt s,-
Li- ~
(b I- 4: ,
m
< .
.- -11-information required by the TS. During the period January 1 through -7 December 31, 1989, the licensee performed 228 liquid batch releases and
'
220 gaseous batch releases. The licensee reported seven abnormal gaseous batch _ releases during 1989. All of these abnormal gaseous releases were
- planned and controlled releases of gaseous radioactivity from the primary ' '
coolant-system and the helium storage system. The releases were made and
+ controlled through the reactor building exhaust ventilation. system and monitored throughout the entire release times. Total activity _ released was calculated to be 3.27E+00 curies. The. gaseous releases were reported-in the semiannual effluent release reports as abnormal releases to fully ,
' document the radioactivity released to the environment. The licensee's documentation was found satisfactory. .The licensee reported one unplanned i
'
radiological' gaseous release to the environment during the second calendar quarter of 1989. This unplanned release from 1A waste gas surge tank was , the topic of Licensee Event Report 89-12 which was discussed and closed in i NRC Inspection Report 50-267/89-1 The unpl6nned release of 1A waste gas-
~
surge-tank was monitored and resulted in a total activity release of approximately 2.51E-02 curies or approximately 0.85 percent.of the TS limits. The inspectors reviewed the licensee's changes to.the 00CM as ; detailed in the appropriate semiannual effluent release report as per TS ~ requirements. The inspectors reviewed the licensee's explanation of why various liquid'and gaseous effluent monitoring instrumentation was out-of-service for extended periods of time during 1989. The inspectors verified that the licensee's actions and reporting satisfied the TS action statements and reporting requirements for this type of instrumentatio j
'
No violations or deviations were identified.- j
, 1 Reactor Chemistry Control and Chemical Analysis ,
The inspectors reviewed the licensee's water chemistry program including L establishment and implementation of a water chemistry control program, l> water sampling, facilities and equipment, implementation of a QC program for chemical measurements, and water chemistry confirmatory measurements ,
:
to determine agreement with the commitments-in. Chapter 10 of'the'UFSAR and: L ' compliance with the requirements in Sections 4.3.8, 5.3.7, and 7.4 of the T > The inspectors' review of the water chemistry program found that the , l=
- licensee had revised and approved administrative procedures, chemical :
l control procedures, instrument calibration and quality control procedures, ! , and analytical procedures. A review of selected procedures revised and I, developed since the previous NRC water chemistry inspection conducted in April 1988 indicated that the WCS and RCS had established sufficient progammatic procedures to meet the requirements of the UFSAR and TS. The * @/ procedures reviewed are listed in Attachment 6 to this repor The inspectors ir. pected the facilities and equipment used by the WCS and 14 RCS staffs. The following facilities were inspected: water chemistry laboratory, radiochemistry laboratory, and radiochemistry counting room, i
st, .
.. ~ . ..
M I-12-The laboratories and counting room were equipped with the necessary analytical instrumentation to perform the required analyses. No changes were noted in the facilities and equipment since April 1988. The water chemistry and radiochemistry facilities and analytical instrumentation were adequate to perform routine chemistry and radiochemistry requirements to support plant decommissionin The inspectors reviewed selected water chemistry procedures for operation, calibration, and quality control of the water chemistry laboratory instrumentation used for analysis of the NRC water chemistry standards to determine the adequacy and effectiveness of the licensee's water chemistry measurements program. The inspectors verified that the water chemistr laboratory analytical instruments had been calibrated in accordance with procedures, and an instrument'QC program had been implemented. The licensee'was using instrument QC charts to trend QC data collected from periodic QC analyses of chemical parameters. The licensee had not initiated a program of two independert standards for instrument calibration and QC, Therefore, the licensee had no means of verifying the-integrity of the chemical standards used for calibration and QC of the chemistry. analytical instrumentation. The licensee was using only single point calibrations for instruments such as atomic absorption, UV-Vis-spectroscopy, and ion chromatography. These single point calibrations implied that the instrument results were linear with the standard concentrations for all sample concentrations measured. The licensee was not able:to identify slope changes in the calibration curves . which could cause erroneous results. The licensee had not generated instrument calibration curves using a minimum of three data points, excluding zero, and bracketing the concentration range for the expected analytical results. These observations were discussed with the licensee during the inspection and at the exit interview on June' 15, 199 During the inspection, standard chemical solutions were provided to the licensee for confirmatory measurements analyses. The standards were analyzed by the licensee using routine methods and equipment. The results v -of the measurements comparisons are summarized in Attachments 1, 2, and 3 to this report. The licensee's original analytical results indicated that 12 of the 27 results were in agreement giving a 44 percent agreemen After making attempts to resolve the analytical -problems, including new standard preparation and instrument calibration and preparation of fresh reagents, the licensee's final analysis results showed 89 percent-agreement with the Brookhaven National Laboratory (BNL) results based on 24 agreement results out of 27 total results compared. This was a significant irnorovement over the 64 percent agreement demonstrated:during the previous NRC inspection of the water chemistry area during April 198 The licensee's water chemistry analytical performance was satisfactory during this inspection and demonstrated that the water chemistry laboratory was capable of performing accurate and reliable chemical analyses to support plant decommissioning activitie No violations or deviations were identifie .__._.___________ _ _
..
5f EALi ~ ;
; g;g 1 ,
,
u ,
*L -13- .
11. 0A and Confirmatory Measurements for Radiochemistry Analyses The inspectors reviewed the licensee's radiochemical analysis program including analytical procedures, implementation of an instrument QC program, and radioanalytical confirmatory measurements to determine compliance with commitments in Chapter 4 of the UFSAR and compliance with the requirements in Sections 4.2 and 7.4 of the T . The inspectors reviewed selected radiochemistry laboratory analytical c procedures revised and approved since the previous NRC inspection of the-
-
radiochemistry activities conducted in April 1988, and determined that the '
.
licensee had established and implemented. sufficient analytical procedures ' to meet UFSAR and TS requirement Procedures which were reviewed are , listed in-Attachment 6 to this repor ..>
'
The inspectors reviewed selected licensee's records for the period April 1988 through May 1990 involving radiochemistry counting room instrumentation calibration and QC. It was verified that-the radiochemistry counting room instruments had been calibrated according to procedures and an instrument QC program was being implemente During the inspection, radiological confirmatory measurements' were performed on a split sample by the licensee and the inspectors. The <
'
sample was analyzed by the licensee using routine methods and equipmen The results of the measurements comparisons are summarized in -
' Attachments 1, 4, and 5. The licensee's tritium.and gamma isotopic results from the waste water sample listed in Attachment 4 showed '100 percent agreement with the NRC analyses results. The licensee's performance in the area of radiological confirmatory measurements was at . .the same 100 percent agreement achieved during the last NRC inspection of this area in April 198 The licensee's radiochemistry analytical performance was satisfactory during this inspection and demonstrated that the radiochemistry laboratory and counting facility were capable of -
performing accurate and reliable radiochemistry analyses to support plant 1
'
decommissioning activitie No violations or deviations were identifie . Radiological Environmental Monitoring Program
'The inspectors reviewed the licensee's radiological environmental monitoring program to determine compliance with the requirements in Section 7.5.1.d of the TS. The Radiological Environmental Monitoring - Program Annual Summary Report for 1989 was reviewed and the inspectors determined that the sampling and analysis requirements specified in the TS and ODCM had been me The licensee had conducted the 1989 annual land-use census on July 21, 1989, and the results of the census were documented in the Radiological Environmental Monitoring Program Annual Summary report for 1989 as per TS requirement ..
No violations or deviations were identifie .-
,
,
,. - t .- 4 ;
*
1
.
.
!
4' 14 13. Exit Interview 3
.
The inspectors met with tte senior resident inspector and the licensee-representatives denoted in paragraph I at the. conclusion of the inspection
-
on June 15, 1990, and summarized the scope and findings as presented in this. report. The licensee did not identify as proprietary any of the
-
materials provided to, or reviewed by, the inspectors during.the inspectio ' l
>
l h-l- '
-
i
- -
.
I l l'r
- ;- .
l' L
#4 4 -
e g, 3E y ..
"*
p ,
' ~y '
-
-
,
, :- p pgJts W '
'
S,< .> i < y. - v : , g4 , ,
*
-
f+ 9 -
-
'
. , , ; i
.w ~7*
,
~ ' ' ' - * '
b , . . , g w '
. , ,
i > J
* -$ r; hb y . k ,: ,j ~q, 4 2 ~
U, 'q t ATTACHMENT 1 ' S , ,
>...W1 .
.. ,
'
e Anal vt i cal' M,eesurement s _
. .
f '
< '
,
,,S Wit M '
-
.
, ,
'
h
'
Fort-St. Vrain Nuciear Station # W ..
, , l NRC!: I nspec t i on' .Repor t t 50-267/90-10 0
..j
,
g h]m ~ 3 ,
'
e ,
-
,
'
6: 4' .. '1
*
& '
-
W i>_ '
* , L1'.i ; Water i Chemi strv Con'f i rmat or V ' Measurements -
i,
, ,
N # During / t he l'nspecti on, standard chemi cali soluti ons. weret provided @o'-
*
m, - the 1 i censee f ory anal ysi s.-
.
tThe standard solutions were preparedf t%
'
> 3
~
,1 , . the g Brookhaven : National Laboratory."(BNL),a Saf ety#and; Environmental .t hi% jProtecti oni Di vi si on,d orEthe iNRCh : The standardsf were anal yzed bywhel g C1.icensee using; routine:.methodsland. equipment.; The Janal ysi s).o fl
"
% o cchemical standards isiused4to: verify 1the!-1icensee's:capabil'ity;to-
;4 J '
Fmoni. tor:chemicalNparametersnincvariouse plant systems.cwithirespectLto 4 ) Tech'nica1E spe t fi cati on - (TS) :requi rements and- other industry ' J:
, ** ; standard :Inv addi tion, .the analyses of standards-are usedtto; 4 s
yy'
~ : eval _uate the111 censee's* anal yti cal ~ procedures with respect to: accuracy l, s 1 Eand? precisio .
4 , 4
.
k7 1The;results of-the measurements comparisons'are 1isteA. in' Attachment
? Attachment 3~' describes the criteria used,.to:compareithe results'.. +
S
: l
"9
, ' Allistandardi were ca'n~al yz ed at three concentrations spread"over9the' q oliicenceeVsinormalLcalibration rang .O gs -
, %.
$.a u
" ,
Dheil i censee's or i gi nal manal yt i c al '_ resul tis ii ndi cated problemsiwith/thef % 7 1' ' 1 anal yses if orf chl'orl ds, J sul.f ate, o i ron, . chromium,phydraz i ne, Land si l i ca. . ;[
; ;Th_e original:results showed'13"of the'27:results-were'in' agreement.or' L:'7 qual:i f i ed f agreement usi.ng ethe. criteria _ presented in. Attachment?-3'.- , . .
in gh,y . The 1icensee*s originalLchloride; midrange.andjhigh range _ t
. ,
*
'
4 concentration.results were;in. disagreement'and blased high., 'The~
*4 , .
1 i censee's c qual i tyf conteal standards:were'also blased{ slight'lyl' hig The li censee did not l retest thel staridardsif or1chl ori d g
+p : , y A
)The 1.icensee's origi nal - sul f ate resul ts /were -al-1 li n di sagreement:
. ..
lg" - (b .' 4 jk and biased high._ .The 1icensee prepared new dilutionsiof>the)BN_Lv 6 sulfate standards'~(OOA,c888, and BBC) and reran the' sulfate" . , f _ anal pse j
~
y . The retest results f or: the~ sul.f ate Janalyses Lwere all.. ?m ein agreemen
, ,
'
;]
@ Q ',
p* M, c.- The 3:li censee's or A gi nal -i ron resul tsi were ' all , i n ei ther 'quaii f _l ed/ agreement'or, disagreement and-blased. low. The11icenseenprepared s
'il f
&_ new' Iron calibration standards and recalibrated the atomi t
'
?
ji >
. absorption instrument _using a two" point calibratton_insteadyof a );
I' 'one; point calibratio The li censee. prepared new dil uti ons ' of- ' the'BNL iron. standards -(88G,'08H, and-881) and reran ~'the iron
.
y
'"
a n a l ys es'. The retest-results for the iron analyses were_all.'in-agreement.
b? '
<t
, . 14: . y- .f
.
es
' =
> -
<
, , q
_ _ 1
p?W#
' ~
&: ,
1 n 1 49 n , - ; -
,
- +
; x y?
' n
' K g+7 ' W+ w , < , - d c 'R , 7 3W
' -' '
g Nyt w m ,; imgg ,
=
3m
,
.
+ y, - *
O'
+ b N: 7 (q V.f , ,- ! ,
~
-
.' "r A
,
a .g 16 pp$*bl:8 w * 7 74"
.
W- s 4 < >
,pg f
,
'
_w- w,
'.
-
t
, ,
,
w .m , - i w , , +7-g - y
.
, w . %
N.ag, .. cATTACHMENT'1
"
.a # / '2~ ,
pv,.t m '< .
.
=
. ,
,-^
,
,' _ . ,
._ , q4lrf:
'
_
;
' -W x
. , :. = ,
g @w? . , e j d '. ? LThe Wi'censeO'sToriginal chromi um l resul t s .'weref al ll. .inkdisagreement ' 5 $ ,
>
iandiblasedblow. LThe.-~ 11 censee Jpr eparedinew ' chromi umical,i br ati on hfL s ,% , Estandardsf and * recali brated ' th.e. atomi ct absorpti ony instrumentfusing; f a[two" poi nt _ cali brati on, instead y ofi a= oneipol'n.tYcali br ati'onh - Th _
* ,
Q""+i W '
, J 1.i censee prepared l newE di l uti ons ; of,[ thei BNLS ch'romi um: standards ; .,
r
. [
388G, 88H,fand 881)'.andfrerans,thefchromiumianalysesh 4Thejretesty* >
.
b ,
-
. . L resUl t s (f or lthe . chromi um! anal yses werefallG i n - agreemeriti v
-
'
~
4 - t .,e: n ,
.
- . , , J .
,o ~_ ) - t .
.
. .i m - . . . .
;Thellicensee's original . hydrazine resul ts 'were ' ail;3 6 !el the y %,
; ; qual;i'{i ed' agreementfor' di segreementy and[bi ased _hl gh.g {The c . ( ,
'
='
'
41 .w 111censee's Equali tyj.controlf standard 1 wa'sf al so > bi ased; high? lThe;
' ;.1icensee preparedfnew hydrazine.reagentfand2neW dilUtionsjof7the! q" , . ,
E
~
h NW JBNL7hydrazinetstandards?(88P,1880,Jand380R)<andCreran1thei ' m j - , thydrlazi ne ? anal yses . fusi ng . a %100 mm cell pathjlengthb %Their'etestl
'
7; M N tresultshwere/allhin agreemen o / I
'
: +
,
~
~_ "
j g - g -- s ' tt , - . . . W
..
W
. . .
f .1 ' 1Thegli censee's originalo st li ca l owirang e c onc ent ra t i onp resul t Cwa s ; g M' $ * finfdisagreement:andfbiased high. 'The li'c'enseefprepared6new- t y 3? U di_l utfons Lof f theiBNL si~l i ca - standards '(87S,. 87T7and:'870) f and ' ; '
'N Rl <
(-r'erans the t sil i ca danal yses. JThevretest-results[for(the'silicar "
E/jy , M . fanal yses wer e L al lL 'i n_ .'agreemen '
'
_q >+ , M' , .-
-
y>; ~ gy
'
s Mi? - y Jhe yli censee's; fi nal\ anal yti cal ; resul ts, . af ter1the Jr etestsi toiretq , "e/ g i , s
' -
Fthe?origina1Wquali'fied; agreements (and-disagreements, indicated 89> W1 'y
@ y O peptien tj agr eemen t? wi ti the3 BNLiresults based;on'27 results ,
ecompared. Thelli censee's water ~ chemi stry' secti on penf or.mancefi ng the, ,
.
n i i area [obnontradiologl1 cal water) chemistry confirmatciry measurements ' .
.7'
y;s Jn :showeda al.;si gnif i cantfi mprovement c overJ the164;percentf achi eved dur_i ng:
.
s
'
h * thetl astt NRCDi nspecti onf of f thi s7 area 'i n L April' 1988. . (
~
y J ge > * En 'n
:
,
c 1 1' i
.
.,
y; _, r ,
' q; i + ,, -
i, 4 > f g
;
... -
' ,. - -- .
I . ,
*
-
,
j g e o ay f {it } _ p
~s *
; Q, :
.f
- + 1' ?
-t, . v:. n '
h_ i'
~
I y ,' v ,.,
.g.,-,-
b r' _,[ I v
&z i h y L
, a .
p +, 7 7 . . y , Q-j s tJ; v' ,1 Wi q i fw f- ayhn f,o,_ s' . l[ , mw 3: , r
., . _ . - , , , i
an: u .- y< m: + , ,,u w , o q z xwny;"
< <
,
-
~.
w mmt 1_ ;9' m ~ .c:?G ; q&
< -
,
.h ,2$ iy, - g" l ^ %":~s r' ?
~
,
Qi'0 :lX
~
*
; ' >
.1,
" , 1 ' - ' 'j 1
'b N@,
&W27% lW .
", i W' e ^x J y 9:e,r;
- _
.ws4 g ; , ,
<
,, p , ,1 r
h;f g&; ' 9; lA . n W':: , i t .
,
'
.b nb ' ,_
'<~
;
in e- &.c w ' ^ -c e
'
i
,-
~
< ,k , .'h. b b) 'l '{
* .
.
'
*
J Qi ! A .s <Yb -- ;
,.,%
M
'
'I- 1
" :%
,
*
'
ji EMa s3 . RJ Rm ATTACHMENTS.,_1(-
',n
,
4 , . , a V- yy , Mc n .. "Nb j?y$4 we et"' t
.e e a . ..
'
'
p % &2d5 c Rabi ~ol~ool' e alk Con f i e ma t or'v Meas 0remen t s , dipi _ i s ,
>
N
.
fs D Nl yThejadlocherki str y ; confi rmatory.. measurement.s wa re perf ormed 1on tbe 2
'
M.,@ ' sial l_owi ng? sampi es) i ns the. NRC; Regi on: IV Jaboratory' f orl owing[;; thel ~ p i, " j onsi m w teW nspecti o s
,
<m
&
Nh \' ._ . .
. . . , '. . _ .. .
4 4 W j ,((lb FSV?Wa'steiLa qui d LSampl e 41: ,Li terf-Marli1'nelli= Beaker '[ W gn, s .. . . . . - .
.
~
~s
.
,
-- ;i
'
#Q
~. .
! Sampie H 20 ml:Scinti11ation? Vial'
N@a-e W , ' M2f FSVfTr1 tium:. ,
- '-
. 2 V _- c '
,
<
.,. ... s s - . .. i _
gC,, M The) r adi ol ogi calfconf i rmatory measurement tests c6ns'istediof/comparingc y;WC % 4 j thekan'al ysi s ' resul ts ' 6f hthe? li censee ;'andythe !NRC LRegi onblVil ab6catorp.) , * 1 D jTheLNRC? Region [lVjl aboratoryLmeasurements care ref erenced tolthe: ' ' J(yf@ys g
!Nationalz[InstituteEofaStandards and Technololgy bynljaboratory,
_intercomparison ' MUQ 3 .. ._ .
. .
. . .
, __ ._
. Mhe 711 censee"maintai ns; three - hi gh-puri ty , germani um :detectc<rsii n thelry _ >
y; g]%M radi ochemi stry counti ng; room. , These detectors are'.used routinelyTforf
,, 11 sotopi c : anal ysi s lo f _ 'radi oacti ve sampl es : to demonstr ate Jco ,pl i ance/ +
,g,s'
*
% Lwi t h) TSi and iregu l a t oryir e_ qui r emerit s . The - anal'yti c ali: resul ts-' + Tom"on1 y) '
.
q" ' Lone 2 detector were compared;withithe: NRC.results.. The'licenseeJ _V' g' , a jperf ormedL the a tri ti.umfanalysi'sfon; thelrflijuidiscintillationjounting] . lO v nystem niLni thei rJ radi ochemi strya counti ng' rcom'.i ' Thel i nd i vi dual! ,sampl e i ' k7~ ' - Janal v~sesl andicompari son? ofianal y't i cala resul ts, of ' thelradi ol ogi cal? - g3 W , conf.irmatory[measuree usedLto its are'tabulatedfin?AttachmentL4h
-
4Attachmentj5.< ' ; , 1" ' - idescribessthe=criter
< >
compare theranalytical resultsh
,
'- i n.: . .
N' _ ITk1li censeej s 4 9'ammafi sotopi cf reeu. ' = f romf the- sampl e li sted < ini ' 'T i s 1 Atit achinentt4 showedE100ipercent sementiwithitheLNRC+analystsy _
^ , . d" c "r'esul t s> The' 11 consee's tr i-ti ur .-esul t wasii nf agreement <.(wi th Athe - NRC:
N^ 8,' analysistresult.. jTheL1icensee's performance;inlthe-areaJof? ,
" ' a radiologicali conf irmatory rNeasurementsD was identica10to the: 100 l 4 7 percent 9 agreement:: achieved durira-the lastHNRC'i_nspection of[thisTarea . y
.y gja
&
i.n; Apr i;1' 4198 f
-
ed hhy' 4
' ..: -.(_ . ,.i u > ! c
[ :1 1 y ( . @P: o
~ '
y' y J N* + 4 s n;M$ p- > s
.
-
Qj{{. ' 4 'ti- k dm sv $ ,
"
4, .' g.,-< -
,, !
jlhl{ N yuy
. <
! t[ 3 lin a
,
(
;
w's
t 9 l Y*j# ] _
g, Q ' l0 f hbfkdb s '
,
, , _
._ ]
p -m p , ,4 m
[* Q[t ^ a;
,Y c'
.
"
..
.BITACHNENT 2
, ,
W J ter Chemistry Conu tmptory Neanurementu Resultu ( ',
' ,
!r l,l Fort St. Vrain Nuclear Station y NRC Inspection Reports 50-267/90-10 L.
f i pit 1,ori stf Anal ysi n (5-25 ppb) Ion Chromatography FSV Results NRC Results Comparison
.c l}amnl e ip,nt ,1, i 10.pJy ) Decluion 00A< 7.46 7.50 Agreement 800 .2P.20 15.50 Disagreement i
'
000 31.68 23.00 Disagreement
, ; 21 hplfate Analv91s (5-25 ppb) Ion Chromatography
. FSV Results NRC Results Comparison '"
Samnin 1pptO_ (nnb) Decision i OSA 7,00 4.75 Disagreement + 000 14.00 9.50 Disagreement GOC 22.70- 15.00 Disagreement
~ Retest: ~- prepared new DNL standard dilutions and performed retest'
analy'ses ; 00A _S.24 4.75 Agreement f DOH 9.94 9.50 Agreement ;
'
ORC 14.06 15.00 Agreement-
, > . 1ron Anal vni s '(100-1000 ppb) Flame Atomic Absorption ,
FSV Results , NRC Results Comparison
.
Samnie _( nnh)' 1 ppb) Decision DOG 176 190 Qual. Agre f DOH 200- 392 Disagreement-881_ 435 500 Disagreement
,
' Re t.est - prepared new DNL standard dilutions, retalibrated the atomic absorption instrument using a two point calibration, and performed retest analyses D80 212 190 Agreement DOH 301 392 Agreement-88 Agreement ;
,
b
'
u , - .
.- __ _ - - .
, 5 i: <; ,
- '
,
, i
' .. * - i -
'e
> , ATT ACHMENT 2, 2 l
;
;
i i 7 Conner Anal ysi s (100-1000 ppb) Flame Atomic Absorption ;
,
FSV Results NRC Results Comparison .
!
!: o , Gamptig (pob) 1gpil)L Detision i
'000 107 199 Agreement f HGH 3G7 40S Agreement j 4 001 575 595 Agreement
" ! 'Qbromium Analvnis (100-1000 ppb) Flame Atomic-Absorptio '
-i'
FSV Results NRC Results Comparison ;
? Spmple jpnb) -(pob) Decision' r DOG 145 200 Disagreement GBH 262 404 Disagreement'
001 370 600 Disagreement
'
Rutest - prepared new BNL standard dilutions, recalibrated the ! atomic absorption instrument uuing a two point calibrationf and performed retest analyses-DDG 109 200 Agreement , 0 011 301 404 Agreement _l
,
001 573 600 Agreement i ED d ium AnafyyLn (10-100 ppb) Flame Atomic Absorptas ; FSV Results NRC'Hesults Comparison-
,
Samni,g (nob) 1 ppb) Decision DOJ 19 1 Disagreement DOK SS 4 Agreement ' OBL 00 7 Agreement 7.f Ammnni a Anal yst s (0.5-10 ppn Selective Ion Electrodo , FSV Results NRC Results Comparison Dampl e ip_p m ) Inpm) Deci si on ! DBM O.46 0.51 Agreement - BON 1.45 1.55 Agreement' ; 000 4.04 S.00 Agreement
.
P
' ' ,
I w
. :)- '
4i
! -.. '+ ,,
- ,.
I .'
'
'I
' ' ATT ACHMENT 2 3
'
<
!
'
l-l cf . O. - L Hydrar i ne Anal ysi s (10-100 ppb) Spectroscopy ; . . Y" FSV Results NRC Results Comparison l; Sample (pob) 1pp_ta)_ P_ecini m t- . i l , OOP- 13 1 Disagreement ;
, 000 49 4 Disagreement ,
[- BOR 94 8 Qual. Agre l
Retent - prepared.new HNL utandard dilutions, prepared new hydrazine j L reagent, used a 100mm cell path length, and performed retest ,
- . analyses j l
00P 1 .2 Agreement 'l 800 4 .3 . Agreement- l BRR 8 .4 Agreement l
!
t
t Gilica Analysis (S-100 ppb). Spectroscopy FSV Renults NRC'Results Comparison Dampl e Ipnb7 -jppb). Deci ni on !
>
07B 25 2 Disagreement 'f ' 07T 30 4 Agreemen G7U 74 7 Agreement I ;
'
Retest - prepared new HNL standard dilutions and perf ormed retest analyses .i c G7 .1 Agreement i i 07T 39 4 Agreement j 07U 71- .7 Agreement-
-i f
%
-
>
>
h
&
P i v
.' h . . _ . s . .
--
-
, >
/
L f
. *- . ..
O x 8 i
' , ATTACHMENT 3 '
CRITERIA FOR COMPARIND_ WATER'CHENISTRY ANALYTlGAL NEASUREMENTD-
.
t
:The itsllowing are the criteria used in comparing the results of the capability touts and verification measurements. The criteria .
f or' the judgement limits are based on the data irum Table 2.1 of NURCO/CR-5244, Eval uation of Non-Radiological Water Chemistry-et -l' Power Reactors." -Licensee values within the pluu or minus two-
'6tadnard deviations range of t h r. HNL known values are considered to bo in agreemen Licensee values outside the plus-or minus ?
i two standar d deviations range but wi thin the plus. or minus three l F- Lutandard deviations range of the BNL known values are considered to be:in qualified agreement. Retest results which are in~ l- . qualified agreement wi'l receive additional attention.;(Licensee C values greater than tt.e pluu or minus three standard deviations ; range of the !!NL knc.u values are.in. disagreemen The standard [ deviations were comr uted using the average _ percent standard ;
'
deviation valuun of .each analyte ir Table i The rangen f or the dat.a in Attachment 2 aro as f ollows: ' F
'
~)
L Agreement Qualified Areement Qmpule faalvte Renne Range _ __
^{
f ODA C1 7.0 - .0 - [ GO 4.3 - .0 - C1 14.3 - 1 .0 - 1 SO
0.5 - 1 .3 - 1 < DOC C1~ 22.0 - 2 .3 - 2 , SO 4 13.5 - 1 .0 - 1 t 800 Fe 179 - 2.17 169 - 227 '
'
Cu 100 - 210 171 - 227 Cr 101 - 219 171 - 229
!
OOH Fe 354 - 430 336 - 440 Cu 366 - 444 347 - 463 - Cr 365 - 443 345 - 463 : 001 Fe 524 - 636 496.- 664 i Cu 530 - 652 010 - 600 J Cr 542 - 650 512 - 600-i DOJ Na 11.0 - 1 .0 - 1 OUR Na 42.5 - 5 .0 - 6 !
-DOL Na 65.5 - 0 .0 - 9 ; , &
p,., '.
.. . . - .
ATTACHMENT 3 2 Agreement Qualified Areement Amnul e Analyte Ranoe Ranoe GUM NH 0.46 - 0.56 0.44 - O.T1
OON NH 1.40 - 1.70 1.33 - 1.70
000 NH 3 4.52 - 5.40 4.20 - 5.72 OOP N, H j4 9.4 - 1 .0 - 1 N,jH4 39.0 - 4E 6 37.4 - 4 R NH
77.9 - 9 .6 - 9 S Si O l0*9 ~ 23*4 lU*l ~ 24*2
07T SiO 37.4 - 4 .0 - 4 U SiG, j 70.6 - 0 .3 - 9 y _:
- -
.
.
( l 4.; < - , -s
'
au
~ .: #.
li l ;
. . ,= .1. , i U ATTACHMFNT 4 1 ,
m s o h$ . Radi al noi cal Confirmq1ory ~Measurgament - Resol t n
' i ,
EgCi St. Vrajn Nuclear Station
' '
NRC Inspection Reports ~S0-267/90-10
,
c
. . . .); . ,
p < ' Wast e Li nui d Sampl e - (1 1Ater Liquid Marinelli Heaker) k' (Sampled: 10:00, MDT, June'12, 1990) e Ib ' ' FSV Results NRC Results FSV/NRC Comparison' u , Nuctida tuC1/mLL TuCi/ml) Rat i o ' .Dect31un j.-, Cu-137- 3.3SiO.22E-7 5.07dO.06E-7- 1.06- Agreement { NNp54 'O.0110.20E-7 8.3310.00E-7 -1.06 Agreement: ' P' Co-60 3.7310.17E-7 3.6310.06E-7 1'.03 Agreement-k Tri t ium Sample (20 m) Scintillation Vial
*i (Sampied 10:00, MDT,-June 12, 1990) 'FSV Results NRC Results FSV/NR Compariso Nyclide (uCl/ml). (uCi/ml) Retto Recisign ,
H-3- 5.1,'iO.01E-2 6.10iO.03E-2 -0.04- AgreementL
i r-. W
~ -' , 4o=.,
c Jet ... ,
'
,; :=
:
ATTACHMENT S y . .
-
.
"" . CRITERIA FOR COMPARING RADIOCHEMISTRY ANALYTICAL MEASpREMENTS
.
k
'
;The f ollowirig 'are .the cri teria used in comparing 'the resul ts of .
~j capability touts and verifir.ation measurements. The criteria are
' based on at empirical relationship establishedt through prior
,'
'
-experience and this program * s' analytical requirements.-
In these criteria, the judgement limits vary in relation to the-comparinon of the resolutio . < , 4 Resolution = __ NRC UNCERTAINTY 'I t
.
,-7 ! LICENSEE VALUE Ratio =- _
'NRC VALUE '
!
'
Comparisons are made by first determinlag the: resolution and then reading across; the same 1ine'to.the corresponding ratio. The-following table shows the acceptance value , t t
-- _
'(
RESOLUTION AGREEMENT RATI ,; _ _
. <4 0.40 - 2.50 4-7 0.50'- 2.00 ?
I O- 15 0.60 - 1.66 , 16s- SO O.75 1.33 31 - 200 0.00 - 1.25 l
>200 0.05 - 1.10 '
i
. _ _ . - _-. -- _-. -
%
*
The above criteria are applied to the f ollowing analysos:
( 1 )- Gamma Spectrometry
~(2) Tritium in liquid samples
.
(3) Iodine on adsorbers O
(4) Sr and Sr determinations
*
,
(5) ' Gross Beta where samples are counted on the same date-using the same reference nuclid (
-r
l V
4't e
.. ..c
.
.
ATTACHMENT 6
*
n Fort St. Vrain Nuclear Generating Station
,
NRC Inspection Report 50-267/90-10 ; ri Documents Reviewed .
, - ,
Procedure Title Issue Date
~~~ ~N o .
1. Fuel Handling Procedura Work Packet (FHPWP) FHPWP-159 Loading of New Fuel Elements onto Cargo Restraint Transporter (CRT) FHPWP-302 Spent Fuel Shipping of Six E6ements From FSW-6
,
2. Nuclear Production Administrative Procedures (NPAP) NPAP-19- Radioactive Gaseous Effluent 2 12/27/89. : Releases 3. FSV Administrative Procedures , G-30 Chemistry Control 1 10/11/89
' Health Physics Procedures (HPP)
HPP-30 Shipment of Radioactive Materials 9 11/03/87 HPP-175 Receiving Padioactive Materials 1 03/27/89 HPP-605 Radioactive Liquid (System 62) 2 02/20/89 Effluent Sampling and Release Determination HPP-610 Reactor Building Sump (T-7202) 2 12/20/89 Effluent Sampling and Release Data
s .e ,. . o_
[
.
.
. Procedure Title Issue Date
%
HPP-615 Radioactive Gas Waste Release Rate 1 03/27/89 Calculations
-
HPP-630 Radioactive Material Control and 1 09/27/89 Handling
,
' Effluent Surveillance Requirement (ESR) Procedures ESR-8.1.1 be-xm Re'toactive Gaseous Effluent Prior 1 12/27/89 :
'
to Release-ESR-8.1.1 d-w Equivalent Curies of Kr-88 in Gas 2 12/09/88 Waste Tanks
.ESR-8.1.2 bed-xm Radioactive Liquid Release 1 12/20/89 i Authorization
^
SR-0P-41-X Volume (Batch) Release from Reactor 8 06/17/88 Building Sump Support Services Manager's Administrative Procedures (SUSMAP) SUSMAP-2 !.,ffsite Dose Calculation Manual 17 10/11/89 Water Chemistry Procedures (WCP)
,
WCP- Determination of Antons by 2 09/18/86 , Dionex 20201 Ion Chromatograph WCP- Ammonia by Specific lon Electrode 6 09/30/88' WCP-14 Hydrazine, Colorimetric, High 10 09/30/88 and Low Levels WCP-1 Metals, Flame Atomic Absorption 7 10/04/89 WCP-20 Silica Heteropoly Blue Method, 12 12/15/87 Colorimetric WCP-11 Instrument Operability - 1 05/24'6h " Spectrophotometer, Beckman 0U-50 WCP-11 Operation of UV-VIS 1 06/23/88 Spectrophotometer Bausch and Lomb Models
~
,
P 1
,. *- e . c:o -
r
.
,
-3- '
Procedure Title Issue Date N WCP-20 Calibration of Atomic Absorption 4 03/12/86 Unit; Perkin-Elmer Model 306 '
WCP-20 Calibration of Ion Chromatograph - 3 11/17/88 Dionex 20201 > l.' WCP-21 Calibration of Spectrophotometer, 5 11/17/88 s Bausch and Lomb 100 WCP-21 Calibration of Spectrophotometer, 1 10/04/89 Beckman 0U-50
'
WCP-300 Chemistry Control 5 02/07/90 WCP-302 Chemistry Specifications Secondary 8 02/28/90 : Coolant - System 31 WCP-304 Chemistry Specifications Condensate 4 02/07/90 Makeup Water - System 33-1
.
WCP-305 Chemistry Specifications Circulating 5 02/07/90 i= Water - System 41 WCP-306 Chemistry Specifications Service 4' 02/07/90 Water - System 42 WCP-307 Chemistry Specifications - PCRV 3 02/26/90 Cooling Water - System 46 WCP-308 Chemistry Specifications for Primary 5 02/07/90 Coolant Purification Cooling Water - System 47 , WCP-353 Calibration Program 13 03/14/90 i WCP-354 Cross-Check 9 02/28/90 WCP-356 Analytical Control Charts 3 06/07/89 8. Radiochemistry Procedures (RCP) l RCP-8 Sample Preparation for Tritium 11 04/25/90 L Analysis RCP-9 Sample Preparation for Gamma 4 09/23/85 Spectral Analysis l l
_ _ _ - _ _ _
. e
- O C
.*
+
-4- .
,
!
Procedure Title Issue Date N '
RCP-10- Sample Preparation for Gross Alpha 11 09/21/88 and Gross Beta Analysis ,
-
RCP-11 Sample Preparation for Strontium-89 10 07/13/88 > and Strontium-90' Analysis
;
RCP-18 Operation and Calibration Procedure 12 05/17/89 for the Beckman LS100C ; RCP-21 Quality Assurance Program for the 18 03/21/90 Radiochemistry Laboratory ! RCP-38 Operation and Calibration of 13 06/16/89 ; Computer-Based Gamma Analysis System RCP-41 Operation and Cali'o ration P,ocedure 10 05/17/89 ' for the Beckman LS3801 L " RCP-48 Operation and Calibration of the 2 12/21/88 Canberra Industries Series 90 Anslyzer and the Portable Davidson , Multi-Channel Analyzer * Quality Assurance (QA) Procedures Q-2 Quality Assurance Program 8 11/01/89
'
Q-16 Corrective Action System 10 10/04/89 Q-18 QA Auditing and Monitoring Program 14 07/20/88
, '1 QA Audits QA Au ',it: ENRP-88-01, " Environmental Protection Plan," conducted June 20 through July 19, 1988
.- QA Audit: NMAT-88-01, " Nuclear Material Control," conducted December 19, 1988, through January 6,1989 QA Audit: HPHY-89-01, " Health Physics," conducted March 13-27, 1989' QA Audit: ENRP-89-01, " Environmental Protection Plan," conducted May 22 through June 14, 1989-QA Audit: WCRC-89-01, " Water Chemistry / Radiochemistry," conducted June 19 through July 15, 1989 l
*
o e ',.
. s: o * . * -5- ,
11. QA Monitoring Reports (QAMP) 4 QAMP-CHC-04-88-01, " Radiochemistry," performed June 8,1988
:
0 AMP-CHC-04-88-02, " Radiochemistry Instrument Calibration / Documentation," performed November 8 through December 5, 1988 QAMP-CHC-06-88-01, " Chemical Control Program," performed March 3-22, 1988 QAMP-CHC-06-88-02, " Water Chemistry Cross-Check Program," performed , September 7-23, 1988 '
:
QAMP-CHC-06-88-03, " Followup (QDC-179) Water Chemistry Cross-Check Records," performed October 12, 1988
,
QAMP-CHC-06-88-04, " Chemical Control Program" (QAI-160), performed '
'
December 6-7, 1988 i QAMP-CHC-06-88-05, " Water Chemistry - Calibration / Documentation," performed November 2-21, 1988 QAMP-CHC-05-89-01, " Water Chemistry - Analytical Control Charts," performed March 16,'1989 QAMP-CHC-06-89-03, " Water Chemistry - Cross-Check Program," performed December 12-13, 1989
.
QAMP-CHC-06-90-01, " Chemical Control Program (QAl-258)," performed i February 23-28, 1990 l QAMP-RAP-15-88-01, " Accuracy Factors for Radiochemistry and Meteorology 1 Measurements," performed May 3, 1988 !
'
QAMP-RAP-15-88-04, " Gas / Liquid Releases (QAI 169 and 170)," perfr "sd December 6-28, 1988 ' QAMP-RAP-15-89-04, " Radiochemistry Training," performed May 23, 1989 QAMP-RAP-15-90-01, " Liquid Waste Releases," performcd April 18, 1990 QAMP-RAP-15-90-02, " Gas Waste Releases (Health Physics)," performed j June 4, 1990 e QAMP-RAP-15-90-03, " Gas Waste Releases (Operations)," performed June 4, 1990 QAMP-RAP-15-90-04, " Gas Waste Releases (Radiochemistry)," performed June 4, 1990
. - - _ - - _ _ - _ _ _ - _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ -
'
FJe k,. e 2; , '
-
' '
-
1 <
~!
p: pf,e es, ,
+, ,
,
,
' '
;
R /: < v
.g
, , .
-
'
-
l' f. i ' . ,,t'- s
;
h, . ,4 !.
;- '1
-
,;j
-
f , . wm, '
;
G: W ; .
;;
,
. , . . . . :i
; :" 12,. Fort St. Vrain Station Semiannual Ef' fluent' Release Reports: ;
, ..
[. W ; January 1 through June -30, '1989 - i
:*.. .
July'1:.through' December 31, 1989 ,
!
to ? a
.
'
.
.
i;: ,' .13,' Fort St'. Vrain~ Station Radiological' Environmental Monitoring Program' l ,
-
Annual. Summary Report r ,u ,
,.
!- -
' January I througn December 31, 1989 e.. w e
f
*
h'g j_l; _ ?.,*, ,
. 4- [..
F p ,
<
..
,
r,[. g is -
{l
'
i'
'.?:
t
? '
I 1 e'
. ' ' f 4 -
,, v
$ --y - ).-. '.. < , \
L w y 5 4 I i
' -
s
'h.
t ,,1 ' .? n l v b 'l?7
: ru L i I t
l
> :_f G .
a> ,i .i
-
., _J k _ kl _m }}