IR 05000269/1980036
| ML19341D673 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/03/1981 |
| From: | Gibson A, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19341D657 | List: |
| References | |
| 50-269-80-36, 50-270-80-32, 50-287-80-29, NUDOCS 8104080383 | |
| Download: ML19341D673 (12) | |
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u UNITED STATES
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NUCLEAR REGULATGRY COMMISSION I ch'
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101 MARIETT A ST., N.W., SUITE 3100
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ATLANTA, GEORGI A 30303
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Report Nos. 50-269/80-36, 50-270/S0-32 and 50-237/S0-29 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos. 50-269, 50-270 and 50-28','
License Nos. OPR-38, DPR-47 and DPR-55 Inspection at Oconee Site near Seneca, South Carolina
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Inspector:
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D. M. Montgomery /
Date signed Accompanying Persr'nn{l P.;C
, McPhail f
Approved by:
A. F. Gibson, Section Chief, FF&MS Branch Date Signed SUMMARY Inspection on December 8-12, 1980 Areas Inspected This routine, unannounced inspection involved 53 inspector-hours onsite in the areas of quality control and confirmatory measurements including: review of the laboratory quality control program; review of chemistry and radiochemistry proce-dures; review of quality control records and logs; and comparison of the results of split samples analyzed by the licensee and the NRC RII Mcbile Laboratory.
Results Of the 4 areas inspected, no violations or deviations were identified in 3 areas; 2 violations were found in 1 area.
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DETAILS 1.
Persons Contacted Licensee Employees
- J. E. Smith, Plant Mclager
- J. A. Long, Support Functions Coordinator
- S. L. Morgan, Counting Roon Supervisor
- C. L. Harlen, Associate Health Physicist
- T. Mattews, Licensing Coordinator
- T. E. Cribbe, Licensing Coordinator
- R. T. Bond, Technical Services Supervisor T. B. Owen, Superintendent of Technical Services B. Fender, Primary Chemistry Unit Coordinator Other licensee employees contacted included 3 technicians.
~ NRC Resident Inspector
- D. O. Myers 2.
Exit Interview The inspection scope and findings were summarized on December 12,1950, with those persons indicated in Paragraph 1 above.
The Plant Manager acknowl-edged the item of noncompliance regarding failure to follow procedures and agreed to address the items identified by the inspector in Paragraphs 6.b -
6.e.
Licensee representatives agreed to perfcrm the analyses referred to in Paragraph 9.b.
On Cacember 22, 1980, the inspector notified the Plant Manager by telephone that the failure to have an approved procedure for radiostrontium analysis of liquid and gaseous effluents would be carried as a violation rather than an unresolved item. The Plant Manager indicated that the issue of procedures for contracted services would have to be discussed within the Duke organization since it appears to be a generic issue that could affect other areas. The. inspector reiterated that the time required to receive access to the plant during this inspection was excessive and that either an abbreviated site specific training with unescorted access or escorts for the NRC inspectors is necessary. The Plant Manager stated that Duke Power would revise the training requirements so that unescorted access
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could be granted with a short site specific training session and that this should be available by July 1981 (269/80-26-09, 287/80-32-09, 287/80-29-09).
3.
Licensee Action on Previous Inspection Findings f
j (Closed) Infraction (269/79-08-02, 270/79-08-02, 287/79-08-02) Failure to Follow the Approved Procedure for Calibration of GeLi Detectors. The inspec-tor reviewed the calibration program and noted that calibration standards had been purchased and that the approved procedure HP/0/B/1003/09 was being utilized for calibrations.
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l (Closed) Deviation (269/79-08-03, 270/79-03-03, 237/79-02-03) Use of Cali-bration Standard that was not Representative of Contamination Being
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Measured. The inspector verified that Cs-137 was being used for calibration of the beta gamma counters used for counting smears.
(Closed) Unresolved Item (269/79-08-04, 270/79-08-04, 237/79-08-04) Certifi-l cation of Tritium Standard.
The inspector verified that the licensee was utilizing a certified standard for tritium calibra'. ion of the liquid
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scintillation counter.
(Closed) Unresolved Item (269/79-08-05, 270/79-03-05, 237/79-CS-05) Use of Cross Calibration Technique for Efficiency Calibration of GeLi Counters.
Licensee has discontinued use of the cross calibration technique and certi-fied solutions from vendors participating in the NBS measurement assurance program are being utilized.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Lahoratory Quality Control Program a.
The inspector reviewed the licensee's Quality Control Program for radiochemical measurements in the following areas:
(1) Assignment of Responsibility and Authority to Manage and Conduct the QC Prograr.:
l The chemistry and health physics procedures do not specifically address the assignrrent of authority to manage and conduct the QC program.
The Healtn Physics Counting Room Supervisor has the l
responsibility for quality control associated with the counting l
room instrumentation as designated by nis job description.
The responsibility for the chemistry quality control program is i
delegated to the Supervisors of the various chemistry sections.
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Chemistry procedures do not specifically address the assignment of responsibility and duties associated with operation of the chemistry QC program.
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'(2) Provisions for Audits / Inspections
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The inspector noted that there are no provisions for audits /
inspections by the station health physics and chemistry staff.
Technical Specification 6.1.3.1 specifies that the Nuclear Safety l
Review Board shall provide independent review and audits in cheuistry, radiochemistry, and radiological safety.
Periodic audits are carried out by the Duke Power Company Quality Assurance Department in accordance with Procedure QA-210.
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(3) Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, anc Corrected.
The inspector noted that there are no specific metnods for iden-tifying deficiencies in the QC Program at the plant level in so
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far as there are no provisions for management review. The audits by the Quality Assurance Department provide for corrective actions fo. deficiencies that are recognized during audits.
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(4) Quality Control of Purchased or Contracted Analyses The vendor performing radiochemical analyses for radiostrontium and H-3 had been audited by Corporate Quality Astarance and placed on the approved vendor list as per Chapter 2.9 cf the Duke Power Company Administrative Policy Manual for Nuclear Power Plants.
The inspector ncted that licensee's qtality control program for chemistry and radiochemistry did not stet NRC Regulatory Guice 4.15, Quality Assurance for Radiological Monitoring Programs-Effluent Streams and The Environment, February 1979, in two areas.
These were:
(1)
Specification of Organizational Structure and Responsibilities of Managerial and Operational Personnel, and; (2) Auoits.
The inspector stated that the QC program should specify the organiza-tional structure and various responsibilities within the structure.
There should also be provisions for audits / inspections by Station Management to ensure the QC program is being implemented and to rrview the general adequacy of the program. The Corporate Quality Asstrance Department performs periodic audits but these audits are apparently not performed by individuals qualified in chemistry and radiochenistry and do not address. the adequacy of the program. The inspector noted that the licensee does not have any specific regulatory requirements for laboratory quality control. Licensee representatives agreed to review the quality control program for chemistry and radiochemistry and consider addressing the areas of organizational responsibility and audits. (269/80-26-01, 270/80-32-01, 287/80-29-01). No violations were identified.
6.
Review of Chemistry and Radiochecistry Procedures
.ne inspector reviewed the following precedures:
a.
(1) HP/0/8/1003/09, Procedure for Calibration of GeLi Detectors on the ND 6600 System, 12/27/79, Rev. 2 (2) HP/0/B/1003/08 Calibration Procedure for the Beckman LS-100 Liquid Scintillation System, 10/16/79.
-(3)' HP/0/B/1000/60A, Procedure for Gaseous Waste Sampling, 4/4/80
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(4) HP/0/B/1000/67, Procedure Efor Quality Assurance.for Radiological-Monitoring Systems, Rev.1.
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(5) CP/0/A/400/1, Chemistry Procedure for Determination of Gross 2 eta Activity, 7/7/SO.
(6) CP/0/B/100/3, Instrument and Reagent Checks and Calibrations, 11/19/80.
(7) CP/0/A/300/10, Chemistry Procedure for Determination of Fluoride, 6/19/79.
The results of the procedur9 reviews were discussed with licensee representatives as noted in Paragraphs 6.b. through 6.e.
b.
The inspector. toted that the following deficiencies in Precedure HP/0/B/1000/67, Quality Assurance for Radiological Monitoring Systems:
(1) Paragraph 4.1.1.2 - No daily performance checks and acceptance criteria for count rates in photcpeaks are previded; resciution check with acceptance criteria is noc provided; ar.d acceptance criteria for linearity check is not provided.
(2) Paragraph * 1.2.1 - Replicate analyses should also reflect the
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validity of the sampling technique and acceptance criteria for replicate analyses should be provided.
(3) Paragraph 4.1.2.2 - Background counts should be more frequent.
(4) Paragraph 4.4.3, Acceptance criteria for interlaboratory compari-sons should be specified.
Recommendations set by General Office Laboratory Services are not specified.
Licensee representatives agreed to address these items and revise the procedures as necessary.
(239/80-26-02, 270/80-32-02, and 287/80-29-02).
The inspector noted that calibration procedures for counting equipment c.
did not specify the radionuclides to be used for calibration. Licensee representatives agreed to revise the applicable procedures and specify the radionuclides. (269/80-26-03, 270/80-32-03, and 287/80-29-03).
d.
The inspector noted that Procedure HP/0/B/1000/60A, Gaseous Waste
Sampling did not provida for r?moval of noble gases from the tritium sample.
This may result in overestimation of tritium releases.
Licensee representatives agreed to modify the procedure to correct this problem..(269/80-26-04, 270/80-32-04 and 287/80-29-04).
e.
The inspector noted that there was no approved procec.re for the analysis of raciostrontium in liquid and gaseous radioactive wastes.
Techr.ical Specification 3.9.8 and 3.10.9 requires sampling and analysis of liquid and gaseous radioactive wastes in accordance with Table-4.1.3 which provides for monthly radiostrontium analyses'. A licensee repre-sentative stated. that radiostrontium analyses were performed by a vendor that had been approved by Duke Power Company's Quality Assurance
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Department. The inspector stated that this did not relieve them of the
responsibility to review and approve the procedure as required by Technical Scecification 6.4.1 and 6.2.1.
A licensee representative stated that the procedures may have been reviewed at the Corporate level.
On December 19, 1930 the inspector discussed this matter by telephone with M. Birch, Duke General Office Health Physics Staff, and T. Cribbe, T. Owen, and C. Yongue of the Oconee Nuclear Station.
M. Birch stated that there were no approvec radiostrontium methods since these analyses were performed by a vendor that was on the Duke list of approved vendors. The inspector restated that vendor approval did not relieve the plant staff of the responsibility of reviewing and approving this procedure. The inspector informed the plant manager by telephone on December 23, 1980, that failure to have approved radio-strontium procedures for analysis of liquic and gaseous waste is a violation. (269/80-26-05, 270/50-32-05 and 237/80-29-05).
7.
Review of Reccrds and Logs a.
The inspector reviewed the following re:ords and logs:
(1)
1980 Quarterly Interlaboratory Comparison of Counting Room Equip-ment for Liquid Scintillation Counter, Ge(Li) detectors, and GM Counters.
(2)
1980 Background Counts for Ge(Li) Detectors.
(3)
1980 Interlaboratory Comparison for Ge(Li) Detectors.
(4) Semi-Annual Calibration of Countir.
Room Equipment:
Ge(Li)
Detectors, GM Counter, and Liquid Scintillation Counter,1980.
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(5) GM Performance Logs,1/1/80 to 12/10/80.
(6)
Liquid Scintillation Logs,1/6/80 to 12/10/80.
(7) Calibration Certificates for Ge(Li) Detectors including the following geometries: 4-L Marinelli, Charcoal Cartridge, Partic-ulate Filter, 500 cc bottle, and 60 cc bottle, 7/18/80.
(8) Analytical Balance Calibration,1980.'
,,;c (9) pH Meter Calibrations,11/1/79 to.12/10/80.
(10) Boron' Titrator. Calibrations,11/1/79 to 12/10/80.
(11) Fluoride Probe Calibration,11."./79 to 12/10/80.
'(12)1Spectronic 70 Calibrations,11/1/79 to 12/08/80.
(13) Conductivity Meter Colibrations,11/1/79 to '12/6/80.
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(14) Quality Assurance Audits, QA-0-30-3, September 19, 1930 and
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QA-0-79-5, June 11,1979.
The inspector discussed the record review with licensee representatives as discussed in Paragrapns 7.b. anc 7.c.
b.
The inspector noted that the daily creck counts for 3H and gross teta by liquid scintillation were not recorded during the pericd of September 10, 1930, to December 10, 1930, as required by P~ccedure HP/0/B/1000/67.
A licensee representative stated that the CC check had been changed due to orcblems in preparing a stable source and a temporary change had been made to Procedure HP/0/B/1001/11, C;erating Procedure for the Beckman LS-100 Liquid Scintillation System, :sut Procedure HP/0/2/1000/67 had net been changed.
The inspector ncted that the change resulted in a CC check that was not as comprehensive as that required by Procedure HP/C/B/1000/67.
The inscector informed licensee representatives that failure to folicw Procedure Hp/0/B/
1000/67 was a violation of Technical Specification 6.4.1 that recuires the station to be c;erated in acccedance with aporoved precedures.
(269/80-26-06, 270/50-32-06, and 257/30-29-06).
c.
The inspector noted that the accuracy erformance check for bcron analysis exceeded the control limits on 2/6/80, and the performance check was not repeated as required by Precedure CP/0/B/100/3.
In addition, the precision control charts for chosphate, boren, and chloride analysis were not dated as required by Procedure CP'0/B/100/3.
The inspector stated that the documentation of quality control data was
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sloppy and in some cases illegible and that it appeared that the data was not being carefully reviewed by the responsible supervisor.
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insepctor informed licensee representatives that this was anather example of failure to follow procedures which is a violation of Technical Specification 6.4.1.
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8.
. Review of South Carolina NRC Contract for Environmental Monitoring in Vi_cinity of Oconee Nuclear Plant Thh inspector met with Nolan Sivens, South Carolina Department of Health and i
Environmental Control and J. J.
Sevic, Oconee Plant Environmentalist, to discuss implementation of the NRC Contract with the State of South Carolina to split environmental samples with the Oconee Plant for a crosscheck of
.i radiological analyses, The-inspector re-emphasized the necessity for
'I co-operation from the.icensee in splitting samples and expediticus. report-ing of 0conee data so that the state can submit a timely annual repert. The details of the latest contract including type of samples, sampling location, collection, and analyses were reviewed. Both parties were in agreement that there would be no problems in fulfilling the contract requirements.
9.
Confirmatory Measurements a.
The results of samples collected during the period of February 15-23, 1980, were discussed with the licensee. The results are presented in t
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Table I and show agreement or possible agreement except for Co-60 in the liquid waste samole ar.d Co-58, Co-60, Ru-106, and Cs-134 in the charcoal cartridge / particulate filter sample.
Li cen s ee results that were in disagreement were higher tnan the NRC values and woulc nave resulted in overestimation of station releases. Ine previous calibra-tions were done by a calculational-comparative technique ratner tnan an enpirical calibration with radionuclices. The reason for the cisagree-ment was not apparent. Since the results from the licuid and charcoal cartridge from the current sample split were in agreement, this item is considered closed. (209/79-08-01, 270/79-08-01, 287/79-08-01)
6.
Liquid and gaseous samples were collected curing this ins::ection and counted by the licensee and NRC RII Yobile Laboratory to verify the licensee's capability to measure racianuclices in effluent anc reactor coolant samples. Samples were analyzed by gamma-ray spectroscopy and included:
a liquid waste sample, reactor coolant sat.ple, crud filter sample, waste gas cecay tank sample, anc a cnarcoal cartridge sample f rom the station vent. The cruc filter sampic was counted in place of a particulate filter since a particulate filter sample of sufficient activity was not available. An aliquot of the liquid waste sample was sent to the NRC contract Laboratory for tritium and radiostrontium analyses.
The results will be compared to licensee results in a subsequent inspection report (269/80-26-07, 270/80-32-07 and 287/80-29-07.)
The comparisons of licensee and NRC results are presented in Table 2 with acceptance criteria in Attachment 1.
The results showed agreement for all samples except the gas sample where the Xe-133 result was outside of the acceptance criteria.
This is apparently due to the licensee calibration technique which uses a resin matrix that has a much higher density than gas. This results in the attenuation of low
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enargy gamma-rays and a lower efficiency that causes over reporting of L
Xe-133. The inspector stated that this calibration technique was not l
. acceptable, and a licensee representative agreed to use gas standards for the calibration of gas georstries. (269/80-26-08, 270/80-32-08 and i
287/80-29-08).
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TABLE 1 RESULTS OF C0riFIRMATORY MEASUREMEllIS AT OC0tiEE fiUCLEAR PLAtli FEBRUARY,1979
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Concentration, Ci/cc
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RATIO SAMPLE ISOTOPE Og flRC ONP/fiRC COMPARIS0ft Liquid Waste Co-58 8.8 E-7 5.8 1 1.0 E-7 1.5 Agreement
'3/15/79 Co-60 8.4 E-7 2.0 1 0.5 E-7 4.2 Disagreement 10:00 Cs-134 7.8 E-7 1.11 + 0.08 E-6
.7 Agreement
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Cs-137 1.29 E-6 1.6 + 0.1 E-6
.8 Agreement
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H-3 2.23 E-1 2.68 + 0.01 E-1
.83 Agreement
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Sr-89 4.3 E-8 1 + l E-8
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tic Sr-90
<7 E-9 1[3E-9 f1C
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Particula te.
Ag-110m 9.0 E-10 2.3 1 0.2 E-10 3.9 Disagreement
+ Charcoal Mn-54 1.32 E-10 6.6 1 0.9 E-Il 2.0 Agreement 3/23/79 Co-58 2.52 E-9 1.30 1 0.03 E-9 1.9 Disagreenent
.10:00 Co-60 9.39 E-10 5.14 1 0.2 E-10 1.8 Disagreement Ru-103 1.67 E-10 1.4 1 0.2 E-10 1.2 Agreement Ru-106 3.06 E-9 1.9 1 0.1 E-9 1.6 Disagreement Cs-134 1.17 E-9 5.9 + 0.2 E-10 2.0 Disagreement Cs-137 1.97 E-9 1.36 1 0.08 E-9 1.4 Possible Agreement Gas Sample Kr-85 1.74 E-3 2.0 1 0.2 E-3
.87 Agreement 3/26/80 Xe-133 1.91 E-1 2.04 1 0.08 E-1
.94 Agreement 0915 fiC - tio Comparison
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TABLE'2
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RESULTS OF CONFIRMATORY MEASUREMENTS
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AT OCONEE NUCLEAR PLANT DECEMBER 8-12, 1979
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Concentration, pCi/cc RATIO
-SAMPLE IS0 TOPE ONP NRC ONP/NRC RESOLUTION COMPARIS0N Liquid Waste Mn-54 2.3 1 1.2 E-7 flD
12/10/80 Co-58 8.3 + 0.3 E-6 6.2 + 0.4 E-6 1.3
Agreenent 9 1115 Co-60 2.0 + 0.2 E-6 1.4 + 0.2 E-6 1.4
Agreement I-131 4.5 T 0.2 E-6 4.2 T 0.4 E-6 1.07
Agreement
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Cs-134 1.19 + 0.04 E-5 1.12 + 0.06 E-5 1.06
Agreement Cs-137 2.01 + 0.04 E-5 1.81 + 0.07 E-5 1.11
Agreement Cs-136 5.8 1 1.1 E-7 ND RCS Liquid Na-24 4.3 + 0.3 E-3 3.8 + 0.3 E-3-12/10/80
' Mn-54 6.0 7 0.2 E-3 ND --
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Agreement
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NC 0 1614 Co-58 2.3.10.2E-3 1.9 + 0.2 E-3 1.21 9.5 Agreement I-131 5.95 + 0.04 E-2 5.82 + 0.05 E-2 1.02 116 Agreement I-132 8.09 T 0.2 E-2 8.55 T 0.3 E-2
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Agreement
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I-133 2.36 T 0.01 E-1 2.38 T 0.01 E-1
.99 238 Agreement I-135 1.80 T 0.03 E-1 1.77 T 0.04 E-1 1.02
Agreement Sr-92 3.47 + 1.4 E-3 ND
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Tc-99m 3.5 + 0.4 E-3 2.7 + 0.4 E-3 1.30 6.8 Agreement Cs-134 6.2 + 0.9 E-4 ND
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flC Cs-137 6.911.7E-4
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Crud Filter Cr-51 2.8 + 0.4 E-4 2.8 + 0.1 E-4 1.0
Agreement 12/9/80 Mn-54 3.7 T 0.3 E-5 3.9 T 0.2 E-5
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Agreement i
0 815:00 Co-58 2.60 + 0.02 E-3 2.49 + 0.01 E-3 1.04 249 Agreement Fe-59 2.1 + 0.1 E-4 2.33 I 0.05 E-4
.91
Agreement
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Co-60 7.2 T 0.5 E-5 7.4 + 0.6 E-5
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Agreement
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1-131 5.76 + 0.09 E-4 5.38 + 0.04 E-4 1.07 134 Agreement
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Nb-95 1.4 + 0.4 E-5 1.8 + 0.2 E-5
.78
Agreement Tc-99m 9.6 T 0.9 E-4 1.16 + 0.04 E-3
.83
Agreement
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Cs-134 5.4 T 0.6 E-5 4.2 + 0.2 E-5 1.04
Agreement
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Cs-137 6.9 + 0.4 E-5 6.4 + 0.2 E-5 1.08
Agreement Ba-140 8.612.1E-5 4.6[0.9E-5 1.90
Agreement Waste Gas Kr-85 2.8 + 0.5 E-3 ND
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Decay. Tank Xe-131m 1.19 + 0.06 E-3 9.3 + 0.2 E-3 1.21
Agreement 12/10/80 Xe-133 1.39 1 0.01 E-2 9.9 + 0.02 E-3 1.40 495 Disagreement 0 1143:13
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TABLE 2
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(Cont.)
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Charcoal I-131 2.34 + 0.05 E-11 2.38 + 0.08 E-11
.98
Agreemeilt Cartridge Station I-133 4.7 + 0.3 E-12 5.6 & 0.6 E-12
.84
Agreement Vent
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12/10/80 0 0025:00
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NC - No Canparison ND - Not Detected __
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Attachment 1
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CRITERIA FOR COMPARING ANALYTTCAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements.
The criteria are based en an e=pirical relationship which combines prior experience and the accurac:.
needs of this program.
In these criteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its asscciated uncertainty. As that ratio, referred to in this program as " Resolution",
increases, the acceptability of a licensce's neasurement should be more selective.
Ccnversely, poorer agrec=ent must be considered acceptable as the resolution decreases.
LICENSEE '.'ALUE RATIO = 5RC REFERENCE VALUE Possible Possible Resolutica Agreement Agreement A Agreement 3
<3 0.4 - 2.5 0.3 - 3.0 No Comparison 4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5 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
>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33
"A" criteria are applied to the following analyses:
Ca==a Spectrometry where principal gamma energy used for identification is greater than 250 Kev.
Tritium analyses of liquid sanples,
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"B" criteria are' applied to the following analyses:
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Gamma Spectrometry whete principal gamea energy used for identification
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is.less than 250 Kev.
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'Sr and "Sr Determinations.
Cross Beta where sa=ples are' counted on the same date using the same
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reference nuclide.
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