IR 05000269/1982021

IE Insp Repts 50-269/82-21,50-270/82-21 & 50-287/82-21 on 820614-18.No Noncompliance Noted.Major Areas Inspected: Review of Chemistry & Radiochemistry Procedures & Airborne Effluent Sampling & Accountability

ML20058H538
Person / Time
Site:	Oconee
Issue date:	07/07/1982
From:	Evans C, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058H508	List: IR 05000269/1982021 ML20058H507
References
50-269-82-21, 50-270-82-21, 50-287-82-21, NUDOCS 8208030613
Download: ML20058H538 (10)

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+ g UNITED STATES

[ g NUCLEAR REGULATORY COMMISSION g REGION il

[ 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGfA 30303 C,'+9 *****[

Report Nos. 50-269/82-21, 50-270/82-21, and 50-287/82-21 Licensee: Duke Power Company P. O. Box 2178 Charlotte, NC 28242 Facility Name: Oconee Docket Nos. 50-269, 50-270, and 50-287 License Nos. DPR-38, DPR-47, arid DPR-55 Inspection at Oconee site npar Senece, South Carolina

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Inspector: ~

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e, -  ?[Date[-Signed C. D. Evans Accompanying Personnel: P. C. McPhail Approved by: },I 4 Gta 7/~7[8 b

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D. M. Montgomery, Chiefi/.MEP Section Date Signed EPOS Division SUMMARY Inspection on June 14-18, 1982 Areas Inspected This routine, unannounced inspection involved 52 inspector-hours on site in the areas of quality control and confirmatory measurements including: review of the laboratory quality control program; review of chemistry and radiochemistry procedures; airborne effluent sampling and accountability; and comparison of the results of split samples analyzed by the licensee and the NRC RII Mobile Labora-tor Results Of the four areas inspected, no violations or deviations were identified in four areas.

8208030613 820709 PDR ADOCK OS000269 G PDR

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DETAILS Persons Contacted

. Licensee Employees t *J. E. Smith, Plant Manager

*T. C. Matthews, Licensing Coordinator i i *R. T. Bond, Licensing and Projects Coordinator

• T. B. Owen, Technical Services Superintendent

• C. Yougue, Health Physics Supervisor

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• J. A. McCoal, Quality Assurance Supervisor

S. L. Morgan, Health Physicist I Other licensee employees contacted included three technician NRC Resident Inspector

• W. Orders

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• Attended exit interview Exit Interview

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2.

The inspection scope and findings were summarized on June 18, 1982, with

! those persons indicated in paragraph 1 above. The plant manager agreed to

provide a written response within 60 days of the Exit Interview to the j unresolved item discussed in paragraph 7.a, below, j Licensee Action on Previous Inspection Findings

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(Closed) Infraction (269/80-26-06, 270/80-22-06, and 287/80-29-06) Failure i to repeat performance checks for boron when control limits are exceeded and i

. failure to date calibration curves and control charts for boron and phos-phate. The inspector reviewed recent performance check data and calibration curves and noted that the documentation meets the requirements of appropriate

! plant procedures, j (Closed) Unresolved (269/80-26-05, 270/80-32-05, and 287/80-29-05) Failure j to have approved radiostrontium procedures for analysis of liquid and

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gaseous waste. The licensee considers that approval of the contract labora-tory's QA/QC program, is an approval of the procedures used for analysis of radiostrontium in effluent sample i i

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2 Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. The unresolved item identified during this inspection is discussed in paragraph . Laboratory Quality Control Program 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 QA Program The chemistry and health physics procedures do not specifically address the assignment of authority to manage and conduct the QC prog ram. The Health Physics Counting Room Supervisor has the responsibility for day-to-day quality control requirements for the counting room instrumentation. Supplemental assistance in the areas of review of analysis results, instrument calibration, and computer software modification is provided by the onsite Health Physics Technical Support staff. The responsibility for the chemistry quality control program is delegated to the Supervisors of the various chemistry section (2) Provisions for Audits / Inspections The inspector noted that there are no provisions for audits /

inspections by the station health physics and chemistry staf Periodic audits are conducted by the Duke Power Quality Assurance Department implementing Technical Specification 6.1.3.1. The inspector reviewed the most recent departmental audits in Health Physics and Chemistry and noted the audits were apparently not f performed by individuals qualified in chemistry and radiochemistry and did not address the adequacy of the program (3) Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Corrected.

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The inspector noted that there are no specific methods for identi-fying deficiencies in the QC Program at the plant level in so far as there are no provisions for management review. The audits by l the Quality Assurance Department provide for corrective actions for deficiencies that are recognized during audit (4) Quality Control of Purchased or Contracted Analyses

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The vendor performing radiochemistry analyses for radiostrontium and H-3 had been audited by Corporate Quality Assurance and placed

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! on the approved vendor list as per Chapter 2.9 of the Duke Power Company Administrative Policy Manual for Nuclear Power Plant (5) Interlaboratory Cross-Check Program The inspector noted that the interlaboratory cross check program had been implemented in accordance to a report issued by the Duke

. Environmental Center dated October 14, 1980. The report specifies l cross-check frequency, sample type, and preparation. The inspec-i tor also reviewed licensee cross-check results for a charcoal cartridge and liquid sample issued during the first half of 1982.

The inspector noted that the licensee results appeared to be

! acceptable, but that no acceptance criteria existed for the-cross-check program. Licensee representatives indicated that they

, would investigate the need for establishing appropriate acceptance criteria for the program. This will be reviewed in a subsequent j inspection report. (269/82-21-01,270/82-21-01,287/82-21-01). Review of Chemistry and Radiochemistry Procedures

! The inspector reviewed the following procedures:

i 1 (1) CP/0/A/2004/02/B, " Determination of Boron Concentration using FEP Titralyzer II System", 12-24-8 (2) CP/0/B/300/6, " Chemistry Procedure for Chromates",1-24-8 (3) CP/0/B/300/16, " Chemistry Procedure for Phosphates", 6-2-8 (4) HP/0/B/1000/60/D, " Procedure for Unit Vent Sampling and Analysis"

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6-4-8 (5) HP/0/B/1000/60/B, " Procedure for Reactor Building Gaseous Purge",

10-22-8 (6) HP/0/B/1000/60/A, " Procedure for Gaseous Waste Sampling and Analysis", 1-29-8 (7) HP/0/B/1000/72, " Procedure for Removing Noble Gases from Tritiated Airborne Samples, 7-9-8 (8) HP/0/B/1001/14, " Procedure for Calibration of Ge(Li) Detectors on ND6600", 2-12-82.

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l (9) HP/0/B/1001/14, " Procedure for Nuclear Data 6600 System Opera-tion", 2-12-82.

l (10) HP/0/B/1003/08, " Calibration Procedure for the Beckman LS-100 Liquid Scintillation System", 7-9-81.

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(11) HP/0/B/1000/67, " Procedure for Quality Assurance for Radiological Monitoring Systems", 9-10-8 The results of the procedure review were discussed with licensee representatives as noted in paragraphs 6.b. through The inspector noted the addition and approval of HP/0/B/1000/72,

" Procedure for Removing Noble Gases from Tritiated Airborne Samples",

which specifies vigorous boiling of the impinger solution to remove noble gases that might possibily result in overestimation of tritium releases. This closes a previously identified item (269/80-26-04, 270/80-32-04, and 287/80-29-04). The inspector noted that HP/0/B/1003,/09, " Procedure for Calibration of Ge(L1) Detectors on ND6600", had been modified to specify the radio-nuclide standards to be used for calibration of various sample geometries. This closes a previously identified item (269/80-26-03, 270/80-32-03, and 287/80-29-03). The inspector noted that HP/0/B/1000/67, " Procedure for Quality Assurance for Radiological Monitoring Systems," had been modified to include the requirement for a daily response and resolution check and a weekly background determination for the Ge(Li) gamma spectroscopy system. Appropriate acceptance criteria for the performance tests have also been included. This closes a previously identified item (269/80-26-02,270/80-32-02,and287/80-29-02). Review of Records and Logs The inspector reviewed the following records and logs:

(1) Boron Titrator Standardization Checks, 5-31-82 to 6-14-8 (2) Spectronic 70 - Absorbance Curve for Phosphate, 6-2-8 (3) Spectronic 70 - Absorbance Curve for Chromate, 6-2-8 (4) RIA-33 Liquid Waste Radiation Monitor Correlation Graph and Calcula-tions, 10-16-8 (5) Interlaboratory Cross-Checks,1981 to 198 (6) Waste Gas Decay Tank Sampling and Analysis Reports,198 (7) Containment Purge Ssmpling and Analysis Reports,198 (8) Ge(Li) Detector - Calibration Records, 1981 to 198 The inspector discussed the record review with licensee representatives as discussed in paragraphs 7.a. through . -._ - _ . . .

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1 The inspector noted that deadtime values for gamma spectroscopy analyses of waste gas silver zeolite cartridges were as high as 25 percent for several of the sample analyses conducted during the first half of 1982. These analyses were approved for effluent accountability although the deadtime exceeded the 10 percent control limit. The inspector informed licensee representatives that high resolution gamma-ray spectrometers are very susceptable to pulse pile-up losses which would result in underestimating the quantity of radiciodine

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released. Licensee representatives indicated that they would purge the silve zeolite cartridges to remove the noble gas contributing to the excessive deadtime. The inspector stated that this item will be considered unresolved pending further investigation by the licensee on the effect of excessive deadtime on the analyses of silver zeolite cartridges for radiciodine and the effect of that concern on effluent accountability. Licensee representatives indicated they would conduct an investigation and report results to the regional office by letter within sixty days from the date of the exit interview (269/82-21-02, 270/82-21-02,287/82-21-02). The inspector examined the particulate and iodine samplers used for effluent accountability. The inspector noted that the sampling train of the containment purge was arranged such that the rotameter was on the discharge side of the sampling pump. This arrangement allows the rotameter to see a higher pressure than the charcoal and particulate filter assembly on the suction side of the pump. The inspector informed licensee representatives that it is considered good practice to position the rotameter just after the sampling assembly to minimize the effects of inleakage and pressure differences between the rotameter and sampling assembly. The higher pressure at the rotameter resulted in a determination of total volume less than which would have flowed through the sampling assembly. This resulted in reporting higher concentrations of particulate and iodine than were released. A licensee representative indicated they would rearrange the sampling train and apply proper pressure corrections for the vacuum at the l sampling assembly, allowing for a more accurate determination of total l volume. This area will be examined in a subsequent inspection

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(269/82-21-03,270/82-21-03,287/82-21-03).

8. Confirmatory Measurements Liquid and gaseous samples were collected during this inspection and counted by the licensee and NRC RII Mobile laboratory to verify the licensee's capability to measure radionuclides in effluent and reactor coolant samples. Samples were analyzed by gamma-ray spectroscopy and included: an evaporator condensate sample, a containment gas sample, a charcoal and silver zeolite cartridge from containment, a reactor coolant sample, and a reactor coolant crud filter. The crud filter sample was counted in place of a particulate filter since a particulate filter sample of sufficient activity was not available. The results showed agreement and or possible agreement for all sample comparison An aliquot of a liquid waste sample was also sent to the NRC contract l

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laboratory for tritium and radiostrontium analyse The 'results will be compared to licensee results in a subsequent inspection report (269/82-21-04, 270/82-21-04, and 287/82-21-04).

b. The inspector noted that the licensee had recalibrated their gas geometries with a NBS traceable mixed gas standard replacing the use of the higher density polymer matrix. Recalibration with the mixed gas standard has resulted in improvement between the licensee and NRC for gas sample comparison. This closes a previously identified item (269/80-26-03, 270/80-32-08, and 287/80-29-08).

c. The inspector reviewed licensee results for H-3 and Sr-89 and Sr-90 analyses of a liquid waste storage tank collected during the previous inspection. The comparison of licensee and NRC analyses are given in Table 2, with acceptance criteria in Attachment 1. The comparisons show agreement for H-3, but radiostrontuim levels were too low for a meaningful comparison. This closes a previcusly identified followup item (269/80-26-07, 270/80-32-07, 287/80-29-07).

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I TABLE 1 RESULTS OF CONFIRMATORY MEASUREMENTS AT OCONEE, JUNE 14, 1982 - JUNE 17, 1982 CONCENTRATION, MICR0 CURIES /CC.

SAMPLE NUCLIDE LICENSEE NRC RATIO RESOLUTION COMPARISON

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Containment Gas Xe-133m 1.40 E-06 1.27 .25 E-06 1.10 5 Agreement 1460 cc. Marinelli Xe-133 1.30 E-04 1.23 .01 E-04 1.06 175 Agreement Xe-135 3.97 E-06 3.32 .08 E-06 .84 42 Agreement

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Condensate Mn-54 1.93 E-06 2.15 .43 E-06 .89 5 Agreement Monitor Tank-B Co-58 7.29 E-05 7.12 .I4 E-05 1.02 51 Agreement 500cc bottle Co-60 4.78 E-06 4.60 .43 E-06 1.06 10 Agreenent j

, I-131 1.59 E-05 1.75 .07 E-05 .90 25 Agreement

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Cs-134 8.61 E-06 9.20 .57 E-06 .93 16 Agreement i'

Cs-137 1.61 E-05 1.67 .07 E-05 .96 24 Agreement RCS-Crud Filter Cr-51 3.68 E-04 3.12 .01 E-04 1.17 31 Agreement Mn-54 2.06 E-05 1.73 .01 E-05 1.19 17 Agreement Co-58 1.12 E-03 1.06 .01 E-03 1.05 151 Agreement Co-60 5.36 E-05 4.71 .02 E-05 1.13 23 Agreement

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I-131 1.48 E-04 1.42 .03 E-04 1.04 47 Agreement I-133 3.92 E-04 3.72 .09 E-04- 1.05 41 Agreement ,

Reactor Coolant I-131 1.70 E-02 1.32 .06 E-02 1.28 22 Agreement

' Sample I-133 5.17 E-02 3.71 .08 E-02 1.39 46 Possible Agreement j I-135 5.90 E-03 5.24 .53 E-03 1.13 10 Agreement Silver Zeolite I-131 4.93 E-09 4.46 .11 E-09 1.10 41 Agreement j I-133 2.62 E-09 2.301.10 E-09 1.14 23 Agreenent i

, Charcoal Cartridge I-131 5.20 E-09 4.94 .11 E-09 1.05 45 Agreement i I-133 2.30 E-09 2.05 .10 E-09 .92 25 Agreement

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. , - .- - TABLE 2 RESULTS OF CONFIRMATORY MEASUREMENTS AT OCONEE, JUNE 14, 1982 - JUNE 17, 1982 C0f1CENTRATON, MICR0 CURIES /C SAMPLE NUCLIDE LICENSEE NRC CONTRACT RATIO PESOLUTION COMPARISON LABORATORY Liquid Waste Sample Sr-89 E-08 32 E-08 N. N. N. C.*

Collected 12/10/82 Sr-90 E-09 57 E-09 N. N. N. H-3 E-02 9.17 .02 E-02 .98 450 Agreement

• C. - No comparison, activity is to low for a meaningful comparison

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Attachment 1

_ CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra In these criteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertainty. As that ratio, referred to in this program as " Resolution",

increases, the acceptability of a licensee's measurement should be more selectiv Conversely, poorer agreement must be considered acceptable as the resolution decrease LICENSEE VALUE

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" NRC REFERl3CE V.\l.U E Possible Possible Resolution Agreement Agreement A Agreement B

<3 .5 .0 No Comparison 4- 7 .0 .5 0.3 - .6 - 1.66 .0 0.4 - .75 - 1.33 .66 0.5 - .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:

Camma Spectrometry where principal gamma energy used for identification is greater than 250 Ke Tritium analyses of liquid sample "B" criteria are applied to the following analyses:

Camma Spectrometry where principal gamma energy used for identification is less than 250 Ke Sr and '*Sr Determination ' Gross Beta where samples are counted on the same date using the same reference nuclid _ _ _ - _ - . _

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