IR 05000271/1986023
| ML20214K795 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/17/1986 |
| From: | Davison B, Kottan J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214K773 | List: |
| References | |
| 50-271-86-23, NUDOCS 8612020464 | |
| Download: ML20214K795 (10) | |
Text
b.:
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-271/86-23
Docket No.
50-271 License No.
NPF-28 Priority Category C
--
Licensee: Vermont Yankee Nuclear Power Corporation Ferry Road Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At: Vernon, Vermont Inspection Conducted: October 6-10, 1986
[
/bl7 M Inspectors
-
. S. Davi son,' R 1ation Specialist date w
Q - N ' MdA
// - I '7 ' 94 J. J. Kottan( Radiation Laboratory Specialist date
{k'.PasciaE,Chiefl.On & d - I 7-%
Approved by:
W. J date Effluek.s Radiation Protection Section Inspection Summary:
Inspection on October 6-10, 1986, Inspection Report No. 50-271/86-23 Areas Inspected:
Routine, unannounced inspection of the licensee's radiochemical measurements program. The NRC Region I Mobile Radiological Measurements Laboratory was used and laboratory assistance was provided by the DOE's Radiological and Environmental Sciences Laboratory. Areas reviewed included: licensee actions on previous inspection findings; radioactive sample confirmatory meastrements, laboratory QC/QA, and audits.
Results: No violations or deviations were identified.
h0 64 861119 G
CK 05000271 PDR
_
_
.
__
_. _
. - _ - - - - -
_ _.__.
.
Details 1.
Individuals Contacted 1.1 Principal Licensee Employees
- D. Reid, Operations Supervisor R. Leach, Chemistry and Health Physics Supervisor
- R. Gerdus, Chemical Engineer
- S. McAvoy, Chemistry - Health Physics Assistant L. Savard, Chemistry - Health Physics Assistant P. Caruso, Engineering Assistant - Quality Assurance
- R. Morrisette, Health Physicist D. Tolin, Whole Body and Respiratory Systems Engineer E. Brackett, Associate Engineer, Yankee Atomic Environmental Laboratory M. Fuller, Chemistry - Health Physics Assistant 1.2 NRC
- B. Raymond, Senior Resident Inspector
- V. Rooney, LPM, NRR
,
- Denotes those present at the exit meeting.
The inspectors also talked with and interviewed other licensee personnel including members of the chemistry staff.
.
2.
Licensee Action on Previous Inspection Findings (0 pen) Follow-up Item (271/84-07-03).
Licensee to implement applicable criteria of Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" and expand QC practices in the laboratory.
The inspector determined that some aspects of the Regulatory Guide had been incorporated into.the licensee's laboratory QA/QC practices but that the applicable guidance was not proceduralized.
3.0 Laboratory QA
~
The inspector performed a selected review of the licensee's program for the quality assurance of radioanalytical measurements.
The review was perforri.ed with respect to criteria contained in the following:
Regulatory Guide 4.15 " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment"
Principles of Quality Assurance of Chemical Measurement: (NBS)
ANSI N42.14-1978 " Calibration and Usage of Germanium Detectors for Measurement of Gamma-Ray Emission of Radionuclides"
r.
-
- The inspector reviewed the following procedures
DP 2631, " Radiochemical Instrumentation"
OP 0631, " Radiochemistry"
_AP 6600, " Chemistry and Health Physics Department Quality Assurance"
In addition the inspector _ reviewed the following data.
- Efficiency calibrations performed during 1986
Interlaboratory comparisons performed with YAEC Environmental Labs during 1985 and 1986
Control charts for daily source and resolution checks of the three Ge detectors and the daily source check of the liquid scintillation counter.
Within the scope of this review the following concerns were identified:
D.P. 2631 does not specify minimum number of counts in the peak area of interest for efficiency calibrations. The inspector noted that ANSI N42.14-1978 recommends accumulating a minimum of 20,000 counts in the peak _ areas for calibration.
The procedure specifies a 1000 second count time as a minimum. Although the calibration data was found to contain at least 10,000 counts in peaks, there is no procedural guidance to ensure this level or the preferred 20,000 count value is obtained.
- The inspector discussed the method for calibration of stack gas samples in the Marinelli chamber. The licensee stated that they use liquid standards of one liter volume for this calibration. The total volume of.this geometry is 1260 cc. The difference between these values introduces a conservative, systematic bias of 26%.
Also the difference in low energy photon attenuation between water and gas provides an additional source of conservative systematic bias. The inspector discussed commercially available standards in gas and low density foam which would obviate this problem. The inspector stressed the importance of accurate versus conservative values, and that either the use of foam or gas standards for calibra-tion or mathematical correction for the displacement volumes and attenuation of photons would be satisfactory.
- The inspector observed that some of the licensee's measurements were made directly on the top of the detector and determined that calibrations were made in this fashion as well. The inspector described the phenomenon of angular correlation summing, which is also discussed in ANSI N42.14-1978, to the licensee.
This is an undesirable method of calibration readily overcome by moving standards and samples a few centimeters above the detector face.
The licensee stated that they would modify their procedures and
s
-
techniques for calibration and measurement of samples to minimize this effect.
The inspector stated that these aspects of calibration would be followed up.in a subsequent inspection (50-271/86-23-01).
The inspector observed offgas and stack gas sampling by the licensee.
Both samples were made according to procedurally described methods.
The inspector determined that the stack gas sample marinelli was at a slight negative pressure with respect to ambient due to the layout of the pump and sample device. The licensee stated that they would correct this-by reversing the pump and sample container, causing slight excess pressure in the chamber and subsequent relief of the excess pressure to ambient conditions.
The inspector stated that this would be evaluated in a subsequent inspection (50-271/86-23-02).
- In addition to these concerns, the inspector discussed additional aspects of laboratory QC and QA and implementation of commitments to Regulatory Guide 4.15.
The licensee stated that a revision to AP6600 was in its review cycle.
Upon completion this should provide guidance for QA/QC implementation in the lab.
The inspector had no further questions in this area.
4.0 Confirmatory Measurements During the inspection, liquid, particulate and charcoal filter, and gas samples were split between the licensee and the NRC for the purpose of intercomparison. Joint analyses of actual effluent samples verify the licensee's ability to measure radioactivity in effluents with respect to Technical Specification and other regulatory requirements. When possible, the samples are actual effluent samples or inplant samples which duplicate counting geometries used by the licensee for effluent sample analysis.
These samples are analyzed by the licensee using normal methods and by the NRC Region I Mobile Radiological Measurements Laboratory.
Also, a liquid effluent was split with the licensee with part of the sample being sent to the NRC reference laboratory, Department of Energy, Radiological and Environmental Sciences Laboratory (RESL), for analyses requiring wet chemistry. The analysis to be performed on the samples are Gross alpha, Sr-89, Sr-90, and tritium.
The results will be compared with the licensee's results when received at a later date and documented in a subsequent inspection report. The licensee agreed to analyze his portion of the sample for the same radionuclides.
The results of the split sample from the previous inspection were found in agreement except for gross alpha, which could not be compare _
_
.
s The results of the intercomparison sample measurements were'in agreement. W-187 was not identified in one of the liquid samples because it failed an abundance parameter criterion. An on-the spot correction was made by the licensee.
The results of the intercomparison sample analyses are listed in Table 1..The criteria used for evcluating the results are provided in Attachment 1.
The values for the stack gas sample were not representative of the actual stack gas effluent. These values are for residual contamination from a sample made at another facility but are provided since the measurements were made. Actual stack gas samples were taken but no activity was found.
The inspector observed that the licensee omitted counting the charcoal cartridge on both sides during the intercomparison and discussed the importance of this technique. The licensee's procedure, OP 2611, specifies that the stack charcoal is to be flipped during the measurement.
It was determined that this technique was normally employed.
The inspector had no further questions in this area.
5.0 Audits The inspector discussed internal audits of the chemistry area with cognizant members of the quality assurance group. The most recent audit in this area, 86-2, 3/24-28/86 was an extensive audit of chemistry effluent releases, calibrations, documentation, QA records, etc.
Seventeen previous audit observations were outstanding and nineteen new ones were opened. These are minor observations used to improve the program to improve the overall program quality. Also, several discrepancies had been noted. These range from semantics (e.g. use of less thar vs. not detected) to pertinent areas of improvement which could be made for example, petri dish smaller than sample size, documentation of software f..r calcula-tions, etc. Areas not resolved on-the-spot are sent to the Plant Position Report Committee which decides if these discrepancies should or should not receive further attention by the auditor.
The inspector had no further questions in this area.
6.0 Whole Body Counting Program During this inspection the licensee's ability to adequately perform radiological bioassay using a whole body counting system was reviewed.
An NRC whole body counting phantom containing radioactive sources traceable to the National Bureau of Standards (NBS) was submitted to the licensee for analysis. The phantom duplicated the nuclides and the organ burdens that the licensee might encounter during normal operation.
The phantom was analyzed using the licensee's normal methods and equipmen.
-
6.1 Comparison of Results The licensee's whole body counter censists of a chair containing three detectors: a 16% relative efficiency intrinsic germanium detector for the G.I. tract, a 16% relative efficiency intrinsic germanium detector for the lung, and a sodium iodide detector for the thyroid. The system software was supplied by the Yankee Atomic Environmental Laboratory.
The NRC phantom was counted for 180' seconds,.the licensee's normal counting time.
The lung results are based on an average of five measurements, and the GI tract results are based on an average of two measurements. The results of the comparisons are listed in Table II.
85 sed on these results, no violations were identified in this area.
6.2 Procedures and Data The licensee's procedure, OP 05333, Body burden Analysis, was reviewed as well as various references listed in the procedure. The procedure requires a QC check, using check sources for each detector, to be performed at least once per shift.
The QC check consists of peak width, gain, and efficiency checks. The procedures also requires that a background check be performed once per shift.
Calibrations are performed annually.
The inspector reviewed the calibration data for 1986 and noted that NBS traceable standards were used. The inspector also reviewed selected 1986 QC data.
Since July, 1986 the licensee has been plotting the whole body counter QC data on control charts. The inspector discussed the use and evaluation of control chart data with the licensee.
No violations were identified in this area.
7.0 Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on October 10, 1986. The inspector summarized the purpose, scope, and findings of the inspectio __
.
TABLE 1 VERMONT YANKEE VERIFICATION TEST RESULTS RESULTS IN uCl/mi SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON 1784 Split Cross alpha (1 12)
E-10
<6 E-8 No Compa rison WCT S r-90 (1.4 1 0.4)
E-8 (8.7 1 5.1)
E-9 Ag reement 3/27/84 S r-89 (2.3 1 0.2)
E-7 (2.2 i O.2)
E-7 Ag reement (INEL)
H-3 (7.27 1 0.02) E-3 (6.97 1 0.07) E-3 Ag reement Simulated Stack Cas Xe-133 (7.1 i O.2)
E-6 (8.6 1 0.2)
E-6 Ag reement 12/9/86 1520 HRS WCT Na-24 (3.1 1 0.2)
E-6 (3.2 1 0.1)
E-6 Ag reement 10/8/86 Hn-54 (2.9 i O.2)
E-6 (2.7 i O.1)
E-6 Ag reement 0905 HRS Co-60 (1.21 1 0.03) E-5 (1.05 i O.02) E-5 Ag reement Zn-65 (1.18 1 0.06) E-5 (1.10 1 0.04) E-5 Ag reement Tc-99m (4.3 1 0.1)
E-6 (3.7 1 0.1)
E-6 Ag reement Cs-137 (3.7 1 0.2)
E-6 (3.4 1 0.1)
E-6 Ag reement Cffgas Vial K r-87 (7.9 i O.7)
E-4 (7.9 i O.2)
E-4 Ag reement 10/7/86 Xe-135 (4.7 i 0.2)
E-4 (4.9 1 0.1)
E-4 Ag reement 1026 HRS Kr-88 (3.9 1 0.7)
E-4 (3.9 1 0.2)
E-4 Ag reement Kr-85m (1.0 i O.2)
E-4 (1.14 i O.04) E-4 Ag reement Rx Coolant Na-24 (1.5 1 0.1)
E-3 (1.50 1 0.01) E-3 Ag reement 10/8/86 Mn-56 (1.0 1 0.3)
E-4 (8.6 1 0.5)
E-5 Ag reement 0830 Co-60 (1.0 1 0.2)
E-4 (1,09 i O.04) E-4 Ag reement Cu-64 (5.2 1 0.6)
E-2 (5.3 i O.1)
E-2 Ag reement 2n-65 (1.2 i O.1)
E-3 (1.1 i O.1)
E-3 Ag reement As-76 (7.0 1 0.4)
E-4 (6.0 i O.1)
E-4 Ag reement Tc-993 (3.77 i O.03) E-3 (3.02 1 0.01) E-3 Ag reement I-132 (5.3 i O.7)
E-4 (4.6 1 0.1)
E-4 Ag reement I-133 (3.8 1 0.3)
E-4 (3.34 1 0.05) E-4 Ag reement 1-134 (3.1 1 0.4)
E-3 (2.6 i O.1)
E-3 Ag reement 1-135 (1.1 i O.1)
E-3 (8.5 1 0.3)
E-4 Ag reement Sr-92 (8.2 1 0.6)
E-3 (8.0 1 0.2)
E-3 Ag reement
!
l l
.
,
r, TABLE 1 VERMONT YANKEE VERIFICATION TEST RESULTS RESULTS IN TOTAL MICROCURIES SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON Stack Particulate Mo-54 (4.1 1 1.4) E-5 (2.9 i 0.9)
E-5 Ag reement 10/7/86 Co-60 (3.5 i O.2) E-4 (3.6 1 0.2)
E-4 Ag reement 1000 HRS Tc-99m (2.2 1 1.2) E-5
_(2.1 i O.7)
E-5 Ag reement Stack Charcoal 1-131 (0.8 1 0.3) E-4 (1.14 1 0.11) E-4 Ag reement 10/7/86 1000 HRS Rx Water crud Mn-54 (2.0 1 0.1) E-3 (2.4 1 0.2)
E-3 Ag reement 10/9/86 Mn-56 (6.3 2 0.1) E-2 (7.5 1 0.6)
E-2 Ag reement 08G0 Co-58 (6.2 1 1.0) E-4 (4.7 1 0.1)
E-4 Ag reement Fe-59 (2.4 1 0.2) E-3
'(3.4 1 0.2)
E-3 Ag reement Co-60 (1.5 i O.1) E-3 (1.8 i O.1)
E-3 Ag reement Cu-64 (3.1 i O.3) E-1 (4.0 1 0.3)
E-1 Ag reement Zn-65 (2.8 i O.2) E-3 (4.4 1 0.3)
E-3 Ag reement W-187 (3.7 i O.4) E-3 Not found*
No Comparison
- W-187 not found due to abundance percentage pa rameter criteria which was subsequently change.
,t'
TABLE II Results of-Whole Body Counting Phantom Data *
LUNG'RESULTS Licensee Value Isotope NRC Value Licensee Value NRC Value Co-60 71 1 9 104 1 9 1.5 0.2 Cs-137 93 i 12-145 i 12 1.6 1 0.2 GI Results Licensee Value Isotope NRC Value Licensee Value NRC Value Co-60 64 i 8 108 1 11 1.7 i 0.3 Cs-137 84 1 11 135
1.6 1 0.3
- Results in nanocuries
c.
.
,
.
..
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 program.
In these criteria, the judgement limits are variable in relation to the comparison 'of the NRC Reference Laboratcry'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 selective. Conversely, poorer agreement must be considered acceptable as the resolution decreases.
Resolution Ratio For Agreement 2
<3 0.4 - 2.5 4 - 7 0.5 - 2.0 8 - 15 0.6 - 1.66 16 - 50 0.75 - 1.33
200 0.80 - 1.25
-
>200 0.85 - 1.18 I Resolution = (NRC Reference Value/ Reference Value Uncertainty)
2 Ratio = (License Value/NRC Reference Value)
,
.
,
_
- -.. _ _.
.
-.
.
._.
. -
-
.
.
.
-.
.
-
.