IR 05000289/1976016
| ML19276H171 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/30/1976 |
| From: | Kottan J, Paperiello C, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19276H166 | List: |
| References | |
| 50-289-76-16, NUDOCS 7910150309 | |
| Download: ML19276H171 (11) | |
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IE:I Form 12
(Jcn 75) (Rev)
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U. S. NUCLEAR REGULATORY CC:CIISSION OFFICE OF INSPECTION %'D ENFORCCIENT
REGION I
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i IE Inspection Report No:
50-289/76-16 Docket No:
50-289 i
Licensee:
Metropolitan Edison Company License No: DPR-50 P. O. Box 542 Priority:
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j Reading, Pennsylvania 19603 Category:
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Safeguards Group:
Loca tion:
Three Mile Island Unit 1, Middletown, Pennsylvania t
Type of Licensce:
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Independent Measurement. Announced I
T w ')of Inseection:
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Dates cf Inspection: July 13-16, 1976 Dates of Previous Inspection:
July 7-15, 1976
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Reporting Inspector:
T T-7bd 7A J. J. Kottan, Radiation Specialist
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Ac:ompanyir.;; Inspectors:
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Dr. C. J Paper ello, Radiation Specialist DATE DATE DATE Other Acconpanying Personnel:
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Reviewed By:
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J. P. Stohr, hl/ef, b vironmental and Special Projects Section,(
DATE Fuel Facilit and Materials Safety Branch
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3Ol 791015030C/
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SUMMARY OF FINDINGS Enforcement Action
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A.
Violations None.
B.
Infractions Appendix B to Facility Operating Licence DPR-50, Environmental Technical Specifications, Sections 5.5.1h and i require procedures for the analysis of radioactive liquid and gaseous wastes.
Three Mile Island Station Chemistry Procedure 1973, Verification of Sample Representativeness and Accuracy - Effluents, requires blind duplicate samples of one evaporator condensate storage tank and one
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waste gas decay tank taken prior to the release of the tank and shall be run each month to determine the reproduceability of sampling and analytical techniques.
Analysis of duplicate samples shall be performed by different persons and the results of the-()
first analysis shall not be made available to the person performing the second analysis.
Contrary to the above requirement blind duplicate samples of the evaporator condensate storage tank and waste gas decay tank were not taken and analyzed for the months of February, March, April, May and June of 1976.
(Details, Paragraph 5)
C.
Deficiencies None.
Licensee Action on Previously Identified Enforcement Items (Independent Measurements)
None.
Unusual Occurrences None.
Other Significant Findings
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A.
General kk
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This report summarizes the results of an Independent Measurements Inspection conducted to evaluate the capability of the licensee to measure radioactivity in effluent samples and to evaluate the adequacy I
of the licensee's management controls for maintaining the quality of
measurements of radioactivity in effluent samples.
The results of the actual effluent sample analyses and the capability test standards analyses indicate that 92% of the analyses were in agreement with the NRC reference laboratory and eight percent were not in agreement.
(Details, Paragraph 3)
B.
Unresolved Items 1.
Radioactive Gas Analysis.
(Details, Paragraph 3)
2.
Addition of Acid to Samples.
(Details, Paragraph 4)
C.
Infractions and Deficiencies Identified by the Licensee None.
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Deviations I
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None.
Management Interview The following individuals attended ~the management interview at the conclusion
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of the inspection.
Mr. J. Colitz, Unit 1 Superintendent, TMI Mr. J. Romanski, Chemistry and Health Physics Supervisor, TMI Mr. R. Neidig, Jr., Quality Control Specialist, TMI Mr. K. Fredrick, Staff Chemist, TMI
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Mr. K. Horner, Chemist, TMI Mr. J. Reed, Chemistry Foreman, TMI Mr. R. Dubiel, Engineer-Health Physics / Chemistry, TMI Dr. C. Paperiello, U.S. NRC Mr. J. Kottan, U.S. NRC The inspector discussed his ir.spection findings in the following areas.
A.
Scope of the Inspection The inspector stated the purpose of the inspection.
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B.
Item of Noncompliance The inspector stated that the failure to sample and analyze blind duplicate samples of one evaporator c;udensate storage tank and one waste gas decay tank each month as required by Three Mile Island Station Chemistry Procedure 1973, Verification of Sample Representa-tiveness and Accuracy-Effluerxs was an Item of Noncompliance.
The inspector stated that the re. quired samples and analyses were not performed for the months of February, March, April, May and June of
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1976.
(Details, Paragraph 5)
C.
Results of Verification Test Samples The inspector stated that 22 of the 24 measurements to test the licensee's capability to measure radioactivity in effluent samples were in agree-ment.
The inspector stated that the two measurements in disagreement
were vaste gas decay tank samples.
The licensee stated that his counter calibration for radioactive gases would be reviewed and consideration given to using gaseous radioactivity standards for calibration instead of liquid standards with attenuation corrections.
The inspector stated this this would be considered an Unresolved Item and would be reviewed in a subsequent inspection.
(Details, Paragraph 3)
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D.
Additional Analyses on Verification Samples j
The inspector stated that the NRC Reference Laboratory, Idaho Health Services Laboratory (IHSL), would perform strontium 89, strontium 90, gross beta, gross alpha, and tritium analyses on the split liquid
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i radioactive waste sample.
The licensee stated that he will perform
the same analyses for the comparison of results.
The inspector stated that the results of the compa.ison would be documented in a subsequent inspection report.
(Details, Paragraph 3)
i E.
Sampling The inspector stated that comparison of a split evaporator condensate storage tank sample indicated the analyses results might depend on the amount of acid present in the sample in order to prevent the
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radionuclides in the sample from " plating out" on the walls of the sampling container. The licensee s;ated that the results of acid additi~n to the sampling container would be reviewed. The inspector o
stated that this would be considered an Unresolved Item and would be reviewed in a subsequent inspection.
(Details, Paragra 41 4)
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DETAILS 1.
Persons Contacted i
Mr. J. Colitz, Unit 1 Superintendent, TMI Mr. J. Romanski, Chemistry and Health Physics Supervisor, TMI t
Hr. R. Neidig, Quality Contrvl Specialist, TMI
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Mr. E. Daniels, Quality Control Specialist, TMI Mr. K. Fredrick, Staff Chemist, TMI Mr. K. Harner, Chemist, TMI Mr. J. Reed, Chemistry Foreman, TMI Mr. R. Dubiel, Engineer-Health Physics / Chemistry, TMI Mr. K. Beal, Health Physics Supervisor, TMI j
Mr. E. Houser, Rad Chem Tech Sr., TMI j
Mr. D. Ethridge, Rad Chem Tech Jr., TMI
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2.
General
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This inspection consisted of a review of the licensee's effluent collection and analysis procedures, effluent' records, quality
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assurance records, certain monitoring and counting equipment, (T and performance on actual effluent * samples split between the
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licensee and the NRC, IE:1. The actual effluent samples were analyzed by the licensee using his normal methods and equipment; l
the NRC, IE:I using the NRC, IE:I mobile laboratory at the site; I
and the NRC reference laboratory, Idaho Health Services Laboratory (IHSL). Results of the sample analyses were compared. Joint analyses of the actual effluent samples and subsequent comparison
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of the results determines the licensee's capability to measure i
radioactivity in effluent samples.
In addition, certain capability test standards, prepared by IHSL, were submitted to the licensee for analysis.
The licensee's performance in these samples was also reviewed.
An actual liquid effluent sample was sent to IHSL for analyses requiring wet chemistry.
These results will be compared with the licensee's results when received at a later date and will be docu-mented in a subsequent inspection report.
3.
Results of Verification Test Samples The comparison of the licensee's analyses with those of the NRC, IE:I mobile laboratory and the Idaho Health Services Laboratory (IHSL) in-dicated that 22 of the licensee's measurements were in agreement under the test criteria used by the Office of Inspection & Enforcement
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for comparing test results (See Attachment 1) and two of the licensee's measurements were not in agreement.
The samples analyzed consisted of splits of actual effluents and test standards prepared by IHSL.
The results of the measurement comparisons are as follows.
Type of Sample:
IHSL-St-4, December 1, 1975.
Results in Units of Microcuries per Milliliter
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Radionuclide NRC Measurement Licensee Measurement Comparison
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Sr-89 3.34 0.07 E-5 21.1 2.3 E-6 Agreement *
t Sr-90 4.79 ! 0.14 E-6 6.24 0.92 E-6 Agreement Type of Sample: Primary Coolant, 0945, July 14, 1976.
Results in Units of Microcuries per Milliliter Radionuclide NRC Measurement Licensee Measurement Comparison i
Cs-134 1.28 0.09 E-3 1.07 0.12 E-3 Agreement i
Cs-137 2.9 0.1 E-3 2.43 0.26 E-3 Agreement
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Na-24 1.72 0.04 E-1
.1,44 0.01 E-1 Agreement j
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I-131 1.95 0.10 E-2 1.92 0.03 E-2 Agreement I-132-6.7 1.0 E-3 6.37 0.42 E-3 Agreement I-133 1.14 0.03 E-2 8.74 ! 0.28 E-3 Agreement I-134 7.8 0.4 E-3 9.93 0.55 E-3 Agreement I-135 8.4 0.4 E-3 6.34 0.87 E-3 Agreement
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Type of Sample: MWST, 1505, July 15, 1976.
Results in Units of Microcuries per Milliliter Radionuclide NRC Measurement Licensee Measurement Comparison I-131 8.6 0.4. E-6 1.27 0.02 E-5 Agreement *
Co-58 4.8 1 0.2 E-5 5.39 0.05 E-5 Agreement
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Cs-134 8.1 2 0.6 E-6 7.84 t 0.26 E-6 Agreement Cs-137 1.7 2 0.1 E-5 1.53 t 0.03 E-5 Agreement Mn-54 1.11 0.05 E-5 1.06 0.02 E-5 Agreement Co-60 1.17 0.06 E-5 8.62 1 0.25 E-6 Agreement *
Possible Agreement Criteria A
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6-e Type of Sample:
Gas Decay Tank "A",
1615, July 15, 1976.
Results in Units of Microcuries per Milliliter Radionuclide NRC Measurement Licensee :4easurement Comparison I'
Xe-133 3.6 0.2 E-4 1.84 1 0.03 E-3 Not in Agreement Type of Sample:
Gas Decay Tank "A",
1043, July 14, 1976.
Results in Units of Microcuries per Milliliter Radionuclide NRC Measurement Licensee Measurement Comparison Xe-133 4.9 0.1 E-4 1.39 0.07 E-3 Not in Agreement Type of Sample:
IHSL Filter Paper, October 28, 1974.
Results in Units of Total Microcuries Radionuclide NRC Measurement Licensee Measurement Comparison ()
Sb-125 4.5 0.1 E-2 4.45 0.05 ?-2 Agreement Cs-134 6.0 ! 0.3 E-2 4.77 0.04 E-2 Agreement Ag-110m 2.6 ! 0.1 E-2 2.22 1 0.07 E-2 Agreement Na-22 1.11 0.04 E-2 9.52 0.02 E-3 Agreement
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Type of Sample:
IHSL Charcoal Cartridge, June 1, 1975.
Results in Units of Total Microcuries Radionuclide NRC Measurement Licensee Measurement Comparison j
Ba-133 4.86 0.07 E-2 6.26 1 ?
E-2 Agreement *
Type of Sample:
IHSL Charcoal Cartridge, June 1, 1975.
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Results in Units of Total Microcuries t
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Radionuclide NRC Measurement Licensee Measurement Comoarison Ba-133 9.69 0.10 E-2 1.21 0.04 E-1 Agreesent
Possible Agreement Criteria A
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The inspector noted that the two measurements in disagreement were the measurements of gas decay tank samples.
The licensee stated that his counting equipment was calibrated for gaseous radionuclide analyses using liquid standards traceable to the National Bureau of Standards with attenuation corrections being made for the Marinelli counting
geometry and no attenuation corrections made for the other counting geometries.
The licensee further stated that his counter calibration for gaseous radionuclides would be reviewed with consideration given
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to using gaseous radioactivity standards for calibration instead of liquid standards. The inspector stated that the licensee's measure-
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ments were higher than those of the NRC and this vould not result in the licensee exceeding any gaseous release discharge limits.
l The inspector further stated that this would be considered an Unresolved i
Item and would be reviewed in a subsequent inspection.
I 4.
Sampling The inspector witnessed the sampling of a gas decay tank and noted i
that an exhaust hood had been installed over the entire sampling l
panel and that a radiation monitor was present in the sampling area.
The inspector noted that the evaporator condensate storage tank is sampled in a one gallon container and that 3.5 liters of the sample i
is transferred to a Marinelli beaker for analysis prior to discharge.
The inspector stated that comparison of a split evaporator condensate
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storage tank sample indicated ~the analysis results might depend on the amount of acid present in the sample in order to prevent radio-
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nuclides in the sample from " plating out" on the a 11s of the
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sampling container prior to transfer to the Marinelli beaker for analysis. The licensee stated that he would review the results of adding acid to the sample container prior to sampling. The inspector stated this would be considered an Unresolved Item and would be
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reviewed in a subsequent inspection.
5.
Procedures The inspector reviewed the licensee's procedures and noted that an internal laboratory QC procedure had been implemented.
The inspector
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further noted that Three Mile Island Station Chemistry Procedure 1973, Verification of Sample Representativeness and Accuracy-Effluents, requires blind duplicate samples of one evaporater condensate storage tank and one waste gas decay tank taken prior to the release of the tank shall be run each month to determine the reproduceability of sampling and analytical techniques. Analyses of duplicate samples C
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i shall be performed by different persons and-the results of the first analysis shall not be made available to the person performing the second analyses. The inspector noted that the required duplicate sample analyses had not been performed for the months of February, March, April, May, and June, 1976. The inspector stated that Appendix
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B to Facility Operating License DPR-50, Environmental Technical Speci-fications, Sections 5.5.1h and i require procedures for the analysis of l
radioactive liqui 2 and gaseous wastes.
The inspector stated that this was an item of noncompliance.
The following procedures were reviewed by the inspector:
i 1604 - Alpha Surveys 1608 - Air Sampling for Tritium
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1621 - Releasing Radioactive Liquid Waste 1622 - Releasing Radioactive Caseous Waste 1629 - Health Physics Procedure for Liquid Waste Disposal System Operation 1631 - Sampling of Waste Gas Decay Tanks 1675 - Radioactive Release Records 1685 - Health Physics. Internal Audits 1701 - Background Determination for G-M Scalers (}
1702 - Background Determination for PCC-11T
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1703 - Background Determination for Beckman Wide Beta 1704 - Efficiency Determination for G-M Scalers 1705 - Efficiency Determination for PCC-11T
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1706 - Efficiency Determination for Beckman Wide Beta
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1707 - Plateau Determination for G-M Scalers 1708 - Plateau Determination for PCC-11T J
1709 - Plateau Determination for Beckman Wide Beta 1710 - Background Determination for Packard Tri-Carb 1711 - Efficiency Determination for Packard Tri-Carb 1714 - Plateau Determination for Ludlum 2000 Scaler i
i 1950 - Determination of Gross Beta Gamma i
1951 - Determination of Tritium 1952 - Determination of Iodine 1954 - Determination of Iron-59 1741 - Instrument Operation of Packard Tri-Carb 1955 - Strontium 1958 - Gamma Spectrometry 1959 - Determination of E-bar 1962 - Gross Alpha Activity Measurement 1971 - Spiked Sample Program 1973 - Verification of Sample Representativeness and Accuracy-Effluents The inspector had no additional questions in this area.
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6.
Records
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The inspector reviewed the plant logs and records in the following areas:
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Gaseous Discharge Release Permits (January, 1976 to July, 1976).
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Liquid Discharge Release Permits (January, 1976 to July, 1976).
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Counter Calibration Records (January,1976 to July,1976).
d.
Daily Counter Check Logs and Graphs (January, 1976 to July, 1976).
Internal Laboratory QA Records (January,1976 to July,1976).
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Corporate QA Audit No. 75-34 dated February 18, 1976.
The inspector had no additional questions in this area.
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Attachment 1 Criteria for Comparing Analytical Measurements
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This attachment provides criteria for comparing results of capability tests and verification measurements.
The criteria are based on an
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empirical relationship which combines prior experience and the accuracy needs of this program.
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In these criteria, the judgement limits are variable in relation to the
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comparison of the NRC Reference Laboratory's value to its associated
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uncertainty.
As that ratio, refe; red to in this program as " Resolution",
increases the acce,ptability of a licensee's, measurement should be more selective.
Conversely, poorer agreement'must be considered acceptable
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as the resolution decreases.
LICENSEE VALUE RATIO = NRC REFERENCE VALUE Possible Possible Resolution Agreement Agreement A Agreement B
<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
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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:
I Gamma Spectrometry where principal gamma energy used for identification is greater than 250 Kev.
Tritium analyses of liquid samples.
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"B" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification
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is less than 250 Kev.
89Sr and 90Sr Determinations.
Cross Beta where sa=ples are counted on the same date using the same reference nuclide.
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