IR 05000289/1978015
| ML19224A141 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/11/1978 |
| From: | Todd Jackson, Kottan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19224A137 | List: |
| References | |
| 50-289-78-15, 50-320-78-25, NUDOCS 7809270283 | |
| Download: ML19224A141 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTICN AND ENFORCEMENT
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Region I 78-15 Report No.
78-25 50-289 Docket No.
50-320 DPR-50 C
License No.
CPR-73 Priority
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Category C
Licensee:
Metropolitan Edison Company P. O. Box 542 Reading, Pennsylvania 19603 Facility Name:
Three Mile Island, Units 1 and 2 Inspection at:
Middletown, Pennsylvania Inspection conducted:
Ju y 19-21,1978
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Inspectors: 4 4-rM4#4
~74 J. J. Kottah, Radiation Specialist
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T. J. Jackson, Radiation Specialist-Intern date signed date signed
[/[/7f Approved by:
~J. P. Stohr,* Chief 7 Environmental and date signed Special Projects Section, FF&MS Branch
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Inspection Summary:
Inspection on July 19-21,1978 (Recort Nos. 50-289/78-15 and 50-320/78-25)
Areas Insoected:
Routine, unannounced inspection of the licensee's chemical and radiochemical measurements program using laboratory assistance provided by DOE Radiological and Environmental Services Laboratory.
Areas reviewed included:
program for quality control of analytical measurements; internal audit results, performance on radiological analyses of split effluent samples and spiked samples; and effluent control records and procedures.
hours on site by two NRC regional based inspectors.The inspection involved 4-4 inspector-Results:
Of the four areas inspected, no items of noncompliance were identified in three areas, and one item of noncompliance (Infraction - failure to follow procedures - paragraph 3.g) was identified in one area.
Region I Form 12 1N (Rev. April 77)
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- J. O'Hanlon, Unit 1 Superintendent R. Dubiel, Radiochemistry and Health Physics Supervisor
- G. Reed, Unit 1 Chemist
- K. Harner, Unit 2 Chemist J. Fornicola, QC Engineer L. Landry, Health Physics Engineer
- T. Mulleavy, Radiation Protection Supervisor The inspector also interviewed other licensee employees including members of the chemistry, health physics and QC staff.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findinos (Closed) Unresolved Item (50-289/77-17-01): Airborne tritium measurements. The licensee has recalibrated his liquid scintil-lation counter and modified his analysis procedure.
The inspector reviewed records of airborne tritium in effluents and noted the effects of the recalibration and procedure modification.
(Closed) Open Item (50-320/77-21-02):
Effluent procedures. The inspector noted the licensee has written and implemented gaseous and liquid effluent discharge procedures for Unit 2.
The inspector
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reviewed these procedures.
(Closed) Infraction (50-289/78-08-06):
Radiation levels in unre-stricted areas in excess of 10 CFR 20.lC5b limits.
The inspector, in the company of a licensee representative, perfonned a radiation survey of the area, and noted that action taken by the licensee had reduced the radiation levels to acceptable limits.
(Closed) Deficiency (50-289/78-08-02):
Failure to collect air iodines and air particulates as required.
The inspector noted this deficiency had occurred because the samples had not been collected due to sampler failures.
The inspector reviewed the system instituted 1.106
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by the licensee to ensure timely corrective action when the monitors are out of service. The inspector also reviewed the work request for a monitor which had been out of service and noted it resulted in timely repair of the monitor.
The inspector had no furthe, questions in tnis area.
3.
Laboratory QC Program The inspector reviewed the licensee's ; ogram for quality control of analytical measurements in the following areas:
a.
Assignment of Authority and Resoonsibility to Manace and Conduct the Program The inspector noted the licensee does not have a single labora-tory QC procedure, but elements of a laboratory QC program are contained in several procedures:
1.
1971 - Split / Spiked Sample Program 2.
1970 - Standardization of Analytical Procedures 3.
1973 - Verification of Sample Representativeness and Ac-curacy - Effluents 4.
1810.1 - NPDES Permit - Chemistry Requirement Split Samples The responsibility for the program is assigned by the above procedures to the Chemistry Supervisor.
b.
Provisions for Audits /Insoections The licensee's procedures contain no specific requirements for audits / inspections of the laboratory QC program.
However, there are requirements for review of the data by the Chemistry Supervisor.
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c.
Methods for Assurino Deficiencies and Deviations in the Prooram_
are Recoonized andlcentified The inspector noted the licensee's procedures contain provisions for review of split or spiked sample analysis by a Chemistry Supervisor and evaluation of deviations by a Chemistry Super-visor, d.
Methods for Taking Carrective Actions on Identified Deficiencies The inspector noted the licensee's procedures contain provisions for taking corrective actions on idantified deficiencies.
e.
Methed of Recording Audits /Inspactions The licensee's procedures contain no specific requirements or methods of recording audits / inspections, but do contain provisions for documentation and filing of results.
f.
Method of Reporting Results of %udits/Insoections to Suoervisor for Review and Aoproval The inspector noted that since the licensee's procedures do not require the performance of audits, there were no provisions or methods for reporting results of audits / inspections to supervisory personnel for review.
g.
Raauirements for Purchased or Contracted Services The inspector noted the licensee's procedures contain the management and procedural controls for purchased and/or con-tracted laboratory services as listed in a. through f. above.
The inspector discussed laboratory QC with the licensee. The inspector also discussed various aspects of NRC Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Nomal Operations) - Effluent Streams and the Environment". The inspector noted that procedure 1973, " Verification of Sample Representa-
.tiveness and Accuracy - Effluents", requires that checks for changes in composite samples be performed twice per year, and that quarterly duplicate samples be sent to an offsite laboratory for analysis.
The inspector detemined that the checks for changes in composite
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samples had not been performed in 1977, and that quarterly duplicate samples were not sent to the offsite labor 6 tory during 1977 and the first and second quarters of 1978.
The inspector stated that this was an item of noncompliance (78-15-01).
4.
Audit Results The inspector determined that the licensee's d,emistry, radio-chemistry, and effluent analyses and procedures were audited by the Quality Assurane.e (QA) staff. The inspector reviewed audit numbers 77-09, dated April 1, 12, and 22, 1977, and 77-10, dated June 21, 1977.
In addition, tiie inspector also reviewed tho following site Quality Control (QC) Surveillance Reports:
77-11, 77-52,77-159, 77-236,77-288 and 77-3C8, which covered the above areas.
The inspector had no further questions in this area.
5.
Confirmatory Measurements During this inspection, certain capability test standards, prepared by the NRC reference laboratory (Department of Energy, Radiological and Environmental Services Laboratory (RESL)), were submitted to the licensee for analyses.
In addit-:on, during this inspection, actual liquid and gaseous effluent samples were split with the licensee and sent to RESL for the NRC's analyses.
The analyses to be perfonned on the samples are:
a.
the liquid waste is to be analyzed for gross, alpha, tritium, strontium 89 and 90, and gama isotopes; and, b.
the gas sample is to be analyzed for gamma isotopes.
These results will be compared with the licensee's results when re-ceived at a later date, and will be documented in a subsequent in-spection report. Joint analyses of actual effluent samples determine the licensee's capability to mecsure radioactivity 'n effluent samples.
The comparisons of the capability test standards analyzed by the licensee during this inspection indicate that all of the measure-ments were in agreement under the test criteria used for comparing results.
(See Attachment 1). The results of the comparisons are listed in Table I.
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6.
Records and Procedures The inspector reviewed the following records and procedures:
a.
Gaseous effluent release permits (January,1977 to March, 1978)
b.
Liquid effluent release permits (January,1977 to March,1978)
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Counter calibration and check records (January,1977 to June, 1978)
d.
Laboratory QC sample analyses (January,1977 to June,1978)
c.
The following procedures:
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1621, Releasing Radioactive Liquid Waste, Unit 1 2.
1621.2, Releasing Radioactive Liquid Waste, Unit 2 3.
1622, Releasing Radioactive Gas Waste 4.
1622.2, Releasing Radioactive Gas Waste, Unit 2 5.
1675, Radioactive Release Records 7.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on July 21, 1978.
The inspector summarized the purpose and scope of the inspection and the inspection findings.
The licensee agreed to perform the analyses listed in paragraph 5, and report the results to the NRC.
The licensee acknowledged the item of noncompliance.
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TABLE I l
Three Mile Island, Units 1 & 2 Verification Test Results
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SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE_
COMPARISON RESULTS IN MICR0 CURIES PER MILLILITER RESL Standard 11-3 2.92 + 0.06E-3 2.48 8 + 0.02E-3 Agrer.;nen t 6/13/77 RESULTS IN TOTAL MICR0 CURIES g$
Charcoal Ba-133 4.24 + 0.20E-2 4.27 + ?E-2 Agreement
Cartridge a
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<d Charcoal Ba-133 6.59 + 0.33E-2 5.80 + ?E-2 Agreement Cartridge
- 26 Particulate Co-57 1.06 1 0.03E-2 1.26 1 ?E-2 Agreement Filter
- 41 Cs-134 1.54 1 0.06E-2 1.34 i ?E-2 Agreement
Cs-137 7.8 i 0.3E-3 8.73 1 ?E-3 Agreement
Co-60 1.02 1 0.05E-2 1.11 1 ?E-2 Agreement
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Attacit=ent 1 Criteria for Comparine Analytical Measurements This attachment provides criteria for cocparing results of capability tests and vecification qeasurements. 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 ia relation to the comparison of the NRC Reference Laboratory's value to its associated uncertainty. As that ratio, ref erred 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.
LICENSEE VALUE, RATIO = NRC REFERENr.i VALUE Possible Possible Resolution Acreement Agreement A Agreement B
<1 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:
Ga==a Spectrcmetry where principal gac=a energy used for identification is greater than _!v Kev.
Tritium analyses of liquid sa=ples.
"B" criteria are applied to the following analyses:
Ca==a Spectrometry where principal ga=ma energy used for identification is less than 250 Kev.
89Sr and 90Sr Determinations.
Gross Beta where sample: are counted on the same date using the same reference nuclide.
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