IR 05000298/1990030

From kanterella
Jump to navigation Jump to search
Insp Rept 50-298/90-30 on 900827-31.Violations Noted.Major Areas Inspected:Licensee Water Chemistry & Radiochemistry Program,Including Water Chemistry & Radiochemistry Confirmatory Measurements
ML20059M478
Person / Time
Site: Cooper Entergy icon.png
Issue date: 09/27/1990
From: Murray B, Nicholas J, Wilborn L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059M466 List:
References
50-298-90-30, NUDOCS 9010040242
Download: ML20059M478 (25)


Text

{{#Wiki_filter:E ,. ' ..a, . e APPENDIX B-U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/90-30 Operating License: DPR-46-Docket: 50-298 Licensee: Nebraska Public Power District (NPPD) P.O. Box 499 Columbus,. Nebraska 68602-0499'

Facility Name: Cooper Nuclear Station (CNS)

Inspection At: CNS, Brownv111e,_ Nebraska , Inspection Conducted: August 27-31, 199) Inspectors M N .- J B. Nffholas, Senior Radiation Specialist Da'te RadioloVical Protection and Emergency Preparedness Section WAi AbWV

$ ' L.'Wilborfl, Radiation Specialist, Radiological Dste - Protection and Emergency Preparedness

Section - Approved: M f>/XM O/' 9-Z7-90 B.Murray, Chief,RddiojlogicalProtectionand Date-i Emergency PreparednH s Section > . ' Inspection' Summary Ins'pection Conducted August 27-31, 1990 (Report 50-298/90-30) Areas.' Inspected: Routine, announced inspection of the licensee's water chemistry and radiochemistry programs, including water chemistry and ' radiochemistry confirmatory measurements, and the initial confirmatory dose calculations of offsite doses from radioactive waste effluents released to the

,

environment.

Results: The licensee had implemented a water chemistry program and ! radiochemistry program in accordance with NRC requirements.

The 'icensee's l ~ 9010040242 9009273"* gDR ADOCK 05000298' PNU

'.

l-2-

chemistry staff had experienced a personnel turnover of approximately

- 20 percent during.the past 20 months. This replacement of two chemistry technicians did not significantly impact the quality of performance of the chemistry / radiochemistry section (C/RS). The licensee had performed satisfactory quality assurance (QA) audits and surveillances of the chemistry / radiochemistry activities. The licensee's' training and qualification program appeared to be-satisfactory to train C/RS personnel to perform their required tasks.

However, there appeared to be a weakness in the training department's required trr.ining tracking program for requalification of postaccident sampling system (PASS) operators.

The results of the nonradiological water chemistry confirmatory measurements showed-100 percent agreement which indicated an improvement over the 81 percent . agreement achieved during the previous NRC water chemistry confirmato.y

measurements inspection in October 1988. The radiological confirmatory measurements results for the radiochemistry counting room indicated 100 percent-agreement and for the health physics (HP) counting room showed 100 percent agreement which was an improvement over the 97 percent agreement achieved by.

the radiochemistry counting room in October 1988. This inspection was the ~ first time the licensee's HP counting room instrumentation-had been includediin the radiological confirmatory measurements inspection.

Initial confirmatory dose calculations were performed during the inspection using the new NRC PC DOSE computer code for offsite dose calculations.

Comparisons between the licensee's dose calculations and NRC dose calculations were'in 100 percent agreement for all organ and total body dose results compared. These results confirmed that the licensee's dose calculations were accurate and performed as defined in the licensee's Offsite Dose Assessment Manual.(0 DAM).

Within the. areas inspected, one violation was identified concerning the failure to complete PASS operator requalification training for all C/RS technicians within the time interval allowed by CNS procedures. No deviations were identified.

y

m - ---_-________-______--___-L_____--_-_-__________-_-_-_________-________________-_-__-_______-___________

.- ,.. .,7 .

l-3 ' DETAILS 1.

Persons Contacted NPPD

  • J. M. - Meacham,- Division Manager, Nuclest Operations-R. L. Beilke, Radiological Support Stpervisor
  • L. E. Bray, Regulatory Compliance Specialist
  • J. W. Dutton, Nuclear Training Manager K. L. Fike, Chemist
  • R. L. Gardner, Senior Operations Manager
  • J.,Haes, Radiological Advisor B. L. Hall, Health Physicist

'J.. H..Kutler, Senior Chemistry and HP Specialist

  • R. J. Mcdonald,-Chemistry Supervisor D. P. Oshio, Lead HP Technician C..:H. Putman,--Jr., Senior QA Specialist

-

  • J. V. Sayer.1 Radiological. Manager
  • G. E. Smith, QA Manager ~

. D. L. Snyder, Chemistry Training Instructor J. R. Warren, 'enior Chemistry and HP Specialist 'M. C. Wright, Lead Chemistry Technician NRC

  • W. R. Bennett, Senior Resident Inspector
  • Denotes those present during the exit-meeting on August 31, 1990.

$ 2.. Organization and Management Controls The inspectors' reviewed the. licensee!.s organization, staffing.and_ staff l . functional, assignments related to the water chemistry and' r9diochemistry programs to determine-agreement with commitmentsiin Section XIII of the . Updated Safety Analysis Report (USAR) and compliance with the requirements- -in Section 6;l of.the TS. The procedures and documents reviewed during ,- this inspection:are identified in Attachment 1.

Ihe inspectors verified that the organizational structure of the CNS'C/RS was as defined-in the USAR and TS.' The C/RS_ staff assignments, management

]

control procedures, and. position descriptions.were reviewed for'the assignment of responsibilities-for the management-and implementation of' the CNS water chemistry and radiochemistry programs. There had been no C/RS organizational changes since the previous NRC. inspection of the chemistry / radiochemistry area conducted in October 1988. The inspectors a verified that the administrative control and program implementing responsibilities specified in the USAR, TS, and CNS procedures were being implemented.

i .

l

. ,

The inspectors review 6d the staffing of the C/R$ and noted that, since the previous NRC chemistry / radiochemistry inspection in October 1988, the C/RS had filled two chemistry technician vacancies created by the ' loss of the lead chemistry tachnician and one chemistry technician during 1988. The curront C/RS consisted of a chemistry supervisor, senior chemistry 'ad HP specia H st, chemist, lead chemistry technician, and five chemistry +echnicians.

The C/.iS personnel turnover was approximately 20 perce., in the past 20 nonths.

The inspectors determined that the replacement of two chemistry technicians had not significantly affected the quality of performance of the C/RS.

The CNS staffing of the C/RS appeared adequate to support the licensee's water chemistry and radiochemistry programs and was determined to be in accordance with licensee commitments.

No violations or deviations were identified.

3.

Training and Qualifications The inspectors reviewed the licensee's training and qualification program for C/RS personnel including education and experience, adequacy and quality of training, employee knowledge, and qualification requirements for new employees to determine agreement with commitments in Section XIII-3 of the USAR and.he requirements in Sections 6.1.4 and 6.3.7 of the TS.

The inspectors reviewed the education and expe-tence of the'present CNS C/RS staff and determined that all of the C/RS staff met the required qualifications required in the USAR, TS, and ANSI N18.1-1971. The two recently hired chemistry technicians came from other CNS departments. One of the new chemistry technicians had been a licensed operator at CNS since-January-1982 and the other new hire had been employed in the CNS radiation protection section since June 1978. The inspectors determined that the -- nine C/RS staff had a total of 101 years of operating experience at CNS.

The inspectors reviewed the licensee's training program for C/RS personnel including a review of the chemistry training instructor's qualifications; . training facilities; chemistry training program descriptions (TPD), TPD-0411 TPD-0412, and TPD-0414 for chemistry technicians, and TPD-0409 l and TPD-0413 for training and qualifying HP and chemistry technicians to provide oasite backshif t HP and chemistry availability; on-the-job i

chemistry instructor certifications; selected course lesson plans and job i

erformance measures; and C/RS personnel training records.

The inspectors teviewed the individual statf training recor s of the two most recently d hired chemistry technicians and noted that ti.ey had completed all the l.

required training for ANSI chemistry technician Level 11 as described by L TPD-0413.

The inspectors reviewed the required requalification training records for the chemistry technician PASS operator training. TS 6.3.7c requires that a program be established using the PASS to ensure the capability to obtain and analyze reactor watst, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident -)

.. .,

l ' -5-conditions. This p n gam is to include training of personnel, procedures for sampling and analysis, and provisions to show operability of sampling and analysis equipment. The licensee's PASS operator training program is directed by TPD-0411 and TPD-0412 and requires that all chemistry technicians (Level III) and ANSI chemistry technicians (Level II) be trained and requalified semiannually. The PASS operator training for the chemistry technicians is implemented by the nuclear training department conducting PASS training in accordance with the Nuclear Training Courses SKLO19-06-01 through SKLO19-06-06 every 6 months. The licensee's nuclear power group directive, " Nuclear Training and Indoctrination, Revision 0, paragraph VI.C states that all continuing activities must be accomplisted within the continuing training period, plus 25 percent to the nearest month, in order to retain training certification.

For PASS training, this translates that PASS requalification operator training must be performed within at least 7.5 months after the initial or previous qualification.

Contrary to lhe above requalification training requirement of every 6 months, the inspectors determined on August 30, 1990, during a review of the C/RS personnel training records, that PASS operator training and associated postaccident assessment training had not been completed routinely within the time period of every 6 months plus 25 percent.

For six chemistry technicians reviewed, numerous examples were found since October 1988 where the Nuclear Training Courses SKLO19-06-01 through SKL019-06-06 were not conducted and completed by the six chemistry technicians within a 7.5-month time interval from the previous qualification. The failure to conduct and complete semiannual PASS operator requalification training every.7.5 months during the period October 1988 through August 1990, is an apparent violation of TS 6.3.7c and the license's implementing Training Program Descriptions TPD-0411 and TPD-0412 (298/MT t-01).

The inspectors noted that this apparent violation is similar to a previous NoticeofViolation(298/8827-01) which was issued in December 1988 to document the licensee's failure to perform PASS operator requalification trair.ing during the time period May 1987 through June 1988. The corrective actions which were taken in response to that violation to prevent recurrence were apparently not adequate.

No deviations were identified.

4.

9AProgram The inspectors reviewed the licensee's QA surveillsnce and audit programs regarding water chemistry and radiochemistry activities to determine agreement with commitments in Section XIII of the USAR and compliance with the requirements in Section 6.2 of the TS.

The inspectors reviewed the audit schedules for 1989 and 1990 ar.d QA surveillance and audit plans and checklists used in planning and conducting QA surveillances and audits of the C/R$ ?ctivities. Audit end surveillance reports generated from QA activities during 1989 and 1990 in the areas of radiochemistry analysis, radiochemistry sample control, .,.... ...... . . . ___

n i l i 4, j , j l

! -6-i r laboratory conditions, and chemistry / radiochemistry instrument calibration i were reviewed for scope to ensure thoroughness of program evaluation.

The inspectors noted that the 1990 QA audit of chemistry had beer started l July 30,1990, and was still in progress at the time of his inspection.

l The inspectors verified that surveillance and audit findings had been i reviewed by licensee's management and that responses and corrective ' actions to findings had been documented in accordance with QA procedures.

No violations or deviations were identified.

5.

Radioactive Liquid and Gaseous Waste Effluent Dose Calculations

' -The inspectors reviewed the licensee's radioactive waste effluent dose calculations to deter'nine compliance with the requirements in f Sections 3/4.21 and 6.3.2G of the TS.

t The inspectors conducted initial confirmatory calculations of the offsite , doses from the plant's liquid and gaseous radioactive waste effluents , released to the environment.

Radioactive waste effluent dose calculations were performed by the inspectors for liquids, airborne particulates, and noble gases using the NRC computer code, PC DOSE, which was developed to

verify the dose calculations described in the licensee's ODAM, The licensee performed offsite dose calculations using methodologies, assumptions, equations, and factors described in the ODAM and implemented by the licensee's computer code, EFFECTS. The inspectors compared the NRC ' dose results with the licensee's dose re mits and determined that all organ and total body doses calculated by the licensee were in 100 percent agreement with the NRC results for all examples tested.

Therefore, the licensee's computer calculations of offsite doses resulting from radioactive waste effluents discharged to the environment were confirmed to be accurate and in acct,' dance with the methods, assumptions, bioaccumulation factors, anu equations described and defined in the ODAM.

, L No violations or deviations were-identified.

6.

Light Water Reactor Chemistry Control, Chemical Analysis, and l Confirmatory Measurements ,

L The inspectors reviewed the licensee's water chemistry ontrol and ' analysis program including implementation of a water c.nistry control program, facilities and equipment, implementation of a quality control (QC) program for chemical measurements, and water chemistry confirmatory measurements to determine agreement with commitments in Section IV of the USAR and compliance with the requirements in Section 3/4.6 of the TS.

The inspectors' review of the water chemistry program found that the I . licensee had approved administrative procedures, surveillance procedures, chemical control procedures, sampling procedures, instrument calibration and perforniance check procedures, and analytical procedures.

A review of > elected procedures *evised and approved since the previous NRC inspection ' o i 'f.

i A _

._ l O

j , lo i-7- ]

l of the chemistry / radiochemistry area in October 1988 indicated that the C/RS had established sufficient programmatic procedures to meet the requirements of the USAR and TS.

j The inspectors inspected the facilities and equipment used by the C/RS staff. The following facilities were Inspected: chemistry / radiochemistry i laboratory, radiochemistry counting room, and chemistry sampling panels.

The laboratory and counting room were equipped with the necessary ' chemicals, reagents, labware, and analytical instrumentation to perform the required analyses.

The facilities inspected were undergoing design , modifications at the time of the inspection. The changes will provide more efficient sampling capability and less crowded working conditions in the sample room and laboratory. The chemistry technicians desks are being moved out of the laboratory to a nearby area designed as an office area for the C/RS technical staff. This will provide much needed

additional laboratory space.

The inspectors reviewed selected C/RS procWures for operation, cal'bration, and QC of the laboratory analytical instrumentation used for analysis for the NRC water chemistry standards to determine adequacy and accuracy of the licensee's water chemistry measuremeM.s program.

The chreistry nonradiological laboratory analytical instruents had been calibrated in accordance with approved procedures and ar instrument QC program was implemented.

The inspectors provided standard chemical solutions to the licensee for nonrddiological confirmatory measurements analyses.

The chemical

standards were analyzed by the licensee using routine methods and , equipment. The final results of the nonradiological water chemistry confirmatory measurements showed 100 percent agreement or qualified , agreement with the NRC.ertified standard values.

These results indicated an improvement in nonradiological water chemistry analytical performance over the 81 percent agreement during the previous NRC chemistry confirmatory measurements inspection in October 1988.

The results of the measurements comparisons are summarized in Attachments 2, 3, and 4 to this report, e No violations or deviations were identified.

7.

Radiological Chemistry Control, Radiochemical Analysis, and Confirmatory Measurements i The inspectors reviewed the licensee's radiochemistry control and analysis program including analytir.61 procedures, radiochemistry instrumentation, implementation and radiochemistry control of the reactor water system and auxiliary water systems, implementation of a counting instrument calibration and QC program, and radioanalytical confirmatory measurements to determine agreement with commitments in Section X of the USAR and compliance with t!.< requirements in Sections 3/4.6 of the TS.

! , _... . _ ,

d o.

, I l-8-L The inspectors reviewed selected radiochemistry analytical procedures revised and approved since the previous NRC inspection of radiochemistry activities in October 1988 and determined that the licensee had established and implemented satisfactory radioanalytical procedures to meet the commitments in the USAR and the TS requirements.

The inspectors found the type and quantity of radiaanalytical instrumentation in the radiochemistry counting roon and the HP counting room adequate to perform the required analyses specified in the TS. The inspectors noted that the licensee had installed a new liquid scintillation counting system in the radiochemistry counting room.

Radiological confirmatory measurements were perforned on a standard and split samples by the licensee and the inspectors in the Region IV mobile laboratory onsite.

The NRC standard and split samples were analyzed by the licensee using routine methods and equipment. The radiological confirmatory measureme.ts included analyses performed in the radiochemistry arJ HP counti.ng rooms.

This involved comparisons of analytical results from four detectors. The licensee's radiological confirmatory measurements results were in 100 percent agreement with the NRC analyses results. These results showed an improvement over the 97 percent agreement during the previous NRC radiological confirmatory measurements inspection conducted in October 1988. This inspection was < the first time the HP counting instrumentation had been included in the radiological confirmatory measurements inspection.

The results of the radiological measurements comparisons are summarized in Attachments 2, 5, and 6 to this report.

No violations or deviations were identified.

8.

Exit Meetina The inspectors met with the senior resident inspector and the licensee representatives identified in paragraph 1 of this report at the conclusion

of the inspection on August 31, 1990.

The inspectors summarized the scope and findings of the inspection and discussed the results of the water chemistry and radiochemirtry confirmatory measurements as presented in this report. The licenree did not identify as. proprietary any of the materials provided to, or reviewed by, the inspectors during the inspection.

_ - _. _

', j . ! i ATTACHMENT 1 COOPER NUCLEAR STATION NRC Inspection Report 50-298/90-30 Documents Reviewed . 1.

Nuclear Power Group Directive Procedure ! No.

Title xevision Date 3.3 Nuclear Training and Indoctrination

06/28/88 [ 2.

Training Job Performance Measures Procedure No.

Title Revision SKL019-01-24 Chemistry: Operate RC-18A

r Conductivity Bridge SKL019-02-01 Chemistry: Operate the Ion

Chromatograph SKL019-03-17 Chemistry: Obtain Sample of

Steam Jet Air Ejector Of f-Gas SKL019-03-52 Chemistry: Use EFFECTS Program

. 3.

Training Program Descriptions (TPD) ' Procedure No.

Title Revision Date TPD-0409 Health Physics On-Site Availability

12/16/88 TPD-0411 _ Chemistry Technician (Level III)

06/06/89 TPD-0412 ANSI Chemistry Technician

06/06/89 (Level II) TPD-0413 Chemistry On-Site Availability

06/06/89 i TPD-0414 Chemistry Technician (Level I)

06/06/89

~ i

. i , ' -2- , t i , i 4.

Quality Assurance (OA) Audit and surveillances ] " QA Audit Report 89-15, QAP-900 - Quality Assuranet Plan, Chemistry, I ' Health Physics, and Environmental Monitoring, conducted July 18 through September 22, 1989 QA Surveillance (QAS) - 50-900-05,- Radiochemistry Analysis, performed

January 31, 1989 l t QAS-SC-900-04, Chemistry Laboratory Conditions, performed February 28 j 1989

. QA$-SC-900-06, Radiochemistry Sample Control, performed March 31, 1989 ' ! QAS-SC-900-02, Chemistry Instrument Calibration, performed June 29, 1989

QAS-SC-900-05, Radiochemistry Analysis, performed May 11, 1990 j QAS-SC-900-05, Radiochemistry Analysis, performed August 8, 1990 s

i 5.

Chemistry Proceduce f Drocedure i ' No.

Tit 13 Revision Date 8.2.1 Chemistry Analysis and Instrument

04/12/90 i Calibration Schedule j 8.3 Control Parameters and Limits

11/09/89 8.4 Routine Sampling Procedure and

11/09/89 Liquid / Gas Sample Points ' - . 8.4.1.1 Postaccident-Sampling System

07/13/90 l 8.5.1.2 Conductivity Bridge RC-18A

04/13/89 8.5.1.6 Eppendorf Calibration

_04/25/90 8.5.1.11 Spectrometer DU-2

06/08/89 -; 8.5.1.13 Atomic Absorption Spectrometer

04/05/90 i Model 11008 8.5.1.18 Ion Chromatograph

If/21/89 [ w.

'8.5.2.1 Canberra System Operation

06/08/89 u , - i t c . y_ - -

- . ... .. - -. . -.... - -. . , s " ' =*

  • g,,:

c . '-

- ! ' l . -{ . ' Procedure ' -, '* .. ! <* No.

Title Revision Date I 8.5.2.2 Alpha / Beta Counter 5-02/20/89 ll .! 8.5.2.3 Liquid Scintillation System

10/27/88 i

8.7.1.37 Silica Analysis

06/23/88 l . 8.8.1.31, Radiochemical Analysis of Tritium '2 04/28/88 -! i .8.8.3 . Metals Analysis

07/06/89

! 8.8.4. -Off-Gas. Grab Samples Isotopic.

01/29/87 'l Analysis ?, l '8.8.8 Particulate, Iodine, and Noble Gas

06/22/89- ' Sample Collection for Effluent Monitors-j

8.11.1 Effects Program

10/27/88.

- 't j !

j-1

){ -! 1; - t '?

}

E , _ a i i, l' . l^ t >

f I ? 1; r L l .

.

l:

' , , .-.. . .. -.. .. - -. . ... . - - -.

. .,. . ATTACHMENT 2 Analvtical Measurements

Cooper Nuclear St at i on NRC Inspection Reports 50-298/90-30 i i 1.

Water Chemi st ry Confirmatory Measurements ! During the inspection, standard chemical solutions were provided to the licensee for analysis.

The standard solutions were prepared by , the Brookhaven National Laboratory (DNL), Safety and Environmental Protection Division, for the NRC.

The standards were analyzed by the licensee using routine rethods and equipment.

The a.ial ysis of , chemical standards is uaed to verify the licensee's apability to monitor themical paraneters in various plant systemr with respect to Technical Specification (TS) requirements and othe' inductry standards.

In addition, the analyses of standcri's are used to evaluate the licensee's analytical procedures wi th respect to accuracy , and precision.

The results of the measurements comparisons are listed in Attachment 3.

Attachment 4 describes the criteria used to compare the results.

All standards were analyzed in triplicate at three concentrations spread over the licensee's normal calibration range.

I The licensee's original analytical resul ts indicated problems wi th the analyses f or chloride, sulfate, and silica.

The original results showed 16 of the 23 results were in agreement using the criteria presented in Attachment 4.

a.

The licensee's original' chloride results were all in

disagreement.

The licensee prepared new chloride calibration standards end recalibrated the ion chromatograph l for chlcride concentrations greater than 4.0 ppb.

The licensee prepared new dilutions of BNL chloride standards ( 8 8/., BBB, and 88C) and reran the chloride analyses.

The l retest results for the chloride analyses were all in , ag"eement.

b.

The licensee's original sulfate results were all in disagreement.

The licensee prepared new sulfate calibration standards and recalibrated the ion chromatograph for sulfate concentrations greater than 5.0 ppb.

The licensee prepared new dilutions of BNL sulfate standards (BBA, BBB, and BBC) and reran the sulfate analyses.

The retest results for the sulfate analyses were all in agreement.

, e , ef .,

.

ATTACHMENT 2

c.

The licensee's original silica low range concentration result was it. disagreement and biased low.

The silica high range concentration result was in qualified agreement and biased low.

The low silica results were attributed to dirty pipet tips causing dilution errors in the preparation of the BNL standards.

Dust f rom the construction in the laboratory on the pipet tips was causing the pipet tips not to deliver completely.

The licensee prepared new dilutions of the BNL silica standards (87S and 87U) using new clean pipet tips and reran the silica analyses.

The retest results fc-the silica analyses were in agreement except for the low *ange concentration result which was in qualified agreement.

The licensee's final anal yti c al results, after the retests to resolve the original disagreements, indicated 100 percent agreement with the DNL results based on 23 results compared.

The licensee's chemistry section perf ormance in the vea of non-radiological water chemistry confirmatory measurements siowed sn improvement over the 81 percent agreement achieved during tS* 1 ass NRC inspection of this area in October 1988.

2.

Radi ol oai c al Confirmatory Mea sur ems.it s The radiochemistry confirmatory measurements were performed on the f ollowing standard and samples in the NRC Region IV mobile laboratory at Cooper Nuclear Station during the inspection.

(1) NRC Particulate Filter Standard (34118-109) (2) Elevated Release Point Charcoal Cartridge Sample (3) Liquid Floor Drain Storage Tank Sample (500ml Marinelli Beaker) (4) Off Gas Sample (15cc Gas Serum Viali (5) Reac:or Water Sample (500ml Marinelli Beaker) (6) Condensate Demineralizer Ef fluent Tritium Sample The radiological confirmatory measurement tests consisted of comparing the analysis results of the licensee and the NRC Region IV mobile laboratory.

The NRC's mobile laboratory measurements are ref erenced to the National Institute of Standards anc Technology by laboratory intercomparisons.

Confirmatory measurements are made only for those nuclides identified by the NRC as being present in concentrations greater than 10 pertent of the respective isotopic values f or l i qui d and gas concentrations as stated in 10 CFR Part 20, Appendix B, Table ,- II.

i

,. .. i

  • i

, . i ATTACHMENT 2

! The licensee maintains one high-purity germanium detector in t he radiochemistry counting room and three high-puri ty germanium cetectors

in the health physics counting room f or a total of four detectors.

] These detectors are used routinely for isotopic analysis of radioactive samples to demonstrate compliance with TS and regulatory . requirements.

The analytical results from the four detectors were compared with the NRC results.

'he respective analytical results are reported for each detector.

The licensee performed the tendensate demineralizer effluent sample tritium analyris on their l i qui d i scintillation counting system in the radiochemistry counting room.

The individual sampl e analyses and compari son of anal yti cal results of the radiological confirmatory measurements are tabulated in Attachment 5.

Attachment 6 describes the criteria used to crmpare the analytical resultt . The licensee's radiochemi stry co anting room gamma isotopic resul ts

f rom the - samples li sted in Attachment 5 showed 100 percent agreement with the NRC analysis results based on 28 agreement results out of 28 total results compared.

The licensee's tritium result of the condenstae demineralizer ef fluent sample was in agreement with t he NRC analysis result.- The licensee's radiochemistry counting room perf ormance in the area of r adi ol ogi c al confirmatory measurement.s showed an ~ improvement over the 97 percent agreement achieved dur t ig the last NRC inspection of this area in October 1988.

( The licensee's health physics counting room gamma isotopic results f rom the samples listed in Attachment 5 showed 100 percent agreement with the NRC analysi s results based on 82 agreement results out of 82 total results compared.

This inspection was the first time the licensee's health physics counting room instrumentation has been included in the radiological :onfirmatory measurements inspection, i . f .

s .- _

- - .-- _ _. -- - - _ - . . $- ., -. ATTACHMENT 3 ,

Water Chemintry Confirmatory Measurements Results t Coooer Nuclear Station NRC Inspection Reports 50-298/90-30 i i 1.

Chl ori de Anal ysi s (10-100 ppb) Ion Chromatography

i I CNS Results NRC Results Comparison ' Sampl e (opb) (nob) Decision ! 88A 21.3 30.0 Disagreement 088 15.9 62.0 Disagreement BBC 66.3 95.0 Disagreement , Retest - prepared new BNL chloride standard dilutions, prepared new chloride calibration standards, performed new instrument callbration, and performed retest analyses , 88A 27.7 30.0 Qual. Agree.

888 64.6 62.0 Agreement-BBC 98.2 95.0 Agreement - 2, Gyl f ate Anal vr.in (10-100 ppb) Ion Chromatography CNS Results NRC Results Comparison

Sampl e (Dob) (pobl Decision

88A 9.1 19.0 Disagreement 888 8.7 38.0 Di sac;-eemen t BBC 34.5 60.0 Diragreement Retest - prepared new BNL sulfate standard dilutions, prepared new sulfate calibration standards, performed new instrument calibration, and performed retest analyses , BBA 18.3 19.0 Agreement 888 38.1 38.0 Agreement 88C 57.4 60.0 Agreement , - -- - -- ,

., ,-

! ATTACHMENT 3

3.

Iron Analysis (0.1-5.0 ppm) Flame Atomic Absorption CNS Results NRC Results Comparison Samol e (com) (DDm) Deci si on ., BOG 1.82 1.98 Agreement 80H 3.60 3.92 Agreement BOI 2.71 2.90 Agreement 4.

Cooper Anal ysis (0.1-5.0 ppm) Flame Atomic Absorption CNS Results NRC Results Comparison Samole (com) (nom) Decision BBG 1.92 1.99 Agreement 88H 3.81 4.05 Agreement 081 2.80 2.98 Agreement 5.

Nickel Analysis (0.1-b.0 ppm) Flame Atomic Absorption CNS Results NRC Results Comparison Samoln (com) (nom) Decision 80G 2.03 2.03 Agreement 80H 3.88.

4.03 Agreement ODI 2.95 3.05 Agreement 6.

Chromi um Anal yst_ s_ (0.1-5. 0 ppm) Fl ame Atomic P',sorpti on CNS Results NRC Results Comparison Samoln (com) (nom) Decision BGG 1.97 2.00 Agreement 80H 3.59 4.04 Qual. Agree.

OBI 2.70 3.00 Qual. Agree.

7.

Sodium Analysis (10-100 ppb) Ion Chromatography CNS Results NRC Results Comparison Sample (oob) ingb t Decision B8J 10.9 10.2 Agreement BBK.

23.9 19.8 Qual. Agree.

. - -__m _--_.m_-._ .mm._m..<_______m_'_'.. _ _ _ _. _. _ _ _. _ _ _. _. _ _ _ ____..___._.__.___-__..____._.______._-_m m___.m__.m.__.m.-_____ _ _ _. _ ___.___m___

. ._.

._ __ _ .-. . , '.

,

! , ! ATTACHMENT 3

r G.

Silica Anal ysi s -(5-1000 ppb) Spectroscopy CNS Results NRC Results Compari son Sample 4006) (oob) Deci si on 07S 22.5 26.4 Disagreement B7U 71.0 78.5 Agreement 87U 135.0 157.0 Qual. Agree.

Retest - prepared new BNL silica standard dilutions using new clean pipets and performed retest analyses , 87S 23.0 26.4 Qual. Agree.

87U 71.0 78.5 Agreement ' 87U 150.0 157.0 Agreement , ? I ! l l . L 1'

1 .. . . .. . _., _ _ _. _.. _.. -., _ .. - - -_. _. . ! ., . . ATTACHMENT 4 ) CRITERIA FOR COMPARING WATER CHEMISTRY ANALYTICAL MEASUREMENTS ! , The following are the criteria used in comparing the results of the capability tests and verification measurements.

The criteria f or the judgement limits are based on the dat6 from Table 2.1 of ' NUREG/CR-5244, " Evaluation of Non-Rad,riogical Water Chemistry at ' Power Reactors."

Licensee values within the plus or minus two stadnard deviations range of the BNL known values are considered to be in agreement.

Licensee values outside the plus or minus two standard deviations range but within the plus or minus three ' standard deviations range of the BNL known val'Jes are considered ! to be in qualified agreement.

Retest results which are in qualified agreement will receive additional attention.

Licensee values greater than the plus or minus three standard deviations range of the BNL known values are in disagreement.

The standard l deviations were computed using the average percent standard deviation values of each analyte in Table 2.1.

The ranges for the data in Attachment 3 are as follows: , Agreement Qualified Areement Amnule Analvte Ranoe Ranoe 88A C1 28 - 32 27 - 33 SO 17 - 21 16 - 22

888 C1 57 - 67 55 - 68 SO 34 - 42 33 - 43

BBC C1 88 - 102 85 - 105 SO 54 - 66 52 - 68

88G Fe 1.79 - 2.17 1.69 - 2.27 Cu 1.80 - 2.18 1.71 - 2.27 Ni 1.90 - 2.16 1.04 - 2.22 l Cr 1.81 - 2.19 1.71 - 2.29 l l 88H Fe 3.54 - 4.30 3.36 - 4.48 Cu 3.66 - 4.44 3.47 - 4.63 ' Ni 3.78 - 4.28 3.66 - 4.40 Cr 2.86 - 3.24 2.77 - 3.34 l 881 Fe 2.62 - 3.18 2.48 - 3.32 l Cu 2.69 - 3.26 2.55 - 3.40 Ni 2.86 - 3.24 2.77 - 3.34 Cr 2.71 - 3.29 2.56 - 3.44 88J Na 8.8 - 11.6 8.0 - 12.4 . BOK Na 17.0 - 22.6 15.6 - 24.0 l .. ... . ..- ,.

. _ _ ., . . , . ATTACHMENT 4

Agreement Qualified Areement Amoule Analvte Ranoe Ranae , i 87S SiO 24.1 - 28.7 23.0 - 29.8

, 87U SiO 71.0 - 86.0 67.0 - 90.0

87U SiO 142 - 172 134 - 180

? > t , i t.

> -P

( r i + '$ & I '! . P y-w - -- - , - , . _,, ~

.__ . ... -. . _ _ _. __ --_ ., .' . I I ATTACHMENT 5 . Radi ol oai cal Confirmatory Measuresment Resulta l Cooper Nuclear Station j NRC Inspection Report: 50-298/90-30

. 1.

NRC Particul_ ate Filter Standard (34118-109) CN041A (Standardized: 11:00, CST, January 1, 1990) Standard was analyzed by one radiochemistry detector and by three ' ' health physics detectors.

The results of the analyses are reported.

for each detector in the above stated order.

CNS Results NRC Results CNS/NRC Comparison Nuclide (uCi/ sample) (uCi /samol e) Ratin Decision , Cd-109 1.1110.02E+0 9.35tO.05E-1 1.19 Agreement ' 9.93iO.10E-1 1.06 Agreement 9.85tO.10E-1 1.05 Agreement i 9.63tO.10E-1 1.03 Agreement Co-57 2.7510.06E-2 2.62 0.02E-2 1.05 Agreement 2.54tO.03E-2 0.97 Agreement 2.59tO.03E-2 0.99 Agreement 2.4610.04E-2 0.94 Agreement r Ce-139 3.7110.10E-2 3.6810.04E-2 1.01 Agreement 3.5510.06E-2 0.97 Agreement 3.55tO.06E-2 0.97 Agreement 3.4310.06E-2 0.93 Agreement Hg-203 5.05iO.88E-2 4.2810.33E-2 1.18 Agreement ' 3.9910.58E-2 0.97 Agreement 4.73tO.54E-2 1.11 Agreement 4.3710.53E-2 1.02 Agreement Sn-113 7.92iO.25E-2 8.0710.09E-2 0.98 Agreement 7.92iO.17E-2 0.92 Agreement 8.50iO.17E-2 1.05 Agreement 8.02iO.15E-2 0.99 Agreement Cs-137 ,7.4510.12E-2 7.00iO.04E-2 1.05 Agreement 6.8610.OBE-2 0.97 Agreement 7.0610.00E-2 1.00 Agaeement 7.OOiO.07E-2 0.99 Agreement , -1-*w - ,+ +, ,m.,,,,,y., % ,._w_a.

.._.._,,,,_m,mm__,_,._ _,_,_,,,m______._mm_m,.,_,,__,_,__ _, _ _,,,,,_

_. --. _ _ - -. .-. . - - - . - - . 9 * . ATTACHMENT 5

CNS Results NRC Results CNS/NRC Comparison Nuclido (uC1/sampl e ) (uCi /sampl e) Ratio Deci si on Co-60 3 1/tO.15E-2 8.1310.04E-2 1.00 Agreement 7.B9tO.11E-2 0.97 Agreement 8.OOiO.11E-2 0.98 Agreement 7.6910.09E-2 0.95 Agreement Y-88 1.4610.04E-1 1.39 0.02E-1 1.05 Agreement 1.33iO.03E-1 0.96 Agreement 1.3710.03E-1 0.98 Agreement 1.34iO.03E-1 0.96 Agreement , 2.

Elevated.elease Point Charcoal Cartridae Samole CNO39A (Sampled: 14:40, CDT, August 27, 1990) Sample was analyzed by one radiochemistry detector and by three health physics detectoro.. The results of the analyses are reported for each detector in the above stated order.

! CNS Results NRC Results CNS/NRC Comparison Nuclide (uCi/ce) (uCi/et) Ratio Deci si on . I-131 2.12 0.09E-12 1.9 bio.10E-12 1.07 Agreement 2.36 0.OBE-12 1.19 Agreement 2.5710.00E-12 1.30 Agreement 2.63tO.08E-12 1.33 Agreement I-133 2.7710.11E-12 3.02iO.19E-12 0.92 Agreement 3.48iO.16E-12 1.15 Agreement > 3.48iO.17E-12 1.15 Agreement-3.35to.15E-12 1.11 Agreement 3.

Li quid Floor Drain Storaae Tank Samole (500ml Marinelli Beaker) CNO37A I ISampled: 13:12, CDT, August 27, 1990) t Sample was analyzed by one radiochemistry detector and by three health physics detectors.

The results of the analyses are eported for nach detector in the above stated order.

CNS Results NRC Results CNS/NRC Compari son Nuclide (uCi/ml) (uCi/ml) Ratio Deci c i.gn Mr -54 4.10iO.19E-6 4.0510.13E-6 1.01 Agreement 3.99iO.13E-6 0.98 Agreement 3.76tO.12E-6 0.92 Agreement 3.82io.12E-6 0.94 Agreement I-131 - 3.0610.78E-7 2.80iO.51E-7 1.09 Agreement 1.7910.67E-7 0.63 Agreement 2.92io.41E-7 1.04 Agreement 3.18io.43E-7 1.14 Agreement -. . . _ ,. .- - . . - - a

.- ., 4' ATTACHMENT 5

CNS Results NRC Results CNS/NRC Comparison Nuclide (uCi/ml) (uCi/ml) Ratio Decision Cs-134 1.5310.15E-6 1.3910.12E-6 1.10 Agreement 1.60 0.09E-6 1.15 Agreement 1.6710.00E-6 1.20 Agreement 1.53iO.07E-6 1.10 Agreement Cs-137 3.72iO.16C-6 3.1510.13E-6 1.18 Agreement 3.1510.16E-6 1.00 Agreement 3.42tO.12E-6 1.02 Agreement 3.40iO.11E-6 1.00 Agreement Co-60 6.2410.23E-6 6.8710.17E-6 0.91 Agreement 6.5510.20E-6 0.95 Agreement 6.53tO.18E-6 0.95 Agreement 7.01iO.17E-6 1.02 Agreement 4.

Off Gas Sample (15cc Serum Vial) CNO42A (Sampled: 10:58, CDT, August 29, 1990) Sample was analyzed by one radiochemistry detector and by three health physics detectors.

The results of the analyses are reported j ' for each detector in the above stated order.

CNS Results NRC Results CNS/NRC Comparison Nuclide (uC1/cc) (uCi/cc) Ratio Decision Kr-85m 2.20iO.77E-5 3.1310.30E-5 0.70 Agreement No Comparison No Result (1)


No Comparison No Result'(1)


No Comparison No Result (1)


Kr-BO 1.43to.27E-4 1.1910.13E-4 1.21 Agreement No Comparison No Result (1)


No Comparison No Result (1)


No' Comparison I No Result (1)


I No Comparison

Xe-131m No Result (1)

  • 0610.76E-4

No Comparison No Result (1)


No Comparison No Result (1)


No Comparison

No Result (1)


Xe-135 0.8310.OBE-4 1.07iO.04E-4 0.77 Agreement 0.9610.06E-4 0.90 Agreement No Comparison No Result (1)


No Comparison No Result (1)


(1) Isotope had decayed to below the lower limit of detection prior to analysis.

! J

. -. - -. -.. _ ._ _- . , l ., l .. ..- l l ATTACHMENT 5

,

5.

Reactor Water Samole- (500ml Marinelli Beaker) CNO40A l (Sampled: 11:30, CnT, August 27, 1990) , ! Sample was analyzed by one radiochemistry detector and by three ' health physics detectors.

The results of the analyses are reported for each detector in the above stated order.

j CNS Results NRC Results CNS/NRC Comparison Nuclide (uCi/ml) tuC1/ml) Ratio Decision Cr-51 3.53tO.05E-3 3.1110.01E-3 1.14 ogreement 3.2110.02E-3 1.03 Agreement 3.22iO.02E-3 1.04 Agreement 3.22iO.02E-3 1.04 Agr eement Mn-54 9.8610.16E-5 9.7910.09E-5 1.01 Agreement ~ 1.0310.01E-4 1.05 Agreement' 1.0510.01E-4 1.07 Agreement 1.0410.01E-4 1.06 Agreement . Co-30 1.7510.02E-4 1.70tO.01E-4 1.03 Agreement

1.8910.02E-4 1.11 Agreement 1.00iO.02E-4 1.10 Agreement 1.8710.02E-4 1.10 Agreement Co-60 1.53tO.02E-4 1.47 0.01E-4 1.C4 Agreement 1.60iO.02E-4 1.08 Agreement 1.62iO.02E-4 1.10 Agreement 1.5610.01E-4 1.06 Agreement i Sr-91 1.5910.21E-4 1.1110.14E-4 1.44 Agreement L No Result (1) No Comparison


s ' No Result (1) No Comparison


, No Result (1) No Comparison


Mo-99 5.92il.06E-5 5.28to.46E-5 1.12 Agreement 4.9410.58E-5 0.94 Agreement 5.3110.49E-5 .1. ' 1 Agreement

5.48io.47E-5 1.04 Agreement L Ag-310m 3.9511.09E-6 6.63to.7BE-6 0.60 Agreement 7.92iO.45E-6 1.19 Agreement 6.92iO.42E-6 1.04 Agreement , l 7.40iO.43E-6 1.12 Agreement I-131 2.7110.95E-6 2.3310.35E-6 1.16 Agreement

3.42iO.45E-6 1.46 Agreement 3.78tO.34E-6 1.62 Agreement 3.47 0.33E-6 1.48 Agreement .

. - - - - -. -- .. -., -. ,- ,- , - - - - -- , .-

.- . . - --. - - _ _ -. _ ~ -. - 4...

l .- ) ATTACHMENT 5

CNS I.esults NRC Results CNS/NRC Comparison Nyclide (uC1/ml) lyC1/ml) Ratio Deci si on ( I-133 5.6110.22E-5 5.4510.17E-5 1.03 Agreement 5. 4410. 43E;-5 1.00 Agreement 4. 6610. 39f.*-S 0.86 Agreement J 5.OBiO.24E-5 0.93 Agreement i No Comparison ) Ba-140' No Result (2) 1.3910.21E-5


1.1510.14E-5 0.83 Agreement J 0.76tO.10E-5 0.54 Agreement 1.OOiO.15E-5 0.72 Agreement No Comparison La-140 No Result (2) 5.3410.86E-6


4.06io.54E-6 0.91 Agreement

5.10iO.42E-6 0.96 Agreement 5.4410.3BE-6 1.02 Agreement Na-24 1.6410.01E-3 1.5410.01E-3 1.06 Agreement 1.7110.02E-3 1.11 Agreement . 1.7110.02E-3 1.11 Agreement 1.70iO.01E-3 1.10 Agreement Zn-65 No Result (2) 9.2811.39E-6 No Compariwan


9.7111.18E-6 1.05 Agreement , 1.07tO.12E-5 1.15 Agreement 1.1610.11E-5 1.25 Agreement (1) Isotope had decayed to below the lower limit of detection prior to analysis.

(2) Isotopic activity was below thi wer limits of detection at the o time of analysis.

! ! 7.

Condensate Demineralizer Effluent Tritium Samole l (Sampled: 12:20, CDT, August 29, 1990) CNS Results NRC Results CNS/NRC Comparison Nuclide (uC1/ml) (uCi/ml) Ratio Deci si on H-3 1.1 Bio.09E-3 1.5710.09E-3 0.75 Agreement . N -.- -. - . . .. - - -. . -

F i , J > s <. s.

I . . i ' ATTACHMENT 6 f ' i CRITERI A FOR COMPARING RADI0 CHEMISTRY ANALYTICAL MEASUREPENTS I The f ollowing are the criteria used in comparing the results of ! capability tests and verification measurements.

The criteria are based on an empirical relationship established through prior experience and this program's analytical requirements.

In these criteria, the judgement limits vary in relation to the i comparison of the resolution.

NRC VALUE Resolutiyn a . f NRC UNCERTAINTY l , LICENSF: ' VALUE Ratic = NRC VALUE l , Comparisons are made by first determining the resolution and then reading across the same line to the corresponding ratio.

The - i following table shows the acceptance values.

' , RESOLUTION AGREEMENT RATIO ' , <4 0.40 - 2.50 -

4 -7 0.50 - 2.00 8-

0.60 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 l >200 0.85 - 1.18 The above criteria are applied to the following analyses: (1) Gamma Spectrometry , (2) Tritium in liquid samples - , (3) lodine on adsorbers O O (4) Sr and Sr determinations .(5) Gross Beta where samples are counted on the same date using the same reference nuclide.

. . . .. .. . .. _., . ._ _ . _ }}