IR 05000302/1986037

Insp Rept 50-302/86-37 on 861117-21.No Violations or Deviations Noted.Major Areas Inspected:Radwaste Processing, Effluent Releases & Environ Monitoring.Criteria for Comparing Measurements & Table Comparing Isotopes Encl

ML20211L216
Person / Time
Site:	Crystal River
Issue date:	12/05/1986
From:	Harris J, Kahle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211L212	List: IR 05000302/1986037 ML20211L205
References
50-302-86-37, NUDOCS 8612150359
Download: ML20211L216 (12)

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DEC 0 91986 Report No.: 50-302/86-37 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.: 50-302- License No.: DPR-72 Facility Name: Crystal' River 3 Inspection Conducted: Noveinber 17-21, 1986 Inspec or: [_

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/ W /S Date Signed Accompanying Personnel: D. M. Collins'

R. R. Marston Approved by: M3 J/e_[t.(c /2/3 f7, J., 'Kahle, Section Chief Date Signed Div ion of Radiation Safety and Safeguards SU N RY Scope: This routine, unannounced inspection was in the areas of radioactive waste processing, effluent releases, and environmental monitorin Results: No violations or deviations were identifie DR ADOCK0500g2

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REPORT DETAILS Persons Contacted Licensee Employees

• F. J. Hickle, Nuclear Plant Operations Manager

• V. R. Rappel, Manager, Technical Support

• W. L. Rossfeld, Nuclear Compliance Manager

• P. J. Skramstad, Chemistry / Radiation Superintendent

• J. E. Colby, Manager, Nuclear Mechanical / Station Engineering Services R. Clark, Radiation Protection Manager J. Roberts, Nuclear Chemistry Manager S. Chapin, Assistant to Chemistry / Radiation Protection Superintendent B. Mikell, I&C Electrical Supervisor G. Clymer, Nuclear Waste Supervisor D. McCollough, Nuclear Chemistry Supervisor R. Pinner, Nuclear Chemistry Supervisor R. Browning, Radiation Protection Supervisor P. R. Gerardin, Quality Auditor

• D. T. Wilder, Radiochemistry and Environmental Specialist

• S. Mann, Nuclear Compliance Specialist

• D. S. Green Nuclear Licensing Specialist P. Ezzell, Nuclear Compliance Specialist B. Roberts, Nuclear Waste Chief Operator Other licensee employees contacted included technicians and office personne Nuclear Regulatory Commission

• T. Stetka, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on November 21, 1986, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio .

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3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 85-05-01: Failure to Have a Whole Body Counting Procedure. The inspector reviewed the following Health Physics procedures:

HPP-320 Whole Body Counting System Operation, Rev. O, May 2, 1986 HPP-321 Whole Body Counting System Linear Energy Calibration and Quality Control Check, Rev. 2, May 13, 1986 HPP-322 Whole Body Counting System Calibration, Rev. 1, May 2, 1986 The inspector reviewed the records generated during the August 1986 efficiency calibration of the Whole Body Counting System and of the quality control checks performed during November 1986. The inspector concluded that the licensee has fully established and implemented appropriate procedures for the Whole Body Counting Syste . Organization and Management (80521)

The inspector discussed the organization and management of the Radiological Environmental Monitoring System with licensee representatives. Licensee personnel stated that the program was performed by the State of Florida Department of Health and Rehabilitation Services (DHRS) and by the University of Florida Department of Environmental Engineering Sciences under contracts with the licensee. The contracts were managed by a member of Radiological Support Services in the plant organization. This part of the licensee's organization received the data from the contractors and was responsible for issuing the Annual Radiological Environmental Operating Report and the Semiannual Radiological Effluent Report. The Florida Power Corporation (FPC) Quality Programs organization performed audits of the DHRS and University programs and of Radiological Support Services' management of the contracts. Radiological Support Services also performed a quarterly check of the environmental monitoring and sampling station No violations or deviations were identifie . Audits (80721)

Technical Specification 6.5.2.9 requires audits of facility activities to be performed under the cognizance of the Nuclear General Review Committee (NGRC) encompassing the conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months; the radiological environmental monitoring program and the results thereof at least once per 12 months; and

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the performance of activities required by the huality Assurance' Program for effluent and environmental monitoring at 'least'on_ce per 12 months. The inspectors reviewed selected portions of the following audit reports:

ETS-129, Radiological Environmental Monitoring Program, July 1986

ETS-130, Radiological Environmental Monitoring Activities, AGoust 1986 The above audits were conducted of the 'Jniversity of Florida program and the State (DHRS) program, respectively. 'The inspector discussed audit results with cognizant licensee representatives tr.d noted that the audits were conducted against Technical Specifications and contract and procedural requirement There were no adverse findings on Audit ETS-13 Three findings were identified in Audit ETS-129 which called for revision of several of the University's Standard Operating Procedure:. Licensee representatives stated that the contractors were responsive to licensee request Licensee representatives also discussed Audit QP-298 with the inspecto This audit was conducted of the Radic1cgical Site Services Environmental Monitoring Program in October 1986, but had not yet been publishe Licensee reprasentatives stated that the scope of this audit included:

procedures for surveilhnce requirements, releases, sampling, contracts, and Technical Specification comp!!anc No violations or deviations were identifie . Implementation of the Radiological Environmental Monitoring Program (80521)

Technical Specification 3.12.1.1, which includss Tables 3.12-1 and 4.12-1, specifies how the radiological environmental ranitoring program shall 'be conducte The inspector reviewed the Annual EnvironTental Operating Report and licensee and contractor procedure The report had oeen written and submitted in accordance with Technical Specification 6.9.1.5. The report and procedures indicated that the monitoring program was conducted in accordance with Technical Specifications. The inspector and a licensee representative took a tour of the area and verified that the monituring and sample stations were as described in the requirements. It was noted that the TLDs were missing frcm one location. The licensee representative notified the responsible contractor at the conclusion of the tou The Annual Environmental Operating Report (for 1985), dated April 30, 1986, Part II, provided results of the 1985 annual land use census as required by Technical Specification 3.12.1.2. The inspector reviewed a decument dated July 23, 1986, which included the results of the latest land ute census which was conducted June 18-20, lu8 Part V of the report provided information on the Interlaboratory Comparison Program in which the University of Florida and DHRS participate with EP __

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Licensee representatives stated that Emergency Teams would operate in accordance with Procedure EM-210, Duties of the Environmental Survey Team, conducting plume tracking until relieved by State team The only environmental media for which they would require access would be the TLD

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No violations or deviations were identifie . Implementation of the Meteorological Monitoring Program (80521)

Technical Specifications 3.3.3.4 and 4.3.3.4 establish the operability and surveillance requirements for the meteorological monitoring instrumentatio The inspector reviewed the following Surveillance Procedures:

1) SP-153, Primary System Meteorological Monitoring Instrumentation Calibration, Rev. 3, June 3, 1985 2) SP-157A, Meteorological System Surveillance (Daily), Rev. 3, August 16, 1985 3) SP-1578, Meteorological System Surveillance (Weekly), Rev. 3, January 27, 1986 4) SP-158, Meteorological Monitoring Instrumentation Calibration, Rev. 13, June 19, 1986 5) SP-159, Meteorological System Quarterly Availability, Rev. 4, November 6, 1985 The inspector reviewed selected records generated since the last inspection (Report 50-302/86-16) and discussed them with licensee representative The records, discussions, and an inspection of the equipment located in the instrumentation shacks at the base of the meteorological towers indicated that the program was conducted in accordance with Technical Specifications and procedure The inspector noted that there had been problems with the 33-foot temperature reading on the primary tower since November 4, 1986. Licensee representatives stated that a cause had been identified, but resources could not be assigned to repair the problem until the outage was over. It was noted that the backup tower lower temperature system was functionin No violations or deviations were identified.

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8. Procedures (80521, 84523, 84524, 84525)

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The following procedures were reviewed and discussed with cognizant licensee representatives:

Site Nuclear Services Department RSS-01, Radiological Support Services Schedule, Rev. O, July 19, 1985

RSS-02, Basis for Radiological Effluent Technical Specifications, Rev. 1, March 18, 1986 RSS-04, Implementation of Crystal River Unit 3 Radiological Environmental Monitoring Program, Rev. 3, June 27, 1985 RSS-05, Demonstration of Compliance to 40 CFR 190, Rev. 3, May 12,1986 s

RSS-03, Preparation of the Annual Radiological Environmental Operating Report, Rev. 1. April 25, 1986 RSS-09, Preparation of the Semiannual Radioactive Effluent Release Report, Rev. 2, May 12, 1986 RSS-10 Execution of LADTAP and GASPAR Computer Codes, Rev. 4, October 15, 1986 Chemistry Department:

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CH-230, Gamma Spectroscopy Utilizing the ND 6685, Rev. 3, June 18,1986 CH-232, Atmospheric Radiation Monitoring System Calibration Procedure, Rev. 13, May 15, 1986 CH-233, Liquid Radiation Monitoring System Calibration Procedure, Rev. 7, June 18, 1986 CH-234, Daily Energy Calibration and Yearly Efficiency Calibration of the Post Accident Sampling System High Priority Germanium Detectors, Rev. 3, June 10, 1986 CH-255, Determination of Iron-55 Activity in Liquid Samples, Rev. 5,

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September 15, 1986 CH-268, Liquid Radwaste Evaluation, Rev. 11, June 13, 1986 CH-269, Gaseous Radwaste Evaluation, Rev. 7, June 18, 1986 CH-280, Radiation Monitoring System Operating Parameters, Rev. 5, May 13, 1986

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CH-381, Sampling the Sewage Treatment Facility, Rev. 1 June 20, 1983 Health Physics

HPP-320 Whole Body Counting System Operation, Rev. O May 2, 1986

• - HPP-321, Whole Body Counting System Linear Energy Calibration and Quality Control Checks, Rev. O. May 13. 1986 HPP-322, Whole Body Counting System Calibration, Rev.1, May 2,1986

HPP-323, In Vitro Bioassay, Rev. O, May 2,1986 Ventilation Testing PT-128 Technical Support Center Emergency Ventilation System Testing, Rev. 3, September 18, 1986 In addition, the inspector reviewed procedures in use by the State DHRS and the University of Florida in support of the Crystal River Radiological Environmental Monitoring Program. The State procedures covered sampling, analysis, calibration, interlaboratory comparisons, intralaboratory comparisons, and quality control procedures. The University procedures included the above types in addition to a Monitoring Laboratory and Quality Assurance Manual. The manual included procedures for the monthly and annual environmental reports to be submitted to the license A licensee representative stated that contractor procedures were reviewed by the licensee prior to implementatio No violations or deviations were identifie . Records (80521)

The inspector reviewed the following records in addition to those discussed elsewhere in this report:

State and DHRS Direct Radiation TLDs for the seven DHRS site Collected February 17, May 13, and August 4, 198 First and second quarter,1986, sampling reports for:

Airborne (Iodine and particulate)

Direct (TLDs)

Groundwater Food Products

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University of Florida First and second quarter 1986, Environmental Monitoring Program progress report of activitie Licensee Second quarter 1986 Sample Station Inspection, May 2, 198 No violations or deviations were identifie . Liquid Radwaste (84523)

Technical Specification 3/4.11.1 defines the sampling and analysis program for radioactive material released to unrestricted areas in liquid effluent, and the related doses to members of the general publi The inspector made several observations of routine activities relating to the liquid radwaste processing program. Operations observed included liquid waste processing, liquid waste sample collection and sample analysis, laundry operations, and surveys of clean protective clothing. Activities observed were evaluated in regard to Radiation Work Permits, procedural adherence, health physics practices, and general safety considerations. The inspector discussed operational history of related components and instrumentation during the year. Other than the demineralizer failure that occurred in May 1986 (see NRC Inspection Report No. 50-302/86-28), all major equipment had performed wel The inspector verified by review of laboratory logs and sample sheets that the routine sampling program was performed in accordance with regulatory requirement During the inspection, the inspector noted that the licensee sampled effluent from a sewage treatment facility located at an adjacent fossil electric plant. The inspector requested that the licensee obtain samples of liquid effluent and solid byproduct generated by the facility for gamma emitting radioisotope No detectable activity was indicate The inspector discussed the possibility of concentration of radioactive material in sewage treatment facilities as demonstrated by abnormally high levels of radioactive materials from plant effluent in sewage sludge discovered at other licensed facilities. The licensee was aware of these occurrence No violations or deviations were identifie . Gaseous Radwaste (84524)

Technical Specification 3/4.11.2 establishes the regulatory limits for the dose received by a member of the general public due to radioactive material in gaseous effluents.

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The inspector observed routine operations, including operations involving the release of a waste gas decay tank. The instrumentation reviewed was in calibration, and the release was well within regulatory limit The inspector discussed the operational history of instrumentation and other systems related to gaseous releases. No major operational deficiencies were note During a tour of the protected area, the inspector noticed loose components and extensive use of duct tape on the Technical Support Center (TSC)

, Emergency Ventilation System In discussions with cognizant licensee personnel, no records of inplace leak testing of HEPA and charcoal filters or charcoal retention efficiencies were availabl The licensee had recently included this filter system in a periodic testing program after discovering.these program weaknesses during a previous drill. There are no Technical Specification requirements for this filter system, but the desired function would indicate maintenance and testing comparable to the Emergency Control Room Filter System. The TSC is located near the reactor building and is to be occupied during the course of possible accident The inspector discussed the issue at the exit meeting to ensure proper attention was given this matter in a timely manner. Licensee representatives stated that a procedure had been developed and testing would be conducted. This issue will be reviewed during future inspections (IFI 50-302/86-37-01).

No violations or deviations were identifie . Confirnetory Measurements (84725)

As part-of the NRC Confirmatory Measurements Program, spiked liquid samples were sent to the licensee in September 1986 for selected radiochemical analyse The inspector reviewed the licensee's results during the inspection. The licensee's results were in agreement for H-3, Sr-89, and Sr-90. The licensee was in disagreement for Fe-55. The inspector reviewed

! the licensee analytical procedure and interlaboratory cross check result The inspector noted no obvious weaknesses in the procedure, and the cross check results showed agreement for Fe-55 between the two laboratories'

results. The inspector informed the licensee by telephone on November 26, 1986, that the resolution of the disagreement for Fe-55 for 1985 and 1986

< cross checks will be reviewed during a future inspection (50-302/86-37-02).

Another spiked sample could be sent to the licensee to help resolve this issue.

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Comparison of licensee and NRC results are listed in Table 1 with the acceptance criteria given in Attachment No violations or deviations were identifie . Inspector Followup Items (92701)

(Closed) IFI 85-05-02, Evaluate Deadtime Effect on GeLi Counter. The inspector discussed this evaluation with cognizant licensee personnel. The licensee has adopted a procedural limit of ten percent deadtime in

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Procedure CH-230, Gamma Spectroscopy Utilizing the ND 6685, Rev. 3, 6/16/8 During the inspector's reviews of related release permits and laboratory records, no instances of exceeding the deadtime limit were note (Closed) IFI 85-05-03, Establish Recalibration and Periodic Test Program for the Post Accident Sampling System (PASS). The inspector noted that the accident range gaseous effluent monitors were included in the routine surveillance and calibration program covering process and effluent monitor The inspector also reviewed Procedure CH-402, Secondary and Primary Cycle In-Line Monitors Quality Control Scheduling Program, Rev. 7, November 12, 198 This procedure establishes a routine intralaboratory cross check program for the PASS to routine sampling points and analysis technique Analyses covered included boron, pH, dissolved hydrogen, chloride, and gamma isotopic. The results of these comparisons will be reviewed during routine inspection (Closed) 85-05-05, Review Calibration of GeLi Gas Geometries. The inspector reviewed GeLi calibrations of gas geometries that were performed in September 1985 and November 198 The licensee has revised calibration procedures to ensure detector deadtime effects on calibration are relatively small. Comparisons made during the interlaboratory cross checks for 1965 and 1986 have been favorabl (Closed) 86-28-01, Review Final Corrective Actions for Demineralizer Vessel Failure of May 1986. The inspector noted that the vessel that failed had been repaired and placed back into servic The defect corrected is considered to be of minor concern with respect to the other vendor supplied demineralizer vessel The licensee is considering supplemental modifications to further ensure loss of resin to storage tanks does not recu .

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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.

In these criteria, the judgement limits are variable in relation to the comparison of the NRC'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 decrease RATIO = LICENSEE VALUE NRC REFERENCE VALUE Resolution Agreement 44 0.4 - .5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 -200 0.80 - 1.25 7200 0.85 - 1.18

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TABLE 1 ,

CONFlRMATORY MEASUREMENT COMPARISONS OF H3, FE-55, SR-89, AND SR-90 ANALYSIS FOR CRYSTAL RIVER NUCLEAR PLANT ON SEPTEMBER 29, 1986 Liconsee NRC Ratio 1sotope fuCi/ Unit) fuCi/ Unit) Resolution iLicensee/NRC) Compa ri son 51 - 3 2.09 E-5 1.76 i .04 E-5 44 1.19 Ag reement Fe-55 1.81 E-5 1.30 i .03 E-5 43 1.39 D i sa g reement S r-89 2.57 E-5 2.21 i .07 E-5 32 1.16 Ag reemen t S r-90 1.84 E-6 2.09 i .08 E-6 26 .88 Ag reement

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