IR 05000321/1981007
| ML20010A272 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/16/1981 |
| From: | Montgomery D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20010A260 | List: |
| References | |
| 50-321-81-07, 50-321-81-7, 50-366-81-07, 50-366-81-7, NUDOCS 8108110263 | |
| Download: ML20010A272 (10) | |
Text
.
.
.
- p," "'%,fo
,
UNITED STATES
,
! ',,,y NUCLEAR REGULATORY COMMISSION i
g e
REGION il
-
.
o, Y.
- fg 101 MARIETTA ST., N.W., SUITE 3100 p
g ATLANTA, GEORGIA 30303
. *
'""
JUN 161981 Report Nos. 50-321/81-07 and 50-366/81-07
)
Licensee:
Georgia Power Company 270 Peachtree Street Atlanta, GA 30303 Facility Name:
Hatch 1 and 2 Docket Nos. 50-321 and 50-366 License Nos. DPR-57 and NPF-5 Inspection at Hatch Units 1 & 2 near Baxley, GA and Georgia Power Company Corporate office, Atlanta, GA q
Inspector:
D. Ib k//.'h5enU tu
[-/bk/
D. M.' Montgomery,/
j Date Signed Accompanying Personnel:
P. C. McPhail Approved by:
[/
8[
J. P.
to6r, EPOS Branch Chief Bate signed
Inspection on April 27-30 and May 12, 1981 Areas Inspected This routine, unannounced inspection involved 60 inspector-hours onsite in the areas of quality control and confirmatory measurements including; review of the laboratory quality control program; review of chemistry and radiochemistry procedures, review of quality control records and logs, comparison of the results of split samples analyzed by the licensee and the NRC RII Mobile Laboratory, and collection of ground water samples for tritium analyses.
Results
'
Of the five areas inspected, no violations or deviations were identified in three areas; two violations were found in two areas (failure to fully implement the quality control program for chemical analyses, paragraph 7b; failure to implement
a quality control program for flow meters and pressure guage associated with
'
reactor building and plant vent gaseous sampling systems, paragraph '76).
.
8108110263 810730 PDRADOCK05000g G
.
. -. -
- -,
. _ _ _
.
- -.. _ -
.
.
.., - - - -.. - - -
.-
.'
.
.
.
.
REPORT DETAILS 1.
Persons Contacted Licensee Employees M. Manry, Plant Manager
- T. Greene, Assistant Plant Manager
- W. H. Rogers, Health Physics Superintendent
"R. C. Hand, Laboratory Supervisor
- W. C. Parker, Laboratory Foreman
- D. Smith, Health Physics Supervisor
- P. E. Fornel, Jr., Senior Quality Assurance Field Representative D. R. Savage, Supervisor Nuclear Procurement Standards NRC Resident Inspector
"R. Rogers
,
" Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on April 30,.1981 with those persons indicat ed in paragraph 1 above. A licensee representative agreed to perform the analyses referred to in paragraphs 8 and 9 and submit the results to NRC:RII.
The inspector stated that a dedicated area' with appropriate power receptacles was needed to accomodate the NRC mobile laboratory.
A licensee representative agreed to provide the necessary facilities and contact RII as to the projected date L of availability.
(321/81-07-08,366/81-07-08)
'
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Laboratory Quality Control Program The inspector reviewed the licensee's quality control program for chemical and radiochemical measurements in the following areas:
'
'
.
.
.
.
.
.
a.
Assignment of Responsibility to Manage 'and Conduct the QC Program The Quality Assurance programs for chemistry and radiochemistry are described in procedures HNP-7650, " Quality Assurance Program _ for Environmental Tech Specs, and HNP-7651, " Analytical Control' for Chemical Analysis.
The Health Physics Superintendent has the overall responsibility for th Quality Assurance program.
Responsibility for day to day operations in chemistry and radiochemistry has been dele-gated to the Laboratory Supervisor.
b.
Provisions for Audits / Inspections Procedure QA-05-06 provides for annual audits of Plant Chemistry and the Environmental Technical Specifications. The QA Site Supervisor is responsible for developing and implementing the audit program.
c.
Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Corrected.
Provisions have been made for the. documentation of factors affecting the quality of laboratory results and for review and/or followup by supervision. In addition data and results are required to be. reviewed by a laboratory foreman or supervisor with subsequent investigation or correction of recognized deficiencies. Any nonconformance or program deficiency identified in audits is documented in an Audit Finding Report along with corrective action necessary to_close out the item.
Open items are reaudited for compliance whenever a final corrective action statement is received from the audited organization.
d.
Requirements for Purchased or Contracted Services Radiochemical analyses of liquid effluents for tritium and radio-strontium and analyses of gaseous effluents for radiostrontium are performed by contract at the Center for Applied Isotope Studies, University of Georgia. Contractors performing laboratory services are audited by Nuclear Procurement Standards Department to verify that the j
contractors' quality assurance programs are adequate to ensure quality services.
The requirements for auditing. of contracted services is given in Section 7 of the Georgia Power Quality Assurance Manual.
6.
Review of Chemistry and Radiochemistry Procedures a.
The inspector reviewed the following procedures:
l (1) HNP-7650 " Quality Assurance Program, for Environmental' Tech Specs,
'
- Rev. O.
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
__.
-
,.
.
.
.
.
(2) HNP-7651, " Analytical Quality Control for Chemical Analysis,"
2-26-81.
(3) HNP-7209, "Beckman Wide Beta II, Planchet Counter, Rev. 4, 3-25-81.
(4) HNP-7210, " Internal Gas Flow Proportional Counter (NMC), Rev. 2, 1-17-78.
(5) HNP-7215, " Gamma Spectrometer System Ge(L1), Rev. 2, 9-20-79 (6) HNP-7137, " Preparation of Samples for Counting," Rev. 3, 9-18-79.
-
(7) HNP-7136, " Radioactive Standards Preparation," Rev. 3, 9-18-79.
(8) HNP-7140, " Laboratory Instrument Calibrations," Rev. 5, 11-4-80.
(9) HNP-7116, " Gaseous Waste Sample Analysis," Rev. 6, 6-13-79.
(10) HNP-7601, " Liquid Radwaste Analysis and Discharge Program, Rev. 7, 8-18-79.
(11) HNP-7130, " Gaseous Release of Tritium," Rev. 3, 6-25-80.
(12) HNP-7600, " Gaseous Waste Discharge Program," Rev. 4, 4-14-81.
(13) HNP-7652, " Quality Control Chemistry Sample Program," Rev. O, 9-17-79.
The procedure review was discussed with licensee representatives as dis-cussed in paragraphs 6b-e.
b.
The inspector noted that the procedure HNP-7215 for operation of the GeLi counting system specifies that A.P.T. solid standards are to be used for efficiency calibrations and that solid sources are not valid for gas samples without attenuation corrections.
A licensee repre-sentative stated that attenuation corrections are made to correct for the difference in densities and that this is part of the computer.
program supplied by A.P.T.
The inspector noted that documentation describing the techniques should be available for verification as to the validity of the correction factors. The inspector also noted that NBS traceable gas standards are available and can be used for direct calibration or verification of previous calibrations and attenuation factors. A licensee representative stated that' documentation regarding attenuation factors would be obtained from the contractor and sent to i
,..
..
..
.
.
.
.
_ - - _____ - - _ __ _ - ---_ __-__-__ A
.
..
.
.
.
.
.
NRC:RII. The licensee also agreed to review the methodology for gas calibrations and supply information as to how and when gas standard:
will be utilized in the Ge(L1) calibration program.
(321/81-07-01, 366/81-07-01)
c.
The inspector noted that procedure HNP-7402 for collection of gas samples utilizes a pressurize,d sampie container but does not provide instructions for operation of the compressor. Licensee representatives agreed to revise the procedure and provide more detailed instructions for collecting pressurized gas samples. (321/81-07-02,366/81-07-02)
d.
The inspector noted that HNP-7650 specifies that Teledyne Isotopes and Eberline Instrument Corporation are the two contract laboratories used for analysis. A licensee representative stated that the Center for Applied Isotope Studies, University of Georgia was now performing tritium and radiostrontium analyses on effluent samples. The procedure further states that the contractor laboratories are subject to audit by the Corporate Quality Assurance Department.
On May 12, 1981 the inspector met with D. R. Savage of the Nuclear Procurement Department, Georgia Power Corporate Office, and reviewed the audit of the Center for Applied Isotope Studies.
The inspector noted that an audit was performed on November 1, 1979.
The inspector stated that HNP-7650 should be revised to specify all laboratories currently performing analyses and that another audit of the Center for Applied Isotope Studies would be appropriate in view of the additional analyses being performed.
e.
The inspector noted that a new type of charcoal cartridge was being used for collection of radiciodine.
The new cartridge is TEDA-Impregnated and should be more efficient than the type previously used.
A licensee representative stated that the same collection efficiency as for the other cartridge type was being used. The inspector stated that an appropriate collection efficiency for the new type of cartridge should be established and verified under actual operating conditions.
In addition, the Ge(Li) system should be recalibrated for counting charcoal cartridges since the physical configuration is slightly di f f ere'.t.
Licensee representatives agreed to recalibrate as soon as the :gy.opriate standards can be obtained and to re-evaluate the charcoa' cartridge collection efficiency and revise the correction factor as necessary. (321/81-07-03, 366/81-07-03)
7.
Review of Records and Logs a.
The inspector reviewed the following records and logs:
(1)
1980 Ge(Li) Calibration Records for the following geometries:
(a)
15/8" Filter (b)
5/8" Filter i
..
.
.
.
.
.
(c) Cesco Cartridge (d) 50 cc Bottle (e) Ag Zeolite Cartridge (f) Gas Lecture Spere (g)' MSA Charcoal Cartridge (h)
14 ml Off Gas Vial (i)
100 cc Bottle
,
(j) 500 cc Bottle (k) 2 ml Glass Vial (1) 33 cc Gas Sampler (m)
1-Liter Bel Art Bottle (n) Mixed Gas Standard (2) Daily Quality Control Checks for Ge(Li) Counters June 1930 - March 1981.
(3) Daily Quality Control Checks for Gas Flow Proportional Counters June 1980 - March 1931.
(4) Quality Control Records for, Chemistry 7-31-80 to 3-22-81:
Chlorides, Boron, pH Meter, Mettler Balance, Spectrophotometer.
"
The record review was discussed with licensee representatives as discussed in paragraphs 76-7c.
b.
The inspector noted that the precision control checks for chloride analyses had not been recorded on control charts during the period of 5-21-80 to 1-1-81 as required by Procedure HNP-7651. In addition the quality control data for silica analyses had not been recorded on control charts during the period of 11/19/80 to 3-22-81. The inspector informed licensee representatives that failure to follow Procedure HNP-7651 was a violation of Technical Specification 6.8.1 that states:
" written procedures shall be established, implemented and maintained *
!
covering the applicable procedures in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978."
Regulatory Guide 1.33 includes chemistry and radiochemical control procedures.
TSe inspector
'
expressed his concern that failure to record quality control. data as
,
required may indicate inadequate supervision or review in the chemistry area. (321/81-07-04, 366/81-07-04)
c.
The inspector noted during the review of records that there were no calibration records for the air flow meters associated with the plant vent or reactor building vent sampling systems for particulate radio-activity and radiciodines and the pressure gauge used for measuring the pressure of gas samples. Licensee representatives indicated that the flow meter associated with the plant vent sampling system had not been calibrated or checked since its installation in 1974, and the pressure gauge had not been calibrated since procurement in November,1975.
s
--
- -. -
.--
-
.
- _ -
.
-
,.
,
,
.
.
.
.
~
The inspector stated that the accuracy of gaseous effluent measurements are directly related to the accuracy of the flow meters and the pressure measurement, and therefore, should be part of the calibration program.
The inspector informed licensee representative that failure to imple-ment a calibration program for the flow meters associated with the plant and reactor building vent gaseous effluent sampling systems and the pressure gauge for gaseous sampling was a violation of Environ-
,
mental Technical Specification 5.6 which requires that detailed written procedures shall be prepared for all activities involvec in imple-menting the Environmental Technical Specifications including instrument calibration.
The inspector stated that corrective action should include an evaluation of the accuracy of the flow and pressure
,
measuring devices in their present state and this effect on the accuracy of gaseous effluent monitoring in the past. (321/81-07-05, 366/81-07-05)
8.
Collection of Groundwater Samples for Tritium Analyses An inspector accompanied licensee representatives and collected fourteen groundwater samples from wells that have been established for monitoring the
potential for tritium contamination of groundwater. These wells included; T2, T3, T4, T8, T12, T13, T16, T18, PISA, P17A, P178 and N7A. Samples were split with licensee representatives for the purpose of verifying licensee measurements and an independent measurement of the current tritium levels in some of the sampling wells.
The water samples were analyzed in the RII Laboratory and will be compared to licensee results when the latter have
,
been submitted to NRC:RII.
Preliminary results show that there have not been any significant increases in tritium for those wells sampled by the NRC in March 1980 and April, 1981.
Tritium concentrations in some wells have
.
decreased significantly fre-the values observed in March, 1980.
These
,
results generally confirm I evious observations that the potential for
~
exposure of the general public from releases to unrestricted areas is negligible.
This item will be carried as an inspector followup item and reviewed during a subsequent inspection. (321/81-07-06, 366/81-07-06)
9.
Confirmatory Measurements Liquid and gaseous samples were collected by the licensee and the NRC RII Mobile Laboratory to verify the licensee's capability to measure radio-nuclides in effluent and reactor coolant samples. Samples were analyzed by gamma ray spectroscopy and included: a licuid waste surge tank sample, off gas pretreatment sample, reactor coolant sample, charcoal cartridge from plant vent, and particulice filter from plant vent.
A spiked particulate filter and charcoal cartridge were counted by the licensee since the activities associated with plant vent particulate filter ard charcoal cartridge were to low for comparison. An aliquot of a waste holdup tank
,
_--_
__.
.
.
.
.
.
.
sample was sent to the NRC contract laboratory for tritium and radio-strontium analyses.
The results will be compared to licensee results and carried as an inspector followup item pending review during a subsequent inspection. (321/81-07-07, 366/81-07-07)
The comparisons of licensee and NRC results are presented in Table I with acceptance criteria in Attachment 1.
The results show agreement for all samples except the Off 'as Sample where the results for Kr-85m and Xe-135 were in possible agreemant. The other radionuclides detected in the off gas sample were in agreement, but, che licensee gas values appeared to be systematically higher than the NRC values. This would tond to overestimate the concentration of noble gases released to the environment and therefore
<
would not result in exceeding the applicable limits for gaseous releases.
I This may be related to the method of calibration as discussed in paragraph l
6b and is being carried as an inspector followup item.
l l
l
.
/
.
.
C I Allt [ 1 ftfSol.lS Of CONFIRMA10HY MLASulttMIfdlS Al HAICil. APRIL 19ti l
,
CONCENTRAT10N. M1 Cit 0CHH Ii S/CC
.
SAMPtf I SOIOPF HATClj NRC HAICHLfptC RFSotofIGN rnitPAHlSON
_
WSI #2 Liquid Mn-58s 2. 6 t 0. 84 E-7 2.510.5 E-/
1. 014
Agreement Cr-Si NO 7.612.7 E-1
-
-
HC Co-58 5.9t.3 E-7 6.7t.8 E-7
.88 8.3 Agreement Aiecement Co-60 1.201.05 E-6 1.21.1 E -fi 1.0
l In-65 2.91.1 E-6 2.8t.2 E-6 1.04 lis Agreerant N ti-95 1.8t.2 E-7 1.71.5 E-1 1.06 3.4 Ag r ee.nes,t Os-131 Not Detected 1.51.3 E-7
-
14C Spiked Pa rt icu l a te Co-51 8.0t0.5 E-4 6.31.2 E-4 1.27
Aqueement 1.861.08: E-3 1.40 t.05 E-3 1. 08:
A9:eement filter Cs-134
Cs-137 4.581.06 E-3 4.061.12 E-3 1.13
Agreement.
2.48.t.06 E-3 2.131.06 E-3 1.15
Agreement Co-60
Iteactor Coolant Ha-24 1.76t.01 E-2 1.681.01 E-2 1.05 168 A9:eement 4-30-81 0 7: 15 Cr-51 1. 60 t. Ola E-3 1.2+0.3 E-3 1.33 1s. 8 Ag reement Cn-58 2.210.3 E-4 1.210.2 E-4 1.83 6.0 A9seement Co-6fs 2.38t.07 E-1 2.111.08 E-1 1.10
Agreement 2n-65 7.810.7 E-4 7. fa l. 8 E-8s 1.05 9.3 Aqseement 2n-69m 8. u t o. fs E-4 7.It0.3
[-is 1. 0f:
Agreemetit 1-132 7.410.5 E-4 5.91.5 E-88 1.25 11.8 Ag reemen t 1 - 1 38s 1.?!O.2 E-3 1.110.2 E-3 1.09 5.5 Ayseement 1-135 5.710.1 E-4 ND
-
-
HC 1-133 3.210.2 E-4 2.210.3 E-la 1. fa 5 7.3 A9 ccment alr-Cas Unit #2 A r-la l 1.591.07 *-3
.98t.16 L-3 1.62
Agscement 4-30-81 Kr-85 3.51.7 i-8s 2.351.08 E-ta 1. 8s 8
l'ossible Agreement O 11:18 K r-81 2.051.09 E-3 1.581.04 E-3 1.29 iso Agreement K-88 8.6!0.4 E-4 8.7t.4 E-4
.98.
Agreement 6.8+1.5 E-5 4.01.8 E-5 1.59
Agseement Xc-133
j Xo-l35m No 5.0 t 84 E-3 NC lis NC Xo-135 1.201.02 F-3 8.21.1 E-4 1.45
!!2 Possible Agreement j
l Sp i ked Cha rcoa l lla-13 3 3. 381.02 E-84 3.fs21.09 E-la
.98
Agreement Ca r t r i dge i
NC - No Comparison. ND - Not Detected i
!
!
I f
!
\\
___
.
,
.
..
.
.
.
.
Attachment 1 CRITERIA FOR COMPARING ANALYTICAL 11EASUREMENTS 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 tha accuracy needs of this program.
In these criteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory'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 acceptab'.e as the resolution decreases.
LICENSEE VALUE ATIO = 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 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:
Gamma Spectrometry where principallgamma energy used for identification is greater than 250 Kev.
Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification is less than 250 Kev.
89Sr and '0Sr Determinations.
[
Cross Beta where samples are counted on the same date using the same
,
l reference nuclide.
l
[
$