IR 05000321/1989032

Insp Repts 50-321/89-32,50-366/89-32,50-424/89-34 & 50-425/89-39 on 891115-17.No Violations or Deviations Noted. Major Areas Inspected:Environ Monitoring & QA for Corporate Environ Lab

ML20011D373
Person / Time
Site:	05000000, Hatch, Vogtle
Issue date:	12/04/1989
From:	Adamovitz S, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20011D371	List: IR 05000321/1989032
References
50-321-89-32, 50-366-89-32, 50-424-89-34, 50-425-89-39, NUDOCS 8912270075
Download: ML20011D373 (12)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET,N.W.

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DEC i1 ;ggg i

Report Nos.: 50-321/89-32, 50-366/89-32, 50-424/89-34, and 50-425/89-39 j

l-Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 Docket Hos.: 50-321, 50-366,~50-424 License Nos.:

DPR-57 NPF-5, NPF-68 s

and 50-425 and CPPR-109 i

Facility Name:- Hatch and Vogtle Inspection Conducted: November 15-17, 1989

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Inspector:

Idr14-

/J2-N7 5. 5. Adamovitz Date Signed fpt.

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Approved by: MMI 4h

/# '/ E 9 g,y T. R. Decker, Chief Date Sioned Radiological Effluents and Chemistry Section

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Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

I-This routine, announced inspection was conducted in the areas of environmental i

monitoring and quality assurance (QA) for the corporate environmental laboratory.

Results:

l In the areas. inspected, violations or deviations were not identified.

The Georgia Power Company (GPC), Power Supply Laboratories demonstrated the ability to accurately measure radioisotopes in the environment.

Laboratory staffing, procedures and count room quality assurance were adequate (Paragraph 3, 4, and 6)' to perform the technical specification (TS) required environmental

monitoring.

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89122700758bOOOb21 121 PDR ADOCK O Q

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REPORT DETAILS 1.

Persons Contacted

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Licensee Employees J. Adams, Senior Laboratory Analyst

• P. Bell, Senior Laboratory Analyst T. Broadwell, Senior Environnental Analyst

• T. Collins, Senior Health Physicist S. Ewald, Manager, Environmental Services. Southern Company Services B. Maulsby, Manager Power Supply Laboratories

• M. Nichols. Health Physics and Chemistry Operations Supervisor W. 0111nger, Senior Nuclear Specialist, Southern Company Services

• Attended exit interview 2.

Audits (84750)

The inspector reviewed portions of the following audits:

a.

Southern Company Services Audit Report of GPC Environmental Affairs Department, conducted May 22-26, 1989.

b.

EAQA 88-01, Power Supply Laboratories, Dosimetry and Ensironmental Radiochemistry Section. Chemistry Section Quality Assurance Internal

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Audit conducted November 14-28, 1988.

c.

American Association for Laboratory Accreditation, conducted March 1989 for the Chemistry Laboratory, Radiochemistry Laboratory and the Fuel Laboratory.

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The audits were examined for review of environmental monitoring and radiochemistry laboratory activities.

Any identified findings or improvement items were adequately reviewed and acted upon in a timely manner.

No violations-or deviations were identified.

3.

Procedures (84750)

a.

The inspector reviewed selected portions of the following procedures related to environmental monitoring, radiochemical analyses, and count room activities:

(1) PSL-12450.600 Procurement, Receiving, Inventory and Disposal of Radioactive Material, Revision (Rev.) 2, December 18, 1987.

(2) PSL-12450.602, Training Documentation, Rev. 1, June 17, 1987.

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ATTACHMENT 2 CRITERIA FOR COMPARISONS OF ANALYTICAL MEASUREMENTS

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This attachment provides criteria for the comparison of results of analytical radioactivity measurements.

These criteria are based on empirical relationships which combine prior experience in comparing radioactivity analyses, the measurement of the statistically random process of radioactive emission, and the accuracy needs of this program.

In these criteria, the " Comparison Ratio Limits"2 denoting agreement or disagreement between licensee and NRC results are variable.

This variability is a function of the ratio of the NRC's analytical value relative to its associated statistical and analytical uncertainty, referred to in this program as " Resolution"2, For comparison purposes, a ratio between the licensee's analytical value and the NRC's analytical value is computed for each radionuclide present in a given sample.

The computed ratios are then evaluated for agreement or disagreement based-on " Resolution."

The corresponding values for " Resolution" and the

" Comparison Ratio Limits" are listed in the Table below.

Ratio values which are either above or below the " Comparison Ratio Limits" are considered to be in disagreement, while ratio values within.or encompassed by the " Comparison Ratio Limits" are considered to be in agreement.

TABLE NRC Confirmatory Measurements Acceptance Criteria

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Resolution vs. Comparison Ratio Limits Comparison Ratio Limits Resolution for Agreement

<4 0.4 - 2.5 4-7 0.5 - 2.0 8 - 15 0.6 - 1.66

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16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25

>200 0.85 - 1.18 1 Comparison Ratio = Licensee Value NRC Reference Value 2 Resolution = NRC Reference Value Associated Uncertainty l~

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(3) PSL-12450.604, Radiation Monitoring Surveys, Rev. 1,

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. September 21, 1987.

(4) PSL-12450.606. Dosimetry and Environmental Radiochemistry Training and Qualifications, Rev. 2 April 7,1988.

(5) PSL-12450.608, Reporting of. Results for Environmental Samples Analyzed for Radioactivity, Rev. 1, October 6, 1986.

(6) PSL-12450.609 Record Transmittal and Storage,. Rev. 2.

September 28, 1987.

(7) PSL-12450.611. -EPA Environmental Radioactivity. Laboratory Intercomparison (Cross Check) Program, Rev. 1 June 3, 1987.

(8) PSL-12450.612, Envircomental Radiochemistry Section Quality

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Control, Rev. 1. March 16, 1987.

(9) PSL-12450.613 Receipt and Logging of Environmental Samples, Rev. 1, May 25, 1987.

(10) PSL-12450.620, Gross Beta Activity in Filters (in the absence of Alpha Activity), Rev. 2 May 3, 1989.

(11) PSL-12450.621, Gross Alpha and Gross Beta Activity in Filters.

Rev. 2, May 1, 1989.

(12) PSL-12450.622, Gross Beta Analysis of Water Samples (in the

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absence of Alpha Activity) Rev. 2, May 3, 1989.

(13) PSL-12450.623, Gross Alpha and Gross Beta Analysis of Water Samples, Rev. 2, May 3, 1989.

.(14) PSL-12450.625, Gamma-ray Spectroscopy of Environmental Samples, Rev. 1. February 23, 1987.

(15) PSL-12450.628, Determination of I-131 in Water, Rev. 1, October 6, 1986.

(16) PSL-12450.631, Determination of Tritium in Water Samples, Rev. 3 May 22, 1989.

(17) PSL-12450.638, Determination of Activity for Fossil Plant Radioactive Source Leak Tests, Rev. 2 May 31, 1989.

(18) PSL-12450.700, Calibration and Operation of Low Background Alpha / Beta Gas Flow Proportional Counter, Rev. 2, April 22, 1988.

(19) PSL-12450.701, Calibration and Operation of Liquid Scintillation Counter, Rev. 2, November 9, 1987.

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-(20) PSL-12450,703, Calibration and Operation of Intrinsic Germanium Spectroscopy System Rev. 1. May 27, 1987.

(21). PSL-'12450.705, Preparation of Calibration Standards, Rev.1 December 1,-1986.

(22) PSL-12450.706,- Calibration of Mettler AE160 Analytical Balance

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and Sartorious 1700- Analytical Balance, Rev. 3. September 28, 1987.

(23) PSL-12450.1000, Power Supply Laboratories Internal Audit,

Rev. 4, December 4, 1987.

(24) PSL-12450.1001, Procedures Preparation and Manual Control.

Rev. 3. april 13, 1986.

'(25) PSL-12 E.1003, Power Supply Laboratories Organization, Rev. O.

July 3, 1986.

(26) PSL-12450.1051, Disposal _of Laboratory Waste, Rev.1, April 26, t

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(27) PSL-12450.1053, Quality Procedure for the Central Laboratory, Rev. 1 March 17, 1987.

(28) PSL-12450.850, Vogtle Radiological Monitoring - Airborne Dust and Gaseous Iodine, Rev. 5 April 4, 1989.

(29) PSL-12450.856, Vogtle Radiological Monitoring-Sediment, Rev. 4, April 4, 189.

(30) PSL-12450.858 Vogt1c Radiological-Monitoring - Grass, Rev. 4 April 4', 1989.

(31) PSL-12450.859, Vogtle Radiological Monitoring - River Water, Rev. 4 April 4, 1989.

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(32) PSL-12450.860 Vogtle Radiological Monitoring - Milk, Rev. 6, April 4,1989.

(33) PSL-12450.930 Hatch Environmental Radiological Data Handling, Rev. 6, April 4, 1989.

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_(34) PSL-12450.932. Hatch Collection of Sediment Samples for Radiological Analyses, Rev. 7 April 4,1989.

(35) PSL-12450.935 Hatch Land Use Survey, Rev. 5, April 4, 1989.

(36) PSL-12450.936 Hatch Radiological Monitoring - Milk Sampling, Rev. 2, April 4, 1989, s.

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~(37) PSL-12450.937 Hatch Radiological Monitoring - River Water s

Survey, Rev. 4. April 4,1989.

(38) PSL-12450.940, Hatch Radiological Monitoring, Thermoluminescent Dosimeters (TLDs), Rev. 3. April 4, 1989.

b.

The inspector discussed various procedures with environmental

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laboratory personnel and noted the following:

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(1) In reviewing the procedures for laboratory quality control and instrument operation, the inspector noted that the frequency to generate control limits for instrument performance checks was not specified. The laboratory calculated the two or three sigma control limits for the performance checks and currently checked t

and possibly generated new control limits after instrument maintenance, down time, or any changes in equipment conditions.

Control limits were not changed as long as the instrument performrace was stable and tracked within the previously defined limits.

The inspector considered these practices to be acceptable and the licensee agreed to incorporate steps in laboratory procedures specifying the frequency for generation of control limits.

(2) The procedure, PSL-12450.703

" Calibration and Operation of Intrinsic Germanium Spectroscopy System," Rev. 1 May 27, 1987, requires the comparison of current efficiencies to previously determined efficiencies but did not specify acceptance criteria - for the comparison.

The inspector and

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licensee discussed the need to include instructions for the acceptance. comparison of new to old efficiencies in order to identify any significant changes in the efficiency curves.

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(3) While reviewing analytical records, the inspector noted that the potassium iodate carrier used in the iodine-131 determinations in water had been standardized September 11, 1986.

This solution was still being used for current analyses, and the licensee did not have a procedural requirement for the frequency of carrier standardizations. The inspector examined the carrier solution and noted that the solution had been stored properly in a brown glass bottle.

Discussions with the licensee indicated that laboratory personnel had not identified a decrease in the percent recovery for the iodine analyses indicating carrier stability; however, the licensee agreed that the carrier solution should be standardized on a more frequent basis and that this frequency should be defined in a procedure.

These procedural items will be tracked as an IFI and will be reviewed during a future inspection.

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F IFI 50-424/89-34-01; 50-425/89-39-01; 50-321/89-32-01, and i

50-366/89-32-01:

Modify procedures to specify the frequency of carrier standardization; to specify the frequency for generation of control limits; and to specify the acceptance criteria for efficiency determinations.

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No violations or deviations were identified.

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Records (84750)

a.

The inspector reviewed selected portions of. the following records:

-(1) Tennelec Beta / Gamma Coincidence Counter a)

Quality Control Notebook October-November 1989, daily source checks, daily / weekly background checks b)

Instrument Log August 1988'- November 1989 (2) Tennelec Alpha / Beta LB5100 System m

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Quality Control Notebook 1989, daily source checks, daily background checks, particulate filter backgrounds and efficiences, alpha-in-beta crosstalk, plateau determinations, self-absorption curves.

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Instrument Log June-November 1989 (3) Beckman Liquid Scintillation Counter a)

Quality-Control Notebook 1989, daily source checksi daily background checks, quenched background and standard counts.

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Instrument Log 1989-(4)

Intrinsic Germanium Gamma Spectroscopy Systems (SN No. 24-P-805B and SN No.'24-P-1365A)

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Quality Control Notebook 1989, daily calibration checks, weekly energy calibration checks, lower limit of detection verification for the sludge geometry.

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Instrument Log 1989 c)

Calibration Notebook for the following efficiency determinations:

Detector 0 (SN No. 24-P-805B)

Point source at 10 cm July 1989

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Charcoal cartridge, face loaded May 1989 One liter liquid Marinelli May 1989 0.5 liter liquid Marinelli May 1989 Detector 1(SNNo.24-P-1365A)

Point source of 10 cm April 1989 Air particulate filter October 1988 Charcoal cartridae, face loaded May 1989 One liter liquid Marinelli April 1989 0.5 liter liquid Marinelli April 1989 (5) EPA Crosscheck Results 1987-1989 for the following sample types:

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Particulate filter - alpha, beta, Sr-90, Cs-137 b)

Milk - Cs-137, Sr-89, Sr-90. K-40

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c) ' Water - alpha, beta, mixed gamma H-3, 1-131, Sr-89 Sr-90

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1989 (blanks, duplicates, and spikes) y Control Samples - 1988, Intralaboratory Crosschecks and Qualit

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(7) Sample Receipt Log 1989 (8) Training Outlines for Procedural. Training - 1989 (9)

Individual Training Outlines 1989 for a Health Physicist and a Senior Laboratory Analyst (10) Current Isotopic Calibration Certificates (11) Gamma Spectroscopy Printouts for Environmental Samples 1989.

j A total of 20 printouts reviewed i

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(12) Self-Absorption Worksheet for I-131 in Water August 10, 1989.

b.

The licensee used instrument logs to record power outages and

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instrument problems.

Instrument Quality Control notebooks were well.

organized and kept near the associated instrumentation.

The. laboratory did not have a requirement for annual efficiency calibrations of the intrinsic germanium systems but performed calibration checks using the EPA crosscheck data.

Milk, air particulate, and food spikes were analyzed on a quarterly basis.

Water spikes were analyzed bimonthly.

In reviewing the intralaboratory crosscheck data, (blanks, spikes, replicates) the inspector noted that the analyses were not distributed evenly throughout the 1989 year.

The licensee agreed that the crosschecks should be analyzed on a routine frequency.

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No violations or deviations were identified.

5.

Staffing and Laboratory Facilities (84750)

The inspector toured the Environmental Section which conducted environmental monitoring and ' sample collection, and the Power Supply Laboratories which included the Environmental Radiation Laboratory.

During 1989, the Power Supply Laboratories, located in Smyrna, Georgia, had undergone renovation and expansion nearly doublino the amount of available space.

The new expansion allowed a wet chemistry laboratory solely for radiochemical analyses, a separate count room for radiation instrumentation, and a significantly laroer storage area for retention of processed samples.

Additionally, the Environmental Section (formerly the Environmental Affairs Center) was moved from Decatur, Georgia to the Smyrna facility so that environmental monitoring and radiochemical analyses were consolidated into one location, j

The Environmental Section was staffed by a total of three people and was l

responsible for environmental sample collection, some sample preparation, i

environmental TLD exchange, and field equipment calibration - and

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maintenance for the Hatch and Vogtle Nuclear Power Plants.

The three individuals' experience in various types of environmental monitoring (radiological, chemical, biological) totalled 42 years.

l The Power Supply Laboratories included the Environmental Radiation Laboratory, a non-radiological chemistry laboratory and a dosimetry

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section for analysis of Hatch and Vogtle in-plant TLDs. The Environmental Radiation Laboratory was staffed by three analysts and one supervisor.

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L Routine assignments designated one individual for radiochemical analysis

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and two. individuals for count room operation'.

All four individuals including the supervisor, were qualified in both areas of wet chemistry q

and' instrumentation.

However, since the supervisor was recently assigned

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additional responsibilities for the nonradiological chemistry laboratory, the supervisor had little time to devote to actual analyses or equipment

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Current staffing appeared adequate to handle the sample load with no apparent sample backloo or excessive personnel overtime.

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Experience in environmental monitoring and chemical analyses totalled 47 years for the four individuals.

The counting room of the Ei.vironmental Radiation Laboratory was equipped

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with the following instrumentation:

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Tennelec LB5100 Low Background Alpha / Beta Proportional Counter b.

Tennelec Beta / Gamma Coincidence Counter c.

Beckman LS7800 Liquid Scintillation Counter

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Two Intrinsic Germanium Ortec Detectors

1. 0 SN-24-P-805B L

1. 1 SN-24-P-1365A The licensee used Ortec software for the gamma spectroscopy systems and planned to update this software in 1990.

The Power Supply ' Leboratory was planning to implement a-program for analysis of Hatch and Vogtle environmental TLDs.

The environmental TLDs were currently placed in the field by the Georgia Power Environmental i

Section but were read by a vendor. The Power Laboratories hait acquired a

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co-op student from the Georgia Institute of Technology to implement this l

program and planned to issue duplicate TLDs for one year in order to

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compare their readings to the vendor's.

The program was due to be implemented during 1990.

No violations or deviations were identified.

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Laboratory Quality Control Program (84750)

The inspector reviewed selected portions of the Environmental Radiation

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Laboratory's QA program and determined that the program management-and i

organizational structure had not changed since the previous inspection

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(50-424/86-119).

The inspector determined that the licensee's QA program was adequate to ensure the accuracy of radiological environmental

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measurements.

No violations or deviations were identified.

7.

Environmental Report for Plant Vogtle (84750)

i The inspector reviewed the licensee's 1988 Annual Radiological Environmental Surveillance Report for Plant Vogtle Unit 1.

The 1988 data was routinely compared to 1987 and preoperational data in order to i

establish trends. The licensee identified tritium in downstream river and drinking water. samples but noted that the values were similar to calendar

year 1987 and preoperational data.

Additionally. low levels of Mn-54, i

Co-58, and Co-60 were identified in sediment samples collected downstream from the plant. -

The licensee calculated a whole body dose of 0.0036 mrem / year (0.12 percent of the TS limit) based upon direct radiation from these isotopes.

In reviewing the EPA crosscheck results, the inspector noted that the licensee was using the NRC " Criteria for Comparing Analytical Measurements" to determine agreement with known values.

The sigma calculation in the NRC acceptance criteria was based upon counting errors only and did not take into account sample collection and analyses errors.

The EPA crosscheck program calculated a one sigma uncertainty which included not only counting, but sample collection and analytical uncertainties.

Using the EPA's one sigma value to calculate a range of agreement by the NRC acceptance criteria allowed a wider range of

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Typically, environmental laboratories used the EPA's-two sigma uncertainty as a warning'11mit and three sigma as an "out of control"- limit requiring investigations ~ into the cause of the disagreement.

The inspector determined that laboratory personnel were already using the EPA three sigma range to determine acceptable analytical

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results.

Corporate personnel had applied the NRC acceptance criteria and attached it to the environmental reports.

Laboratory and corporate personnel agreed to use the EPA's three sigma controls limits and to delete the~ NRC acceptance criteria from future radiological environmental monitoring reports.

No violations or deviations were identified.

8.

Confirmatory Measurements (84750)

The licensee was provided with a simulated liquid waste sample by the NRC contract laboratory in January 1989 and was requested to complete radiochemical analyses for H-3.- Fe-55, Sr-89, and Sr-90 concentrations.-

Comparison of licensee and NRC results are listed in Attachment I with the acceptance criteria listed in Attachment 2.

Results were in agreement for H-3, SR-89, Sr-90, and Fe-55 analyses.

No violations or deviations were identified.

9.

Exit Interview The inspection scope and results were summarized on November 17, 1989, with those persons indicated in Paragraph 1.

The inspector described the areas inspected and discussed in detail the inspection results listed below.

Proprietary. information is not contained in this report.

Dissenting comments were not received from the licensee.

The Power Supply Laboratories demonstrated the ability to accurately measure radioisotopes in the environment. Laboratory staff (Paragraph 5),

procedures (Paragraph 3), and count room quality assurance (Paragraphs 4 and 6) were adequate to perform TS required environmental monitoring.

One IFI was identified concerning procedural amendments to specify the -

frequency to generate control limits for instrument performance checks, to specify the criteria for acceptable comparisons of new to previously determined gamma spectroscopy efficiencies, and to specify a frequency for carrier standardization (Paragraph 3).

The licensee agreed not to use the NRC acceptance criteria for EPA crosscheck results (Paragraph 7).

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