IR 05000327/1981010
| ML19345H452 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/27/1981 |
| From: | Hosey C, Montgomery D, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19345H447 | List: |
| References | |
| 50-327-81-10, NUDOCS 8105200320 | |
| Download: ML19345H452 (9) | |
Text
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Report No. 50-327/81-10 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Facility Name:
Sequoyah 1 Docket No. 50-327 License No. DPR-77 Inspection at Sequoyah,Nucleplant near Daisy, Tennessee Inspectors:
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G. L. Troup '
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Date' Signed f).p. ide 3/-D/n D. M. Montgompy f Date Signed Approved by:
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f CTM. 'Hosey / Agyihg Sectia l Chief
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Dat6 Sigged Technical InspYction Branch Engineering and Technical Inspection Division SUMMARY Inspected on March 3-5, 1981 Areas Inspected l
This special, announced inspection involved 44 inspector-hours onsite in the l
area-of radioactive ef' fluent control including effluent release pathways, special reporting requirements, calculation of doses, dose models, laboratory analytical procedures and environmental sample results.
Results Of the six areas inspected, no violations of NRC requirements or deviations were l
identified in four areas; two violations were found in two areas (failure to make l
required written report to the Commission in accordance with Technical Specifi-l cation 3.11.1.2.; and failure to follow approved chemistry procedures for quality control in accordance with Technical specification 6.8.1).
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REPORT DETAILS
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1.
Persons Contacted Sequoyah Nuclear Plant
- J. M. Ballentine, Plant Superintendent
- J. M.. McGriff, Assistant Plant Superintendent
- W T. Cottle, Assistant Plant Superintendent H. Kinsey, Results Supervisor
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J. L. Taylor, Jr., Chemical Section Supervisor J. T. Dills, Jr., Lead Chemical Engineer
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D. Amos, Chemical Engineer
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Controls and Test Branch, Division of Nuclear Power N. E. Scott, Acting Supervisor, Chemistry Section Office of Natural Resources J. Lavender, Biological Associate Radiological Hygiene Branch, Division of Occupational Health and Safety M. S. Robinson, Health Physicist Other licensee employees contacted included 3 technicians.
NRC Resident Inspectors E. J. Ford S. D. Butler
- Attended exit interview'
2.
Exit Interview The inspection scope and findings were summarized on March 5,1981 with those persons indicated in paragraph 1 above. The inspectors discussed the two violations (paragraphs 6 and 8); these were acknowledged by licensee management representatives.
3.
Licensee Action on Previous Inspection Findings Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
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Background On February 18, 1981, the licensee informed Region II by telephone that calc'ulations of the doses from radioactive material in plant liquid efflu-ents were greater than the limits of Technical Specification 3.11.L2 for the third and fourth quarters of 1980. Subsequently, the licensee deter-mined by preliminary calculations that the liquid effluents would produce doses greater than the quarterly limit for the first quarter 1981. Releases from the radwaste system were stopped on February 12 pending confirmation of the high doses, identification of the source of radioactivity, and initia-tion of corrective action to reduce the amount of radioactive material released. Discharges continued from the Turbine Building sump as there is no storage capacity in this system.
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6.
Radioactive Effluents a.
Technical Specification 3.11.1.2.a requires that the dose or dose commitment to an individual from radioactive materials in liquid effluents released from the site during any calendar quarter be less than or equal to 1.5 mrem to the total body and less than or equal to 5 mrem to any organ. The maximum calculated dose to an organ for the thi H quarter wts 9.1 mrem to the bone and for the fourth quarter was 11 mrem to the bone.
For both quarters the critical pathway was through consumption of fish; the most significant isotope causing these doses was phosphorus-32 (P-32). The principal release pathway during these quarters was discharges from the Turbine Building sump, which is not normally a significant radioactive effluent pathway.
Doses were calculated using the Offsite Dose Calculation Manual (ODCM).
b.
The inspectors discussed the sample results for the monthly composite samples which were used to calculate the doses. Several questions were raised concerning the results because:
(1) the highest activity for the third quarter occurred during July, when the plant was at zero power and had no power history; (2) the activity levels in the Turbine Building sump were higher than in the radwaste system, which receives reactor coolant and should be the highest activity; and (3) the activity levels in the sump were zero during August and September,
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which would indicate that the source of the activity decreased but is inconsistent with the additional power history for the primary system.
Licensee representatives had identified cross-contamination of samples and/or equipment as a possible cause of the high sample results.
An inspector reviewed the laboratory quality control program, which is discussed in paragraph 7.
Since fish ingestion was the critical pathway for the high doses, an inspector collected fish samples from the river-for analysis; this is discussed in paragraph 10.
c.
Technical Specification 3.11.1.2 requires that when the calculated dose from the release of radioactive materials in liquid effluents exceeds the limits, a report shall be submitted to the Commission within 30
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days. An inspector asked licensee representatives when it had been determined that the calculated organ dose for the third quarter had been determined to be greater than the Technical Specification limit.
A licensee representative stated that the dose had been calculated in October 1980 and had been reported to the plant staff verbally. No further confirmation had bt-en made until February 9,1981 when the doses. for both quarters were " officially" reported to the plant staff ~.
These doses are included in the report " Radiological Impact Assess-ment-Sequoyah Nuclear Plant, July-December 1980, RH-81-2-S21".
A written report to the Commission had not been made at the time of the inspection.
d.
An inspector stated that the failure to make a report to the Commission within 30 days after the dose was determined to be greater than the Technical Specification limit is a violation of NRC requirements (81-10-01). Licensee management representatives acknowledged this and stated that the reports for the two calendar quarters were being prepared and would be submitted to the Commission with a report covering the January releases from the radwaste system.
e.
The inspectors discussed the need for timely communications between the various groups involved in the dose calculations so that problems are rapidly identified. The concept of " official" and " unofficial" noti-fications was discussed; the inspectors emphasized that reporting of high calculated doses should be done as soon as possible because of the need for corrective action and the reporting requirements. An inspec-tor stated that a four month delay between " preliminary" and " official" notification was an unacceptable delay. Also, the distinction between the two notifications was not clear. A licensee management representa-tive acknowledged these comments and stated that reporting procedures were being reviewed. so that problens could be readily identified and corrective action initiated.
l 7.
Review of P-32 Analyses and Radioanalytical Quality Control
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l a.
An inspector reviewed the results of the P-32 analyses of composite samples from the Turbine Building sump, condensat.e demineralizer, and liquid radwaste tanks during the period of July 1980 through January 1981. Licensee representatives stated that P-32 concentrations associated with the Turbine-Buildirg sump were 8 X 10 ' pCi/cc, 9.6 X 10 7 pCi/cc, and 4.7 X 10 7 pCi/cc in JLly, October and November of 1980, respectively. The highest concentration in the Turbine Building sump during 1980 was observed in the July 1980 composite during a period when the plant was operating at 0 pcwer after initial startup in the first part of July. It is unlikely that P-32 would be present at such concentrations since the average P-32 concentration in radwaste was only 4.2 X 10 7 pCi/cc during July 1981. Licensee representatives stated that the July samples were analyzed along with a cross check
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l sample at a concentration of 10 ' pCi/cc and the effluent samples may l
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have been cross-contaminated. This appears to be likely since P-32 was not detected in the August and September, 1980 composites or the Turbine Building sump and the plant was operating at 30 percent and 75 percent full power during August and September: respectively. Licensee'
representatives stated that. blank samples were not included with the
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effluent samples, and that the radiochemical purity of the separated P-32 was not checked-by gamma ray spectroscopy or half-life verifica-tion as recommended by the licensee's procedure for P-32 analysis. The average P-3E concentrations in the Turbine Building sump during October and November of 1980 also appear to be higher than expected. Licensee representatives indicated that the samples may have been contaminated from sample bottles that were previously used for storing higher level radwaste samples. The inspector inquired as to why sample bottles were reused in view of the potential for contamination of samples. Licensee representatives indicated that teflon bottles were used to maintain sample integrity (prevent plateout) and that they were too expensive to discard after use.
The inspector determined that prior to January 1981, the sample bottles were not specifically reserved for a partic-ular type of effluent sample and cross-contamination of samples could have occurred.
In addition, licensee representatives suggested that instability of the liquid scintillation counter used for counting P-32 may have been responsible for over-reporting P-32 concentrations. A review of the counting data did not support this conclusion since the sample counts and background counts appeared to be reproducible with no apparent counter instability. Although it appears unlikely that P-32 was actually discharged in Turbine Building sump effluents at the reported concentrations, there was no data or evidence that would definitely support this conclusion.
b.
The inspector noted that the licensee's current laboratory quality control program and practices should be reviewed to eliminate some of the probl, ems encountered in providing reliable analyses of liquid effluents for P-32.
The following items were identified to licensee representatives:
(1) At least one blank sample should be processed with the effluent samples to provide a reagent blank for background measurements and to identify cross-contamination problems. Duplicate analyses on selected samples would also be desirable to check out purity of separations and reproducibility of the analyses.
(2) Composite samples should be retained until analytical results have been evaluatad and the need for additional analyses has been discounted.
(3) Samples should be segregated according to activity levels and processed accordingly (i.e., high-level samples should not be processed with low-level samples).
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(4) Sample bottles should not be reused unless abs'olutely recessary.
If sample bottles are reused, they should be dedicated for a particular type of liquid effluent or activity level and should be checked for contamination prior to use.
(5) Samples showing detectable levels of P-32 should routinely be recounted after seven to_ fourteen days to verify that the sample-is decaying with the 14.3 day half life of P-32. Gamma spectral analyses may also be useful for verifying the efficacy of the chemical separation.
(6) Variable background of the liquid scintillation counter due to the presence of other samples in the proximity of the liquid scintil-lation counter should be evaluated and controlled to ensure the validity of the data.
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A licensee representative agreed to revise procedures to address the above items (81-10-02).
8.
Review of P-32 Analysis Procedure and Quality Control Records a.
An inspector reviewed the P-32 procedure used for the analyses of liquid effluent suples as noted in paragraph 7, and noted that the
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purity checks for the separated P-32 sample hed not been performed for analyses during July through December 1980. Since the procedure only involves two precipitations, the radiochemical purity of the final separation should be checked routinely until the validity of the procedure has been demonstrated for a wide variety of samples with different isotopic compositions and concentrations.
Licensee repre-sentatives ino'cated that analyses of blank samples have shown count rates significantly above background. The inspector stated that this may indicate'incompatability of the final counting form with liquid scintillation counting (i.e., chemluminescence). The inspector noted that the procedures for P-32, Sr-90 and Fe-55 should be evaluated to ensure that the data generated by liquid scintillation counting is valid. Licensee representatives stated that additional evaluations and studies will be conducted to ensure validity of the effluent analyses.
b'.
An inspector reviewed -the QC records for the liquid scintillation counter.
Procedure TI-12, " Radiological Analytical Methods", Appen-j dix B.6 and TI-4a, " Radiological Chemical Laboratory Test Equipment l
Calibration Program", Appendix F.3 require that standard samples and
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background samples be counted with each set of samples and that the data be recorded on worksheet 49-F.3-3.
The procedure further requires that the results be compared against
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j acceptance criteria on Worksheet 49-F.3-3.
The inspector noted that the required data had not been recorded for P-32 analyses in September, i
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October, November and December 1980 and that acceptance criteria for the counting efficiency, C-19 standard, and Beckman background had not been recorded on a Form 49-F.3-3.
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The-licensee representative-responsible for supervision of the counting room indicated that the results had not been compared against accept-ance criteria because the procedure for establishing acceptance criteria requires more data than had been generated (P-32 analyses are only performed monthly). The inspector stated that other methods can be used for establishing acceptance criteria and that the program should be revised as necessary to meet the overall requirements. The inspector further noted that the counting room supervisor has been given the authority to initiate procedure changes as necessary, to implement the required QC program. The inspector informed licensee representative:s that failure to document quality control data and compara against acceptance criteria as required by procedures was a violation of Technical Specification 6.8.1 that states in part, 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 states in part that chemical and radiochemical control procedures should be written to specify laboratory instructions and calibration of laboratory equipment (81-10-03).
c.
The inspector noted that the overall requirements foe counting or performing quality control checks had been performed.
However, the inspector noted that some of the tritium performance checks for the liquid scintillation counter did not meet the acceptance criteria. A licensee representative stated that the data had been reviewed and it had further been determined that the instrument was performing satis-factorily. The inspector noted that there was no documentation to sug-gest that corrective actions had been taken when the acceptance criteria were not met. The inspector stated that good quality assur-ance practice dictates that the review of acceptance criteria along with corrective action be clearly documented. A licensee representa-tive agreed to revise procedures, as necessary, to provide for proper review and documentativu (81-10-04).
l d.
An inspector requested that the licensee collect a liquid waste sample i
for the purpose of providing split samples for intercomparison of P-32 results with the licensee and NRC. A liquid waste sample from Waste
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Holdup Tank A was collected on March 4, 1981 and split with the licensee and NRC. A licensee representative agreed to analyze the liquid sample for P-32 and submit the results to NRC:RII. Two 1-liter samples, provided to NRC, were sent to USEPA and USDOE laboratories for analyses.
The results will be reviewed upon receipt to verify the validity of the licensee's methodology for P-32 analyses.
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The inspector noted that Technical Specification 6.8.4 specifies that written procedures shall be established, implemented, and maintained by the Radiological Hygiene Branch covering the quality assurance program for effluent and environmental monitoring using the guidance contained
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in Regulatory Guide 4.15, December 1977. A licensee representative stated that the quality. assurance program for effluent monitoring was not being maintained ' by the Radiological Hygiene Branch since the
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Radiological Hygiene Branch-is only responsible for environmental moni-toring.
He further stated that quality assurance procedures for effluent monitoring are being implemented by the Sequoyah Plant Chemistry Section and this was the intent of the -Technical Specifi-cation.
The inspector noted that the program must meet the require-ments of the Technical Specification. A licensee representative agreed
to initiate Technical Specification changes to delete the requirement i
that the Radiological Hygiene Branch maintain procedures for quality assurance-for effluent monitoring under Technical Specification 6.8.4,
and add the requirement for procedures covering the quality assurance
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program for effluent ~ monitoring using the guidance in Regulatory Guide l
4.15 under Technical Specification G.8.1 (81-10-05).
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9.
Off-Site Dose Calculation Manual (ODCM)
a.
Technical Specification 3.11.1.1, et seg, requires that the doses from
various effluent pathways be calculated usign the ODCM.
Technical Specification 6.14.1 requires that the ODCM be approved by the Commis-sion prior to implementation, which was done in 1980.
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b.
Technical Specification 4.11.1.2 requires that cumulative dose con-tributions from liquid effluents shall be determined in accordance with
l the ODCM at least once per 31 days. Technical Specification 3.11.1.3 i
l requires that the liquid radwaste system shall be used when the
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projected doses averaged over 31 days exceed 0.06 mrem to the total body or 0.2 mrem to any organ. An inspector reviewed the monthly dose projections for April-December 1980 which were calculated in accordance with the ODCM; all monthly dose projections were less than the Tech-nical Specification limits so the radwaste system was not operated. No processing capability is installed on the turbine building sump system.
Monthly dose calculations are performed in accordance with ODCM section 2.3.2, which uses five isotopes based on the design source term.
The inspector noted that the plant effluent records indicate that four of these five isotopes were not the principal isotopes released during the third or fourth quarter. When other isotopes are present in signifi-cant quantities their impact should be evaluated rather than rely l
solely on a design basis distribution.
A licensee representative acknowledged this and stated that the ODCM would be revised to require that the monthly analysis include any isotope which is greater than a predetermined percentage of the total activity released, such as 10%
(81-10-06).
The inspector noted that during the third and fourth
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system but from the turbine building sump. However, the inclusion of isotopes other than the pre-selected ones in the dose calculation should provide early identification of effluent control problems and their resulting impact on the dose calculations.
c.
In reviewing the monthly and quarterly dose calculations an inspector noted.that equations in the ODCM neglect several factors which result in higher calculated doses. While this introduces conservatism into the calculations, the result is a calculated higher dose.
For instance, the radwaste release pathway neglects the dilution provided by the diffuser pond. A licensee representative stated that a change.
had been approved on November 24, 1980 which includes the diffuser pond dilution in the calculation; this change became effective in January 1981 and was not included in the 1980 calculations. Other changes to better define the calculations are being considered by the licensee.
10.
Collection of Fish Samples for P-32 Analyses At the request of the NRC, TVA personnel collected fish samples downstream from the plant's effluent discharge point in the Tennessee River.
An inspector observed the collection of fish samples on March 4, 1981.
Seven channel catfish and twelve white crappies were collected 17 +'c.e iennessee River approximately one-half mile downstream from the effluent discharge point.
In addition, TVA submitted two samples of crappie and catfish that were collected on February 27, 1981.
The fish samples were collected for the NRC to evaluate potential doses to individuals from the consumption of fish that have been exposed to P-32 from liquid discharges using measured levels rather than calculated levels from models.
The fish samples were sent to the USEPA Eastern Environmental Laboratory in Montgomeiy, Alabama for analysis. of P-32.
The results will be evaluated upon receipt of the data from the USEPA.
11.
Environmental Water Samples l
An inspector reviewed the results of the licensee's analysis of drinking water supplies and surface water samples collected near the plant diffuser pipe discharge for the period July-December 1990. All gross gamma analyes
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were less than the lower detection leval; the maximum gross beta analysis value was 3.5 pC1/1 which is 1/14 of tne maximum allowable value for gross beta in drinking water of 50 pCi/1 (40 CFR 141). Five of the seven surface water samples were less than the lower detection level. The inspector had t
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no further questions.
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