IR 05000327/1981025
| ML20009G718 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/13/1981 |
| From: | Montgomery D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20009G709 | List: |
| References | |
| 50-327-81-25, 50-328-81-32, NUDOCS 8108040589 | |
| Download: ML20009G718 (6) | |
Text
<
.
.
M
- o UNITED STATES
'
E'
~ ^s NUCLEAR REGULATORY COMMISSION n
$
E REGION ll g**"*,e[
101 MARIETTA ST N.W.,SulTE 3100
$
ATLANTA, GEORGIA 30303 JUL i 41981 Report Nos. 50-327/81-25 and 50-328/81-32 Licensee: Tennessee Valley Authority 500A Chestnut Street Tower II Chattanooga, TN 37401
,
Facility Name:
Sequoyah 1 and 2 Docket Nos. 50-327 and 50-328 License Nos. DPR-77 and CPPR-73 Inspection at Sequoyah Nuclear Plant near Daisy, Tennessee 7[/A /8/
Inspector:
. $
$n tm
'
O. M. Montgomery U g
Date S'igned
.
Approved by:
/-
7 /3 P/
,
J. f. Stohr,7Fancfi chief Date Signed Emergency Preparedness and Operations Support Branch SUMMARY Inspection on June 10-12, 1981 Areas Inspected This routine, unannounced inspection involved 18 inspector-hours orisite in the areas of quality control and confirmatory measurements including; review of the laboratory quality control program; review of radiochemistry procedures; and review of quality control records and logs.
Results Of the three areas inspected, no violations or deviations were identified.
.
.
e h
8108040589 810714 PDR ADOCK 05000327
G PDR L
_ _ _.
~
.
.,
.
i
.
i REPORT DETAILS
,
1.
Persons Contacted
!
Licensee Employees r
- W. T. Cottle, Assistant Plant Superintendent W. H. Kinsey, Results Supervisor
- J. L. Taylor, Chemical Engf aaer
'
R. L. Moore, QA Evaluator M. R. Harding, Compliance Supervisor j
J. D. Pierce, Chemical Engineer Associate
-
T. B. Lee, Audit Section Supervisor
,
NRC Resident Inspector E. J. Ford S. D. Butler
- Attended exit interview 2.
Exit Interview The inspecticn scope and findings were summarized on June 12, 1981 with those persons indicated in paragraph 1 above. A licensee representative agreed to perform the analyses referred to in paragraph 9 and submit the results to NRC:RII.
3.
Licensee Action on Previous Inspection Findings
'
'
Closed Violation - Severity Level IV (81-10-01) Failure to submit written
!
report to the NRC in accordance with Technical Specification 3.11.1.2.
The inspector reviewed the corrective action submitted by the licensee in the
,
correspondence dated April 24, 1981. The required report was submitted to the NRC on March 6, 1981 and management controls have been initiated to
{
prevent reoccurrence. This item is considered closed.
Closed Violation Severity Level V (81-10-03) Failure to follow approved chemistry procedures for quality control.
The inspector confirmed that i
corrective action as stated in correspondence to the NRC, dated April 24, j
1981, had been implemented. This item is considered closed.
4.
Unresolved Items l
Unresolved. items were not identified during this inspection.
!
-
i
!
.
,
-
.
.
5.
Laboratory Quality Control Program The inspector reviewed the licensee quality assurance program in chemistry and radiochemistry.
Technical Specification 6.8 specifies that written procedures shall be established, implemented and maintained covering the quality assurance program for effluent and environmental monitoring using the guidance contained in Regulatory Guide 4.15, December 1977.
The licensee program was reviewed to verify compliance with the following elements as specified in Regulatory Guide 4.15:
a.
Organization Structure and Responsibilities of Managerial and Opera-tional-Personnel The Results Supervisor has overall responsibility for Quality Control associated with the chemistry and radiochemistry programs as specified in TI-20, " Chemical Laboratory Test Equipment Calibration Program" and TI-49, " Radiochemical Laboratory Test Equipment Calibration Program."
Responsibility for managing the quality control program on a day-to-day basis has been delegated to the Chemical Section Supervisor.
The inspector determined from discussions with licensee management and procedure review that management controls are adequate to meet the guidance of Regulatory Guide 4.15.
b.
Specifications of Personnel Qualifications The training and qualification requirements for staff members per-forming chemical and radiochemical analyses are given in TVA position descriptions and the Sequoyah Radiochemical Training Manual.
c.
Operating Procedures and Instructions The inspector verified that written procedures have been established and implemented for activities involved in effluent monitoring and
,.Semical analyses including sample collection, operation and calibra-tion of instrumentation, and quality control checks.
Procedures include acceptance criteria for instrument performance checks and corrective action.
d.
Records The inspector verified that the operating procedures provide for the documentation of activities including records of sample collection analysis, and reporting.
Records of the calibration program and quality control checks are required by the operating procedures.
e.
Quality Control in Sampling The inspector verified that procedures for collection of liquid and gaseous samples have been implemented. The inspector noted that the
.
t g
_
___.
.
.
-.
]
quality control program for air flow meters associated with the Unit 1 Shield Building Vent Monitor and the portable air sampling systems used by chemistry does not provide for calibration or calibration checks of these devices as recommended in Regulatory Guide 4.15.
A licensee representative agreed to establish a program to meet the recommenda-tions as specified in Regulatory Guide 4.15.
This will be carried as an inspector followup item and reviewed during a subsequent inspection.
(81-25-01, 81-32-01)
f.
Quality Control in the Radioanalytical Laboratory l
l The inspector determined from a review of TI-49, " Radiological Chemical Laboratory Test Equipment Calibration Program" that the licensee's laboratory quality control program meets the basic requirements set
,
forth in Regulatory Guide 4.15 including:
use of NBS relatable radionuclide reference standards, performance checks of radiation measurement systems, and an interlaboratory crosscheck program. The TVA Nuclear Power Division Training Center has established a crosscheck
.
program and the Sequoyah plant is participating.
The crosscheck i
program is still in the developmental stage and will be reviewed during subsequent inspections. (81-25-02, 81-32-22)
g.
Review, Analysis, and Reporting Data
Chemistry operating procedures provide for review of analytical results by supervisory personnel. Operating procedures provide for acceptance criteria for performance checks and corrective action, if necessary.
h.
Audits The Sequoyah Nuclear Plant Quality Assurance Staff carries out periadic surveys c' the chemistry and radiochemistry program as specified in QA-SIL-18.1, "QC Surveys and Observation." These surveys include a review of compliance with Technical Specifications and Operating procedures.
Quality Assurance Instruction Letter 16.1 provides guidelines for reporting and correcting adverse conditions that are identified by Quality Assurance surveys.
Technical Specification 6 5.2.8 provides for audits of activities required by the Quality Asstrance Program to meet the criteria of Regulatory Guide 4.15.
The inspector varified that provisions have been made for audits in this area by the TVA Office of Power Quality Assurance Staff (OPQAA).
Review of audits by OPQAA is discussed in paragraph 8.
6.
Review of Radiochemistry Procedures a.
The inspecto reviewed the following procedures:
(1) TI-12, Appendix B.1, " Determination of Tritium, Rev. 5.
.
s u
_
.-
_
__ _
.
.
.
.
.
'
!
..
-
(2) TI-12, Appendix B.2, " Determination of Sr-89 and Sr-90, Rev. 5.
(3) TI-12, Appendix 8.3, " Gross Alpha Counting," Rev. 5.
t (4) TI-12, Appendix B.6, " Determination of P-32," Rev. 5.
(5) TI-12, Appendix B.7, " Determination of Fe-55," Rev. 5.
.
l (6) TI-12, Appendix C.6, "Compositing Liquid Effluent Samples," Rev.
5.
.
(7) TI-49, - RadiochJmical Laboratory Test Equipment Calibration
"
,
Program," Rev. 5.
(8) TI-16, C.5, " Sampling Particulate Filter and Charcoal Filters,"
Rev. 4.
The inspector noted that procedure revisions had been made to improve the quality control program in response to the inspector followup item (81-10-02) that was identified during last inspection of this area (0IE Report 50-327/81-10).
Based on recent P-32 monitoring results, the quality control requirements appear to be adequate and this item is
closed. The inspector noted that acceptance criteria and corrective action for tritium performance checks have been established in response to inspector followup item 81-10-04, and this item is closed.
i b.
The ' inspector noted that Procedure TI-16, C.5.3, " Sampling Charcoal Filters and Particulate Prefilters did not include a correction factor for converting measured flow rates at pressures of less than 1 scmosphere to the equivalent flow rate at 1 atmosphere. A licensee representative reviewed the sampling procedure and noted that the
,
correction factor had not been included and that such a factor was appropriate. On June 19,.1981 a licensee representative informed the inspector that a procedure change to TI-16, C-5, had been initiated to
,
provide for appropriate correction factors. A licensee representative
.
i stated that typical correction factors would decrease the measured flow rates by about 10 percent.
The inspector noted that this would
.
increase the measured particulate and radiciodine concentrations by l
about 10 percent. This factor would affect the concentrations reported for releases monitored by the Unit 1 Shield Building Vent Monitor. A t
review of the July-December 1980 Radiological Impact Assessment Report RH-81-2-SQ1 verified that the calculated doses for radiciodine and particulate releases were less than 2 per cent of the annual guidelines during the fourth quarter of 1980, and that a ten percent systematic error in reporting of particulate radiciodine releases would be
negligible compared to release guidelines. The inspector had no further questions concerning this item.
.
p
"
_,
.
.
.
~.
7.
Record Review The following quality records were reviewed:
(a) Daily Performance Checks for GeLi Detectors, January, 1980 to June, 1981.
(b) Quality Control Records for Liquid Scintillation Counter, January,1980
'
to June,1981.
(c)
Efficiency Calibration Records for Ge(Li) Detectors,1980 and 1981.
(d)
Interlaboratory Crosscheck with Nuclear Power Training Center, January, 196-The inspector had no further questions regarding this arec.
8.
Aadits The inspector reviewed Audit Report No.
OPQAA-SQ-80TS-03, dated January 21-23, 1981.
This audit satisfies requirements of Technical Specification 6.5.2.8 for annual audits of the performance of activities requ' red by the Quality Assurance program to meet criteria of Regulatory Guide 4.15.
The audit verified compliance of the radiochemistry quality centrol program with guidance in Regulatory Guide 4.15. The audit findings indicated that procedural guidance for the plant to meet Regulatory Guide 4.15 was lacking. This finding was discussed with licensee representatives who indicated that guidance in this area is being generated by the Nuclear Power Division. The inspector had no further questions regarding this item.
9.
Confirmatory Measurements a.
The results of P-32 analyses of a liquid waste sample collected during the last inspection were reviewed by the inspector. The P-32 concen-tration reported by the licensee was about a factor of 100 higher than the NRC valve. It appeared that the licensee analyzed and reported the results of a different sample *han was supplied to the NRC. In order to determine the validity of the licensee procedure for analysis of P-32 and Fe-55, a reactor coolant sample was collected on June 12, 1981 at 7 a.m. and split with the licensee and NRC. A licensee representa-tive' agreed to analyze the sample for P-32 and Fe-55 and submit the results to NRC:RII. The NRC sample will be analyzed by USEPA and USDOE laboratories and reviewed upon receipt to verify the licensee's methodology for P-32 and Fe-55.
b.
The inspector noted that the radiochemistry laboratory and counting equipment for measurements of liquid and gaseous effluents are common to Units 1 and 2.
A previous inspection (0IE Report 50-327/79-38)
.
e
- - - -
,,
-
-
. -.
-
_ _ _ _ _ _ _ _ _ _ - - -..
_ _
. _. _ _ _ _ _ _ _
--_.
.. _
._
.
.
.
,
..
.
a j
i demonstrated the licensee's capability for ; easuring radioactivity in liquid waste, charcoal cartridges, and particulate filters.
The inspector determined from a review of the laboratory instrumenta-tien and Unit 1 effluent analysis records that tne licensee is carable i
of meeting the surveillance requirements and sensitivities as specified in the proposed Technical Specifications 'for Unit 2.
'
t
!
i
i
.
n
.
.
9