IR 05000333/1986012

Safety Insp Rept 50-333/86-12 on 860721-25.Noncompliance Noted:Procedure ESP-14, LB 5100 Low Background Counter, for Control of Lab alpha-beta Counter Not Properly Implemented

ML20203K519
Person / Time
Site:	FitzPatrick
Issue date:	08/12/1986
From:	Kramaric M, Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203K504	List: IR 05000333/1986012 ML20203K501 ML20203K506
References
50-333-86-12, NUDOCS 8608200330
Download: ML20203K519 (10)

Text

-

.

!

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-333/86-12 Docket N License No. DPR-59 Category C Licensee: Power Authority of the State of New York P.O. Box 41 Lycoming, New York 13093

.,

Facility Name: James A. Fitzpatrick Nuclear Power Plant

Inspection At: Scriba, New York Inspection Conducted: July 21-25, 1986 Inspectors: I W' -

R. Struckmeyer, Radiatidn Specialist f////f/

' ite

$Y . hN M. K(amaric, Rgdiation Specialist lE dat6 Approved by: 9(ah'/~ M a d W. Pasciak, Chief, Efflue6ts Radiation

,P/u //6

/ dite Protection Section, EPRPB Inspection Summary: Inspection on July 21-25, 1986 (Inspection Report Number 50-333/86-12 Areas Inspected: Routine, announced inspection of the radiological environ-mental monitoring program including: management controls; the licensee's program for quality control of analytical measurements; implementation of the radiological environmental monitoring program; and a follow-up on the licensee's actions on previous inspection finding Results: Within the areas inspected, one item of noncompliance was identified in one area (failure to follow procedure, paragraph 5.c).

'

8609200330 860814 PDR ADOCK 05000333 G PDR .

..

..,%

.

.

DETAILS Individuals Contacted 1.1 New York Power Authority

• J. Brons, Senior Vice President, Nuclear Generation

• R. Converse, Resident Manager

• B. Gorman, Chemistry General Supervisor, RES L. Johnston, QA Supervisor E. Mulcahey, Radiological & Environmental Services Superintendent

• R. Patch, QA Superintendent E. Salvetti, Senior Technician, RES D. Simpson, Training Superintendent

• A. Zaremba, Assistant Emergency Planning Coordinator 1.2 Niagra Mohawk Power Corporation

• H. Flanagan, Environmental Protection Coordinator

• T. Galletta, Assistant Environmental Protection Coordinator W. Joseph, I&C Assistant Supervisor

• E. Leach, Superintendent, Chemistry and Radiation Management J. Lupa, Nuclear Generation Specialist, I&C

• T. Perkins, General Superintendent N. Spagnoletti, Nuclear Division M. West, Environmental Technician A

• Denotes those present at exit interview on July 25, 198 . Status of Previously Identified Items (Closed) Inspector Follow up Item (333/81-05-04): Calibration records for meteorological instruments and control room recorders. This item was reviewed and closed in conjunction with item number 333/83-20-04, described below.

(Closed) Inspector Follow-up Item (333/83-20-01): Review audit program with respect to implementation and adequacy of procedures for radiological environmental monitoring. Audits covering implementation of these procedures were performed in January, March, and November 1984, and August 1985. A licensee representative stated that an appraisal was recently performed covering the implementation of the Radiological Effluent Technical Specifications (RETS), of which radiological environmental monitoring is a part. The inspector reviewed the audits performed in 1984 and 1985, and found that they adequately addressed the issue of implementation of procedures. The RETS appraisal will be reviewed in a future inspection (see paragraph 3.b).

__ _-____ _ _- _ _

i

-

.

l l

3 (Closed) Inspector Follow-up Item (333/83-20-02): Completeness of records of sample collection and analysis. The inspector reviewed the licensee's procedure ESP-2, " Environmental Data Review," and associated records for collection and analysis of environmental samples. These records were complete and up-to-date at the time of this inspectio (Closed) Inspector Follow-up Item (333/83-20-03): Method for assuring operability of meteorological strip chart recorders in control room. The licensee had installed new strip chart recorders, which were operational at the time of this inspectio In addition, the inspector reviewed Procedure No. F-IMP-17.10,

" Meteorology Strip Chart Routine Maintenance and Calibration," which is performed once a year, and Procedure No. SAP-10, " Meteorological Monitoring System Surveillance," which is performed biweekly. The inspector also reviewed selected calibration and surveillance record These procedures appear to provide an adequate method for ensuring the operability and proper functioning of the recorder (Closed) Inspector Follow-up Item (333/83-20-04): Method for assuring calibration of meteorological equipment. The licensee stated that the method chosen was to perform periodic audits of the calibrations performed by Nine Mile Point. The inspector reviewed copies of. audits performed in 1984 and 1985. These audits covered the semiannuai calibrations of the meteorological sensors and associated electronics. An audit of the semiannual calibration records has not yet been performed in 1986. This audit will be reviewed in a future inspectio (Closed) Inspector Follow-up Item (333/83-20-05): Training program for Radiological Environmental Monitoring Program technicians. The licensee has instituted a formal training and qualification progra The inspector reviewed Training Program 9-7, " James A. Fitzpatrick Nuclear Power Plant Qualification Card and Standard for Radiological and Environmental Technician." Each technician in the Radiological and Environmental Services Department receives classroom training and on-the-job training in all areas related to chemistry, radiation protection, environmental monitoring, respiratory protection, dosimetry, and ALARA. Each technician keeps his qualification and training manual until it is complete The successful completion of each aspect of training is indicated by the signature of the appropriate individual (training instructor, supervisor, senior technician). In addition, computerized records are updated by the training staff. The inspector reviewed the computer records for technicians working in the radiological environmental laboratory. These indicated satisfactory progress in the training progra _ - - _ _ - _ - _ _ _ _ _ _ .

_ '

.

.

,

3. Management Controls The inspector reviewed the licensee's management controls for the radiological environmental monitoring program, including assignment of responsibility, program audits, and corrective actions for identified inadequacies in the progra Assignment of Responsibility The inspectors reviewed the organization and administration of the environmental monitoring program. The program is administered by the site Environmental Supervisor who reports through the Chemistry Coordinator to the Radiological and Environmental Services Superintendent (RESS). The RESS reports to the Superintendent of Power, who in turn reports to the Resident Manager.

l

'

The inspector noted that responsibilities for sample collection and analysis for the the Radiological Environmental Monitoring Program (REMP) are shared between the Niagra Mohawk Power Corporation (NMPC), which operates the Nine Mile Point Nuclear Station, and the New York Power Authority (NYPA), which operates the James A. Fiti-patrick Nuclear Power Plan '

Sample collections are perfor'med by two groups. A large portion including milk, food crops, and fish, is performed by Ecological Analysts, Inc. The remain.'er, including in plant canal sampling and air samplers, is performed hintly by personnel from the Nine Mile Point Nuclear Station and tte James A. Fitzpatrick Nuclear Power Plan The licensee stated that radiological analyses (other than those conducted on-site) are contracted to Teledyne Isotopes. Certain

! environmental samples are analyzed by the Site Environmental Laboratcry. These samples are: air particulate filters (for gross beta and gamma spectral analysis), airborne radiciodine (gamma spectral analysis), and lake water (gamma spectral analysis), Program Review and Audits The inspector reviewed the licensee's audits of its contractors for environmental sampling and analysis. These audits are required by Appendix A of the licensee's procedure ESP-2. This procedure did not specify a minimum frequency for performance of these audits. The licensee stated that the procedure would be revised to specify a biannual frequency, as a minimum, for each contractor. This will be reviewed in a future inspection (333/86-12-01).

The inspector reviewed the audit of Ecological Analysts, Inc. (EAI),

performed in January 1986, and the audit of Teledyne Isotopes, Inc.,

performed in January 1985. Both audits were conducted by the Environmental supervisors from NMP and JAF. The EAI audit covered l

I i

.-. , . . - . - - . - - - - . . - , .- ,,n . - --

.-_

-

.

' radiological sample collection, including procedures, specific sampling activities,. shipping and inventory, data handling, and administrative matters. The Teledyne audit covered sample receipt

,

and data handling, selected procedures (including those for i

determination of gamma emitting radioisotopes and for determination of radiostrontium in milk), instrumentation (including calibrations),

and quality control. No open items were identified in either audi The licensee stated that the audit of Teledyne's quality control covered only its performance with respect to EPA crosscheck sample The inspector stated that the audit should also include a review of other aspects of the quality control program, including control charts, analysis of duplicate and replicate samples, et Technical Specification Section 6.5.2.8.k requires that an audit of

.

'

the Radiological Environmental Monitoring Program be performed at least once per 12 months under the cognizance of the Safety Review Committee. The inspector reviewed the following audits covering

aspects of the Radiological Environmental Monitoring Program

1 Standard Audit 481, " Environmental Technical Specifications (ETS) Appendix B to Operating Licen.,e, Section 4.3 (Including Amendment 76)," conducted January 4, 9, and 10, 1984;

Standard Audit 492, "RETS Section Sampling Locations,"

conducted March 19, 26, 27, 1984;

Standard Audit 525, (no title), conducted November 29, 30, December 6, 198 (Purpose of audit was to verify that sampling and analysis were being properly performed, reviewed, and

approved as required by Technical Spectfications and proce-dures.)

Surveillance Audit 1051, " Analysis of Environmental Samples,"

conducted August 22, 198 These audits appeared to adequately cover the implementation of

,

'

procedures used for the collection and analysis of environmental samples. The licensee stated that an appraisal was recently performed covering the implementation of the Radiological Effluent Technical Specifications (RETS), of which radiological environmental monitoring is a part. The inspector briefly reviewed the audit checklist, as the results of the audit were not yet available. The RETS Appraisal will be reviewed in a future inspection (333/86-12-02),

i

(

)

_ _ _ -

_ .

_

-

.

6 Environmental Laboratory Quality Assurance-The inspector reviewed the licensec's program for the quality assurance of radioanalytical measurements performed by the Environmental Laboratory. The program was reviewed against the criteria of Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment."

The inspector reviewed the following procedures:

ESP-12(JAF) Re Environmental Surveillance Program;-

S-ENVSP-12 (NMP) Quality Assurance / Quality Control Program

ESP-5 (JAF) Rev. 1 Analysis of Environmental Samples S-ENVSP-5 (NMP) Rev. 8

ESP-11 (JAF) Rev. 1 Environmental' Lab Gamma Ray Spectro-meter System The inspector reviewed the following quality control data:

interccmparison results for the period January 1986 to the present;

daily resolution, energy and source check data for germanium detect-ors 1, 2, and 3 during the period January 1986 to the presen e

weekly background checks for germanium detectors 1, 2, and 3 during the period January 1986 to the presen Within the scope of this review, the following concern was identified:

The laboratory's computer-based gamma spectroscopy system uses a built-in quality control program for resolution, energy, background and source checks. The software automatically compares the results of these checks to control limits established by the software vendo The laboratory personnel did not appear to be familiar with the software and could not explain the basis for the calculated values or the control limits. The inspector stated that control charts established by the software, in the absence of the user's knowledge and understanding of the methodology employed, do not provide the level of control over the measurement process that can be achieved through the direct involvement of the laboratory i personne In response to this concern, the licensee stated that it would ini-tiate an improvement to the laboratory quality control program. The laboratory personnel will perform a gamma-spectral analysis for a check source daily on each of the instruments when they are in us Control charts for each instrument will be established according to a documented method. The results of the daily source checks will be

-

- - - -_-_-__ __

-

.

plotted on the control charts and compared to the limits established for each instrument. As a minimum, the laboratory personnel will plot the ratio of the daily analytical result to the known value for each of three radionuclides: Cd-109, Cs-137, and Co-60; and the resolution for the 1332 kev peak of Co-60. The licensee stated that these control charts will be in use no later than August 31, 1986, and the procedure covering Environmental Laboratory quality control will be revised to incorporate these changes no later than September 30, 198 The inspector also identified the following concerns:

Procedure ESP-12 indicates that the USNRC participates in annual sample splits with the licensee. The USNRC does not participate in sample splits with any licensee for the purpose of laboratory quality contro The licensee stated that ESP-12 will be revised to remove the refer-ence to the USNRC as part of the licensee's interlaboratory quality control progra *

During the review of source check data for Detector #3, the inspector noted that an efficiency calibration had not been performed for the source check geometr The licensee stated that this calibration was performed prior to the conclusion of the inspectio *

Procedure ESP-5/ENVSp-5 provides instruction for the gamma spectral analysis of water samples. The preparation involves the evaporation of a 4 liter sample down to 100 milliliters, followed by the addition of nitric aci The inspector stated that the nitric acid, which is used to prevent plate-out of nuclides, should be added at the time of sampling and not following evaporatio The inspector further' stated that there is a possibility of losing volatile nuclides from the sample during the evaporation proces Procedure ESP-5/ENVSP-5 specifies that the 100 cc counting geometry be used for gamma analysis of vegetation samples. However, the licensee indicated that the gamma spectrometry system is also cali-brated for vegetation samples using a 1 liter Marinelli beaker, and that analyses are performed using this counting geometr The licensee stated that procedure ESP-5/ENVSP-5 will be revised to add the 1 liter Marinelli counting geometry for vegetation analyses and to specify that nitric acid is'added to water samples at the time of sampling (this should be stated in the appropriate sampling pro-cedure as well).

The licensee plans to perform an evaluation of the method for analy-zing samples of water by gamma spectroscopy using the 4 liter

.

-

Marinelli counting geometry instead of the evaporation techniqu The licensee stated that the results of this evaluation will be used to determine the optimum method for analysis of water samples, including consideration of LLDs and sample counting tim Procedure ESP-11 states that plots of current energy vj! channel number are typically linear and any departure from linearity suggests a problem. The inspector discussed this matter with the licensee since a non-linear fit is commonly used in an energy calibratio The licensee agreed that a quadratic fit or a cubic fit would also provide an effective calibration'and did not necessarily indicate a problem. The licensee stated that this procedure will be revise The inspector stated that the procedure revisions and improvements to the Environmental Laboratory Quality Assurance Program will be reviewed in a future inspection (333/86-12-03).

5. Implementation of the Radiological Environmental Monitoring Program Direct Observation The' inspector examined selected. environmental monitoring stations, including air samplers for iodines and particulates, TLDs for direct i

radiation measurement, and continuous water sampling equipment on the inlet canal at the JAFNPP. All equipment was operational at the time of the inspectio Review of Reports The inspector reviewed the licensee's Annual Radiological Environ-

.

'

mental Surveillance Report for 1985, and noted that all samples required by the Technical Specifications were reported for the year, as were historical data for the years prior to the report. There is also discussion of the monitoring program, the various kinds of samples analyzed, the interrelationship between the Fitzpatrick and

!

Nine Mile Point Programs, and deviations from the required sampling schedule As a result of this review, the inspector determined that the licensee has complied with its Technical Specification requirements for sampling frequencies, types of measurements, analytical sensitivities, and reporting schedule '

The analysis of environmental samples indicated that doses to humans from radionuclides of station origin were negligible.

j Procedures The inspector reviewed selected procedures for analysis of samples by the Environmental Laboratory. Observations concerning procedures

! -. .

l related to laboratory quality assurance are presented in Section 4 of this repor In addition, the following procedures were reviewed:

ESP-2(JAF) Rev. 1 Environmental Data Review

ESP-4 (JAF) Rev. 11 Environmental Station Inspection

,

S-ENVSP-4 (NMP) Rev. 2 and Sample Collection

'

ESP-7 (JAF) Rev. 6 Calibration of Environmental S-ENVSP-7(NMP) Rev. 2 Monitors

ESP-9 (JAF) Rev. 1 Low Background Proportional Counter

ESP-14 (JAF) Rev. 1 LB 5100 Low Background Counter The inspector also reviewed records and data related to these procedures. The review of ESP-14, LB 5100 Low Background Counter, indicated that a step necessary for proper calibration of the instrument was not included in the procedure, and that an existing step was not being implemented. The missing step, which was recommended in the manual supplied by the instrument manufacturer, instructs the user to move the signal cable from the beta port to the alpha plus-beta port as part of the calibration, in order to accumulate gross counts in l channel B of the instrument. This is to be followed by repeated counts l of a check source at increasing voltage increments, and a graph of

! response (counts per minute) versus voltage-is to be prepared. The

!

procedure specified (step 4.4.8) that the user should plot averaged beta counts per minute versus voltage, and averaged alpha-plus-beta

! counts per minute versus voltage. The inspector reviewed calibration

!

records for this instrument and determined that the user had not performed the plot of alpha plus-beta counts per minute versus l voltage. The inspector stated that Procedure ESP-14 was not properly l implemented, and that this was a violation of Section 7.2 of the James

,

A. Fitzpatrick Nuclear Power Plant Technical Specifications l (333/86-12-04). The licensee revised the procedure to include the missing step and instructed laboratory technicians on the proper method of calibration prior to the end of the inspection. The inspectors reviewed the licensee's revised procedure and found it adequat This item is considered close . Meteorological Monitoring The inspector examined the meteorological monitoring system, including the primary, backup, and inland meteorological-towers, as well as the digital readouts in the equipment buildings at each tower and the strip chart recorders in the control rooms. The sensors are maintained and calibrated by NMPC. JAF maintains and calibrates the strip-chart recorders in its control room. The equipment on each tower appeared to be operating pro-perly at the time of the inspection. The primary tower has sensors for l

- _ - . _

- *

v

+

wind speed (WS) and wind direction (WD) at three elevations: 30 feet, 100 feet, and 200 fee In addition, this tower has provisions for measuring AT and sigma-thet The backup tower has WS and WD sensors at an eleva-tion of 92 fee The inland tower has sensors at the 32 foot level; its purpose is to detect differences in weather conditions relative to the towers at the site, which are influenced by the effects of Lake Ontario immediately to the nort The inspector reviewed the NMP calibration procedures for the meteoro-logical monitoring equipment, and noted that calibrations have been per-formed semiannually as required by the NMP Technical Specification These calibrations appear to have been performed satisfactoril JAF performs periodic audits to confirm that these calibrations have been performed satisfactorily. The inspector reviewed the results of these audits for 1984 and 1985 and found that they were adequate. An audit of the semiannual calibration records had not yet been performed in 198 This audit _will be reviewed in a future inspectio . Exit Interview l The inspector met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection on July 25, 1986. The inspector summarized the purpose and scope of the inspection, and discussed the findings. At no time during this inspection was written material provided to the licensee by the inspector,

,

,

I

l

!

l I