IR 05000334/1988013

Insp Repts 50-334/88-13 & 50-412/88-08 on 880411-15.No Violations Noted.Major Areas Inspected:Radiological Measurements Program Using NRC I Mobil Radiological Measurements Lab & Lab Assistance by DOE

ML20154J708
Person / Time
Site:	Beaver Valley
Issue date:	05/16/1988
From:	Kirkwood A, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154J695	List: IR 05000334/1988013 ML20154J691
References
50-334-88-13, 50-412-88-08, 50-412-88-8, NUDOCS 8805270105
Download: ML20154J708 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-13 50-412/88-08 Docket No. 50-334 50-412 License No. DPR-66 Category C NPF-73 Licensee: Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Power Stations, Units 1 and 2 Inspection At: Shippingport, Pennsylvania Inspection Conducted: April 11,-15, 1988

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Inspectors: \) .d /f/M E/.2 'B 6 g(_A. K rkwood, Hadiation Specialist date Approved by: _M . 47 (,t N 6 W. "J. Pas,c ak, Chief Effluent Radiation Protection Section

/da94 Inspection Summary: Inspection on April 11-15,1988 (Inspection Report Nos. 50-334/88-13 and 50-412/88-08 Areas Inspected: Routine, unannounced inspection of the licensee's radiological measurements program using the NRC: I Fobile Radiological Measurements Laboratory and laboratory assistance p ovided by DOE's Radiological and Environmental Sciences Laboratory. Areas reviewed included:

previously identified items, confirmatory measureme.-ts, audits, laboratory QA/QC, sampling and procedures, and management / organizatio Results: No violations were identifie PDR ADOCK 05000334 Q DCD t .

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Details 1.0 Individuals Contacted Principle Licensee Employees

• J. Sieber, Vice President, Nuclear Group (DLCo)

• T. Noonan, Plant Manager

• J. Kosmal, Manager, Radiological Control (DLCo)

• V. Linnenbom, Director, Plant Chemistry

• D. Hunkele, Director, Quality Assurance, Operations

• D. Girdwood, Director, Radiation Operations, Unit 1 W. Wirth, Director, Effluent Control & Environmental Monitoring

• F. Liptak, Count Room Coordinator

• R. Freund, Sr. Health Physics Specialist

• J. Breslin, Health Physics Specialist A. Lonnett, Sr. Health Physics Specialist

• B. Sepelak, Licensing Engineer The inspector also talked with and interviewed other licensee employees, including members of the chemistry and health physics staf * Denotes those present at the exit intervie .0 Previously Identified Item (0 pen) Unresolved Item (50-334/87-07-03)

This item was opened as a result of two similar events occurring within a few days of each other and identified by the licensee in LER's87-009 and 87-011. They both had root causes related to chemistry personnel sampling errors. An administrative concern addressed in the item has been ade Chemistry Manual,quately Chapterresolved 3, Issue through 1, Rev.1changes to BVPS-1/BVPS-2, Sampling and Testing, Section 3, VCT-Vapor Space Grab Sample, as we,ll as mention of the above LER's in Chemistry TrainingT6dule 4135, Advanced Systems Chemistry. A second concern, relating to possible engineering changes (routing the sampling lines back to the source), has not yet been evaluated by the Engineering Department. Chemistry has done a preliminary assessment and this does not seem a viable option. Chemistry is also trying to determine if these samples can be eliminate .0 Confirmatory Measurements 3.1 Split Sample Results During this part of the inspection liquid, particulate filter charcoal cartridge, and gas samples were sdit between the licensee and,NRC for the purpose of intercomparison. W1ere possible the split samples are

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actual effluent samples or inplant samples which duplicate counting geometries used by the licensee for effluent sample analyses. The samples were analyzed by the licensee using normal methods and equipment and by the NRC:I Mobile Radiological Measurements Laborator Joint analyses of actual effluent samples are used to verify the licensee's capability to measure radioactivity in effluent samples with respect to Technical Specification and other regulatory requirement In addition, a liquid effluent sample was sent to the NRC reference laboratory, Department of Energy, Radiological and Environmental Sciences Laboratory (RESL), for analyses requiring wet chemistry. The analyses to be performed on the sample are Sr-89, Sr-90, Fe-55, gross alpha, and tritium. The results will be compared with the licensee's results at a later date and will be documented in a subsequent inspection repor The results of an effluent sample split between the licensee and the NRC:1, during a previous inspection on October Inspection 1-5,1984(inspectio Report No. 50-334/84-24), were also compared during this The results of the sample measurements comparison indicated that all of the measurements were in agreement under the criteria used for comparing results. (See attachment). The results of the comparison are listed in Table 1. The licensee informed the inspector before the split of the gas sample that the Ar-41 energy line could not be reasonably compared as the licensee's gas calibration standard had a maximum energy of 514 kev, whereas, the energy of Ar-41 is greater than 1000 kev. The inspector informed the licensee that gas calibration standards are available which cover energies up to 1836 kev. The licensee stated that they would investigate the purchase of one of these standard .2 Quality Assurance o_f Radioanalytic Measurements The inspector performed a selected review of the licensee's program for the quality assurance of radioanalytic measurements. The review was performed with respect to criteria contained in the following:

Regulatory Guide 4.15, "Quality Assurance For Radiation Monitoring Programs (Normal Operations)-Effluent Streams & The Environment"

Principles of Quality Assurance of Chemical Measurements (National Bureau of Standards)

Procedures selectively reviewed included:

BVPS-Chemistry Manual, Administrative Directives, Part 4-Laboratory Control Program, Issue 5, Rev. O

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• Chemistry Manual, Administrative Controls, C.M.O.9, BVPS-1/BVPS-2, Laboratory Qua lit _y Control Program, Issue 1, Re * BVPS-1/BVPS-2, Chemical Aeasurements, Chapter 5, Radiochemical Procedures, C.M.5.13, Operational Counter Verification Data Procedure The inspector also reviewed the following quality control data and records

• Radcon Quality Control Logbook (Det.1025) for the period April 1-13, 1988

• Quality Control Logbook for Packard LSA 2000 CA/LL liquid scintillation counter for the period April 1-13,1988 Within the scope of this review, the following observations and concerns were identified:

The inspector observed the off-shift, daily instrument quality control checks being performed by the chemistry analyst. A daily standard and background check; a weekly energy calibration; and a yearly efficiency calibration is done on the gamma spectroscopy systems. A daily standard and background check and at least a yearly quench curve is done for the liquid scintillation counte The staff member performed these functions adequately. When questioned about instrument control chart limits, the analyst demonstrated that he had a good understanding for the statistical basis for these limits and the actions to take if they were exceeded. When asked a question that he didn't readily know the answer, he referred to the appropriate procedur *

The inspector also reviewed records and data. Entries in the quality control logbooks were adequately maintained. Out-of-limits plots on the control charts were addressed b corrective actions in a timely fashion. One area of concern was hi h' lighted by an entry on the gamma spectroscopy quality control lo book for Unit 1. The system was down April 3, 1988 all day. The explanation was that the countroom coordinator could not be reached. When asked about an i alternate, the anal l handle the problem.yst Thecould not readily licensee stated name someone that this problemwho is could !

overcome by good vendor service and the training of a health physics specialist to assume these duties if the countroom 4 coordinator is not availabl *

While reviewing the Administrative Controls section of the Chemistry Manual, the outline of the Laboratory Quality Control Program, C.M.O.9, mentioned an Intralab and Interlab quality control program. Analysis of blind samples, prepared both in-house

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for intralab comparisons and blind samples prepared outside, for independent quality control checks, were mentioned. Chemistry is not currently utilizing these techniques in its program. The licensee stated that they are including these items in the reissue of C.M.0.9, Chapter 9, of the Chemistry Manual. The licensee is consolidating and expanding its laboratory quality assurance program under this issue. The improvements to the quality control program will be fallowed up on a subsequent inspection (334/88-13-01

& 412/88-08-01).

3.3 Sampling The inspector reviewed the following procedures with respect to the observation of a sample drawn from a liquid waste tank:

BVPS-1/BVPS-2, Chemistry Manual 1-3.18, Chapter 3, Sampling' ~&

Testing Unit 1, Issue 1, Rev. 0

BVPS-R.C.M., Units 1 & 2, Chapter 3, Radcon Procedure 6.1, Liquid Waste Holdup Tank Sampling, Issue 2 A radiation control technician sampled an evaporator test tank, LW-TK-58, in order to obtain a liquid waste sample for analyses. The method used was in conformance with the procedures reviewe .4 Audits The inspector reviewed the following audits:

BV-1-87-25, Unit No.1, Chemistry, with audit dates of July 1-12, 1987

BV-1-87-39, Unit No.1, Chemistry, dated November 9-25, 1987

BV-C-88-07, BVPS Unit Nos. 1 & 2, Chemistry (Administrative Controls), dated March 14-18, 1983 Areas audited included procedures and training, Technical Specification compliance, laboratory quality assurance program and administrative controls. The audits are in checklist format and appear to be thorough and technically adequate. The results of all the audits found that chemistry was performing satisfactorily. One concern the inspector noted after reviewing all the audits, was that no mention is made of the status of previous audit findings in subsequent audit report . - - - - -

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4.0 Management Controls The inspector reviewed organizational charts, interviewed supervisory i and technical personnel and made observations regardin operation of the '

chemistry department. Lines of authority appear clearl defined as outlined on the organizational charts and were underst od by those interviewed. Supervisory personnel were aware of the chain of command and did not express any difficulty of access to their supervisor '

Staffing appears adequate under the current workload, but, based on a conversation with the Count Room Coordinator, additional staff should be considered in order to expeditiously handle an expanded quality control ,

program for radioanalytical measurements. Management material resource 1 support is evidenced by recent chemistry acquisitions of state-of-the-art gamma spectroscopy and liquid scintillation counting ,

system .0 Exit Interview The inspector met with the licensee's representatives (denoted in section 1.0) at the conclusion of the inspection on April 15, 1988, and summarized the scope and findings of the inspectio , - -_

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TABLE 1 . .

DEAVER VALLEY VERIFICATION TEST RESULTS SAMPLC ISOTOPE RESULTS IN TOTAL MICROCURIES COMPARISON HRC VALUE LICENSEE VALUE Particulate f il ter 1-131 (1.5510.12) E-3 (1.610.2) E-3 Ag reeme n t 0835 hr (5.710.3) E-3 (5.510.2) E-3 Ag reement 4-12-88 Unit 1 Co-58 (8.111.2) E-4 (1.210.2) E-3 Ag reement

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Unit 2 Detector I-131 (1.5510.12) E-3 (1.810.2) E-3 Ag reemen t I-133 (5.710.3) E-3 (5.810.2) E-3 Ag reement Co-58 (8.111.2) E-4 (1.0410.13) E-3 Agreement Cha rcoa l Ca rt ri dge 1-131 (6.lio.3) E-3 (6.210,3) E-3 Ag reemen t ( Con ta inment) 1440 hr (3.610.4) E-3 (3.210.2) E-3 Ag reemen t 4-13-88 Unit 1 De tec to r Unit 2 Detector I-131 (6.110.3) E-3 (6.310.2) E-3 Ag reement 1-133 (3.610.4) E-3 (3.610.2) Le 3 Ag reement Cha rcoa l Ca rt ri dge 1-131 (2.510.4) E-4 (2.510.3) E-4 Ag reemen t 4-11-88 0830 hr Unit 2 Oetector Unit 1 Detector I-131 (2.510.4) E-4 (2,210.3) E-4 Agreement HESULTS IN MICR0CUAlES/ml Liquid Waste LW-TK-58 Co-58 (1.3610.03) E-5 (1.3010.04) E-5 Ag reement 1130 hrs. 4-13-88 Co-60 (1.3510.04) E-5 (1.2310.05) E-5 Ag reemen t Unk c 1 Detector Ag-110m (2.210.2) E-6 (2.110.3) E-6 Ag reemen t Sb-125 (3.610.5) E-6 (3.010.5) E-6 Ag reement Sr-92 (1.110.2) E-6 ;9.211.4) E-7 Ag reement Liquid Waste LW-TK-5B Co-58 (1.3610.03) E-5 (1.4010.04) E-5 Agracment 1130 hrs. 4-13-88 Co-60 (1.3510.04) E-5 (1.2410.04) E-5 Ag reement Unit 2 Detector Aq-110m (2.210.2) E-6 (2.210.3) E-6 Ag reemen t Sb-125 (3.610.5) E-6 (3.111.0) E-6 Ag reement S r-92 (1.110.2) E-6 (1.210.2) E-6 Ag racmen t

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TABLE 1 ,

BEAVER VALLEY VERIFICATION TEST RESULTS SAMPLE ISOTOPE RESULTS IN NfCROCURIES/m1 COMPARlSON NRC VALUE LICENSEE VALUE RCS 2ml 1301 hr Co-60 (1.710.2) E-4 (2.510.2) E-4 Ag reement 4-13-88 (24 h r. Coun t ) W-187 (5.610.9) E-4 (5.910.7) E-4 Ag reement Unit I l-131 (1.4310.03) E-3 (1.2810.02) E-3 Ag reement 1-133 (4.8810.08) E-3 (4.7610.06) E-3 Ag reemen t Cs-134 (1.4 0.2) E-4 (1.610.1) E-4 Ag reemen t I-135 (911) E-3 (711) E-3 Ag reement Cs-137 (1.410.2) E-4 (1.710.1) E-4 Ag reement Na-24 (4.210.7) E-4 (5.310.5) E-4 Ag reement Liquid Waste Tank H-3 (1.7710.01) E-2 (1.5017) E- 2 Ag reemen t 1200 hrs. 10-2-84 Gross Alpha (512) E-9 No Compa ri son * ---

Gross Beta (3.4110.13) E-6 fio Compa ri son ** ---

Fe-55 (1.210.5) E-7 No Compa rison* ---

RCS C 2ml 1301 hr (1.4110.07) E-3 (1.3to.1) E-3 Ag reement 4-13-88 Unit 1, 1-133 (4.8710.09) E-3 (4.310.1) E-3 Ag reement De tec to r Unit 2, Detector 1-131 (1.4110.07) E-3 (1.5510.11) E-3 Ag reement 1-133 (4.8710.09) E-3 (4.8910.08) E-3 Ag reement RCS 2ml 1301 hr Co-60 (1.710.2) E-4 (2.3110.12) E-4 Ag reement 4-13-88 W-187 (5.610.9) E-4 (5.110.6) E-4 Ag reement (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Count) 1-131 (1.4310.03) E-3 (1.41f0.02) E-3 Ag reemen t 8Jnit 2, 2 Sigma Error 1-133 (4.8810.08) E-3 (5.0510.06) E-3 Agreement Cs-134 (1.410.2) E-4 (1.510.1) E-4 Ag reemen t 1-135 (8.911) E-3 (8.210.4) E-3 Ag reement Cs-137 (1.410.2) E-4 (1.710.1) E-4 Ag reement Na-24 (4.210.7) E-4 ( 4. 71.0. 3 ) E-4 Ag reement RCS 2ml 1615 hrs., Co-58 (3.610.4) E-4 (3.310.2) E-4 Ag reemen t 4-14-88 Unit 1

• Less than LLD

• • Licensee does not norma l ly ana lyze

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TABLE 1

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O_(AVER _yAllEY VER I flCAT_IO_fi_TLST RESULTS SAMPLC I SOTO P_C RESULTS IN HICROCUREIS/cc COMPARISON NRC VALUE LICENSEE val *JE Sirip Ca_g A r-41 (2.3710.04) E-4 *Jo t Ca i i b ra ted a t this ---

2.726 cc 1050 hr ene rgy 4-14-88 Unit 1 K r-85 m (1.2810.06) E-3 (1.2/10.11) E-3 Agreement Detector Xe-133 (4.3510.09) E-3 (4.210.2) E-3 Ag reemen t Xe-135 (8.1510.10) E-3 (7.410.2) E-3 Ag reemen t Unit 2 Detector K r-85m (1.2810.06) E-3 (1.1710.07) E-3 Ag reement Xe-133 (4.3510.09) E-3 (4.5310.23) E-3 Agreement Xe-135 (8.1510.10) E-3 (7.4310.13) E-3 Ag reement

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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurement The criteria are based on an empirical relationship which combines prict* experience and the accuracy needs of this progra In these criteria, the judgement 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 acceptable as the resolution decrease Resolution 1 Ratio For Agreement 2

<3 No comparison 4-7 0.5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25

>200 0.85 - 1.18 I

Resolution = (NRC Reference Value/ Reference Value Uncertainty)

2 Ratio = (License Value/NRC Reference Value)