IR 05000335/1981007
| ML17209B084 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/16/1981 |
| From: | Montgomery D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17209B083 | List: |
| References | |
| 50-335-81-07, 50-335-81-7, NUDOCS 8105210159 | |
| Download: ML17209B084 (15) | |
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Report No. 50-335/81-07 UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Licensee:
Florida Power and Light Company-P. 0. Box 529100 Miami, Fl 33152 Facility Name:
St. Lucie 1 Docket No. 50-335 License No. DPR-67 Inspection at St.
Lu i site near Ft. Pierce, Florida Inspector:
I-g,L'. M. Montgomery n,'ccompanying Person
.
C..
cPhail Approved y:
J..
P'. Stohr, ief, EPPS Branch D te igned 0 te S gned SUMMARY
'Inspection on March 23-25, 1981 Areas Inspected This routine unannounced inspection involved 50 inspector-hours on site in the areas of quality control and confirmatory measurements including; review of the laboratory quality control program, review of chemistry and radiochemistry procedures, review of quality control records and logs, and comparison of'he results of. split samples analyzed by the licensee and the NRC RII Mobile Laboratory.'esults',
Of the four areas inspected, no items of noncompliance or deviations were identi-fied.
'
DETAILS Persons Contacted Licensee Employees'.
M. Wethy, Plant Manager
"J. H. Barrow, Assistant Plant Manager
"R. J. Frechette, Chemistry Supervisor
"N. G. Rous, g.C. Supervisor
"A. W. Bailey, g.A. Operations Supervisor
"N. T. Weems,. g.A. Department Other licensee employees contacted included two technicians.
NRC Resident. Inspector
- H. E. Bibb
"Attended exit interview 2.
Exit Interview 3.
The inspection scope and findings were summarized on March 25, 1981 with those persons indicated in Paragraph 1 above.
A licensee representative agreed to perform the analysis referred to in Paragraph 8.
The inspector stated that a. dedicated area. with appropriate power receptacl'es was needed to accomodate the NRC van for emergency response and routine inspections.
The licensee agreed to provide. the necessary facilities by June 1981.
(335/81.-07"'1)
Licensee acti'on on Previous Inspection Findings Not inspected.
4.
Unresolved Items 5.
Unresolved items are matters about which more information is required to determine, whether they are acceptable or may involve noncompliance or deviations.
A new unresolved item identified during this inspection is discussed in paragraph 7c.
Laboratory guality Control Program
The inspector reviewed the licensee's quality control program for chemical and radiochemical measurements in the following areas:
a.
Assignment of Responsibility to manage and conduct the gC Program.
The requirements for the chemi stry qual ity control 'rogram are given in gI 12 PR/PSL-5,
"Chemistry Measuring and Testing Equipment."
The
responsibility for managing the. quality control program is assigned to the Chemistry Supervisor who is responsible for the following:
(1)
In-calibration status of certification of chemistry and environ-mental M&TE, reference standards, test standards and reference
- 'sources according to approved procedures.
(2)
Identification in listings, logs, or schedules all METE, reference standards, and reference sources.
(4)
Maintenance of current records, calibration data, and status of items listed in (2).
Establishment of calibration cycles and a recalibration program.
(5)'nvestigation, where possible, of the consequences due to the use of nonconforming MME and reference standards.
(6)
Training chemistry personnel in proficient use of item (1) through (5).
The specific requirements for test calibrations are detailed in Chemistry Operating Procedure C-02,
"Schedule for Test Calibrations."
This procedure provides instructions for scheduling and performing calibrations and calibration checks as well as the management system to ensure that the schedules are met.
b; Provisions..for. Audits/Inspections C.
Procedure QI 18-PR/PSL-2,
"Quality Control Surveillances",
provides that surveillances be carried out to assure that the plant systems or equipment. are tested, operated, contro'lied or maintained according to approved plant procedures,,
technical specifications, regulatory requirements and FP5L Quality Assurance.
Manual requirements.
The Quality Control Supervisor is responsible for scheduling.and carrying out Quality Assurance Surveillances.
Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Corrected.
The-Chemistry Supervisor is responsible for identifying and correcting deficiencies that are identified by the Quality Control program.
In addition, the Quality Control Surveillances that are carried out by the Qual.ity Control personnel provide for documentation of all noncon-forming or deficient items.
Procedure QI 18-PR/PSL-2 also provides for assuring that corrective, actions are carried out, reviewed and verified prior to close ou d.
Adequacy of the equal ity Control Program for Laboratory Instrumentation The inspector noted that Chemistry Procedure C-48,
"Gamma.Spectrum Analysis for Liquids and Gases" had been, revised to address the deficiencies noted in the previ,ous inspection which involved failure to record daily performance checks and to make energy resolution checks.
The inspector had no further questions involving this area.
This item is closed (80-01.-01).
The inspector reviewed the most recent guality Assurance Audit of Chemistry and Radiochemistry conducted during the period of September 2-25, 1980, and had no further questions.
This, item is cl osed (79-05-01).
e 6.
Review of Chemistry and Radiochemistry Procedures a.
The inspector reviewed the following procedures:
(1)
C-01., "Schedule for Periodic Tests,"
Rev.
(2)
C.-02, "Schedule for Test Calibrations,"
Rev.
I ('3)
C-07A,
"Compositing Samples for Meekly, Monthly and quarterly Composites (Liquids)", Rev. 4 (4)
C-09A, "Primary and Secondary Grab. Sample,"
Rev.
(5)
C-09B, "Tank Sampling,." Rev.
(6)
C"40,."Determination of Tritium," Rev.
6'7)
C-42;. "Chemical Separation of Strontium and Barium," Rev.
(8)
C-48,
"Gamma Spectrum Analysis for Liquids and=Gases,"
Rev.
(9)
C-38 "Calibration of Flow Measuring Devices",
Rev.
The inspector discussed the procedure review with licensee representa-tives as noted in 6b and 6c.
b.
C.
The inspector noted that Procedure C-48 for Gamma Spectral Analysis of Liquids and Gases had been revised to limit the dead time to less than 10 percent.
This closes a previously identified item.
(335/80-01-03)
The inspector noted that decay corrections for radioiodine were made to the beginning of sample collection which would significantly over,-
estimate I-133 and I-135 concentrations for long sampling periods.
The plant vent is normally sampled for one week and overestimation of iodine releases would be significant.
The inspector noted that Regula-tory Guide 1.21 states, in part,
"decay corrections should be made as though the effluent were released uniformly throughout-the sampling
d.
period unless it is shown that most of the effluent was released during a particularly short interval."
A licensee representative agreed to revise the method for decay corrections of radioiodine using the guidance of Regulatory Guide 1'.21.. (335/81-07-02)
The inspector reviewed a previously identified item that questioned a
change-in Procedure C-45B to utilize the 'sum of isotopic activities as determined by gamma spectral analysis in lieu of a gross beta activity analysis by liquid scintillation counting.
'The inspector noted that this technique is generally an industry accepted practice since most beta emitting radionuclides also decay by gamma-ray emission'nd would therefore be detected.
This closes out a previously identified item (79"20"04).
7".
Review of Instrument Records and Logs a ~
The inspector reviewed the foll'owing records and logs:
(1)
Ge(Li) Detector Daily Source Checks February March 1981.
(2)
Tritium Daily Efficiency Checks, Februay 22 --March 23, 1981.
'3)
Gross Activity Checks, NMC Gas Proportaional Counter, February March, 1981 (4)
pH Calibration Records,'January March, 1981 (5)
Fluoride Daily Calibration Checks February - March 1981 (6)
Boron Calibration Checks, February - March, 1981 (7)
Mettler Balance Calibration January 1981 I'8)
Dissolved Oxygen Instrument Check, February - March, 1981 (9)
Gas Decay Tank Release Spectra, January - March, 1981 (10)
Liquid Waste Release Spectra, January - March, 1981 (ll) Ge(Li) Efficiency Calibrations, 1980.
(12)
Calibration Records for Fuel Building Exhaust Monitor, October 1979 - November 1980 b.
The inspector discussed the record review with licensee representatives as noted in 7b and 7c.
~ 1 The inspector reviewed the calibration of the fuel building exhaust monitor with known gas concentrations.
The inspector had.,no further questions and this closes a previously identified item (78-19-04)
C.
The inspector noted that the only documentation of instrument per-formance checks were those for the past few months.
A 'licensee representative stated that the documentation of performance-checks was only retained until the card was filled and. then discarded; The inspector stated that this was not a good practice and that performance checks should be retained, as a
minimum, for the period between-recalibration.
A licensee representative stated that they have no regulatory requirement or procedural requirements to retain this type of data.
The inspector stated that 'his would be considered an unresolved item pending further review of regulatory requirements and licensee-commitments regarding record retention.
(335/81-07-02)
8.
Confirmatory Measurements
'a ~
The results of the tritium and radiostrontium analyses of a liquid waste sample split on March 11, 1980 were discussed with the licensee and are presented in Tabl'e 1.
The radiostrontium concentrations were two low for a. valid comparison.
The inspector informed licensee representatives that, a spiked liquid sample would be submitted for analyses'he tritium reslts were in "possible agreement" with licensee values-,
higher than the NRC value.
This was probably.a result of the fact that the licensee did not distill the sample prior to analysis.
A licensee representative'ndicated that this was the normal procedure for liquid waste samples.
The inspector noted that this technique could lead to overestimating tritium releases and that the procedure should be revised.
A licensee representative agreed to revise the procedure for tritium analysis to provide for distillation of al'1 liquid release samples (335/81.-07-03)..
b.
Liquid and gaseous samples were collected during this inspection and counted by the license. and th NRC RII Mobile Laboratory to verify the licensee's capability to measure radionuclides in effluent samples.
Samples were analyzed by gamma ray spectroscopy and inclu'ded:
a waste holdup tank sample, a.reactor coolant sample, containment gas sample, and a
charcoal cartridge'ample.
A spiked particulat'e filter was counted by the licensee since a
sample with sufficient activity for comparison was not available.
An aliquot of the waste-holdup tank sample was sent to the NRC contract laboratory for H-3 analysis.
The results will be compared to licensee results in a later inspection report.
The licensee's
.computer-based multichannel analyzer system that is routinely used for counting samples was not-operational, and a
new system that was being installed was utilized in order to provide for-counting of samples for comparison.
THe licensee's Ge(Li) detector was unshielded and the higher background increased the uncertainties in.-
measurements.
The comparison of the licensee and NRC results are provided in Table II with the acceptance criteria in Attachment 2.
The liquid waste holdup tank and reactor coolant samples showed. agreement for all radionuclides.
The results of the containment
'gas showed possible agreement for Xe-133 and disagreement for Xe=135.
Licensee
results were higher than NRC val.ues which would lead to over-reporting of,. results.
The disagreement could not be determined and the licensee agreed to recalibrate the gas-geometries as soon as the NBS gases were available.
,The results from the charcoal cartridge showed disagreement for I-131.
and I-135.
The licensee values were higher than the NRC values due to the difference in counting techniques.
The licensee counts charcoal cartridges with the inlet side down and uses a
homogeneously spiked cartridge for efficiency calibration.
This technique would over-estimate the radioiodine concentration if the iodine is preferentially absorbed on the face of the cartridge.
The values obtained by the licensee as a result of counting the cartridge on each side for equal times were in agreement with the NRC results.
The inspector stated that the licensee should improve the counting technique to account for the actual distribution of radioiodine in the charcoal cartridges.
A
. licensee representative agreed to investigate techniques available to improve the accuracy of radioiodine measurements and modify procedures as necessary (335/81-07-04).
The results of the spiked filter analysis showed possible agreement for Co-57 and agreement for Cs-134'n view of the differences in the configuration of the spiked filter and, the licensee's filter'eometry, the results were acceptable.
c.
The inspector reviewed the decay parameters used in the computer nuclide library file and noted that the library had been updated.
This closes a previously identified item (335/80.-01-04).
Table
Results of Confirmatory Heasurements at St. Lucie, Harch, 1980 Concen ration Hlc peur les cc
~Sam le
~lsoto e
~SLucte NRC Ratio SLILSRC
~Resolu ion
~Com arl son Liquid
'aste 3"11-80 6 12:00 Sr-89 Sr-90 H3 1.8 E-7 2.5 E-8 7.6 E-2 0+1E-8
'C 025E-9
.
NC 6.2810.02 E"2 1.21 314 NC NC Possible Agreement
Table
Results of Confirmatory Measurements at St. Lucie, March, 1980 Concen ra lon Microcur Ies cc
~eam le Waste Holdup Tank Liquid 3-23-81 Mn-54 Co-58 Co-60 I-131 Cs-134 Cs-137 1.76%.3 E"6 4. 17i. 3 E-6 5.5li.09 E-5 9. 68i. 3 E-6 1'.571.06 E-5 4.]i.07 E-5
~lsoto e
~SLucle
~RC
\\
1.741.4 E-6 3e17i.5 E"6 5.37k. 1 E-5 8.9i.4 E-6 1.43i.06 E-5 3. 62'. 08 E-5 1. 01 1.32 1. 03 1. 09 1. 10 1.13 4. 35 6.54 53.7 22.5 23.83 45.25 Ag reement Agreement Agreement Agreement Agreement Ag reement Ratio
~SL RC
~Ress <<t los
~Com ar1 so Reactor Coo lant 3-23-81 6 16:00 No-24 Co-58
, Mn-54 I "131 1-132 I-133 1-135 8. 4io. 9 E-3 4.5i1.1 E"4 ND 4. 73i. 04 E"2 1. 1io. 3 2. 101. 03 E"2 B.BP0.9 E"3 8,210.2 E"3 3. 4iO. 5 E",4 5.010.7 E"4 4.362.02 E-4 1.45%0.08 E-'3 1. 96k. 02E-2 7.7i0.4 E-3 1.02 1. 32 NC 1.05
.79 1.07 1.40 416.8
220 100 100
Agreement Agreement Agreement Agreement Agreement Agreement Ag reement
.
Xe-135 2.12.6 E-4 Conta lnment Xe-133m ND Gas 3-24-81 Xe-133
. 3.48iOe10 E-3 3.210.6 E-5 2.77%.02 E"3 7.110.3 E"5 NC 1.26 2. 96 138
NC Possible Agreement Disagreement Charcoal Cartridge 3-24"81 12:00 1-131 I "132 I-133 1-135 Spiked Co-57 Particulate Fi I ter Cs-134 1.34 1.0 1. 37 1s70 1. 37 6. 3i0. 2 E-4 8.610.4 E-4 1.610.3 E-3 1.40i0.05 E-3 1.14.
9.28i.OB E-4 6.912.03 E-4 5i1 E-3 5.010.3 E-4
. 3. 9i. 06 E-2 2. 842. 02 E-2 1.7i0.2 E-2 1.010.2 E-2 230
142
31
Disagreement Agreement
'Isagreement Agreement Possible Agreement Agreement
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Attachment
CRITERIA FOR COMPARING ANALYTICALMEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements.-
The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this program.
In these criteria, the judgment 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 decreases.
LICENSEE VALUE NRC REFERENCE VALUE Resolution
~Areement Possible 'ossible A reement B
<34-7 8-15
, 16 50 51 200
>200.5.0.66 0.75 1.33 0.80 1.25 0.85 1.18.0.5 0.5 - 2.0.66 0.75 1.33 0.80 1.25 No Comparison.6.5.0.66 0.75 1.33
"A" criteria are-applied to the following analyses:
Gamma Spectrometry, where principal gamma energy used for identification is greater than 250 Kev.
'Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification is less than 250 Kev.
Sr and Sr Determinations.
Gross Beta where samples are counted on the same date using the same reference nuclid