IR 05000335/1982014

IE Insp Rept 50-335/82-14 on 820419-22.No Noncompliance Noted.Major Areas Inspected:Qc & Confirmatory Measurements Including Review of Lab QC Program,Chemistry & Radiochemistry Procedures & Airborne Effluent Sampling

ML20054H109
Person / Time
Site:	Saint Lucie
Issue date:	05/20/1982
From:	Evans C, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054H103	List: IR 05000335/1982014 ML20054H102
References
50-335-82-14, NUDOCS 8206220581
Download: ML20054H109 (9)

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1. h, UNITED STATES P 't, NUCLEAR REGULATORY COMMISSION

• - r REGION 11

h 101 MARIETTA ST., N.W., SulTE 3100 ATLANTA, GEORGIA 30303 o

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Report No. 50-335/82-14 Licensee: Florida Power and Light Company P. O. Box 529100 Miami, FL 33152 Facility Name: St. Lucie 1 Docket No. 50-335 License No. DPR-67 Inspection at St. Lucie site near Ft. Pierce, FL Inspector: - [2 lh 97% [. (' d 6 - F 1 C. D. Evans > d b Date Signed Accompanying P rsonnel: ,P. E. McPhail Approved by: '

Li'l s1'lL i t;) h0* $h D. M. Montgomery 4 Chiqrf Date Signed Independent Measurements and Environmental Protection Section EPOS Division SUMMARY Inspection on April 19-22, 1982 Areas Inspected This routine, unannounced inspection involved 30 inspector-hours on site in the areas of quality control and confirmatory measurements including: review of the laboratory quality control program; review of chemistry and radiochemistry procedures; airborne effluent sampling and accountability; and comparison of the results of split samples analyzed by the licensee and the NRC RII Mobile Labora-i tor Results Of the 5 areas inspected, no violations or deviations were identified in 5 area U O$fogoy}5 PDR

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DETAILS Persons Contacted Licensee Employees

*N. G. Rous, Quality Control Supervisor
*D. A. Sager, Operations Supervisor
*A. W. Bailey, Quality Assurance Operations Supervisor
*R. P. Frechette, Chemistry Supervisor
*R. E. Cox, Chemistry Foreman Other licensee employees contacted included one technicia NRC Resident Inspector
*S. A. Elrod
* Attended exit interview Exit Interview The inspection scope and findings were summarized on April 22, 1982, with those persons indicated in paragraph 1 abov . Licensee Action on Previous Inspection Findings (Closed) Unresolved (335/81-07-02) Retention of instrument performance check The inspector was informed by licensee representatives that they have no regulatory requirements or procedural requirements to retain instrument performance checks. The inspector stated that performance checks should be maintained for the period between recalibration, as a minimu The inspector also noted during this inspection that gamma spectral analysis data associated with grab samples from plant effluent releases are not kept as part of the permanent radioactive release records. The inspector stated that the discarding of the gamma spectral analysis data prevents evaluating possible discrepancies that might result later concerning effluent release The inspector noted that the licensee is meeting regulatory requirements for record retention and this item is considered close . Li.-asolved Items Unresolved items were not identified during tnis inspection Laboratory Quality Control Program The inspector reviewed the licensee's quality control program for chemical and radiochemical measurements in the following areas:

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a. Assignment of Responsibility to manage and conduct the QC Progra The requirements for the chemistry quality control program are given in QI 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 chemistry and environmental M&TE, refer-ence standards, test standards and reference sources according to approved procedure (2) Identification in listings, logs, or schedules all M&TE, reference standards, and reference source (3) Maintenance of current records, calibration data, and status of items listed in (2).

(4) Establishment of calibration cycles and a recalibration progra (5) Investigation, where possible, of the consequences due to the use of nonconforming M&TE and reference standard (6) Training chemistry personnel in proficient use of items (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 me b. Provisions for Audits / Inspections 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, controlled or maintained according to approved plant procedures, technical specifications, regulatory requirements and FP&L Quality Assurance Manual requirements. The Quality Control Supervisor is responsible for scheduling and carrying out Quality Assurance Surveillance c. Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Correcte The Chemistry Supervisor is responsible for identifying and correcting deficiencies that are identified by the Quality Control progra In addition, the Quality Control Surveillances that are carried out by the Quality Control personnel provide for documentation of all nonconform-ing 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 . . . 3 Review of Quality Assurance Audits The inspector reviewed the most recent audit report (No QA0-PSL-81-09-229) conducted by the Corporate Quality Assurance Department of the

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Radiochemistry Department. . The scope _ of the audit was to verify implementation of applicable onsite portions of the St. Lucie Unit I radiological effluent technical specification No items of. non-compliance were identified in the audit. The inspector noted that the audit does not address laboratory quality controls that would insure valid radiological effluent measurement . Review of Chemistry and Radiochemistry Procedures The inspector reviewed the following procedures:

(1) C-48A, " Operation of the ND 6685 Computer Based Counting System,"

11-11-8 (2) C-40, " Determination of Tritium",1-15-8 (3) C-37, " Determination of Gases2 N ,2 0 . 2H )",3-12-82 (4) C-38, " Calibration of Flow Measuring Devices", 4-4-8 (5) C-01, " Schedule for Periodic Tests",1-15-8 (6) C-41, " Determination of Iodine", 6-5-8 (7) C-72, " Processing Gaseous Wastes", 8-31-8 (8) C-16, " Determination of Hydrazine", 4-8-8 (9) C-42, " Chemical Separation of Strontium.and Barium",1-10-7 The procedure review was discussed with licensee representatives as discussed in paragraphs 6b-6 The inspector reviewed Procedure C-72, " Processing Gaseous Wastes" and noted that decay corrections for radiciodine were made at the midpoint of the sampling perio This closes a previously identified item (335/81-07-02). ' This inspector noted that Procedure C-72 specified an efficiency of 75's for the collection of tritiated vapor by the gas sampling impinge The inspector not n' that this valve was probably conservative and that tests to determine a more representative valve of sampling conditions should be done. Licensee representatives agreed to perform an evalua-tion of the collection efficiency of the gas sampling impinger. This area will be reviewed in a subsequent inspection (50-335/82-14-01).

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. . 4 The inspector reviewed Procedure C-40, " Determination of Tritium", and noted that liquid composite samples were distilled to separate the tritiated water from interfering radionuclides prior to analysis. This closes a previously identified item (335/81-07-03).

7. Review of Records and Logs The inspector reviewed the following records and logs:

(1) Geometry Calibration Curves (a) 4-liter marinelli , 6-10-8 (b) RCS 16 ml . glass vial, 2-9-8 (c) 4600 ml. gas marinelli beaker, 3-18-8 (d) 95 ml . gas chamber, 3-19-8 (2) Waste Gas Decay Tank Reledse Permits 82-14 through 82-17, 3-27-82 to 4-9-8 (3) Daily Ge(Li) Resolution and Response Checks, 3-31-82 to 4-16-8 (4) Daily Tritium Ef ficiency Determination, 3-25-82 to 4-10-8 (5) Beer's Law Calibration Curves for Spectronic 7 (a) Silica, 12-22-8 (b) Chromate, 1-26-8 (c) Hydrazine, 9-8-8 The inspector noted that the calibration curve for the determination of hydrazine by absorption measurements using the Spectronic 70 spectro-photometer was more than a year old. The inspector was informed by a licensee representative that no recalibration had been done as this analysis is used only during start up when hydrazine is added to the primary coolant for oxygen contro The inspector expressed concern that there may not be adequate procedural control to insure a recali-bration before the next start-up. Licensee representatives indicated they would evaluate the concern identified by the inspector. This area will be reviewed in a subsequent inspection (50-335/82-19-02). The inspector determined from discussions with licensee representatives that the charcoal cartridges used for radioiodine sampling were not TEDA impregnated and may not be as efficient for organic radiciodine species. The inspector noted that collection efficiencies for cart-ridges in use should be tested or documented for the radiciodine species actually released or expected to be release Licensee representatives indicated that they would evaluate the area of concern identified by the inspector. This area will be reviewed in a sub-sequent inspection (50-385/82-14-03).

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8. Confirmatory Measurements Liquid and gaseous samples were collected during this inspection and counted by the licensee and the NRC RII Mobile Laboratory to verify the

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licensee's capability to measure radionuclides in effluent and reactor coolant samples. Samples were analyzed by gamma ray spectroscopy and included: a liquid waste holdup tank sample, reactor coolant sample, crud filter sample, containment gas sample, and a containment charcoal cartridge. The crud filter was counted in lieu of a particulate filter since a particulate filter with sufficient activity for analysis was not availabl The comparisons of licensee and NRC results are presented in Table 1 with acceptance criteria in Attachment 1. The results show agreement for all samples. An aliquot of the liquid sample was sent to the NRC contract laboratory for tritium and radio-strontium analyses. The results will be compared to licensee results in a subsequent inspection report (50-388/82-14-04). The inspector reviewed licensee results for H-3, Sr-89 and Sr-90 analyses of a spiked sample prepared by the NRC contract laborator The comparison of licensee results with the values of the spiked sample are given in Table 2, with acceptance criteria in Attachment The comparisons shows "possible agreement" for H-3, " agreement" for Sr-89, and " disagreement" for Sr-90. No reason could be found to explain the 32*a higher valve for H-3 reported by the licensee. The inspector noted that the efficiency determination in Procedure C-42, " Chemical Separa-tion of Strontium and Barium", did not involve the preparation of separate standards for Sr-89, Sr-90, and Sr-90/Y-90 in the same geometry as the separated sample which may attribute to the " disagree-ment" for Sr-90. A licensee representative agreed to evaluate the methology for the efficiency determination and to analyze another spiked sample to be provided by the NRC. This area will be reviewed in a subsequent inspection report (50-335/82-19-05).

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_ _. & t n e m e e r g N A O tttt ttt tttt tt tt tttt t S nnnne nnn nnnn nn nn nnnn n I eeeel eee eeee ee ee eeee e R mmmmb mmm mmmm mm mm mmmm m A eeeei eee eeee ee ee eeee e P eeees rrrrs eeerrr ecee rr r r

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M r O ggggo ggg gggg C. g gr C. g g gggg g C AAAAP AAA AAAA NAANAA AAAA A N O 2 I 8 T 29726 668 1135 381421's 5166 0 9 /6 1 1 t 1 7 41 1 O 1

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1i11 1 A E E 46134 348 9339 008277 9201 0 T R I 07767 348 4642 444208 9422 1 U R . . . . . S U 14322 211 8816 131714 2211 1 A C E O M R C Y 1 R M O T . A 4 f M O R l I N B,0O000 Af 4l4455 O24 O00 0OO0 6f4S5 54 45 2222 2 00 00 0000 0 HE - - - - - - - - - - - - - - - - - O I S EEfEE EEE FLEE LE EE EEEE E C NN Ff 72030 166 14412 .30 30 0911 5 f CC 46297 469 7760 6833 0 O NI . . .. D.3 4.D.1 3

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TABLE 2 l HESULTS Of SPl>ED SAMPLE ANALYSES

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- l CONCENTRAT_ TON,_MICROCUR1[S/CC t SAMPLI IS010PJ _SL LUC 1i NRC ST. LUCIE/NRC ftESOLUT4ON COMPARISON , . , ! ItESL Spike 11 - 3 8 . 2's E-3 6.2210.06 E-3 1.32 1 014 Possible Agreement.

i S r-89 /. / l-3 I.38t.08 E-3 1 . 014 ')2 Agreement r S r-90 8.2 E-5 5.871.24 E-04 .15 2 14 Disagreement i

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os . Attachment 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS 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 progra In these criteria, the judgment limits are variabic in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertaint As that ratio, referred to in this program as " Resolution", increases, the acceptability of a licensee's measurement should be more selectiv Conversely, poorer agreement must be considered acceptable as the resolution decrease LICENSEE VALUE

  " NRC REFERENCE VAI.UE Possible Possible Resolution Agreement Agreement A Agreement B
<3  0.4 - .3 - No Comparison 4- 7 0.5 - .4 - .3 - .6 - 1.66 0.5 - .4 - .75 - 1.33 0.6 - 1.66 0.5 - .80 - 1.25 0.75 - 1.33 0.6 - 1.66
>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33
"A" criteria are applied to the following analyses:

Camma Spectrometry where principal gamma energy used for identification is greater than 250 Kev.

! ' Tritium analyses of liquid sample "B" criteria are applied to the following analyses: Canna Spectrometry where principal gamma energy used for identification is less than 250 Ke "Sr and Sr Determination Gross Beta where samples are counted on the same date using the same reference nuclid _,

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