IR 05000338/1980025

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IE Insp Repts 50-338/80-25 & 50-339/80-26 on 800519-23 & 0602.Noncompliance Noted:Failure to Have Adequate Procedure for Preservation of Milk Samples for Radioiodine Analysis
ML19347B029
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 06/24/1980
From: Montgomery D, Troup G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19347B022 List:
References
50-338-80-25, 50-339-80-26, NUDOCS 8010010283
Download: ML19347B029 (9)


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UNITED STATES

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NUCLEAR REGULATORY COMMISSION o

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ATLANTA, GEORGI A 3o3o3

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Report Nos. 50-338/80-25 and 50-339/80-26 Licensee: Virginia Electric and Power Company Richmond, Virginia 23261 Facility Name: North Anna Power Station, Units 1 and 2 Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 Inspection at North Anna Site near Mineral, Virginia

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[ /l7/ f O Inspector:

/ga D. M. Montgomery

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Accompanying Personnel:

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Approved by:

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G. L. Trouls, Acti g Section Chief, FF&MS Date Signed Branch SUMMARY Inspection on May 19-23, 1980 and June 2,1980.

Areas Inspected This routine, unannounced inspection involved 33 inspector-hours onsite in the areas of quality control and confirmatory measurements including: review of the laboratory quality control program; review of chemical and radiochemical proce-dures; quality control audits; comparison of the results of split samples analyzed by the licensee and the NRC Region II Mobile Laboratory; and environmental monitoring.

Results Of the five areas inspected, no items of noncompliance or deviations were identi-fled in four areas; one item of noncompliance was found in one area (Infraction -

failure to have an adequate procedure for preservation of milk samples for radioiodine analysis, (338/80-25-04, 339/80-26-04).

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DETAILS 1.

Persons Contacted Licensee Employees W. R. Cartwright, Plant Manager D. L. Bensen, Superintendent, Technical Services

  • D. M. Hopper, Health Physics Supervisor J. H. Horton, Chemistry Supervisor
  • J. D. Gilbert, Assistant Health Physics Supervisor
  • M. L. Johnson, Assistant Health Physics Supervisor
  • F. L. Thomason, Corporate Health Physicist
  • F. P. Miller, Quality Control Inspector A. H. Stafford, Health Physicist Other licensee employees contacted included three technicians.
  • Attended Exit interview 2.

Exit Interview

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The inspection scope and findings were summarized on May 23, 1980, with those persons indicated in Paragraph 1 above. A licensee representative agreed to perform the analyses referred to in Paragraph 9 and report the results to NRC:RII.

In addition, the apparent item of noncompliance was discussed with the Acting Plant Manager by telephone on June 10, 1980.

3.

Licensee Action on Previous Inspection Findings Not inspected.

4.

Unresolved items Unresolved items were not identified during this inspection.

5.

Laboratory Quality Control Program

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The inspector reviewed the licensee's quality control program for chemical

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and radiochemical measurements in the following areas:

a.

Assignment of responsibility and authority to manage and conduct the QC programs:

The Health Physics Supervisor is responsible for radiological measure-ments including the QC program for radiation detection instrumentation.

Authority to manage the day to day operations of the QC program has been delegated to an Assistant Health Physics Supervisor who is respon-sible for the counting room. The Chemistry Supervisor is responsible for the QC program for stable chemistry and associated instrumentation.

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b.

Provisions for Audits / Inspections:

Chapter 18 of the VEPCO Nuclear Power Station Quality Assurance Manual provides for annual audits in the areas of chemistry and health physics to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The Station Resident Quality Control Engineer is responsible for the implementation of the station audit program.

c.

Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified, and Corrected:

The individuals conducting audits are required to become familiar with the requirements of the areas to be audited and prepare an audit checklist that is approved prior to use. A written audit report is prepared and distributed within five days from the past audit conference.

All audit reports are reviewed by the cognizant supervisor and when, applicable, members of the Station Nuclear Safety Operating Committee.

The Quality Control Staff is responsible for follow-up action to:

(1) Obtain the written reply to the audit report.

(2) Evaluate the adequacy of the response.

(3) Assure that corrective action is identified and scheduled for each recommendation.

(4) Assure that any required auditee follow-up reply is received when due.

(5) Confirm that corrective action is accomplished as scheduled, d.

Quality Control of Purchased and Contracted Services Analyses of composite liquid effluent samples for Sr-89, Sr-90, and P-32 are contracted to Teledyne Isotopes, Inc. The Teledyne quality assurance program was audited by Corporate Quality Assurance (Audit Number 78-57) and found to be acceptable. Teledyne Isotopes was added to the list of approved vendors for radiochemical analyses.

This review of the licensee's Q.C. program closes out a previously identified item (78-07-01).

6.

Review of Chemistry and Radiochemistry Procedures j

The inspector reviewed the following procedures:

a.

(1)

HP-3.3.9 Health Physics Survey - Minimum Detectable l

Activity (MDA) Dr *crmination, 4/23/79

(2)

HP-3.4.1.1 Health Physics Count Room - Instrumentation Operations Beckman Liquid Scintillation Counter LS-100C, 4/23/79

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HP-3.4.1.2 Health Physics Count Room - Instrument Operation Nuclear Measurements Corporation Proportional Counter PC-4, 4/23/79 (4)

HP-3.4.1.3 Health Physics Count Room - Instrument Operation Nuclear Data ND 6600 Multichannel Analyzer, 3/12/80 (5)

HP-3.4.1.5 Health Physics Count Room - Instrument Operation Nuclear Measurements Corporation Proportional Counter PC-5, 4/23/79 (6)

HP-3.4.1.6 Health Physics Count Room - Instrument Operation Nuclear Measurements Corporation Decade Scaler DS-3, 4/23/79 (7)

HP-3.4.1.7 Health Physics Count Room - Instrument Operation Eberline Instrument Corporation Mini Scaler MS-2, 4/23/79 (8)

HP-3.4.1.8 Health Physics Count Room - Instrument Operation Nuclear Data ND-100 Multichannel Analyzer, 4/23/79 (9)

HP-3.4.2.1 Health Physics Count Room - Instrument Calibration Beckman Liquid Scintillation Counter LS-100C, 9/27/79 (10) HP-3.4.2.2 Health Physics Count Room - Instrument Calibration Nuclear Measurements Corporatian Proportional Counter PC-4 or PC-5, 9/27/79

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(11) HP-3.4.2.3 Health Physics Count Room - Instrument Calibration Nuclear Data ND 6600 Multichannel Analyzer, 3/12/80 (12) HP-3.4.3.1 3ealth Physics Count Room - Standard Source Preparation, 4/16/79 (13) CP-11 Boron High Range Titration, 11/18/77

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(14) CP-12 Boron, Colorimetric, 12/2/77 (15) CP-32 E Calculation, 12/21/78 (16) CP-33 Fluoride, 3/24/77 (17) CP-34 Fluoride, Specific Ion Electrode, 2/11/77 (18) CP-38 Gross Activity, Beta-Gamma, 4/14/78 (19) CP-63 0xygen, Dissolved, Indigo Carmine,- 3/24/77 (20) CP-64 0xygen, Dissolved, Winkler, 6/21/78

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The in. jector discussed the results of the procedure review with licensee representatives as noted in paragraphs 6.b, 6.c, and 6.d.

b.

The inspector noted that the calibration procedure for the liquid scintillation counter (HP-3.4.2.1) requires daily operational checks, but does not specify acceptance criteria or corrective action to be taken. The procedures for operation and calibration of the PC-4 or PC-5 proportional counters, did not require daily response checks with acceptance criteria and corrective action to be taken. The procedures for the operation and calibration of the Ge(Li) gamma ray spectroscopy system (ND6600) did not specify any performance checks or background checks. The inspector noted that as a minimum there should be a daily response check for efficiency, resolution and energy calibration of the Ge(Li) systems with applicable acceptance criteria and corrective action to be taken.

A licensee representative agreed to add the performance check requirements along with acceptance criteria and corrective action, where necessary, for the liquid scintillation counter, PC-4 and PC-5 proportional counters, and the Ge(Li) Gamma Spectroscopy System (ND6600). (338/80-25-01,339/80-26-01).

c.

The inspector determined from licensee representatives that efficiencies of the proportional counters for air filter samples and liquids were determined using a Sr-90 source deposited on stainless steel. The inspector noted that this could overestimate the counting efficiency since the radionuclides commonly measured in air and water samples would have lower beta energies. A licensee representative agreed to review the calibration technique to determine if corrective action is necessary (338/80-25-02, 339/80-26-02).

d.

The inspector verified that the Ge(Li) counting systems met the detec-tion capabilities as defined in Technical Specifications 2.2.2 and 2.2.4 for liquid and gaseous wastes. The inspector noted to licensee representatives that the detection capabilities for the analysis of the daily liquid release composite were met for the primary gamma emitters present in the waste, but the uncertainty in the measurements should be improved by increasing the counting time. This would provide for more accurate accounting of the quantities of radioactivity released via liquid effluents and identify other radioisotopes with lower gamma ray abundances. A licensee representative agreed to modify the procedure for counting the daily liquid effluent composite and count for a longer time which would be dictated by the impact on the counting room schedule and the need for more sensitive analyses. (338/80-25-03, 339/80-26-03).

7.

Review of Records and Logs The inspector reviewed selected sections of the following records and logs j

and had no further questions:

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Calibration Records for Spectronic - 20,11-78 to 5-80.

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b.

Calibration Records for pH meters, 7-79 to 5-80 c.

Calibration Records for Analytical Balances,12-76 to 12-79.

d.

Calibration Curve for Boron Determination,1-8-80 and 5-14-80.

e.

Ge(Li) Calibration Recor s 5-80.

d f.

Liquid Scintillation Calibration Records, 5-22-79 to 4-3-80.

g.

Liquid Scintillation Counter Daily Response Checks,12-79 to 5-79.

h.

Calibration and Plateau Records for PC-4 and PC-5 Counters, 12-77 to 2-80.

i.

Daily Performance Checks for Ge(Li) Counters 1-79 to 5-80.

j.

Chemistry Quality Control Sample Results, December 1979, January 7, 1980, and May 5,1980.

8.

Review of Audits The inspector reviewed the following Quality Assurance audits in the areas of Chemistry and Health Physics and had no further questions:

a.

Audit N19-13, April 19,1979, Chemistry Audit b.

Audit N79-27, 4-20-80, Health Physics and Radiological Controls.

9.

Confirmatory Measurements j

Liquid and gaseous samples were collected during this inspection and counted by the licensee and the NRC RII Mobile Laboratory to verify the licensee's capability to measure radionuclides in effluent samples. The samples were analyzed by gamma ray spectroscopy and included samples from a liquid waste tank, reactor coolant, waste gas decay tank, and station vent (charcoal cartridge and particulate filter).

The particulate filter activity was too low for a valid comparison and a spiked filter will be sent to the licensee for analysis.

An aliquot of the liquid waste tank sample was sent to the NRC contract laboratory for H-3, Sr-89, and Sr-90 analyses. The licensee was requested to perform the same analyses and report the results to NRC:RII for comparison. The results of the licensee and NRC analyses are

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presented in Table I with the acceptance criteria in Attachment 1.

The data show agreement for all radionuclides.

10.

Environmental Monitoring The inspector determined from a licensee representative that Procedure H.P.-REMM-4, dated Septer.ber 27, 1979, for collection of environmental samples specifies preservation of milk samples for radiciodine analyses by addition of ten milliliters of 37% formaldehyde per gallon of milk. The inspector

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noted that this preservation method would cause protein binding of radio-iodine and would make the samples unsuitable for analysis by io..:xchange since protein bound iodine would not be recoverable. A licensee representa-tive stated that Teledyne Isotopes performed the analysis by ion exchange and supplied a copy of the procedure. The inspector informed a licensee representative by telephone on June 10, 1980 that the preservation technique for milk samples was not compatible with the separation procedure used by their contractor for radioiodine analysis, and this constituted an item of noncompliance with Appendix B Environmental Technical Specification 5.5.1, that requires detailed written procedures, including applicable checklists and instructions, be prepared and followed for all activities involved in carrying out the Environmental Technical Specifications. Technical Specifi-cation 5.5.1 further requires that procedures include sampling, data recording and storage, instrument calibration, and measurements and analyses. The written and approved Procedure H.P.-REMM-4 was inadequate in that the preservation method for milk was not compatible with the radiciodine analysis procedure (338/80-25-04, 339/80-26-04).

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Table 1 Results of Confirmatory Measurements at North Anna

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May 19-23, 1980 Concentration, microcuries/cc Ratio SAMPLE ISOTOPE NORTH ANNA NRC NORTH ANNA /NRC COMPARISON W rte Gas Kr-85 ND 1.810.6E-3

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Decsy Tank Xe-131m ND 6.0il.2E-4

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5/22/80, 10:15 Xe-133m 2.610.5E-4 3.610.3E-4 0.72 Agreement Xe-133 6.4510.0.2E-2 7.2210.02E-2 0.89 Agreement Xe-135 1.63.10E-4 1.7010.06E-4 0.96 Agreement Liquid Waste Co-58 1.841 18E-6 2.0510.15E-6 0.90 Agreement LW-TK-3B Co-60 3.510.3E-6 3.810.2E-6 0.92 Agreement 5/21/80, 10:22 I-131 1.2910.15E-6 1.4810.14E-6 0.87 Agreement Cs-134 5.6010.3E-6 5.4810.23E-6 1.02 Agreement Cs-137 1.10t0. 03E-5 1.1110.03E-5 0.99 Agreement Na-24 1.5710.23E-6 1.1610.23E-6 1.35 Agreement Charcoal Cartridge I-131 1.2210.13E-12 1.1510.10E-12 1.06 Agreement 5/21/80, 07:38 I-133 411E-13 4.1810.9E-13 0.96 Agreement Vent A Reactor Coolant I-131 3.610.7E-3 3.110.2E-3 1.17 Agreement

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5/21/80, 13:45 I-132 1.6510.03E-2 1. 3510. 05E-2 1.22 Agreement I-133 9.510.2E-3 9.910.2E-3 0.96 Agreement i

I-134 2.710.2E-2 2. 30t0. 2E-2 1.17 Agreement I-135 1.510.2E-2 1.810.1E-2 0.83 Agreement Cs-137 I.4410.14E-3 1.310.2E-3 1.I1 Agreement Ba-139 5.711.4E-3 4.711.4E-3 1.21 Agreement Na-24 1.3910.01E-1 1.2010.OIE-1 1.I6 Agrecment

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Atta b ent 1

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Ch!TI F.1/. Fi% COMPAR1 ? C AM!iTiCAL !b.4 Sl'P.D!ENTS

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1his attach ent provider. criteria for conparing results of capability tests and verification measurements.

The cet t eria are based on an e.pirical s el.:t ionship which cor.b ner prior experience and the accuracy needs of t:15 p r or,ra m.

I n t h. r e t r i t e:'i.e. t he judr. ment limit, ate vatlable in relation to the conparisor. of tt..

RC Kef erence Laboraterv's vaine to its associated un<ertainty. As that ratio, referred to in this program as " Resolution",

inc r e..rer., t he e.cceptabil it y of a l i. en..ce 's ne.isur ement should be raere s. l ec t ive, conver m ly, poorer agre.- cet nust be considered acceptable a-t in-re nlut inn decreares.

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(Al.t E Pos.sible Possible Eer.olution A reement Atreenent A Acreement E

<3 0.4 - 2.5 0.3 - 3.0 No Comparison 4-7 0.5 - 2.0 0..'.

- 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5 16 - 50 0.75 - 1.33 0.6 - 1.66 0.5 - 2.0 51 - 20r, 0.8n - 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:

Comma Spectrometry where principal garna energy used for identificat ion is greater than 250 Kev.

1ritium analyses of liquid saeples.

"B" criteria are applied to the following analyses:

Guna Spectrometry where ;.-Incipal ga:tro energy used for identification is lese than :'50 rev.

"Sr and "Sr Det err inat ions.

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Cross lieta where samples are count ed on the same date using the same reference nueIide.

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