IR 05000338/1985025
| ML20198B099 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/10/1985 |
| From: | Cline W, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20198B048 | List: |
| References | |
| 50-338-85-25, 50-339-85-25, NUDOCS 8511060293 | |
| Download: ML20198B099 (12) | |
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$ CEGo UNITED STATES i
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o NUCl. EAR REGULATORY COMMISSION
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101 MARIETTA STREET,N.W.
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OCT 2 21985 Report Nos.: 50-338/85-25 and 50-319/85-25 i
Licensee: Virginia Electric and Power Company Richmond, VA 23261 Docket Nos.:
50-338 and 50-339 License Nos.: NPF-4 and NPF-7
Facility Name: North Anna 1 and 2 Inspection Conducted: S ptemb d6-25, 1985 Inspector:
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fG.' B. 'KuzV D#te Sig/ied l
Accompanying Per onnel:. J.
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Approved by:
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h". ii. dCTin&T'Section Chief Dath Signed
Emergency Preparedness and Radiological Protection Br,anch Division of Radiation Safety and Safeguards SUMMARY
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Scope: This routine, unannounced inspection entailed 69 inspector-hours onsite in the areas of radiochemistry quality control and confirmatory measurements i
including review of the laboratory quality control prog ram, procedures and instructions, records and logs, counting room and chemistry laboratory
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facilities, and results of split samples analyzed by ti.a licensee and the NRC Region II Mobile Laboratory and contract laboratory facilities.
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Results:
Violation - failure to have adequate procedures to meet effluent
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analytical measurement requirements.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees E. R. Smith, Assistant Station Manager
- J. A. Stall, Superintendent Technical Services
- J. Leberstien, Licensing Coordinator
- A. H. Stafford, Superintendent, Health Physics
- 0. E. Hickman, Supervisor, Health physics
"J.
G. 0connell, Assistant Health Physics Supervisor
- F. L. Thomasson, Supervisor Health Physics, Corporate
- L. G. Miller, Supervisor, Chemistry
- F. T. Terminella, Supervisor, Quality Control Other licensee employees contacted included technicians and office personnel.
NRC Resident Inspector
- J. G. Luehman
- Attended exit interview 2.
Exit Interview i
The inspection scope and findings were summarized on September 20, 1985, with those irsons indicated in Paragraph 1 above.
Two open items concerning 4libration of gamma spectroscopy systems for the particulate filter geometry (Paragraph 8.a.) and evaluation of analytical techniques for H-3 and Fe-55 analyses (Paragraph 8.b) were discussed. The inspectors noted that failure to have adequate procedures for gamma spectroscopy calibrations and for determination of gamma spectroscopy system lower limits of detection (LLD) was considered an Unresolved Item * pending review by Region II management.
On September 30, 1985, the inspectors notified licensee representatives by telephone that failure to have adequate procedures to
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meet required effluent analytical measurements was considered a violation (Paragraph 6.b.).
Licensee management representatives acknowledged the inspectors' comments.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
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- An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviation.
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3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Laboratory Quality Control Program (84725)
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The inspectors reviewed selected portions of the radiochemistry and chemistry Quality Assurance (QA) programs against Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs.
The inspectors noted that management organization and approved procedures for the radio-chemistry and chemistry QA programs had not changed since the previous inspection (50-338/83-26 and 50-339/83-26).
No violations or deviations were identi fied.
5.
Audits (84725)
Technical Specification 6.5.3.1 requires the Quality Assurance Department to audit station activities encompassing the conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months; the station Emergency Plan and implementing procedures at least once per 12 months; the radiological
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environmental monitori,ng program and the results thereof at least once per 12 months; and the Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.
The inspectors reviewed the following audit reports:
a.
VEPC0 QA Engineering Audit of Teledyne Isotopes Incorporated, October 17, 1984 b.
Audit No. N-84-04 Chemistry, May 7, 1985 c.
Audit No. N-85-06 Health Physics - Dose Control and Administration, July 5, 1985 d.
Audit No. N-85-09 Radiological Environmental Monitoring, May 8, 1985 Audit No. N-84-14 Offsite Dose Calculations Manual, July 18, 1984 e.
The inspectors discussed the audits and reviewed corrective actions taken by the licensee. The inspectors noted that, in general, corrective actions had been taken or were being followed systematically to resolve items of concern.
No violations or deviations were identified.
6.
Procedures (84725)
a.
Technical Specification 6.8.1 requires written procedures to be established, implemented, and mainta ned covering the applicable
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procedures recommended in Appendix A of Regulatory Guide 1.33,
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Revision 2, February 1978; Offsite Dose Calculation Manual imple-l mentation; and the Quality Assurance Program for effluent environmental
monitoring, using the guidance in Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975.
The inspectors reviewed the following procedures:
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l (1) CAP - 13.0 Quality Control Program, 8/28/85
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(2) CAP-3 Assigning and Checking of Expiration Dates, 7/31/85 l
(3) CSI-2.0, Primary Isotopic Analysis, 7/11/84 (4) HP-3.2.1 Radioactive Gaseous Waste Sampling i
(5) HP-3.2.2 Radioactive Gaseous Waste Release Records and Reports, l
2/29/84 i
j (6) HP-3.2.3 Radioactive Liquid Waste Sampling, 7/16/85 (7) HP-3.2.13 Accidental, Unplanned or Uncontrolled Radioactive j
Gaseous Waste Releases, 2/29/84 (8) HP-3.3.2 Hea,lth Physics Survey - Air Sampling, 4/4/85
(9)
HP-3.3.9 Minimum Detectable Activity (MDA) Determinations, i
12/30/81
(10)
HP-3.4.1.1 Health Physics Count Room - Instrument Operation, Beckman Liquid Scintillation Counter LS-100C,12/30/81 i
(11)
HP-3.4.1.2 Health Physics Count Room - Instrument Operation, Nuclear Measurements Corporation Proportional Counter PC-4, 12/30/81
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HP-3.4.1.3 Health Physics Count Room - Instrument Operation,
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Nuclear Data ND6700 Multichannel Analyzer, 2/7/85
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HP-3.4.1.5 Health Physics Count Room - Instrument Operation, l
Nuclear Measurements Corporation Proportional' Counter PC-5,
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HP-3.4.1.9 Health Physics Count Room - Instrument Operation, Daily l
Operation Response Test, 8/30/84
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HP-3.4.2.1 Health Physics Count Room - Instrument Calibration,
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Beckman Liquid Scintillation Counter LS-100C, 7/28/82
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HP-3.4.2.3 Haalth Physics Count Room - Instrument Calibration,
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Nuclear Measurements Corporation Proportional Counter PC-4 or
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i PC-5, 5/19/82
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HP-3.4.2.3 Health Physics Count Room - Instrument Calibration, Nuclear Data ND6700 Multichannel Analy.ier, 2/7/85 (18)
HP-3.4.3.1 Health Physics Count Room -
Standard Source Preparation, 11/30/83 The inspectors discussed results of the procedure review with cognizant licensee representatives as noted in Paragraph 6.b.
b.
The inspectors reviewed with cognizant licensee representatives concerns regarding selected procedures needed to meet regulatory compliance for effluent measurements. Licensee representatives stated that required detail concerning procedures was provided in training and that additional information in the procedures was unnecessary.
The inspectors noted using selected examples that procedural details and/or training was inadequate to meet regulatory compliance for effluent measurements.
Examples of inadequate procedures regarding effluent measurement analytical capability were as follows:
(1) The inspectors reviewed procedures concerning calibration and use of the gamma spectroscopy systems. Current procedures regarding
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the systems did not detail the need for standardization between calibration and normal sample geometries. The inspectors reviewed
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guidance presented in ANSI N42.14-1978, Calibration and Usage of Germanium Detectors for Measurement of Gamma Ray Emission of Radionuclides, which states that samples should be analyzed in the same geometry as the calibration source or that appropriate corrections made.
In a specific example, the inspectors noted that the current geometries for the particulate filter calibration standard and normal sample analysis differed.
This difference accounted for the biased results noted in Paragraph 8.a.
(2) The inspectors noted that the determination of the Lower Limit of Detection (LLD) as noted in procedure HP-3.3.9 dif fered from the computational formula detailed in Technical Specification Tables 4.11-1 and 4.11-2.
Discussion with cognizant counting room personnel verified that the Technical Specification formula was not implemented for determination of regulatory compliance.
The inspectors informed licensee representatives that LLD deter-minations must be consistent with Technical Specifications.
Fr.llowing review of procedures by NRC Region II management, the inspec-tors notified licensee representatives by telephone on September 30, 1985, that the above items were considered an apparent violation of failure to have adequate procedures to meet required effluent measurement capability (50-338/85-25-01 and 50-339/85-25-01).
No deviations and one violation was identified in this program are _-.
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7.
Records (84725)
a.
The inspectors reviewed selected portions of the following records and logs:
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(1) Gamma Spectroscopy System Detector Nos.1 (Serial No. 24-P-445C),
2 (Serial No. 21-P-846A), and 3 (Serial No. 21-P-839A) Quality Control Logs for January - September 1985 including:
(a) Daily Energy Calibration Check (b) Daily Resolution Check (c) Daily Response Check (d) Weekly Background Check I
(2)
1985 Annual Efficiency Calibrations for Gamma Spectroscopy System Detector Nos.1, 2, and 3 for the following geometries:
100 ml Cup, 15 ml Vial, Face-loaded Charcoal Filter, 47mm Particulate Filter, 100 cc Gas Chamber, 1000 ml Marinelli Beaker.
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(3) Gamma Spectroscopy System Detector Nos. 1, 2 and 3 Response Checks for Annual Calibration Comparisons,
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j (4) Nuclear Measurements Corporation Proportional Counter PC-5
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Nos. 1126 and 1670 Quality Control Records for January -
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September 1985 including:
(a) Monthly Voltage Plateaus
(b) Monthly Calibration Records (c) Quality Control Charts: Daily Response and Background Checks
(5) Liquid Scintillation Counter LS-100C Quality Control Records and Calibration Data for January - September 1985 including:
(a) Daily Response Checks (b) Delly Background Checks (c) Monthly Tritium Calibrations (6)
Interstation and Corporate Cross-Comparison Results April -
July 1985 (7)
1985 Chemistry Cross Check Results (8) Quality Control Charts and Logs for the following Colormetric Analyses:
Silica, Ammonia, Hydrazine (9) Primary and Secondary Chemistry Logs for September 1985 including the following analyses:
Chloride, Fluoride, Dissolved Oxygen, Sodium, Silica, Hydrazine, Boron (10) Gaseous Waste Release Reports, January - September 1985 i
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Results of the record review were discussed with cognizant licensee representatives as noted in Paragraph 7.b.
b.
The inspectors noted during review of selected gaseous waste release
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reports that numerous sample parameters for the gamma spectroscopy data
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analyses sheets were mislabelled.
Further inspection disclosed that the identified mislabelled parameters did not result in inaccurate analyses.
However, the inspectors noted that additional detail in procedures and/or training should be evaluated to minimize these errors.
Licensee representatives agreed to evaluate this item.
No violations or deviations were identified.
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8.
Confirmatory Measurements a.
During the inspection, reactor coolant and selected liquid and gaseous plant effluent process streams were sampled and the resultant sample matrices analyzed for radionuclide concentration using licensee and NRC Region II Laboratory gamma-ray spectroscopy systems.
The purpose of these comparative measurements was to verify the licensee's capability to measure radionuclides accurately in various plant systems. Analyses
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were conducted utilizing as many of the licensee's gamma spectroscopy systems as practicable. Sample types and counting geometries included the following: reactor coolant sample, 100 ml cup; liquid waste, 11
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marinelli beaker; charcoal cartridge, face-loaded; gas, 100 cc bomb. A spiked particulate filter sample type was provided for analysis in lieu of licensee samples which did not have sufficient levels of activity l
for analysis.
Comparison of licensee and NRC results are listed in l
Attachment 1.
Excluding the particulate filter geometry, all results i
were in agreement. For the particulate filter geometry, Cs-137 was in disagreement using Detector No. 3.
In addition, the inspectors noted that results for the particulate filter using all detectors were biased approximately 20% to 30% above the known values.
This bias for the
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particulate filter was observed in results from previous inspections l
(IE 50-338/82-36, 50-339/82-36, 50-338/83-26, and 50-339/83-26).
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Further inspection discloe?d that the licensee placed the particulate
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filter geometry source in a petri dish during calibration; whereas, i
during routine gamma spectroscopy analyses particulate filter samples were placed in plastic bags and put directly on the detector.
This
difference between the calibration and normal sample geometries
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resulted in the observed trends.
The inspectors noted that ANSI N42.14-1978, Calibration and Usage of Germanium Detectors for Measurement of Gamma-Ray Emission of Radionuclides states that samples should be analyzed in the same geometry as the calibration source or appropriate corrections made.
A recount of the spiked sample in a petri dish reduced the systematically high bias. The inspectors noted I,
that inadequate details regarding calibration and sample analyses procedures (Paragraph 6.b) resulted in the biased values observed for the particulate filter confirmatory measurements.
Furthermore, the inspectors noted that this high bias did not represent a predetermined i
planned conservatism in the licensee's analytical measurements for this
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geometry.
Licensee representatives agreed to evaluate and correct particulate filter sample analysis methodology.
The inspectors
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informed licensee representatives that this would be considered an I
inspector followup item and would be reviewed during a subsequent inspection (50-338/85-25-02 and 50-339/85-25-02).
b.
The inspectors noted that the licensee was provided with simulated liquid waste samples by the NRC contract lat, oratory, September 1983 and
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March 1985, and was requested to complete radiochemicti analyses for
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Comparison of licensee and NRC results
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are listed in Table 2 with the acceptance criteria listed in Attach-ment 1.
Results were in agreement for all nuclides analyzed for the September 1983 sample.
For the March 1985 sample, results were in disagreement for H-3 and Fe-55, and in agreement for the strontium
isotopes. The inspectors noted that H-3 had been correctly analyzed in the previous NRC confirmatory analysis. Also, the March 1985 sample represented the first vertfication of the licensee's capability to i
analyze for Fe-55.
The inspectors requested licensee representatives to evaluate both H-3 and Fe-55 analyses and complete verification of I
the Technical Specification required analytical capability prior to receiving their next spiked sample from the NRC contract laboratory.
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The inspectors notified cognizant licensee representatives that their
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evaluation and subsequent analyses of the annual NRC spiked sample i
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would be considered an inspector followup item and would be reviewed during a subsequent inspection (50-338/85-25-03 and 50-339/85-25-03).
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No violations or deviations were identified.
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IAB({,_1 RESULTS OE CAMMA SPECTROSCOPY CONFIRMATORY MEASUREMENTS AT NORTH ANNA NUCLEAR PLANT; SEPIEMBER 16-20, 1985
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SAMPLE TYPE ISOTOPE C0NCENTRATION fuCifunR 1 RFSoluil0N RATIO
[0MPARISON (Licensee Geometry)
_ Licensee MR_g LicenseeA RJ
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(1) Reactor Coolant ic-99m 4.46 r-3 4.6010.38 E-3
0.97 Agreement (100 ml Cup)
1-131 3.31 E-3 4.09to.40 E-3
0.81 Agreement i
1-132 7.7T E-2 9.04t0.35 E-2
0.86 Ag reement 1-133 4.11 E-2 4. 73 to.08 E-2
0.87 Ag reement 1-135 8.14 E-2 8.84to.37 E-2
0.92 Agreement J
(2) Reactor Coolant Tc-99m 4.17 E-3 4.60to.38 E-3
0.91 Agreement
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(100 al Cup)
1-131 3.29 E-3 4.09t0.40 E-3
0.80 Ag reement l
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l-132 8.40 E-2 9.04to.35 E-2
0.93 Agreement i
1-133 3.98 E-2 4.7310.08 E-2
0.84 Agreement i
I l-135 8.48 E-2 8.8410.37 E-2
0.96 Agreement i
(3) Reactor Coolant Tc-99m 3.61 E-3 4.60!O.38 E-3
0.78 Ag reement (100 ml Cup)
6-131 3.31 E-3 4.0990.40 E-3
0.81 Agreement j
I-132 7.90 E-2 9.0420.35 E-2
0.86 Agreement I-133 3.96 E-2 4.7310.08 E-2
0.84 Ag reement
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l-135 7.88 E-2 8.8410.37 E-2
0.89 Agreement I
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(1) Liquid Waste I-131 1.00 E-6 1.15to.19 E-6
0.87 Ag reement l
(1 L Ma rine l l i Beaker) Cs-134 5.62 E-6 6.3410.34 E-6
0.89 Agreement Cs-137 1.25 E-5 1.2010.04 E-5
1.04 Agreement i
(2) Liquid Waste 1-131 1.09 E-6 1.1520.19 E-6
0.95 Ag reement j
(1 L Marinelli Beaker) Cs-134 6.50 E-6 6.34to.34 E-6
1.02 Ag reement
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Cs-137 1.39 E-5 1.2010.04 E-5
1.16 Agreement
5 (3) Liquid Waste I-131 1.03 E-6 1.1510.19 E-6
0.90 Agreement
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(1 L Ma rine l l i Beaker) Cs-134 5.72 E-6 6.34to.34 E-6
0.90 Agreement
Cs-137 1.23 E-5 1.2010.04 E-5
1.02 Agreement J
(1) Particulate Filter Mn-54 5.65 E-3 4.3410.19 E-3
1.30 Ag reement l
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(47 mm Filter)
Co-60 2.45 E-2 2.06t0.03 E-2
1. M Agreement
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Cs-137 1.60 E-2 1.3020.02 E-2
1.22 Agreement
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j Ce-144 1.12 E-2 8.85t0.30 E-3
1.26 Ag reement
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(2) Particulate Filter Mn-54 5.67 E-3 4.34to.19 E-3
1.31 Ag reement f
(47 mm Filter)
Co-60 2.45 E-2 2.06to 03 E-2
1.19 Ag reement i
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Cs-137 1.60 E-2 1.30t0.02 E-2
1.23 Agreement Ce-14t4 1.04 E-2 8.8510.30 E-3
1.24 Agreement
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(3) Particulate Filter Mn-54 5.48 E-3 4.34to.19 E-3
1.26 Agreement i
(47 mm filter)
Co-60 2.51 E-2 2.0610.03 E-2
1.22 Agreement
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Cs-137 1.68 E-2 1.30t0.02 E-2
1,29 D i sa g reement Ce-144 1.04 E-2 8.8510.30 E-3
1.18 Agreement i
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TABLE 1
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(cont'd)
SAMPEE T1P1 ISOTOPE CONCENTRATIO O CJ/UnLLI R
ftATIO COMPAR I SOJ E OLUJ_LQN (Licenseo Cecmetry)
Licensee NRJ Licensee /NR_Q ( 1 ) Cha rcoa l Ca rt ridge I-131 3.32 E-8 3.4810.04 E-8
0.95 Ag reement ( 2 ) Cha rcoa l Ca rt ridge I-131 3.52 E-8 3.4820.04 E-8
1.01 Ag reemeest ( 3 ) Cha rcoa l Ca rt ridge I-131 3.20 E-8 3.48to.04 E-8 8T 0.92 Ag reement (1) Waste Gas K r-87 2.33 E-5 2.18t0.55 E-5
1.07 Ag reement (100 cc Bomb)
Xe-133 9.32 E-5 7.9510.50 E-5
1.17 Ag reement Xe-135m 8.44 E-5 7.68t1.06 E-5
1.10 Agreement Xe-135 5.01 E-5 4.5620.27 E-5
1.10 Agreement (2) Waste Cas Kr-87 2.17 E-5 2.1810.55 E-5
0.99 Ag reemen t (100 cc Bomb)
Xc-133 9.16 E-5 T.95to.50 E-5
1.15 Ag reemen t Xe-135m 8.12 E-5 7.6811.06 E-5
1.06 Agreement Xe-135 5.52 t-5 4.5610.27 E-5
1.21 Agreement (3) Waste cas k r-87 2.31 E-5 2.1810.55 E-5
1.06 Agreement (100 cc Bomb)
Xe-133 9.15 E-5 7.9510.50 E-5
1.15 Agreement Xe-135m 6.33 E-5 7.68t1.06 E-5
0.82 Ag reement Xe-135 4.90 E-5 4.56t0.27 E-5
1.01 Ag reement
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(1) Analyzed using Camma Spectroscopy System No. 24-P-4456 (2) Analyzed using Camma Spectroscopy System No. 21-P-846A ( 3) Ana syzed using Camma spectroscopy System No. 21-P-829A ND - Not Detected NC - Not Compa red-2-
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I TABLE 2 RESULTS OF H-3, re-55, Sr-89, and Sr-90 CONF O RMAIORY MEASUREMENTS AT NORTH ANNA NUCLEAR POWER PLANT; SEPTEMBER 16-20, 1985 SAMPL E TYPE ISOTOPE p_0NCENTRATION fuci/U Q J RESOLUTIQ3 RAllC COMPAR f $0g (Licensee Geometry)
Licensee NRG Liqensee/NRC (1) Liquid Waste -
H-3 6.43 E-5 8.19t0.24 T-5
0.78 Agreement
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Simulated Sr-89 3.10 E-4 2.8610.09 E-4
1.08 Agreement Sr-90 5.00 E-5 4.5310.13 E-5
1.10 Agreement (2) Liquid Waste -
H-3 9.51 E-5 2.0910.04 E-4
0.46 Disagreement Simulated Te-55 1.90 E-4 1.42to.oS E-4
1.34 Disagreement
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S r-89 5.70 E-6 7.1310.21 E-6
0.80 Ag reement L
S r-90 9.60 E-7 9.3610.37 E-4
1.02 Ag reement
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t (1) Sample Provided by NRC Contract Laboratory September 1983
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(2) Sample Provided by NRC Contract Laboratory March 1985 l
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Attachment 1
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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 program.
In these criteria, the judgement limits are variable in relation to the compari-son of the NRC's value to its associated uncertainty, As that ratio, referred to in this program as " Resolution", increases, the acceptability of a licensee's measurtment should be more selective.
Conversely, poorer agreement must be considered acceptable as the resolution decreases.
RATIO =
LICENSEE VALUE
'NRC REFERENCE VALUE Resolution Agreement
<4 0.4 - 2.5 4-7 0.5 - 2.0 8 - 15 0.6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25
>200 0.85 - 1.18
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