IR 05000387/1986017
| ML17146A580 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/15/1986 |
| From: | Davidson B, Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17146A579 | List: |
| References | |
| 50-387-86-17, 50-388-86-18, NUDOCS 8610210446 | |
| Download: ML17146A580 (20) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387/86-17 50-388/86-18 Docket Nos.
50-387 50-388 NPF-14 License No.
NPF-22 Category C
Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penn s 1 vani a 18101 Facility Name:
Sus uehanna
¹1 and ¹2 Inspection At:
Berwick Penns lvania Inspection Conducted:
Se tember 8-12 1986 Inspectors:
B.
.
a idson, Radiation Specialist ate R. Struckmeyer Rad ati Specialist
/O /S g'c da e
Approved by:
W. J.
a ia
,
ief, ffluents Radiation Pr t tion Section
/a zs dat Ins ection Summar:
Ins ection on Se tember 8-12 1986 Combined Ins ection Re ort No. 50-387/86-17 50-388 86-18
~A" I
d:
I I, df I
I I radiochemical measurements program.
The NRC Region I Mobile Radiological Measurements Laboratory was used and laboratory assistance was provided by the DOE's Radiological and Environmental Sciences Laboratory.
Areas reviewed included:
licensee actions on previous inspection findings; chemistry management and organization; technician selection, qualification, and training; and radioactive sample confirmatory measurements, laboratory gC and audits.
Results:
No violations or deviations were identified.
-
PDp A
++ 861016 86i02io DOCK ogooo PDR
g'
S l
/
DETAILS 1.
Individuals Contacted-Pr'inci al Licensee Em lo ees 1.2
"J. Topp, Compliance Engineer
~R.
L. Doty, HP/Chemistry Supervisor
"T. R. Clymer, gA Supervisor-Operations
"C.
E. Burke, Plant Chemistry Supervisor
,"T.
M. Crimmins, Superintendent
"J. A. Blakeslee, Jr., Assistant Superintendent D. Sadvary, Compliance Engineer L. Ynuk, Senior Chemist B. Rhoads, Chemist W. J. Stewart, Chemistry Foreman P. Treier, Assistant Chemistry Foreman D. Wright, Assistant Chemistry Foreman L. Humpf, Assistant Chemi stry Foreman D. Heffelfinger, Coordinating Engineer, NgA D. McGarry, NgA Surveillance R. Kichline, Licensing Other Licensee Em lo ees G. A. Appel, Private Consultant 1.3 NRC
"L. Plisco, Senior Resident Inspector
"J. Strosnider, Chief, Reactor Projects Section 1B W. J.
Pasciak, Chief, Effluents Radiation Protection Section
"Denotes those present at the exit meeting.
The inspectors also talked with and interviewed other licensee personnel including members of the chemistry staff.
2.
Licensee Action on Previous Ins ection Findin s
2.1 2.2 (Closed)
Follow-up Item (387/82-28-01; 388/83-30-02):
Review primary containment monitor sample line to determine if it can provide representative samples.
The licensee provided information which indicated that the outside diameter of piping was affected and that
.inside diameter was unchanged.
(Closed)
Follow-up Item (387/84-25-04; 388/84-32-02):
Licensee to establish sampling procedures for radwaste process streams.
The licensee has completed and implemented a matrix of sampling
procedures including location, valve number, requirement, etc. for the radwaste processing streams.
Sample line purge volumes are posted at respective sampling locations.
2.3 (Open) Follow-up Item (387/84-25-0S, 388/84-32-03):
Laboratory QA/QC program.
The licensee has not yet formalized the frequency of
- the interlaboratory measurements QC program and included the frequency in the QA/QC procedures.
Also, increased aggressiveness in resolving unacceptable intracomparison results and internal and NRC findings or concerns should be pursued.
This area will be reviewed in a subsequent inspection.
2.4 (Open) Follow-up Item (387/84-39-03; 388/84-49-02):
Licensee to evaluate LLD parameter setting for counting pre-treatment off gas samples.
Because of elevated background counts, the licensee is unable to identify Xe-133 in pretreatment off gas samples without altering LLD parameters.
This area will be reviewed in a subsequent inspection.
3.0 Mana ement and Or anization of the Chemistr Grou The inspector reviewed the organization and management of the Chemistry Group with respect to criteria contained in:
Unit 1 and Unit 2 Technical Specification 6.2, "Organization" Procedure AD-QA-440, Rev.
0 "Conduct of Chemistry" The licensee's performance in this area was determined from discussions with cognizant licensee personnel and review of the day shift staffing and organization.
Within the scope of this review, no violations were found; the following recommendations for improvement were identified:
Communications between senior chemistry management and line supervisors were not effectively implemented.
The line supervisors were unaware of NRC open items or.their status.
Similarly, the NQA department's audit findings and observations were not conveyed.
A more aggressive approach to resolution of findings, be they NRC, NQA, or as a result of disagreements in inter-and intra-laboratory comparison programs should be pursued.
4.
Personnel Selection and uglification The inspector reviewed the selection and qualification of selected chemistry personnel with respect to the following:
Unit 1 and Unit 2 Technical Specification 6.3, "Unit Staff Qualifications"
V '
.Unit 1 and Unit 2 Technical Specification 6.4, "Training" Procedure AD-QA-440, Rev.
0, "Conduct of Chemistry" Procedure NPT-QA-41. 1, Rev.
1, "Chemistry Personnel Training and Qualification Program" Procedure NTP-QA-41.2, Rev.
2, "Chemistry Technician Certification Program The licensee's performance in this area was based on:
review of selected chemistry personnel records review of chemistry personnel performance discussions with cognizant licensee personnel Within the scope of this review, no violations were found.
The licensee was selecting and qualifying its chemistry personnel according to procedural requirements.
5.
~Lb The inspector performed a selected review of the licensee's program for the quality assurance of radioanalytical measurements.
The review was performed with respect to criteria contained in the following:
Regulatory Guide 4. 15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" Principles of Quality Assurance of Chemical Measurements (NBS)
ANSI N42. 14 1978 Calibration and Usage of Germanium Detectors for Measurement of Gamma-Ray, Emission of Radionuclides The inspector reviewed the following procedures:
AD-QA-445, Rev.
3, CH-GI-011, Rev.
5, CH-IC-004, Rev.
2, CH-RC-039, Rev.
0, CH-TP-024, Rev.
4, CH-QC-003, Rev.
0, Program Chemistry Quality Assurance Instrument Checks Gamma Spectrometry System Calibration Iodine Cartridge Analysis Performance Testing of Germanium Detectors Intralaboratory Spiked Sample Quality Control The inspector also reviewed the following data:
efficiency calibrations performed during 1986 interlaboratory comparisons performed during 1985 and 1986 control charts for daily source, gain, and resolution checks for 1986 of the two Ge(Li) detectors in the counting room.
LLD verification performed 9/7/86 on Detector 1 and 8/31/86 on Detector
Within the scope of this review the following concerns were identified:
CH-IC-004 does not specify a minimum number of counts in the peak area of interest for efficiency calibrations.
The inspector noted that ANSI N42. 14-1978 recommends accumulating a.minimum of 20,000 counts in the peak areas for calibration.
The licensee stated that although the procedure lacks instruction, counts are accumulated per the ANSI recommendation.
The licensee also stated that the procedure would be revised to reflect actual practice and to include plotting of efficiency curves.
During a previous inspectien, 50-387/84-39 and 50-388/84-49, the inspector noted (50-387/84-39-04; 50-388/84-49-03)
that the licensee could not accurately analyze charcoal cartridge samples as a result of the improper placement of the cartridge on the detector.
During this inspection the inspector noted that procedure CH-RC-039 does not provide information regarding the placement of the cartridge.
In addition, the inspector noted several disagreements with interlaboratory comparisons that resulted from several technicians analyzing the outlet face rather than the inlet face of the cartridge.
The inspector discussed with the licensee the importance of maintaining adequate procedures and stated that this area would be reviewed during a subsequent inspection.
(50-387/86-17-01; 50-388/86-18-01).
The inspector noted that the licensee has not formalized the interlaboratory comparison program, a concern identified by 50-387/84-25-05; 50-388/84-32-03.
The licensee stated that a draft procedure is in process and demonstrated that interlaboratory comparisons are performed quarterly.
However, the licensee does not identify the interlaboratory.program in a procedure.
Furthermore, the licensee presently initiates no action or investigation for disagreements with interlaboratory intercomparisons.
The inspector discussed with the licensee the importance of followup on interlaboratory intercomparison disagreements in a timely manner and indicated that items 50-387/84-25-05; 50-388/84-32-03 will remain ope Procedure CH-GI-011 indicates that background counts should be within an expected range for the instrument.
The inspector inquired as to the range of background in the Ge(Li) detectors and discovered that no specific range exists'n addition, there are no indications in the procedure for action should the cave become contaminated.
The inspector discussed with the licensee. the impact of background counts on the licensee's lower limits of detection.
Procedure CH-TP-024 indicates that control charts are created using limits of +10% efficiency deviation for the Ge(Li) detectors.
The inspector queried the licensee regarding warning limits and control limits for this measurement.
The licensee stated that there are no warnings limits and that +10% are the.control limits.
However, the licensee takes no action for values exceeding the limit and does not investigate data that demonstrates a bias.
The inspector discussed quality control with the licensee and determined that the personnel interviewed did not appear to have an understanding of the quality control checks performed.
The inspector stated that the area of quality control would be reviewed in a future inspection'50-387/86-17-02; 50-388/86-18-02).
6.
Confirmator Measurements During the inspection, liquid, particulate filter, and gas samples were split between the licensee and the NRC for the purpose of intercomparison.
Due to insufficient activity on effluent charcoal cartridges, NBS traceable charcoal standards, face and uniformly loaded, were used for intercomparing this geometry.
Joint analyses of actual effluent samples verify the licensee's ability to measure radioactivity in effluents with respect to Technical Specification and other regulatory requirements.
Where possible, the samples are actual effluent samples or inplant samples which duplicate counting geometries used by the licensee for effluent sample analyses.
These samples are analyzed by the licensee using normal methods and by the NRC Region I Mobile Radiological Measurements Laboratory.
Also, a liquid effluent was split with the licensee with part of the sample being 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 when received at a later date and documented in a subsequent inspection report.
The licensee agreed to analyze his portion of the sample for the same radionuclide 'l
I
The licensee was unable to produce results from the previous inspection in this area.
It could not be determined if the shipment was not sent to the licensee's contractor or if the shipment was lost.
The licensee did send a sample to RESL but no comparison with their analysis can be made without the corresponding data.
The results of the intercomparison sample measurements were in agreement except for the offgas pretreatment sample.
This area was previously identified (50-387/84-39-03; 50-388/84-49-02)
as a problem with the licensee's method of LLD parameter setting and library branching ratio errors.
A copy of the licensee's gamma spectroscopy library was reviewed with attention focused on the radionuclide which were in disagreement or could not be compared because they were less than LLD.
The results of the intercomparison sample analyses are listed in Table 1.
The criteria used for evaluating the results are provided in Attachment 1.
The inspect'or noted that intercomparison split samples with the licensee's contractor had not been made since the latter part of 1984.
The licensee stated that its contract with a supplier of split samples had terminated, resulting in this oversight.
The licensee stated that they would resume this activity in oversight of vendors who performed analyses required by technical specifications.
. The inspector had no further questions in this area.
C Audits The inspector reviewed the licensee's performance in its auditing and surveillance activities of the chemistry program against criteria contained in:
Procedure OPS-7, Rev 2, "Auditing and Surveillance Activities" The inspector reviewed audits and survei llances conducted by the licensee's NQA staff, including one performed on the contractor supplying radioanalytical services, for adequacy.
The following audits and survei llances were reviewed by the inspector:
Audit No.
Subject 1A-84-21 SRC-85-42 SRC-85-84 QASR-85-110 SRC-86-031 Teledyne Isotopes QA Program Chemistry Program Radiological Effluents Chemistry Program Chemistry Program
The preficies indicate external activities, Technical Specification 6.5.2.8 activities, and Surveillance respectively.
In addition, a
current audit (86-075) of the Radiological Effluents area is being made.
Audit Number 86-031 was an extensive audit in the Chemistry Program including organization and responsibilities, sampling and sample control Surveillance Testing Program, control of reagents and solutions, control of standards and test equipment, Chemistry QC/QA, and trend analysis.
eight items of non-compliance were identified which required responses from the SSES chemistry group.
At the time of this inspection the written responses had not yet been received by the QA group.
No violations were identified in this area.
8.
Exit Interview The inspector met with the licensee representatives denoted in Section
at the conclusion of the inspection on September 12, 1986.
The inspector summarized the purpose, scope, and findings of the inspection.,
Attachment
Criteria for Com grin Anal tical 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 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.
Resolution=
NRC REFERENCE VALUE REFERENCE VALUE UNCERTAINTY RATIO= LICENSEE VALUE NRC REFERENCE VALUE Resolution
<34-7 8-15
50
200
>200
~Areemeet.5 0.5 -'.0.66 0.75 1.33 0.80 - 1.25 0.85 - 1.18
TABLE
I SUSQUEHANNA 1'ERIFICATION TEST RESULTS RESULTS IN uCi SAMP ISOTOP RC ALU LICE SEE ALU COMPARISO NRC Simulated Cha rcoa I Face Loaded Geometry Cd-109 Co-57 Ce-139 Sr-113 Cs-137 Y-88 Co-60 1. 06 (1.05 (5.58 7.3 9.85 8.74 8.8 k 0.05
+ 0.05)
E"2 2 0.25)
E-3
+ 0.3)
E-3
+ 0.4)
E-2
+ 0.4)
E-3 R 0.4 E-2 1. 260 1. 30 6.56 8.8 (1.200 1. 03 1. 04 N 0.008
+ 0
~ 017)
i 0.15)
+ 0.3)
+ 0.009)
+ 0.05)
2 0.01)
E-2 E-3 E-3 E-1 E-2 E" 1 Agreement Agreement Agreement Agreement Agreement Agreement Agreement Uniform Load Cd-109 Co-57 Ce-139 Sn-113 Cs-137 Y-88 Co-60 1. 02 (1.02 5.38 7.01 9.5 8.43 8.49 2 0.05 2 0.05
+ 0.25)
2 0.32)
+ 0.43)
2 0.37)
k 0.37 E-2 E-3 E-3 E-2 E-3 E-2 1.03 1. 04 5.37 (7.5 (9.85 (8.6 (8.80
+ 0.007)
i 0.016)
+ 0.14)
2 0.32
+ 0.08 R 0.4)
+ 0.09)
E"2 E" 3 E-3 E-2 E-3 E-2 Agreement Agreement Agreement Agreement Agreement Agreement Agreement
TABLE
SUSQUEHANNA 1Sc2 VERIFICATION TEST RESULTS RESULTS IN uCI/ml
~UANPL
"Crud Fl Iter" 9/10/86 1420 HRS ISOTOP Cr-51 Mn-54 Mn-56 Co-58 Fe-59 Co-60 As-76 Tc-99m
~RU ALUE 3.6 R 0.3)
E-4 6.7 2 0.11)
E-4 1.26 2 0.021 E-3 (1.07 R 0.06)
E-4 (5.8 2 0.16)
E-4 (1.89 2 0.07 E-4 (2.1 2 0.1)
E-4 (4.20 2 0.18)
E-5 (3.61 (7. 56 1. 360 1.17 7. 16 2.08 2. 10 (4. 13 2 0.08)
+ 0.03)
2 0.006)
R 0.018)
+ 0.06)
2 0.02)
i 0.04)
+ 0.08)
LICE SEE ALUE E-4 E-4 E-3 E-4 E"4 E-4 E"4 E-5 COMPARISO Ag reement Agreement Agreement Agreement Agreement Agreement Ag reement Agreement
SAMPLE ISOTOP TABLE
SUSQUEHANNA 1&2 VERIFICATION TEST RESULTS RESULTS IN uCI/ml RC ALUE COMPARISO Unlt
RCS 9/11/86 0910 HRS Na-24 Cr-51 Mn-54 Co-58 Mn-56 Fe-59 Co-60 As-76 Tc-99m 7. 81 1. 065 4.6 (1.78 (9. 1 (3.6 2.6 3.3 1. 845 w 0.08)
E-3 2 0.018)
E-2 2 0.3)
E-4
+ 0. 19)
E-4
+ 0.4)
E-4
+ 0.5)
E-4 2 0.2)
E-4
+ 0.3)
E-4
+ 0.005)
E-2 7.25 1.030 i 4.30 1.11
+
1.75
+
2.8
+
1.79 3.2
+
(1.710 i 0.06)
E-3 0. 014)
E-2 0. 16)
E-4 0.03)
E-3 0. 13 E-4 0.4)
E-4 0. 15)
E-4 0.2)
E-4 0. 004)
E-2 Agreement Agreement Ag reement Ag reement Ag reement Ag reement Agreement Agreement Agreement LRM AB Sample Tank 9/9/86 1100 HRS Cr-51 Mn-54 Co-58 Co-60 4.4 1.12 7.8 9.0 X 0.4)
E-6
+- 0.07)
.E-6
+ 0.6)
E-7 2 0.9)
E-7 3.4 R 0.3)
E-6 9.1
+ 0.6)
E-7 (6.6 i 0.5)
E-7 8 ~ 6 R 0.7)
E-7, Agreement Agreement Agreement Agreement
TABLE 1 SUSQUEHANNA 1L2 VERIFICATION TEST RESULTS RESULTS IN uCI/cc SAMP E
Offgas Pre treatment 9/11/86 1545 HRS 12.53 cc 2'8" decay 59'5" decay 12.73 cc Offgas Post Treatment 9/10/86 1340 HRS Upper Drywe I I Particulate Filter 9/10/86 0258 HRS ISOTOP Kr-85m Kr-87 Kr-88 Xe-135m Xe-135 Xe-138 Kr-85m Kr-87 Xe-135m Xe-135 Xe-138 Kr-85m Kr-87 Kr-88 Xe-133 Cr-51 Co-58 As-76 Tc-99m RC ALU 6.03 3.77 1. 92 1.29 1. 87 6. 23 (7.48 (4.72 (1. 35 (2. 12 (6.07 2 0.70)
+ 0.36)
+ 0.39)
+ 0.14)
+ 0 ~ 13)
2 0.51)
+ 0.91)
i 0.44)
2 0.11)
+ 0. 18)
+ 0.49 5.5 8.7 1. 03 (1.281
+ 0.1)
2 1.0)
+ 0.03)
+ 0.006)
8.8 2 0.1)
4.19 2 0.15)
(9.3
+ 0.2)
(4.17 + 0.15)
LICENSEE ALUE E-5 E-4 E-4 E-3 E-4 E-3 E-5
E-3 E-4 E-3 E"6 E-7 E-6 E-6
<1. 48
<2.83 (5-8 2 0.91)
(1 ~ 1 + 0.04)
<1. 59 (3.7 + 0.12)
(7-81 2 0.49)
(2.29 2 0.16)
1.12 i 0.1)
1.59 i 0.07)
(2.08 f 0.15)
(7. 67
<4.89 (7.6 (3.69 2 0.09)
k 0.2)
+ 0.13)
E-4 E-4 E-4 E-3 E-4 E-3 E-5 E-4 E"3 E-4 E-3 E-6 E-7 E-6 E-6 E-9 (5.16 i 0.04)
E-9 E-11 (8.6
+ 0.5)
E-11 E-9 (9.8
+ 0.13)
E-10 E"8 ( 1.230 i 0.003)
E-8
~COMPARI SO No Comparison No Comparison Disagreement Agreement No Comparison Disagreement Agreement Disagreement Agreement Agreement Disagreement Agreement No Comparison Agreement Agreement Agreement Agreement Agreement Agreement
<I C,
I W