IR 05000387/1991016
| ML17157A894 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/27/1991 |
| From: | Bores R, Kottan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157A893 | List: |
| References | |
| 50-387-91-16, 50-388-91-16, NUDOCS 9110140009 | |
| Download: ML17157A894 (19) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387/91-16 50-388/91-16 Docket Nos.
50-387.
50-388 License No.
NPF-14 NPF-22 Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penns lvania 18101 Facility Name:
Susquehanna Steam Electric Station, Units 1 5 2 Inspection At:
Berwick, Pennsylvania Inspection Conducted:
August 26-30, 1991 Inspectors:
J.
Ko Radia an, Laboratory Specialist, Effluents on Protection Section (ERPS), Facilities date Radiological Safety and Safeguards Branch (FRSSB), Division of Radiation Safety and Safeguards (DRSS)
Approved by:
ores, Chief, RP
,
FRSSB DRSS date Ins ection Summar:
Ins ection on Au ust 26-30 1991 Combined Ins ection Re ort Nos. 50-387/91-16 and 50-388/91-16 A~
program.
Areas reviewed included:
confirmatory measurements, laboratory QA/QC, and audits.
Results:
The licensee had in place an effective program for measuring radioactivity in process and effluent samples'ne unresolved item related to the tracking of audits and audit findings was identified.
(See Section 5 for details.)
No violations or deviations were identified.
9110140009 910927 PDR ADOCK 05000387
DETAILS Individua 1 s Contacted Princi al Licensee Em lo ees
- T. Belles, Chemistry Technician - Instruments
- R. Breslin, Chemistry Supervisor
"P. Capotosto, Sr. Project Engineer, NQA
- A. Feldman, Radiochemist D. Heffelfinger, Coordinating Engineer, NQA R. Hock, Health Physicist
- L. Humpf, Assistant Chemistry Foreman
- D. Kennedy, III, Assistant Chemistry Foreman
- T. Nork, Plant Engineering Supervisor - Systems
"B. Rhodes, Chemistry Lab Supervisor
- H. Riley, Health Physics Supervisor
- D. Roth, Sr.
Compliance Engineer
- G. Stanley, Superintendent of Plant
"R. Takacs, QA/QC Chemist
~R. Wehry, Compliance
~II
"J. Stair, NRC Resident Inspector
'Denotes those present at the exit meeting on August 30, 1991.
The inspector also interviewed other licensee personnel including members of the chemistry and health physics staffs.
~Pur ose The purpose of this inspection was to review the following areas.
A.
The license's ability to measure radioactivity in plant systems and effluent samples.
B.
The licensee's ability to demonstrate the acceptability of analytical results through implementation of a laboratory QA/QC program.
Confirmator Measurements During this part of the inspection, liquid, airborne particulate (filter)
and iodine (charcoal cartridge),
and gas samples were analyzed by the licensee and the NRC for the purpose of intercomparison.
The samples were actual split samples with the exception of the liquid radwaste, offgas, and filter samples.
In these cases the samples could not be split, and the same samples were analyzed by the licensee and the NRC.
Where possible the samples are actual effluent samples or in-plant samples which duplicated the counting geometries used by the licensee for effluent sample analysis.
The charcoal cartridge sample was a spiked sample supplied to the licensee by the NRC because no effluent or in-plant charcoal cartridge sample could be obtained which contained radioactive
The samples were analyzed by the licensee using routine methods
'nd equipment and by the NRC I Mobile Radiological Measurements Laboratory.
Joint analyses of actual effluent samples are used to verify the licensee'
capability to measure radioactivity in effluent and other samples with respect to Technical Specifications and other regulatory requirements.
In additon, a liquid effluent sample was sent to the NRC reference laboratory, Department of Energy, Radiological and Enviromental 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 of these analyses will be compared with the licensee's results when received at a later date and will be documented in a subsequent inspection report.
The results of a liquid effluent sample split between the licensee and the NRC during a previous inspection on June 12-16, 1989 (Combined Inspection Report Nos, 50-387/89-16 and 50-388/89-14)
were also compared during this inspection.
The licensee's Health Physics Department also possessed a
gamma spectrometry system which was used to quantify radioactivity on in-plant samples for radiation protection purposes.
During this inspection, the charcoal cartridge and particulate filter were also analyzed by the licensee's Health Physics Department and compared with the NRC results.
These types of samples were those normally analyzed by the licensee's Health Physics Department.
The results of the comparisons indicated that, for the gamma isotopic analyses performed by the Chemistry Department, all of the results were in agreement under the criteria used for comparing results.
(See Attachment I to Table I.)
The Fe-55 result from the liquid sample split during the previous inspection was in disagreement, as were the gamma isotopic analyses of the charcoal cartridge performed by the Health Physics Department.
The reason for the Fe-55 disagreement could not be determined during this inspection.
However, as stated above, a liquid sample was split for Fe-55 analysis during this inspection, and this result will be compared as soon as received in order to resolve this disagree-ment.
Some possible reasons for the disagreement would be a poor sample split or a matrix effect present in the sample.
With regard to the licensee's Health Physics results, the disagreements were due to the manner in which the licensee calibrated the gamma spectrometry system detectors for the charcoal cartridge counting geometry.
These detectors were calibrated with a charcoal cartridge standard in which the radioactivity was distributed uniformly throughout the charcoal cartridge.
The NRC-supplied spiked charcoal cartridge, however, had the radioactive material distributed only on the inlet side or "face" of the charcoal cartridges This type of radioactivity distribution within the cartridge is the type of distribution normally encountered with "real" samples.
The inspector discussed this matter with the licensee.
The licensee stated that a calibration with a uniformly loaded charcoal cartridge was done so that conservative results would be
obtained when counting only the inlet side of the cartridge.
The licensee further stated that this would not result in exceeding any airborne iodine exposure limits because the error introduced by this practice was in a
conservative direction.
In order to evaluate the licensee's calibration, the inspector requested that the licensee analyze both sides of the NRC cartridge and average the results, a practice normally employed when calibrating with a "uniformally loaded" charcoal cartridge.
The licensee complied with the inspector's request and the subsequent results were in agreement with the NRC known value.
After further discussions with the licensee, the licensee stated that the current practice of counting charcoal cartridges would continue, but consideration would be given to reviewing the method.
The inspector stated that this area will be reviewed during a subsequent inspection.
All of the measurement results are presented in Table I.
Laborator A/ C The licensee's radiochemistry laboratory QA/QC program was detailed in a number of procedures.
Specifically the following procedures were reviewed by the inspector.
AO-QA-445, CH-QC-001, CH-QC-002, CH-QC-003, CH-QC-004, CH-QC-005, CH-GI-Oll, CH-TP-064, Chemistry Program Quality Assurance Criteria for Comparing Radiochemical Measurements Split Samples Interlaboratory Quality Control Program Intralaboratory Quality Control Program Chemistry Computer Software Verfication Replicate Sampling and Analysis Instrument Checks Performance Testing of the ND Gamma Spectral System These procedures provide for the control of analytical performance through the use of an intralaboratory QC program and an interlaboratory QC program.
The intralaboratory program consisted of the use of control charts to assess instrument performance, the analysis of replicate samples, and the analysis of spiked tritium samples provided to the technicians.
The interlaboratory program consisted of the quarterly gamma isotopic analysis of spiked samples received from an offsite laboratory.
Also included in the interlaboratory program was the submission of spiked samples on a quarterly basis to the vendor laboratory used for performing effluent sample analyses requiring radiochemical separations.
The interlaboratory spiked samples were submitted to the chemistry technicians on a rotating basis and the results of interlaboratory program were tracked both on an individual technician and grand average basis.
The inspector reviewed selected data generated by the licensee's laboratory QC program and noted that the licensee appeared to be implementing the program as required.
The inspector also noted that the
licensee now had in place a dedicated individual, the gA/gC chemist, to oversee the laboratory QA/gC program.
Additionally, the inspector noted that the licensee was in the process of installing a
new computer-based gamma spectrometry system.
This new system included gC algorithms and data bases to maintain the results of the gC checks for the gamma spectrometry system detectors.
The gC software would also print the control charts for the data maintained in the data base.
During this inspection the licensee stated that the control charts were printed every seven days.
Based on a demonstration of the gC software and discussions with licensee personnel the inspector determined that the gC software would indentify an out-of-control data point, but would not indentify other trends taking place within the control limits which may indicate a
potential problem with the system.
The inspector discussed this matter with the licensee and stated that control charts plotted after the fact provide only a review of.past performance and do not actively control the measurement process.
The licensee responded that the control charts would be printed and reviewed on a daily basis.
The inspector had no further questions in the area.
Audits The inspector reviewed recent quality assurance audits of the licensee's radioactivity measurements programs performed by the Nuclear guality Assurance (NgA) Division.
The following audits were reviewed.
Audit No.91-029,
"Chemistry Program",
performed May 13-June 10, 1991 Audit No.90-036,
"Chemistry Program",
performed April 30-May 14, 1990 These audits included the licensee's programs and procedures for the measurement of radioactivity in effluent samples and the laboratory quality assurance program for those measurements.
The audits appeared to be of adequate technical depth, were performed using an audit plan and an associated check list, and the audit team included a technical specialist.
A single non-safety significant finding was identified as a result of Audit No.91-029.
This finding, however, was not resolved within'he time limit required by the licensee's procedures.
The failure to resolve this item within the required time limit appeared to be due to a clerical error, in that the audit and audit findings were not entered into the NgA audit tracking system.
The inspector stated that although the failure to track and resolve the audit finding as required appeared to be an isolated incident, this 'would be considered an unresolved item (50-387/
91-16-01 and 50-388/91-16-01)
and would be reviewed in greater detail during the next inspection of the licensee's gA program.
During this inspection the licensee's Chemistry Department initiated actions to resolve the above audit finding.
The inspector reviewed the NgA audit schedule and noted that the audits of the chemistry program were scheduled on an annual basi The inspector also reviewed a recent NgA audit of the vendor laboratory used for performing analyses of effluent samples requiring wet chemistry.
This audit, NgA Audit No. 89-0009, was performed on July 10-14, 1989.
Through discussions with licensee personnel the inspector determined that the next audit of the vendor laboratory was scheduled for the fall of 1991 and the audit team would include members of the site Chemistry Department.
The inspector also reviewed the results of selected gA surveillances performed by the NgA/OPS Surveillance Group during 1990 and 1991 to date.
The Surveillance Group maintained an 18-month schedule for chemistry surveillance activities which included the following areas:
approved materials, waste management, surveillance sample/analysis, reagents, standards, instruments, training, gA program, and start-up/shutdown activities.
The surveillances were performed using checklists which were developed to cover the specific surveillance activity and appeared to be of adequate scope.
No concerns were identified by the inspector in this area.
The inspector met with the licensee representatives denoted in Section
at the conclusion of the inspection on August 30, 1991.
The inspector summarized the purpose scope and findings of the inspectio TABLE.I SUS UEHANNA VERIFICATION TEST RESULTS SAMPLE ISOTOPE NRC VALUE RESULTS IN TOTAL HICROCURI ES LICENSEE VALUE
~CONPARISO Offgas (pretreatment)
8"27-91 0842 hrs (Detector 1)
1st Count Kr-87 Xe-135m Xe-135 Xe-138 (1
~ 68
+ 0 15)E 2 (4.0 + 0.5)E-2 (6.3
+ 0.6)E-3 (1.9 i 0.3)E-l (2.3
+ 0.5)E"2 (4.0
+ 0.4)E-2 (7 + 2)E-3 (1.48 A 0.10)E-1 Agreement Agreement No Compa r I son Agreement Offgas (pretreatment)
8-27-91 0842 hrs (Oetector 1)
2nd Count Kr-85m Kr-87 Kr-88 XQ-135 (2.35 + 0.14)E-3 (1.08 2 0.14)E-2 (8.0
+ 0.6)E-3 (7.12
+ 0.14)E-3 (2.44
+ 0. 13)E-3 (1.36 A 0.11)E-2 (8.3 + 0.5)E-3 (7.4
+ 0.4)E-3 Agreement Agreement Agreement Agreement
TABLE
(continued)
.
SUS UEHANNA ERIFICATION TEST RESULTS SAMPLE
~ISOTOP RC VALUE ICENSEE VALUE
~CORPAR I SO RESULTS I N MICROCUR I ES PER M I LLI L I TER Unit
RWCU Crud Filter 8-27-91 1205 hrs (Detector 1)
Cr-51 Mn-54 Co-58 Fe-59 Co-60 (2.63
+ 0. 11)E-3 (8.86
+ 0.08)E-3 (3.5 + 0.3)E-4 (6.83
+ 0. 11)E-3 ( 1.01
+ 0.03)E-3 (2.68 i 0.16)E-3 (9.4
+ 0.5)E-3 (3.9 4 0.3)E-4 (6.8 i 0.2)E-3 (1.04 2 0.04)E-3 Agreement Agreement Ag reement Agreement Agreement Unit
RWCU Crud Filter 8-27-91 1205 hrs (Detector 2)
Cr-51 Mn-54 Co-58 Fe-59 Co-60 (2.63
+ 0.11)E-3 (8.86
+ 0.08)E-3 (3.5 t 0.3)E-4 (6.83
+ 0. 11)E-3 (1.01
+ 0.03)E-3 (2.55 i 0.07)E-3 (9.33
+ 0.04)E-3 (3.6 i 0.2)E-4 (6.95
+ 0.06)E-3 ( 1.04 + 0.02)E-3 Agreement Agreement Ag reement Agreement Agreement
TABLE 1 (continued)
SUS UEHANNA VERIFICATION TEST RESULTS SAMPLE ISOTOPE ERC VALUE LICENSEE VALUE
~CONPARISO RESULTS IN MICROCURIES PER MILLILITER Unit 1 Reactor Water Filtrate 8-28-91 0940 hrs (Detector 1)
1st Count I-132 I-133 I-134 l-135-(1.03 2 0.02)E-4 (4.37
+ 0.12)E-5 (3.15
+ 0.12)E-4 (1.18
+ 0.05)E-5 (1.16 4 0.08)E-4 Agreement (4.3
+ 0.5)E-5 Agreement (3.5 2 0.3)E-4 Agreement ( 1. 12
+ 0. 10)E-4 Agreement Unit 1 Reactor Water Filtrate 8-28-91 0940 hrs (Detector 1)
I-132 I-133 I -135 (1.00
+ 0.04)E-4 (4.27
+ 0. 11)E-5 (1.06
+ 0.05)E-4 (1.09
+ 0.09)E-4 Agreement (4. 1 2 0.3)E-5 Agreement ( 1.07
+ 0.07)E-5 Agreement 2nd Count Unit 1 Reactor Water Filtrate 8-28-91 0940 hrs (Detector 2)
2nd Count I -132 I-133 I -135 ( 1.00 k 0.04)E-4 (4.27
+ 0. 11)E-5 (1.06 i 0.05)E-4 (3.8 + 0.2)E"5 (8.2
+ 0.7)E-5 Agreement Agreement (1.14
+ 0.07)E-4 Agreement
TABLE 1 (continued)
SUS UEHAN A VERIFICATION TEST RESULTS SAMPLE ISOTOPE NRC VALUE RESULTS IN MICROCURIES PER HILLILITER Liquid Radioactive Waste (C8cD Collection Tanks)
8-28-91 1240 hrs (Detector 1)
Co-58 Fe-59 Co-60 Hn-54 Cr-51 ( 4. 32
+ 0. 12) E-3 (5. 18
+ 0.04)E-2 (1.002
+ 0.013)E-2 (9.80
+ 0.04)E-2 (3.30
+ 0.08)E-2 (4.0
+ 0.2)E-3 (4.33
+ 0.14)E"2 (9.1
+ 0.3)E-3 (8.8
+ 0.5)E-2 (3.1
.+ 0.2)E-2 Agreement Agreement Agreement Agreement Agreement Liquid Radioactive Waste (C&D Collection Tanks)
8-28-91 1240 hrs (Detector 2)
Co-58 Fe-59 Co-60 tdn-54 Cr-51 (4.32 i 0. 12)E-3 (5.18
+ 0.04)E-2 (1.002 20.013)E-2 (9.80
+ 0.04)E-2 (3'0 + 0.08)E-2 (3.83
+ 0.10)E-3 (4.59
+ 0.03)E-2 (9. 18 i 0. 12) E-3 (8.55 i 0.03)E-2 (2.86
+ 0.05)E-2 Agreement Agreement Agreement Agreement Agreement
TABLE 1 (continued)
SUS UEHANNA VERIFICATION TEST RESULTS
~SARPL ISOTOPE NRC VALUE LICENSEE VALU
~OORPAR I SO RESULTS IN TOTAL MICROCURIES Offgas (pretreatment)
8-29-91 1000 hrs (Oetector 1)
Marinel I i Beaker Counting Geometry Kr 85m Kr-87 Kr-88 Xe-135 Ar-41 (5.8
+ 0.5)E-4 (3.2 X 0.2)E-3 (1.9
+ 0.2)E-3 (1.73
+ 0.06)E-3 (2.2
+ 0.2)E"3 (6.4
+ 1.3)E-4 (3.6
+ 0.8)E-3 (1.8
+ 0.4)E-3 ( 1.4
+ 0.2)E"3 (2.4
+ 0.2)E-3 Agreement Ag reement Agreement Ag reemen t Ag reement Offgas (pretreatment)
8-29-91 1000 hrs (Detector 2)
Marinel I i Beaker Counting Geometry Kr-85m Kr-87 Kr-88 Xe-135 Ar-41 (5.8 + 0.5)E-4 (3.2 + 0.2)E-3 (1.9 X 0.2)E-3 (1.73 X 0.06)E-3 (2.2 + 0.2)E-3 (3.4 + 0.8)E-4 (3.2 2 0.3)E-3 (not identified)
(1.37 X 0.10)E-3 (2.4 + 0.2)E-3 Agreement Agreement No Comparison Agreement Agreement
TABLE I (COCCIOSO>
SUS UEHANNA VERIFICATION TEST RESULTS SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE
~CONPARISO RESULTS IN TOTAL MICROCURIES NRC Spiked Charcoal Cartridge (85-01)
(Detector 1)
Ba-133 (4.15 i 0.10)E-2 (4.12
+ 0.16)E-2 Agreement RESULTS IN MICROCURI S
PER MILLILITER Liquid Radwaste 6-14-89 1615 hrs Fe-55 gross alpha H"3 Sr-89 Sr-90 (2.62
+ 0.01)E-3 (9 X 6)E"10 (1.92
+ 0.02)E-3 (3.2 + 0.3)E-7 (9 f 4) E-9 (2.2 2 0.1)E"4
<3E-8 (2.2 + 0.1)E"3 (2.6 + 0.3)E-7
<1E-8 Disagreement No Comparison Agreement Agreement No Comparison
TABLE
SUS UEHANNA VERIFICATION TEST RESULTS (continued)
SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE
~COMPAIII SO RESULTS IN MICROCURIES PER MILLILITER Unit
RWCU Crud Filter 8-27-91 1205 hrs Health Physics Analysis (Detector 1)
Cr-51 Mn-54 Co-58 Fe-59 Co-60 (2.63
+ 0.11)E-3 (8.86
+ 0.08)E-3 (3.5 i 0.3)E-4 (6.83
+ 0.11)E-3 (1.01
+ 0.03)E-3 (2.8
+ 0.3)E-3 (1
~ 02
+ 0.06)f-2 (4.2 i 0.3)E-4 (7.6 2 0.4)E-3 (1.08 X 0.05)E-3 Agreement Agreement Agreement Ag reement Ag reement Unit
RWCU Crud Filter 8-27-91 2205 hrs Health Physics Analysis (Detector 2)
Cr-51 Mn-54 Co-58 Fe-59 Co-60 (2.63
+ 0.11)E-3 (8.86
+ 0.08)E-3 (3.5 i 0.3)E-4 (6.83 f 0. 11)E-3 (1.01
+ 0.03)E-3 (2.6 2 0.2)E-3 (1.03
+ 0.06)f-2 (4.1 i 0.3)E-4 (7.7 X 0.4)E-3 ( 1.07 i 0.05)E-3 Agreement Agreement Agreement Agreement Agreement
TABLE 1 (continued)
SUS UEHANNA VERIFICATION TEST RESULTS SAMPLE ISOTOPE NRC VALUE L ICEIISEE VALUE
~CORPAR I SO RESULTS IN TOTAL MICROCURIES NRC Charcoal Cartridge (85-01)
Health Physics Analysis (Detector 1)
Ba-133
"Ba-133 (4. 15 + 0. 10) E-2 (4.15
+ 0.10)E-2 (5.9
+ 0.4)E-2 Disagreement (4.5
+ 0.3)E-2 Agreement NRC Charcoal Cartridge (85-01 )
Health Physics Analysis (Detector 2)
Ba-133
<<Ba-133 (4.15 + 0.10)E-2 (4. 15 + 0. 10) E-2 (5.6 k 0.4)E-2 (4.4 X 0.3)E-2 Disagreement Agreement Note:
Reported uncertainties are one standard deviation counting uncertainties for both NRC and licensee results.
Results from averaging counting results from both sides of cartridge to reflect actual calibration geometry.
(See Section 3. )
ATTACHMENT 1 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 judgement limits are variable in relation to the comparison of the NRC value to its associated uncertainty.
As the 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'atio for A reement
< 4 4-7 8-15
50
200
> 200 No Comparison 0.5 - 2.0 0.6 - 1.66 0.75 - 1.33 0.80 - 1.25 0.85 1.18
'Resolution
= (NRC Value/NRC Value 1S Counting Uncertainty)
~Ratio = (Licensee's Result/NRC Result)