IR 05000395/1982004
| ML20041F987 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/17/1982 |
| From: | Evans C, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20041F984 | List: |
| References | |
| 50-395-82-04, 50-395-82-4, NUDOCS 8203170624 | |
| Download: ML20041F987 (9) | |
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UNITED STATES 8\\
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NUCLEAR REGULATORY COMMISSION
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Report No. 50-395/82-04
Licensee:
South Carolina Electric and Gas Company P. O. Box 764 Columbia, SC 29218 Facility Name:
V. C. Summer Docket No. 50-395
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License No. CPPR-94
'f Inspection at V. C. Summer S J
Inspector:
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C. D. Evans Fa g Signed Approved by: h/k/b caw A//7/ 91 D. M. Montgomety, Cpief, IM&EP Section, Date Signed EPOS Division
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SUMMARY i
Inspection on January 18-22, 1982 Areas Inspected This routine, unannounced inspection involved 33 inspector-hours on site in the areas of quality control for radiochemistry and chemistry including a review of the laboratory quality control program, the radioactive effluent accountability program and capability tests for measurement of radioactive effluents.
Resul ts Of the three areas inspected, no violations or deviations were identified in three areas.
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8203170624 820218 PDR ADOCK 05000395 O
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- 0. S. Bradham, Plant Manager
- L. A. Blue, Health Physics Supervisor
- J. W. Cox, Assistant Health Physics Supervisor
- F. C. Bacon, Chemistry Supervisor L. F. Faltus, Assistant Chemistry Supervisor
- J. Barker, Corporate Staff Health Physicist NRC Resident Inspector
- J. L. Skolds
- Attended exit interview
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2.
Exit Interview l
The inspection scope and findings were summarized on January 22, 1982 with those persons indicated in paragraph 1 above.
3.
Unresolved Items were not identified during this inspection.
4.
Licensee Action on Previous Inspection Findings (Closed) (81-26-01) Correction of air particulate monitor sampling flows for period prior to May 15, 1981 to satisfy one year preoperational mon toring i
requirement.
(Closed) (81-26-02) Status of environmental TLD program regarding its compliance with energy response range as per section 4.8.4 of ANSI 5.45-1975.
(Closed) (81-26-03) Recalibration of Ge(Li) detector with a properly spiked charcoal cartridge standard.
(Closed) (81-26-04) Updating of nuclide identification library with data from recent publications.
(Closed) (80-32-01) Required modification of air particulate monitors to achieve and maintain an assigned sampling flow rate of 1-CFM.
(Closed) (80-32-02) Revise Environmental Surveillance Procedures Manual to identify each procedure as a separate entity and to require documentation of calibration of sampling equipment.
(Closed) (81-25-01) Review of Quality Assurance Program for Radiological Effluent Monitorin _-
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(Closed) (81-25-02) Completion of Radiochemistry Procedures.
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(Closed) (81-25-04) Calibration of Ge(Li) Detector for Gas Counting.
(Closed) (81-25-05) Calibration of Liquid Scintillation Counter.
(Closed) (81-25-03) Capability Test for Radioactivity in Liquids.
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The inspector reviewed the licensee's corrective actions in response to the above items and had no further questions.
5.
Program for Quality Control of Radioactive Effluent Measurements '
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Proposed Technical Specification 6.8.1.c requires that written procedures be established, implemented, and maintained for a Quality Assurance program for-effluent and environmental monitoring using the guidance in Regulatory Guide
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4.15, December 1977. The inspector reviewed the quality assurance program for effluent monitoring with respect to meeting the.gineral guidance of Regulatory Guide 4.15 covering the following areas:
a.
Organizational Structure - The V. C. Summer Nuclear Station Health Physics Section organization is delineated in the Health Physics Manual dated December 12, 1981. The manual assigns authorities, duties, and
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responsibilities of positions within the Health Physics Section from the managerial level down to the technician level. The ddy-to-day responsibility for managing the quality control program for effluent monitoring is delegated to an assistant health physics supervisor, b.
Qualifications of Personnel - The qualifications of individuals perfoming radiochemical analyses are specified in the Health Physics
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Manual. The inspector noted that all members of the Health Physics
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Section assigned duties in the radiochemical labor'atory meet the specifications defined in the manual.
c.
Operating Procedures - The Health Physics Manual rr autres that written s procedures be developed and implemented for all aspcts of the effluent monitoring program. This includes procedures for calibration'and
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quality control of instrumentation, sample processing, and analysis.
The inspector reviewed the procedures listed in paragraph 6:. '
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Records
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The inspector verified that the Health Physics count roor proced[res provide for documentation of activities including records of calibra-tion, perfomance checks, sample collection, analysis, and reporting.
Records of calibration of the Ge(Li) gamma spectroscopy system and
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quality control checks are required by procedures HPP-812 "0peration
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and Calibration of the Ge(Li) System," nd HPP-813 " Quality Centrol of
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a the Ge(Li) System". Records of-sample collection and analysis are required by procedure, HPP.-808 "Sampfe' Analysis";
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Qudity Con' trol in the Radioanalytical Laboratory
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Intra,and Interlaboratory Comparison Checks-The inspector determined from review of procedure HPP-817 " Quality Control of Sa6pling and Suiple Analysis Methods", that the licensee has established requirements for periodic analysis of replicate and spiked samples and for participation in an interlaboratory cross-check program. The inspector noted that the
.. licensee has chosen the EPA Environmental Radioactivity y Intercomparison Program and the NRC Confirmatory Measurements j'
Program. The' inspector stated the EPA program was not appropriate
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for,a comparison because the radioactivity levels of these samples
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are much lower than would be expected for routine effluent releases,'and that the NRC Confirmatory Measurements Program is an enforcemeht, activity and would not fullfill requirements for a
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liceniee cros's-check program. A licensee representative stated
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that the' utilization of SCE&G Environmental Laboratory for the purpose of a cross-check program would be investigated. This area
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will be reviewed'during a subsequent inspection (82-04-01).
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(2) Perfomance Checks
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The inspector detennined from revieu of procedure HPP-813 " Quality
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Control of <the Go(Li) Spectroscopy System", and HPP-801 " Quality Control Test of the Liquid Scintillation and Proportional Counters", that the licensee has instituted performance checks with acceptance criteria and corrective action when perfomance checks fall outsite predetermined control values.
f.
Review, Analysis, and Reporting Data The inspector noted that the Health Physics count room procedures do
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not provide for review of analytical results by supervisory personnel.
A licensee representative stated that procedures would be revised to provide for review by management. The revised procedure will be
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reviewed during subsequent inspection 82-04-02).
g.
Audits of the Quality Assurance Program 1)
The inspector noted that there are no provisions for periodic
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audits of. the radiochemistry and chemistry programs to determine compliance with Technical Specifications and Operating Procedures.
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IA licensee representative agreed to include tnese areas in the
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Quality Ccntrol audit program. This area will be reviewed durin) subsequent inspection (82-04-03).
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2)
Proposed Technical Specification 6.5.2.8.o requires a compre-hensive audit of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, at least once per 12 months. The individuals performing the audit shall be
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bilities in the Sunner radiochemistry programs. A licensee representative indicated that provisions for the annual audit are being made with the SCE&G Environmental Laboratory. This area will be reviewed during a subsequent inspection (82-04-04).
6.
Review of Radiochemistry Procedures
a.
The inspector reviewed the following procedures:
t HPP-802, Operation of the Beckman L.S. 7500 Liquid Scintillation Counter HPP-810, Sampling of Radioactive Gases and Liquids,11-8-81 HPP-808, Sample Analysis, not issued HPP-710, Release of Radioactive Liquid Effluents, not issued HPP-801, Quality Control Test of L.S.-7500 System, G.M. Counters and Gas Flow Proportional Counters,1-17-81 HPP-817, Quality Control of Sampling and Sample Analysis Methods, 1-19-81 HPP-812, Operation and Calibration of the N.D.-66/H.P.-9845 Ge(Li)
Spectroscopy System,1-19-81 HPP-813, Ouality Control of the Ge(Li) Spectroscopy System,1-19-81 HPP-709, Release of Radioactive Gaseous Effluents, not issued HPP-916, Computer Program Control, 11-17-81 HPP-917, Computer Pr9 gram Testing, 11-17-81 HPP-811, Transfer of Nixed Ganma Emitting Gas Standard, 10-27-81 HPP-803, Operation of the Tennelec LB-5100 Automatic Counting System, 1-15-81 AP-600, Chenistry Operations Manual, 5-11-79 CHP-132, Boron Detenilination, 11-30-79
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CHP-902, Chenistry Sampling Point List, 11-20-81 i
CHP-608, Chemistry Group Quality Control Program, 12-7-79 CHP-103, Fluoride Detennination, 4-8-80 f
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CHP-303, Determination of Dose Equivalent Iodine, 1-21-82 CHP-304, Detemination of Tritium,1-21-82 CHP-302, Determination of Average Energy per Disintagration 1-21-82 HPP-920, Post Accident Reactor Building Atmospheric Sampling,1-7-82 The inspector discussed the results of the procedure review with licensee representatives as noted in paragraph 6b - 69 The inspector stated that procedures that have not been approved for plant operation would be carried as an open item. A licensee representative indicated that all radiochemistry and chemistry procedures would be approved before February 28, 1982 (82-04-05).
b.
Proposed Technical Specification 3.11.2.6 requires that the quantity of radioactivity contained in each waste gas storage tank shall be limited to less than or equal to 60,000 curies noble gas (considered as Xe-133). The inspector noted that the licensee did not have an established method to convert the measured noble gases to an equivalent concentration of Xe-133. A licensee representative acknowledged the need for an established method and indicated that a computer program would be developed and documented for this purpose. The computer program and documentation will be reviewed during a subsequent inspection (82-09-06).
c.
Proposed Technical Specification 4.11.1.1.3 requires that a daily grab sample be taken of the continuous releases from the turbine building sump and service water effluent.
It also requires that the daily grab samples from the effluent streams be composited weekly in proportion to the respective daily rate of flow. The inspector noted that procedure HPP-810 " Sampling of Radioactive Gases and Liquids", did not address this requirement. A licensee representative agreed to review and revise the procedure to incorporate this requirement. The revised procedure will be reviewed during a subsequent inspection (82-04-07),
d.
The inspector noted that there was no calibration program for the
photohelic flow gauges on the Main Plant Vent Radiation Monitor (Rft-A3)
and the Containment Purge Radiation flonitor (RM-A4). The inspector stated that this did not meet the recommendation of Regulatory Guide 4.15 for scheduled recalibration of flow measuring devices used for effluent accountability. A licensee representative indicated that calibration of the flow aauge would be included in the MT&E program of the plant maintenance M irtment. This area will be reviewed during a subsequent inspection ( c.2-04-08).
e.
The inspector noted that the technique for calibration of the liquid scintillation counter for tritium in aqueous samples utilized a nonaqueous tritium standard which may not be representative of actual samples. The inspector also noted that sample prepar4 tion did not include distillation for decontamination from other radionaclides l
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present in the sample. A licensee representative agreed to revise the
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procedure to address the above concerns. The revised procedure will be reviewed during a subsequent inspection (82-04-09).
f.
The inspector noted that the licensee had not documented and tested the sof tware packages for ganma spectral analysis, Ge(Li) quality control, and effluent accountability as required in procedure HPP-917 " Computer Program Testing". A licensee representative agreed to document and test all software packages. The testing would consist of entering data into the computer and comparing the results to those calculated manually using the algorithm of the software packages. The docu-mentation and test data will be reviewed during a subsequent inspection (82-09-10).
g.
The inspector noted that the licensee had not routinely perfomed quality control checks on counting room instrumentation. The inspector noted that the licensee procedures require quality control checks on a daily or as used basis and that this practice should be in progress to provide adequate pre-operational testing data for the counting room instrumentation. A licensee representative agreed to institute routine quality control checks for laboratory instrumentation inmediately.
This area will be reviewed during a subsequent inspection (80-04-11).
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Capability Tests The licensee was provided with a simulated liquid waste and filter sample prepared by the DOE Radiological Environmental Services Laboratory for gama spectroscopy, tritium, and strontium 89 and 90 analyses. These analyses serve to verify the licensee's capability to measure radionuclides in effluent samples. The results of the licensee's gamma spectroscopy and strontium 89 and 90 analyses and comparison to NRC values are presented in Table 1 with the acceptance criteria in Attachment 1.
The results show
" agreement" for cl1 nuclides identified by gamma spectroscopy, but the results show " disagreement" for the strontium 89 and 90 analyses for both samples. The inspector noted that this was the licensee's first attempt at perfoming a strontium 89 and 90 analysis. The inspector stated that the procedure should have been tested and verified by analysis of spiked samples prior to approval as an operating procedure. A licensee representative indicated that the procedure would not be finished before issuance of an operating license and that selection of a contract laboratory was under way.
The inspector noted that Regulatory Guide 4.15 also applies to contract laboratories, and this should be a criterion in selection of a contract
laboratory. Another simulated waste liquid and filter sample will be sent to the licensee for analysis by the licensee's contract laboratory for strontium 89 and 90. The licensee had not completed the tritium analysis, but agreed to forward results to NRC:II when completed. This area will be reviewed during a subsequent inspection.
(82-04-12).
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TABLE 1
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RESULTS OF CAPABILITY TESTS AT V.C. SUltMER, JANUARY 18-22, 1982 i
Concentration, microcuries/ml.
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Sample Isotope V.C. Summer NRC Ratio Resolution Comparison
DOE Co-57 (1.131.08)E-3 (1.13t.08)E-4 1.00
Agreement
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Simulated Cs-134 (1.89.08)E-3 (1.81.03)E-3 1.04
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Liquid Waste Co-60 3.65.15)E-3 3.52.09 E-3 1.03
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Sr-89 3.73)E-3 8.29.01 E-3
.44 829 Disagreement
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l Sr-90 1.22)E-4 5.92.04 E-4
.20 148 Disagreement
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Concentration, microcuries/ sample DOE Sr-89 3.97E-3 (8.291.01)E-3
.47 829 Disagreement
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Simulated Sr-90 N.A.R (5.29.04)E-4 N.C.
148 Disagreement l
Particulate
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Filter
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N.A.R. - No activity reported l
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Attachment I
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CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS l
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 judgment limits are variabic 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.
LICENSEE VALUE
" NRC REFERENCE VALUE Possible Possible Resolution Agreement Agreement A Agreement B
<3 0.4 - 2.5 0.3 - 3.0 No Comparison 4-7 0.5 - 2.0 0.4 - 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 - 200 0.80 - 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 sampics.
"B" criteria are applied to the following analyses:
Camma Spectrometry where principal gamma energy used for identification is less than 250 Kev.
Sr and Sr Determinations.
Gross Beta where samples are counted on the same date using the same reference nuclide.
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