ML17352A587
| ML17352A587 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/02/1994 |
| From: | Decker T, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17352A585 | List: |
| References | |
| 50-250-94-04, 50-250-94-4, 50-251-94-04, 50-251-94-4, NUDOCS 9405180142 | |
| Download: ML17352A587 (29) | |
See also: IR 05000250/1994004
Text
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UNITEDSTATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-250/94-04
and 50-251/94-04
Licensee:
Florida Power
and Light Company
9250 West Flagler Street
Miami,
FL
33102
Docket Nos.:
50-250
and 50-251
Facility Name:
Turkey Point Units 3 and
4
License Nos.:
and
Inspection
Conducted:
February
28 - March 4,
and April 5,
1994
I
Inspector:,
~ {t)
u-.~
l ll0
)3
Lt
G.
B.
Kyoto
li~
Dati Signed
<</
Approved
by ~Arorooi~w",dy o'<A~
y
7'2i'.
R. Decker, Chief
Date
igned
Radiological Effluents
and Chemistry Section
Radiological
Protection
and
Emergency
Preparedness
Branch
Division of Radiation Safety
and Safeguards
SUMMARY
This special
announced
inspection
involved selected
review of licensee
programs for liquid and airborne radiological effluent control
and monitoring,
radiochemistry laboratory quality control;
and review of a previously
identified issue tracked
by the
NRC as
an unresolved
item (URI).
Results:
Gaseous
effluent sampling
equipment
was determined to be adequate
with
isokenetic
sampling verified for the main plant vent.
Ventilation system flow
rates
met design specifications.
Housekeeping
and cleanliness
associated
with
the radioactive effluent sampling/processing
areas
and th'e radiochemistry
laboratory were adequate.
Weaknesses
were identified in the licensee's
Radiation Protection
(RP) program for measuring
selected
non-gamma emitting
radionuclides
in liquid effluents.
The identified weaknesses
included
unexplained
biases
in quality control
(gC) tritium (H-3) and iron-55 (Fe-55)
measurements;
failure to have adequate
procedures
for preparation of gC and
samples for vendor Fe-55 analyses,
and for operation of liquid
scintillation counting
(LSC) equipment;
and failure to train adequately,
staff
assigned
responsibility for calibration of the
LSC equipment.
Although non-
conservative,
the identified measurement
biases
would not have resulted
in any
significant increase
in associated
offsite dose estimates
to the public.
94OSisO~4~ ~4>>0~>>-
ADOCK 05000250
8
The following URI, non-cited violation (NCV), and violation (VIO) were
identified.
URI regarding
adequacy of licensee's
H-3 and
Fe-55 surveillances
conducted for selected
effluent analyses
as required
by 10 CFR 20. 1501.
Unresolved
pending licensee
evaluation
and verification of biases
identified from NRC crosscheck
sample
analyses
(Paragraph
2.a).
NCV of Technical Specification (TS) 6.8. 1 for failure to have
adequate
procedures
for preparation of Reactor Coolant
System
(RCS)
and
gC liquid
samples
sent to vendors for Strontium-89/90
(Sr-89/90)
and Fe-55
analyses,
and for calibration/operation
of licensee
LSC equipment
used
for H-3 analyses
(Paragraph
2.c).
VIO of TS 6.4 for failure to have
adequate
specialized training required
for efficiency determination,
and quench
and decay correction
requirements
for
LSC equipment
using the automated
analysis
protocol for
H-3 analyses
(Paragraph
2.d).
REPORT DETAILS
Persons
Contacted
t
Licensee
Employees
T. Abbatiello, Manager, guality Assurance
(gA)
- J. Berg, Supervisor,
Radiochemistry
- C. Bible, Manager, Site Engineering
- J. Danek,
Manager,
Corporate
Health Physics
- R. Earl, Supervisor,
gA
8*D. Jernigen,
Manager,
Operations
J. Knorr, Licensing Engineer
- R. Kundalkar,
Manager,
Engineering
- J. Lindsay, Supervisor,
Health Physics
- M. Lacal, Services
Manager,
Acting
8*L. Pearce,
Plant Manager
- T. Plunkett,
Vice President
- D. Powell, Technical
Hanager
8*R. Steinke,
Supervisor,
Chemistry
8*E. Weinkam,
Manager,
Licensing
Other licensee
employees
contacted
included engineers,
technicians,
operators,
and office personnel.
Nuclear Regulatory
Commission
- B. Desai,
Resident
Inspector
8T. Johnson,
Senior Resident
Inspector
- Attended March 4,
1994 Exit Meeting
8Participated
in April 5,
1994 Teleconference
Radiological
Chemistry Measurements
Program
(84523,
84524,
84525)
During the onsite inspection,
licensee activities associated
with the
radiochemistry
measurements
program for non-gamma emitting radionuclides
including results of a
NRC confirmatory measurements
sample analysis,
laboratory quality control
(gC) activities,
procedural
adequacy,
and
specialized training were reviewed
and discussed
in detail.
'a ~
Confirmatory Measurements
10 CfR 20.1501(a)
requires,
in part, that licensees
cause
or cause
to be
made surveys that
may be necessary
to comply with the
regulations of this part
and are reasonable
under the
circumstances
to evaluate
the extent of concentrations
or
quantities of radioactive material,
and the potential
hazards that
could
be present.
10 CFR 20.1501(b) requires,
in part, licensees
to ensure that
instruments
and equipment
used for quantitative radiation
measurements
be calibrated periodically for the radiation
measured.
During the onsite inspection,
the licensee's
capability to
quantitatively measure
selected,
non-gamma emitting radionuclides
in liquid and gaseous
effluents
was reviewed.
In particular,
the
licensee's
programs to measure
accurately, tritium (H-3), iron-55
(Fe-55),
strontium-89 (Sr-89),
and strontium-90
(Sr-90)
concentrations
in liquid samples
were evaluated
by reviewing
and
discussing results of a confirmatory measurement
sample provided
by the
NRC contractor laboratory to the licensee.
The
radionuclide concentrations
in microcuries per milliliter (I Ci/ml)
for the licensee
and
NRC sample,
the ratio of licensee
to
NRC
values,
the resolution
based
on the standard error of the
known
values
and the results of the comparison
are presented
in Table
1.
The criteria for comparisons
used for the analytical
measurements
are presented
in Table A-1 of Attachment
1.
Table
1
Results of Licensee/NRC
Confirmatory Measurement
Comparisons
Licensee
1.04E-04
Sr-89
NA
2.26E-05
4.80E-06
1.53E-04(+5%)
NA"
2 72E 05(+5%)
1.48E-05(+5%a)
20
0.68
NA
NC
20
0.83
20
0.32
D
NA
A
D
1 Resolution ~ NRC Reference Value/Associated Uncertainty
2 Ratio ~ LicenseaINRC Reference Value; NC ~ Not Compared
3 Comparisons, A ~ Agreement, NA ~ Not Appticeble, D ~ Disegreemant
4 NP ~ Below Detection ln NRC Sample Provided
Excluding the Sr-90 radionuclide,
licensee results for H-3 and
Fe-55 were in disagreement
with the
known values provided
by the
NRC contractor laboratory.
For the H-3 and Fe-55 radionuclides,
the values reported
by the licensee
were approximately
68 and
32 percent of the
known concentrations,
respectively,
and were
outside of the range of values required to demonstrate
agreement.
Followup of the identified differences
between
the licensee
and
NRC values
were conducted
by reviewing additional
analyses
of
liquids containing
known H-3 concentrations,
and review of
selected
radiochemistry laboratory
gC records
associated
with H-3
and Fe-55 measurements
(Paragraph
2.b).
In addition, licensee
procedures,
training,
and potential
vendor activities which may
have affected the sample results
were reviewed
and discussed.
'I
For H-3 analyses
which are performed onsite
by the licensee,
supplemental
analyses
were conducted
during the inspection
using
known H-3 concentrations
similar to those values represented
.in
the
NRC confirmatory measurements
sample.
For the additional
analyses
conducted,
reported concentration
results
generated
using
the liquid scintillation counter
(LSC) automatic analysis protocol
(internal algorithms) for H-'3 analyses
were approximately
20 percent
less
than the
known values.
Further,
the inspector
noted that the
LSC H-3 efficiencies generated
by the. LSC algorithm
differed significantly from the efficiency determined
from manual
calculations
using the H-3 activity detected within the
appropriate
energy ranges
established
on the
LSC equipment.
From review of licensee
gC data for both H-3 and Fe-55
measurements
as detailed
in Paragraph
2.b,
no consistent
biases
for the quantification of either radionuclide were identified nor
were specific causes
for the identified differences
determined
prior to the
end of the onsite inspection.
Potential
causes
to be
evaluated
by the licensee
to verify the non-conservative
results
included improper preparation
for the
NRC
gC sample
analyzed for
the Fe-55 concentrations,
and changes
to equipment
and/or
chemicals
which could have affected the H-3 measurements.
The
inspector
informed the licensee that pending completion of their
review and verification of the identified biases for the H-3 and
Fe-55 radionuclides
in the
NRC spiked
sample,
or performance of an
acceptable
measurement
of additional
spiked
samples
to be provided
by the
NRC, the identified differences
between licensee
and
NRC
values for the H-3 and
Fe-55 analyses
would be considered
an
unresolved
item (URI 50-250,
251/94-04-01).
During an April 5,
1994 teleconference
between
Mr. G. Kuzo,
NRC
RII and Mr. L. Pearce,
Plant Manager,
Turkey Point Nuclear
(TPN),
additional
licensee
evaluations
and results 'associated
with the
differences
in the confirmatory measurement
results
were reviewed
and discussed.
The 'licensee
stated that supplemental
investigations
conducted
since the
end of the onsite inspection
currently indicated
a consistent
non-conservative
bias for H-3
analyses
using the
LSC algorithm, with reported results
approximating
72 percent of expected
values.
As of April 5,
1994,
,no resolution regarding
the specific cause of the bias
had
been
determined,
although'he
licensee
was continuing to evaluate
photomultiplier tube degradation,
changes
made to the type of
liquid scintillation cocktail
used,
and potential electronic
drift'or
the instrument.
Further, licensee
representatives
indicated
that
no additional
studies of potential
causes
for the Fe-55
analysis differences
between
the
NRC and licensee
had
been
conducted,
Licensee representatives
stated that evaluation of
instrumentation,
chemistry,
and procedures
were continuing for
both the H-3 and Fe-55 analyses.
The inspector
informed licensee
representatives
that the identified issue
would remain unresolved
pending completion of their final evaluation.
In addition, licensee
representatives
stated that pending
completion of their review and determination of the accuracy of
their H-3 measurements,
all reported effluent H-3 concentration
values in the recently issued
semi-annual
release
report were
adjusted
by
a factor of 1.32 to account for the potential worst-
case
basis identified for K-3 measurements
based
on the
NRC
confirmatory measurements
sample results.
In addition, licensee
representatives
stated that changes
to offsite dose estimates
were
insignificant based
on the adjusted
H-3 concentrations
in
effluents.
For the Fe-55 radionuclide,
licensee
representatives
stated that
no adjustments
were
made to the reported effluent
concentrations
based
on results of acceptable
gC Fe-55 measurement
results for liquid samples
provided with each quarterly composite
liquid samples
sent to the vendor for=analyses.
For the previous
'ear
the inspector verified that quarterly
gC results
were within
12 percent of the licensee's
reference
laboratory values.
The
inspector
agreed with the licensee
actions
pending completion of
further studies.
P
One
URI to review licensee
evaluation of identified
gC sample
biases
was identified
(URI 50-250,
251/94-04-01).
Laboratory guality Control
Previous results for a 1991
NRC confirmatory measurements
sample
and selected
1992
and
1993 quarterly licensee
interlaboratory
comparison results for H-3, Fe-55,
and Sr-90
as detailed in
Table
2 were reviewed
and discussed.
Nuclear Chemistry Procedure
NC-7, Radiochemistry guality Control
Program,
dated October
17,
1991, provides guidance for
implementation of the counting
room data
gC program.
The inspector verified from review of selected
gC checks
conducted
between
January
1 through April 14,
1993, that the intralaboratory
replicate
and reanalysis
gC sampling
was being conducted
in
accordance
with the licensee's
procedure.
For the specific
geometries
and radionuclides
analyzed,
licensee results
were in
agreement
with the reference
laboratory
based
on the associated
counting statistics.
gC results
including and subsequent
to previous
NRC confirmatory
measurement
analyses
were reviewed
and discussed.
The inspector
noted that licensee results for the previous
NRC confirmatory
measurements
comparison
sample provided in the second
quarter of
1991 were in agreement for all radionuclides
analyzed
(Table 2).
However, the inspector
noted that licensee
gC analyses
conducted
during the fourth quarter
1992
and the second quarter
1993 were in agreement
but were biased
approximately
24 and
23 percent less than the reported reference
laboratory values.
Licensee representatives
stated that these
biases
were identified
and changes
were
made to the
LSC cocktail
used for sample
analyses
and instrument setup.
Subsequently,
the fourth quarter
1993
result
was approximately
10 percent greater
than the value
reported
by the reference
laboratory.
However,
no additional
evaluations
were conducted to verify the
assumed
cause/effect-
relationship.
The inspector
noted that additional evaluations
should
have
been
conducted to verify that the identified change to
the
LSC cocktail
medium was the cause of the observed effect.
From further discussions
with cognizant licensee
representatives,
the inspector determined that,
in addition to the
LSC cocktail
change
made in June
1993, additional modifications to the
chemicals
or equipment
made since the previous
NRC 1991 acceptable
comparison
included replacement
of the
LSC photomultiplier tube in
October
1992,
a change
in the
QC check source
in November
1993,
and slight modifications to the sample tray in November
1994.
The inspector
noted that the positive bias identified in
the fourth quarter of 1993, relative to negatively biased results
for the
NRC and licensee
QC samples,
and supplemental
measurements
conducted
during the onsite inspection,
now may be
an outlier or
the result of some other factor, rather than the effect of changes
to the
LSC cocktail
used in the analyses.
Table
2
Results of Licensee/Vendor
QC Comparisons
RATIOS'arter
2n'tr 91'"
4" Qtr 92
1st Qtr 93
2n'tr 93
3rd Qtr 93
4'" Qtr 93
0.92
0.76
NC
0.77
NC
1.11
0.95
NC
0.82
NC
0.99
NC
Sr-89
90
1.00/0.92
NC
1.00/1.02
NC
1.01/1.19
1 Ratio ~ Licensee/Vendor
Reference Value
2 Results of Previous Mey 6, 1991 Confirmatory Measurements
Analyses
3 NC ~ Not Conducted
The inspector
noted that the lack of detailed
and thorough
followup regarding the
gC identified non-conservative
trends
was
a
0C program weakness.
No violations or deviations
were identified.
Procedures
Licensee
procedures
and/or specifications
provided to the
applicable
vendor laboratory regarding
sample
analyses
were
reviewed
and discussed
as
a result of the identified confirmatory
measurement
differences
between
the concentration
values reported
by licensee
and
NRC.
TS 6.8. 1 requires written procedures
to be
established,'mplemented,
and maintained
covering the activities referenced
in
the applicable
procedures
recommended
in Appendix
A of Regulatory
Guide 1.33,
Revision
(Rev.) 2, February
1978, Sections
5. 1 and 5.3
of ANSI N18.7-1972;
and guality Control
Program for effluent
monitoring using the guidance
in Regulatory
Guide 1.21,
Rev.
1,
dated
June
1974.
During discussions
regarding the confirmatory measurement
samples
provided by the
NRC contract laboratory,
the inspector
was
informed that the low-sample
volume provided required the licensee
to dilute the samples.
From discussions
with the
NRC contractor
laboratory,
the inspector confirmed that the low sample
volume
received
was not the result of spillage.
Further,
the inspector
noted that based
on the licensee dilution factors,
the
radionuclide concentrations
in the sample
as provided to the
vendor laboratory were greater
than the required lower limit of
detection
and Sr-90 radionuclides.
In
addition, licensee
representatives
stated that the
LLDs for the
analyses
were specified in the vendor laboratory contract,
as
applicable,
and that the vendor procedures
were reviewed
as part
of the licensee's
approved
vendor program.
However,
the inspector
noted that if further dilution of the sample
s as conducted
at the
vendor laboratory,
the resultant concentrations
could
be less
than
the
TS required
LLD and subsequently
resulted in the noted
differences.
The licensee
contacted
the vendor
and verified that
no additional dilutions of the sample
were conducted
by the vendor
laboratory.
The following issues resulting from review of licensee
procedures
for operation of selected
equipment
and/or preparation of samples
associated
with non-gamma emitting radionuclides
were identified
and discussed
with cognizant licensee
representatives.
Routine quarterly composite liquid effluent and
gC samples,
and,
as applicable,
special
reactor coolant liquid are sent
to the vendor laboratory for Fe-55,
Sr-89
and Sr-90
analyses.
Licensee
procedure
O-NCOP-003,
Sampling
Preparation
of Liquid Release
Permits,
dated
November .4,
1993, requires
the composites of liquid samples
collected
for monthly and quarterly liquid effluent analyses
to be
acidified using 2: 1 hydrochloric acid.
However,
procedure
O-NCAP-211, Determination of Strontium,
Isotopic Activity, dated
November
12,
1991, which provides
guidance for processing
both
gC and reactor coolant system
(RCS) liquid samples for the Fe-55,
Sr-89
and Sr-90 analyses
did not specify that liquid samples
should
be acidified.
The inspector
noted that the failure of the procedure to
require liquid sample acidification to prevent plate-out of
the Fe-55,
and to
a lesser extent,
the strontium
radionuclides
on the container
surfaces
was
an example of
violation of TS 6.8. 1.
The technician
who diluted and
prepared
the
NRC confirmatory measurement
sample for
shipment
informed the inspector that the
NRC confirmatory
measurement
sample liquid was acidified.
However,
review of
notes
associated
with the dilution calculations failed to
indicate that the sample
was acidified.
The inspector
noted
that lack of acidification and the further dilution of the
"
sample could have resulted
in the significant non-
conservative
difference observed for the Fe-55 analysis.
Licensee representatives
stated that immediate corrective
actions to revise appropriate
procedures
to require
acidification of liquid samples
collected for Fe-55
and Sr-
89 and Sr-90 analyses
were in progress.
In addition,
evaluations
to determine the cause of the noted bias were
continuing.
Guidance for calibration
and set-up,
and for H-3 analysis
using the onsite
LSC equipment is provided in O-NCCP-102,
Liquid Scintillation Counter Set-up
and Calibration,
and
O-NCAP-212, Tritium Determination,
respectively,
both dated
July 23,
1993.
From discussions
with responsible
licensee
representatives
and review of the procedures,
the inspector
noted that the guidance did not provide adequate
details
regarding preparation of a quench
curve
and the source vials
used in the current system.
For example,
the procedure
references
the vendor manual to specify that
a quench
curve
should
be established.
The inspector
noted from discussions
with selected
chemistry laboratory supervisors
and
technicians that different methods for preparing the current
quench
curve were specified
dependent
upon the individual
interviewed.
Further,
no guidance
was provided for
preparation
and
use of the source vials used in the
calibration.
The failure to have adequate
procedures
for
setup
and calibration of the current
LSC equipment
was
identified as
an additional
example of a violation of
Licensee representatives
stated that
a procedural
change to
require acidification of liquid samples for Fe-55,
Sr-89
and Sr-90
analyses
was initiated and changes
to provide appropriate
guidance
for LSC equipment
setup
and calibration for H-3 determinations
would be implemented.
The inspector
informed licensee
representatives
that because
of the low safety significance of the
current issues
and the ongoing corrective actions,
the criteria
specified in Section VII.B of the Enforcement Policy were met and
the examples of the inadequate
procedures
for H-3 and
analytical
measurements
would be considered collectively as
a non-
cited violation (NCV) of TS 6.8. 1
(NCV 50-250,
251/94-04-02).
One
NCV of TS 6.8. 1 for failure to have
adequate
procedures
for
preparation of RCS
and
gC liquid samples
sent to vendors for Fe-55
Sr-89
and Sr-90,
and for calibration/operation
of LSC equipment
used for H-3 analyses
was identified.
Training
TS 6.4. 1 requires
a retraining
and replacement
training program
for the facility staff to be maintained
under the direction of the
Training Hanager
and to meet or exceed
the requirements
and
recommendations
of Section 5.5 of ANSI N18. 1-1971,
and
ANSI 3. 1,
1981,
and shall include familiarization with
relevant industry operational
experience.
Routine
and specialized training provided to licensee
representatives
responsible for calibration
and setup of the
equipment,
and for routine H-3 analyses
in liquid samples
were
reviewed
and discussed
with licensee
representatives.
Licensee
procedures
O-ADH-302, Nuclear Chemistry Training dated
January
31,
1991,
and O-ADH-304, Technical Training Program for
Technical Staff, dated
Hay 11,
1988, provide guidance for initial
and continuing training provided to the chemistry staff.
Licensee
procedure,
O-ADH-304, Section 5.2 states,
in part, that continuing
technical training is provided to enhance
technical staff
knowledge of specialized
technical
tasks
and tl.at the continuing
training will consist of training on specific topics or tasks
presented
to selected
technical staff as required.
During discussions
with responsible
individuals regarding the
identified issues
regarding the licensee
H-3 concentration
determinations,
the inspector
noted inconsistent
responses
to
questions
concerning the general
setup
and calibration of the
current
LSC equipment for use in the automatic analysis protocol.
In particular,
the function of the tritium source vial in H-3
analyses,
methods of determining the counting efficiency,
and
whether decay-corrected
radionuclide
source activity data
had to
be entered
into the
LSC algorithm for initial calibration of the
LSC equipment.
The inspector
reviewed the following lesson
packages
and task analyses
provided to staff as part of training
required for H-3 analyses.
Lesson
Package
No.2100073,
Operation of a Liquid,
Scintillation Detector
Perform Tritium Determination,
dated
December
18,
1991
Perform
a Calibration of the Packard
Model
2200CA Liquid
Scintillation Counter,
dated
June
29,
1990
The inspector
noted that the reviewed training guidance
provided
adequate
details regarding
LSC o'perational
theory
and guidance for
routine operation of the licensee's
equipment.
However,
specialized details indicating the answers
to the questions
regarding tritium source vial, efficiency determination,
and
use
of decay corrected
data to be used with the current algorithm for
H-3 determinations
were not addressed.
Licensee representatives
stated'that
specialized training regarding these
issues,
most
likely, were reviewed
and discussed
by the vendor
and responsible
licensee
representative
during the initial installation
and setup
of the
LSC equipment.
Also, the staff member involved 'with the
current
LSC equipment installation
and setup
was
no longer
employed
by the licensee.
From discussions
with licensee
representatives
the inspector determined that no additional
specialized training regarding the current
LSC equipment
been
provided for those individuals responsible
for the current
equipment.
The inspector
informed licensee
representatives
that
the failure to provide
and maintain specialized training for
personnel
responsible for the current
LSC equipment
was
a
violation of TS 6.4. 1
(YIO 50-250,
251/94-04-03).
One violation of TS 6.4 for failure to have
adequate
specialized
training for LSC equipment operation
was identified.
Ventilation and Air Sampling
Systems
(84524)
Plant systems
associated
with gaseous
effluent releases
and sampling
were reviewed.
The review included verification of ventilation system
design flow rates,
effluent primary and alternate
sampling
system
operability,
and verification of isokenetic
sampling,
as applicable.
a.
Ventilation System Flowrates
During the inspection,
the quantification of main stack flowrates
was discussed
and reviewed.
Comparisons
were
made
between
measured
flow rates
indicated
by on Channel
10 of the main plant
vent System Particulate
Iodine Noble
Gas
(SPING) monitor and the
expected
cumulative flow rate
based
on the individual flow
specifications
indicated in the Final Safety Analysis Report
e
10
(FSAR) Figure 9.8-1.
For the exhaust
systems
in service during
the review including the Auxiliary Building, Unit 4 Spent
Fuel Pit
(SFP),
Radioactive
Waste Building and Laundry Facilities, the
indicated flow rate of 56000 standard
cubic feet per minute '(scfm)
was consistent with the calculated
flow rate of 60000 scfm.
No violations or deviations
were identified.
b.
Gaseous
Effluent Sampling
System
Licensee
programs established
to conduct isokenetic
sampling for
selected
gaseous
effluent release
pathways during routine
and non-
routine activities were reviewed
and discussed.
Li'censee representatives
stated that previous
commitments to the
NRC required only the main plant vent'o meet isokinetic sampli'ng
conditions.
From review of expected
main stack
and associated
sampling
system flow rates
and associated
linear flow velocities,
and discussions
of filtration through High Efficiency Particulate
Airborne
(HEPA) filters for selected
areas
such
as the laundry
ventilation flow to reduce particle size,
the inspector
noted that
established
SPING sampling flow rate of 60 liters per minute
(l/min) met isokinetic sampling requirements.
In addition, the
inspector walked-down selected
portions of the sampling line
leading from the main plant vent to the
SPING located in the
Auxiliary Building Fan
Room.
The inspector
noted that the sample
line construction
was in accordance
with ANSI 13. 1, American
National
Standard
Guide to Sampling Airborne Radioactive Haterials
in Nuclear Facilities,
dated
1969, to minimize sample line
deposition in that the sample line followed the most direct path
from the stack flow nozzle to the radiation monitoring equipment,
and that the radii of bends in the sample line were approximately
20 to 30 times the sample line diameter.
No concerns
were
identified for the main plant vent effluent sampling operations.
'icensee
air sampling
system
equipment
and guidance
used to sample
containment
airborne
hazards for "at-power" entries
and alternate
gaseous
effluent sampling were reviewed in response
to
a previous
URI regarding appropriateness
of portable air sampling
equipment
identified during
a previous inspection
conducted
June
7.-28,
1993,
and documented
in Inspection
Report (IR) 50-250,
251/93-16.,
The
original issue
involved the need to correct the flow meter
(rotometer)
readings for an expected
pressure differential
and
subsequent
issues identified regarding the configuration of the
filter, flow meter
and pressure
gauge in the sample line.
The
following issues
regarding the licensee
program for .the systems
were identified and discussed
in detail.
The inspector
noted that the sampling configuration
used
on
the portable/alternate
airborne effluent or containment
sampling systems,
did not correspond
with the guidance
detailed in ANSI 13. 1 i.e., the flow measuring
device
was
11
positioned
before rather than after the filter.
Positioning
the flow rate meter after the filter is proposed to minimize
degradation
of the instrument
from vapors or particulates
in
the sample
stream.
Licensee representatives
stated that
.only the Steam Jet Air Ejector airborne effluent was
expected to provide potentially corrosive materials
which
could degrade
operation of the flow measuring
device.,
In
addition, the flow measurement
devices
are replaced
annually
and prior to each
use,
are required to be checked for
indications of degradation,
e.g., discoloration,
which might
affect the system accuracy.
From discussions
with licensee
technicians
trained to use the sampling systems,
the current
practice of verifying rotometer operability prior to use
was
verified.
The inspector verified that the containment air sampling
and
alternate effluent sampling
systems
have
a flowmeter and
vacuum gauge in series
to evaluate differential pressure
effects
on flow rate measurements.
Licensee
representatives
stated that the current practice of placing the flow
measuring
device prior to the filter minimizes the effect of
a pressure differential
on the flow meter accuracy.
In
addition, the inspector reviewed
and discussed
Condition
Report
No.93-590,
dated July 7,
1993, which assessed
the
containment
remote air sampling
system in response
to the
previous air sampling issue identified in IR 50-250,
251/
93-16.
The assessment
documented
a floe rate
measurement
error of only,four to five percent
based
on pressure
changes
in the sample line for the current sampling configuration
relative to
a 33 percent under-estimation originally
determined for a configuration with the rotometer placed
downstream of the filter.
For the portable
systems
used for alternate
gaseous
effluent
sampling of the main plant, Unit 3 SFP,
and
Steam Jet Air
Ejector vents,
the sample flow rate
was specified
as
37 l/min although the flow rate
and velocities from the
sample points differed significantly.
Licensee
representatives
stated that isokinetic sampling
was only
required to be demonstrated
for the main plant vent.
Further,
licensee
reviews
and evaluation of the main plant
vent specifications
indicated that based
on the guidance
provided in ANSI 13. 1, the resultant flow velocity would
result in a conservative particulate effluent estimate for
releases
from the main stack.
However, the inspector
noted
that licensee
procedures
did not provide limiting
specifications,
e.g.
minimum or maximum flowrates, for the
portable/alternate
sampling
systems
used for the main plant
vent
and that
a non-conservative
estimate for effluent
particulate concentrations
was possible.
Licensee
representatives.
agreed with the inspector's
comments.
12
Licensee representatives
stated that procedural
changes
to outline
the portable
gaseous
effluent sampling
system specifications
and
to verify rotometer operability prior to each
use would be
initiated.
The inspector
noted that based'n
the licensee
evaluation of the current air sampling
systems
and 'proposed
changes
to the program guidance,
no concerns
regarding the
alternate effluent and containment
airborne sampling
systems
were
'dentified.
No violations or deviations
were identified.
c.
Alternate Sampling
TSs 3/4.3.3,6
and Table 4-11.2 specify, in part, limiting
conditions for operation,
surveillance
requirements
for the
facility radioactive
gaseous
effluent monitoring instrumentation,
and the actions
and auxiliary sampling equipment to be used for
'ampling
as
a result of inoperable
gaseous
effluent monitoring
instrumentation.
Licensee
procedure
O-NCZP-051.3,
Obtaining Plant Effluent Samples
via the
SPING Monitors during Non-accident Conditions,
dated
May 28,
1992, provides-instructions
for obtaining iodine,
particulate,
and grab samples with the
SPING monitor is declared
out-of-service.
Selected April 1993 through February
1994 Equipment Out-of-Service
Logbook and Limiting Condition for Operation
(LCO) Hours Data
Sheets 'were reviewed to identify monitoring instrumentation
which
required alternate
flowrate and/or gaseous
effluent monitoring.
For each incident of inoperable monitoring instrumentation
requiring detailed auxiliary flowrate or effluent sampling,
the
inspector verified that appropriate
flow rate determinations
and/or alternate
sampling
was conducted.
No concerns
were
identified.
No violations or deviations
were identified.
Audits (84523,
84524,
84525)
TS 6.5.2.8 requires
audits of facility activities tu be performed
under
the cognizance of the
Company Nuclear Review Board
(CNRB) encompassing
conformance of facility operation to all provisions contained
in the
TSs
and applicable
License Conditions at least
once per
12 months,
the
Radiological
Environmental
Monitoring Program
and the results thereof at
least
once per
12 months;
the Offsite Dose Calculation
Manual
and
implementing procedures
at least
once per 24 months',
and the Process
Control
Program
and implementing procedures
for processing
and packaging
of radioactive
wastes
at least
once per 24 months.
13
In response
to identified issues
regarding the adequacy of the
licensee's
radioanalytical
measurements
for.H-3 and
Fe-55 radionuclides,
the inspector
requested
to review selected
audits of Chemistry
Program
activities.
The following gA audits
and reports
implementing
were reviewed.
gAO-PTN-92-022, guality Assurance Audit, Radioactive Effluents,
dated July 20,
1992
OAO-PTN-93-014, guality Assurance Audit, Radioactive Effluents
(Process
Control Program),
dated July 30,
1993
guality Control Report 94-0041, Effluent Checks
and Releases,
dated January
24,
1994
In general,
the audits reviewed guidance
and performance of selected
operations
associated
with the process
control
program
and effluent
releases.
The areas
reviewed were detailed appropriately
and sufficient
in scope to review operational
adequacy.
Audit results
were documented
properly, reported to licensee
management,
and tracked for completion of
-corrective actions.
From review of selected
audit findings, the
inspector
noted that corrective actions
were both appropriate
and
timely.
The inspector
noted that
no review of analytical radionuclide
measurement
capabilities
and Chemistry/Radiochemistry
Laboratory
gC
activities evaluated
during the current confirmatory measurement
inspection
were included in the licensee
audits.
Cognizant licensee
representatives
stated that,
as
a result. of the
NRC identified issues
involving H-3 and
Fe-55 nuclides,
the
gA program would be involved in
review and followup of the identified issues.
No violations or deviations
were identified.
Tours
(84523,
84524,
84525)
During the onsite inspection,
selected
areas
containing effluent
sampling equipment,
the Unit 3 and Unit 4 Auxiliary Building and
chemistry laboratory counting facility, and radioactive waste processing
and/or storage locations
were toured
by the inspector.
No contamination or housekeeping
concerns
were identified.
As
a result
of effluent measurement
differences identified during the current
inspection,
the inspector verified that proper controls were in effect
for check
and calibration sources
which could have potentially affected
equipment calibrations within'.the radioanalytical
counting laboratory.
No violations or deviations
were identified.
14
Followup Items
(92701)
The following previously identified issue .tracked
as
an Inspector
Followup Item (IFI) was reviewed
and discussed
with cognizant licensee
representatives.
(Closed)
URI 50-250,
251/93-16-01:
Determine
adequacy of Unit 3/Unit 4
containment
atmosphere
remote
sampling system
equipment configuration.
This issue
involved the lack of an evaluation potential differential
pressure
on the flow rate meter readings
and the adequacy of the
configuration of flow rate meter relative to filters within portable
sampling equipment
used to conduct selected
airborne radionuclide
measurements
for at-power containment entries.
Licensee
actions regarding the identified issue
were reviewed
and
discussed
as documented
in Paragraph
3.b.
The inspector
informed licensee
representatives
that based
on the review
of this program area, this item would be considered
closed.
Exit Interview (84523,
84524,
84525,
92701)
The inspection
scope
and results
were summarized
on Harch 4,
1994, with
those
persons
indicated in Paragraph
1 above.
The general
RP program
areas
reviewed
and associated
strengths
and weaknesses
were outlined.
The specific issues identified during the inspection
and listed below
were reviewed
and discussed
in detail.
Weaknesses
identified for
specialized training
and procedures
used for preparation
and/or
analytical
measurements
of non-gamma, emitting radionuclides
were
reviewed in detail.
In addition,
biases
between licensee
and
known H-3
and Fe-55 concentrations
in a
NRC confirmatory liquid sample
were
identified as
two examples of an
URI pending final resolution of the
observed differences.
Licensee representatives
were informed that
pending
NRC management
concurrence,
the previously identified
NRC item
detailed
in Paragraph
6 would be considered
closed
as
a result of
reviews conducted
during this inspection.
Licensee representatives
acknowledged
the inspector's
comments
and
outlined completed
and proposed
actions to evaluate
the identified
issues
including procedural
changes,
use of other
LSC equipment,
generic
review of the laboratory
gA program,
and review of other licensee
programs.
During an April 5,
1994 teleconference
between
Hr. L. Pearce,
Plant
Hanager,
TPN,
and Hr. K. Landis,
NRC RII, results of licensee
evaluations of the identified analytical
biases
conducted
subsequent
to
the onsite inspection activities were reviewed.
Licensee
representatives
stated that additional evaluation of LSC results for H-3
analyses
using the automated
protocol indicated
a consistent
non-
conservative
bias of approximately
18 percent.
Evaluations
were
continuing to determine
the actual
cause of the confirmed bias for the
e
15
automated
system with all current
H-3 analyses
being conducted
using the
equipment in the manual
mode.
Further,
licensee
representatives
stated
that the most recent
Semi-annual
effluent release
report issued
assumed
the worst-case
bias, i.e.,
increased
the measured
values
by
approximately
33 percent,-for
assessments
of doses resulting from H-3
released
from the site.
~T
e
Item Number
Status
.
50-250,
251/93-16;01
Closed
50-250,
251/94-04-01
Open
50-250,
251/94-04-02
Closed
50-250,
251/94-04-03
Open
Descri tion and Reference
Determine
adequacy of
Unit 3/Unit 4 containment
atmosphere
remote
sampling
systems
configuration
(Paragraph
6).
Determine
adequacy of licensee
measurements
for selected
effluent analyses
as required
(Paragraph
2.a).
Failure to have
adequate
procedures
for preparation of
and
gC liquid samples
sent
to vendors for Sr-89/90
and
Fe-55 analyses
(Paragraph
2.b)
and for calibration/operation
of LSC equipment
used for H-3
analyses
(Paragraph
2.c).
Failure to have
adequate
specialized training as
required
by TS 6.4 for proper
use of LSC counting equipment
(Paragraph
2.d).
ATTACHMENT 1
CRITERIA FOR
COMPARISONS
OF ANALYTICALMEASUREMENTS
This attachment
provides criteria for the comparison of results
on analytical
radioactivity measurements.
These criteria are
based
on empirical
relationships
which combine prior experience
in comparing radioactivity
analyses,
the measurement
of the statistically
random process of radioactive
emission,
and the accuracy
needs of this program.
In these criteria, the "Comparison Ratio
Limits"" denoting
agreement
or
disagreement
between
licensee
and
NRC results
are variable.
This variability
is
a function of the ratio of the
NRC's analytical
value relative to its
associated
statistical
and analytical uncertainty,
referred to in this program
as "Resolution"'.
For comparison
purposes,
a ratio between
the licensee's
analytical
value
and
the NRC's analytical
value is computed for each radionuclide present
in a
given sample.
The computed- ratios are then evaluated for agreement
or
disagreement
based
on "Resolution."
The corresponding
values for "Resolution"
and the "Comparison Ratio Limits" are listed in the Table below.
Ratio values
which are either
above or below the "Comparison Ratio Limits" are considered
to be in disagreement,
while ratio values within or encompassed
by the
"Comparison Ratio Limits" are considered
to be agreement.
TABLE A-1
NRC Confirmatory Measurements
Acceptance Criteria
Resolution vs.
Comparison
Ratio Limits
Resolution
Comparison
Ratio Limits
for A reement
<44-7
8-15
16 - 50
51
- 200
)200
0.4 - 2.5
0.5 - 2.0
0.6 - 1.66
0.75 - 1.33
0.80 - 1.25
0.85
- 1.18
'Comparison
Ratio
= Licensee
Value
NRC Reference
Value
'Resolution
=
NRC Reference
Value
Associated Uncertainty