05000220/LER-1980-030-04, /04T-0:on 801204,discovered That Lower Limit of Detection for Radiological Fish Analysis Was Not within Ets. Caused by Conversion Factor.Tech Spec Changes Proposed to Update Parameter

/04T-0:on 801204,discovered That Lower Limit of Detection for Radiological Fish Analysis Was Not within Ets. Caused by Conversion Factor.Tech Spec Changes Proposed to Update Parameter

ML18037A316
Person / Time
Site:	Nine Mile Point
Issue date:	01/03/1981
From:	Harrison P NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML17053C237	List: 05000220/LER-1980-030, Forwards LER 80-030/04T-0 05000220/LER-1980-030-04, /04T-0:on 801204,discovered That Lower Limit of Detection for Radiological Fish Analysis Was Not within Ets. Caused by Conversion Factor.Tech Spec Changes Proposed to Update Parameter
References
LER-80-030-04T, LER-80-30-4T, NUDOCS 8101150684
Download: ML18037A316 (8)

LER-1980-030, /04T-0:on 801204,discovered That Lower Limit of Detection for Radiological Fish Analysis Was Not within Ets. Caused by Conversion Factor.Tech Spec Changes Proposed to Update Parameter

Event date:
Report date:
2201980030R04 - NRC Website

text

u.s. NucI.I;nR REGUI.ATORY CC',.I'IISSIUN, REP

~

'LP1 3178 17677)

It i.iCENSre EVEN.r RCpoRV CONTROL 6( OCR:

I I J ~J J Ql (PLEA66 PIIINTOR TYPE ALL REOUIREO INPORMATIONT I

6 NJ Y

N jQPL0 JNJ

- J 0

0 0

0 0

0 0

QO II Q4~QE

'7, 8

9 I.ICENSEE CODE 14 15 I.ICENSE NUMBER 25 26 LICENSE TYPE 30 57 CAT 58

'CON'T'

~I 5CCRCE ~LQ6~05~0 0

0 2

2 0 Q7~12 QJ LP~80 QELNJ~~

Qs B,,L.'0 61 DOCkETPRIUthBER

~VENTOATE

/4 75 REPORT DATE 80

", EVENT'OESCRIpTION ANQ PROBABLE coNSEQUENCEs 10

~o2 Xt was discovered that the lower limit of d t I

ot

~o3 fish analysi s did fall within the RIPC Environmental Tech Spec sensivity for all

~o 4 'nalysis.

However, data sensitivitv does fall within the a13T7li

~os

~os 7

Guide 4.8 specifications.

Therefore, there were no radiological consequences.

See'attachment for further details.

~O7

~os 80 7

8 COMP.

VALVE CohIPONENT CODE SUBCODE SUBCODE Q14

~Z Qls

~P Q16 18 19 20 OCCURRENCE REPORT REVISION CODE TYPE NO.

~o4

~m LJ

~o 27 28 29 30 31 32 ATTACHMENT MPRDA PRIME COMP.

CohIPONENT S

Q22 SUBMITTED FOAh1 SUB.

SUPPLIER hIANUFACTURER 0

Y Q23

~NQ24

~ZQ25 Z

O ll COE 40 41 42 43 44 47 SYSTEM

CAUSE

CAUSE CODE CODE SUBCODE

~~ Qll

~P Q12 LNJ Q13 7

8 9

..10 11 12 13 SEOVENTIAL LER RO EVENTYEAR REPORT NO.

Q17 REPORT

~80

~

~03 0

21 22 23 24 26 ACTION FUTURE EFFECT SHUTDOIYN TAKEN ACTION OM PLANT hlETHOD HOUR

~XQIE ~XQIR

~ZQ26

~KQ21 0

0 0

33 34 35 36 37 CAUSE DESCRIPTION nND CORRECTI VE ACTIONS Q27

~IO The Station Tech ST7ecs.

s eci radi

~Os to be* 80p Ci/kg - dry weight, whereas laboratory test data has been T7rovided 3

4 weight units which, when converted, results in higher L.L.D. values.

Conversion w/

1test data has been performed based on conversions, supplied by contractor.

A Tech Spec.

change proposal is being initiated 'to update this parameter to the current

• --=~

8 9

FACILITY STATUS 7

'4 POVIEA OTHER STATUS Q s ~ Q28 ~~Q29 7

8 9

10 12 13 44 ACTIVITY CONTENT AELFASED OF RELEASE AMOUNTOF ACTIVITY s ~ Q33 Q34 N/A 7

8 9

10 11 PEASOMNEL EXPOSURES MUt/IBER TYPE OESCRIPTIOM COT LOOOLOJQ" Z

Qs 7

8 9

11 12 13 PERSONNEL INJURIES NUMBER DESCRIPTION 41 [ll8] ~00 0

Q46 N/A LOCATIONOF RELEASE Qs N/A 44 45 80 80 7

8 9

11

'12 LOSS OF OR DAMAGETO FACILITY 43 TYPE OESCRIPTIOM 6

Z Q42 N/A 8

9 10 PUBLICITY ISSUED OESCRIPTIOM Q4s o

~NQ44 N A 8 $ 0 X 1

~

o - P EPn E

see other side Bo METHOD OF DISCOVERY DISCOVERY DESCRIPTION Q32 LBjQ31 S.R.A.B. audit 45 46 80 80 NRC USE ONI Y 80 1919.

68 69 PHtONEi~712-211.0 EXt

J A

V'

Cause Description and Corrective Actions (cont'd)

'Regulatory Guide values; Tnt;crim efforts to meet the present sensitivity involve -, "

utilizing 'the maximum sample density and counting times in test performance:

ATTACHMENT A An %P-1 Annual Environmental SR&AB audit was performed in October of 1980.

As a result of the audit, we were informed that the sensitivity required by the Environmental Technical Specifications (Table 3.2-1 of Section 3.2) for radiological fish analysis was 80 pCi/kg (dry weight).

The data was received between June 30 and July 7.

This sensitivity or LLD (lower limit of detection) is normally reported as pCi/g (wet weight).

Since the ETS required pCi/kg (dry weight) it was necessary to derive a wet to dry weight ratio for each fish sample.

The contractor upon per-forming the required calculations determined that the required sensitivity of LLD in Ci/kg (dry) was not attained for several samples.

Sample analyses are performed for GSA (Gamma Spectoral Analysis),

Sr-89 and Sr-90 as required by ETS on fish samples collected twice per year.

NMP-1 samples are collected in May and November.

The required sensitivities, (as derived) were attained for Sr-90 analysis.

Sensitivities were attained for Sr-89 except for one sample (RMC f/31698) for which a re-analysis was requested on November 6.

Analyses results for GSA, after converting results to pCi/kg (dry) revealed that most nuclides did not meet the ETS sensitivity.

Although some nuclides in the GSA scan had sensitivities of 80 pCi/kg (dry) or better (such as hfn-54 or Cs-134),

many did not (such as Fe-59, Cs-137, or Zn-65).

The sensitivity problems were reviewed with the Testing Contractor.

It was decided that the sensitivity could be improved by increasing the sample size slightly (the size is limited due to the analysis type but the sample density may be able to be increased) and by increasing the count time.

Count times are normally 100 minutes for Sr-89 and Sr-90 analyses and 5,000 seconds for GSA analyses.

We were also informed that the one Sr-89 sample that was not within ETS sensitivities could be reanalyzed and counted with a maximum count time to achieve the sensitivity.

This re-analysis was ordered on November 6, but the contractor did not think that sensitivities for all the nuclides in the GSA analyses could be attained by increasing sample size and count times.

gt

,I

PAGE 2 Therefore, action taken in regards to this Occurence was three fold.

First, the Sr-89 sample was re-analyzed with maximum sample size and count time.

Second, all Sr-89 and Sr-90 samples will be counted for the maximum count times and sample volumes until NDA requirements are revised.

Third, all GSA analyses will utilize maximum sample size densities and count times in the future.

It must be noted that the NHP-1 ETS for radiological fish analysis of 80 pCi/kg (dry) is not considered to be a reasonable specification.

As-listed in Table 3 of Reg.

Guide 4.8, "Environmental Technical Specifications for Nuclear Power Plants" dated December 1975, or in Table 2

of "Branch Technical Position" to Reg.

Guide 4.8 dated November

1979, the most limiting LLD for GSA analyses is 130 pCi/kg wet weight.

~

~

J C

C