ML18086B416

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IE Insp Repts 50-272/82-02 & 50-311/82-02 on 820118-21. Noncompliance Noted:Lack of Instrument Calibr Procedure for Liquid Scintillation Counter & Inadequacy of Procedure for Compositing of Liquid Samples
ML18086B416
Person / Time
Site: Salem  PSEG icon.png
Issue date: 03/29/1982
From: Bores R, Jang J, Kottan J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18086B414 List:
References
50-247-82-01, 50-247-82-1, 50-311-82-02, 50-311-82-2, NUDOCS 8204200216
Download: ML18086B416 (11)


See also: IR 05000272/1982002

Text

.. .

U. S. NUCLEAR REGULATORY COMMISSION

Region I

50-272/82-02

Report Nos. 50-311/82-02

50-272

Docket Nos. 50-311

~DP~R~-~7~0--

L i cen se Nos. DPR-75

Priority

c

Category _c_

Licensee:

Public Service Electric and Gas Company

80 Park Place

Newark, New Jersey 07101

Facility Name:

Salem Nuclear Generating Station, Units 1 and 2

Inspection At:

Hancocks Bridge, New Jersey

Inspection Conducted:

Inspectors:

,3*-2-r-B'L

Specialist

date signed

3--:<</-~L

date signed

Approved

3 -.J-9-~

date signed

Inspection Summary:

Inspection on January 18-21, 1982 (Combined Inspection Report Nos. 50-272/82-02,

and 50-311/82-02

Areas Inspected:

Routine, unannounced inspection of the licensee's chemical and

radiochemical measurements program using NRC:I Mobile Radiological Measurements

Laboratory and laboratory assistance provided by DOE Radiological and Environmental

Services Laboratory.

Areas reviewed included:

program for quality control of

analytical measurements, performance on radiological analyses of split actual

effluent samples, and procedures.

The inspection involved 56 inspector-hours

onsite by two NRC regionally based inspectors.

Results:

Of the three areas inspected, no items of noncompliance were identified

in 'two. areas.

Two items of noncompliance (failure to have a procedure and an

inadequate procedure) were identified in one area .

Region I Form 12

(Rev. April 77)

DETAILS

1.

Individuals Contacted

Principal Licensee Employees

  • H. J. Midura, Manager Salem Operations
  • J. D. Driscoll, Assistant Manager Salem Operations
  • L. K. Miller, Technical Manager
  • J. Stillman, Station QA Engineer
  • A. Darelius, QA Engineer
  • W. Jocker, Senior Supervisor
  • D. Zak, Technical Supervisor

G. Dziuba, Chemistry Technician

The inspector also interviewed other licensee employees including

members of the chemistry and health physics staffs.

  • denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings

(Closed) Severity Level V Violation (272/80-34-01, 311/80-23-01):

Failure to follow QC procedures.

The inspector reviewed the licensee

1 s

QC data for all of 1981 and noted that the licensee was making the

required QC checks.

(Closed) Unresolved Item (272/80-34-02, 311/80-23-02):

Sb-125 Identifi-

cation.

The inspector verified that the licensee had modified his

nuclide identification library so that Sb-125 would be identified.

3.

Laboratory QC Program

The inspector reviewed the licensee 1 s program for the quality control

of analytical measurements.

The licensee 1 s QC program is detailed in

Procedure PD-3.9.017,

11Quality Control Requirements.

11

This procedure

requires known and unknown spiked and duplicate analyses of reactor

coolant system chloride, fluoride, and boron along with quarterly

interlaboratory sample splits for radioactivity comparisons.

Procedure

PD-3.9.017 also requires instruments efficiency, background, and where

applicable, gain checks.

In addition, individual analytical procedures

include steps to assure quality, such as provisions to control reagents.

The inspector reviewed the licensee 1 s QC data for 1981 and noted that

the licensee was implementing Procedure PD-3.9.017.

The inspector

discussed laboratory QC in general and Regulatory Guide 4.15, Quality

Assurance for Radiological Monitoring Programs (Normal Operations)-

Effl uent Streams and the Environment, with the licensee.

The inspector

had no further questions in this area.

No items of noncompliance were identified.

..

4.

Confirmatory Measurements

During this inspection actual liquid and airborne effluent samples

were split between the licensee and NRC:I for the purpose of intercomparison.

The effluent samples were analyzed by the licensee using his normal

methods and equipment, and the NRC using the NRC:I Mobile Laboratory.

Joint analysis of actual effluent samples determines the licensee's

capability to measure radioactivity in effluent samples.

In addition a liquid effluent sample was sent to the NRC reference

laboratory, Department of Energy, Radiological and Environmental

Services Laboratory (RESL) for analyses requiring wet chemistry.

The

analyses to be performed on the sample are:

Sr-89, Sr-90, tritium,

and gross alpha.

These results 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 an effluent sample split between the licensee and NRC:I

during a previous inspection on December 15-18, 1980 (Inspection

Report 80-34, 80-23) were also compared during this inspection.

The results of a routine health physics air particulate sample and

charcoal cartridge sample, which were analyzed by the licensee's

health Physics personnel using the health physics gamma ray spectroscopy

system, were also compared.

The results of the sample measurements comparison indicated that all

of the measurements were in agreement or possible agreement under the

criteria used for comparing results with the exception of the tritium

comparison.

The licensee's tritium result was higher than the NRC

result and therefore, was in a conservative direction and would not

have resulted in the licensee exceeding any effluent release limits

(See Attachment 1).

The results of the comparisons are listed in

Table I.

The inspector reviewed the licensee's effluent analysis procedures and

observed the analysis of actual samples.

The inspector discussed the

definition of MDA, as contained in the DOE Environmental Measurements

Laboratory Procedures Manual, HASL-300 with the licensee.

The inspector

noted that the 163.9 keV photopeak of Xe-131m was present in the waste

gas decay tank sample, but was not identified by the licensee. The

licensee stated that waste gas decay tanks are allowed to decay and do

not contain Xe-131m. The inspector stated that if a non decayed waste

gas decay tank was released, the Xe-131m ~ould be present and should

be quantified and reported.

The licensee stated that Xe-131m would be

added to his nuclide identification library.

The inspector reviewed

the gamma spectrum peak samples of waste gas decay tank releases for

November and December, 1981 and noted that Xe-13lm was not present in

any of the samples.

Also the reactor coolant sample which was split

to compare the iodine concentrations resulted in I-131 and I-134 not

5.

I_

being detected by the licensee, and the I-135 being in disagreement.

The inspector noted that Procedure.PD-3.3.003, Dose Equivalent Iodine

by Gamma Spectroscopy," does not specify a time for counting the

sample to ensure that both the long and short lived iodines are identified.

In addition, the licensee's nuclide identification library requires

that a photopeak with a low gamma abundance must be present for the

identification of I-134.

This will result in I-134 not being detected

even though higher gamma abundance photopeaks are present in the

sample.

The licensee stated that his nuclide identification library

would be modified to prevent this from happening and his procedure

would be modified to specify times for counting the sample.

A recount

of the reactor coolant sample at a later time, after the decay of

short lived interfering nuclides, resulted in I-131 being identified

and the I-133 comparison was in agreement.

The inspector had no

further questions in this area.

No items of noncompliance were identified.

Procedures

The inspector reviewed the licensee's chemical and radioc~em~cal

analyses procedures.

The inspector noted that the licensee had no

procedures for the calibration of his liquid scintillation counter.

The inspector stated that Section 5.5.1 of the Environmental Technical

Specifications (ETS) requires procedures for all activities involved

in carrying out the ETS requirements.

Section 5.5.1 of the ETS also

requires that procedures include instrument calibration.

The inspector

noted that the tritium measurement comparison made during this inspection

was in disagreement (See Paragraph 4).

Another sample was split

during this inspection for a tritium comparison.

The inspector stated

that the failure to have. a procedure for the calibration of the liquid

scintillation counter was an item of noncompliance (272/82-02-01,

311/82-02-01).

The inspector also noted that Procedure PD-35.036,

"Composition of Liquid Samples," contains no provisions for adding a

preservative, such as mineral acid, to the sample in order to prevent

adsorption of various nuclides on the walls of the sample container.

The inspector stated that Section 5.5.1 of the ETS requires procedures

for activities involved in carrying out the ETS requirements.

Also

Section 5.5.1 requires that procedures include sampling, measurements,

and analyses. In addition Section 2.3.2 of the ETS requires that

liquid waste samples be analyzed in accordance with Table 2.3-1 to

demonstrate compliance with Section 2.3.1 of the ETS.

The inspector

stated that failure to make provisions for preserving composite samples

was an item of noncompliance (272/82-02-02, 311/82-02-01).

The inspector

discussed adsorption of nuclides on the walls of sample containers and

methods of preserving samples.

The inspector stated that unless a

preservative was added to the composite samples, there was no way to

ensure that an analysis of the composite liquid was representative of

the nuclides present in the original liquid aliquots.

The licensee

currently has no method to account for nuclides adsorbed on composite

sample container walls.

The inspector had no further questions in this area.

6.

Ex~t Interview

The inspector met with the licensee representatives (denoted in Paragraph

1) at the conclusion of the inspection.

The inspector summarized the

purpose and scope of the inspection and the inspection findings.

The licensee agreed to perform the analyses listed in paragraph 4 and

report the results to NRC.

(

TABLE 1

SALEM .:. VERIFICATION TEST RESULTS

SAMPLE

ISOTOPE

NRC VALUE

. LICENSEE. VALUE

  • coMPARISON

Results in microcuries per milliliter

In Plant Airborne Particulate

Filter Sampled

by Health Physics

Mn-54

0850 hours0.00984 days <br />0.236 hours <br />0.00141 weeks <br />3.23425e-4 months <br />

(2.15+0.09)E-9

(2.91+0.lO)E-9

Agreement

1-19-82

Co-60

Analyzed by Health

(9.6+0.3)E-9

( 1. 20+/-_0. 02) E-8

Agreement

Physics on their

Cs-134

(L7+0.2)E-9

(2.21+/-_0.09)E-9

Agreement

counting system

Cs-137

(4~9+/-_0.2)E-9

(6.67+/-_0.12)E-9

Possible Agreement

SAMPLE

ISOTOPE

In Pl ant Charcoal

I-131

Ca rtri dge-Samp l e*d

by Health Physics

0820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br />

1-20-82

Analyzed by Health

Physics on their

counting system.

In Plant Charcoal

I-131

Cartridge-Sampled

by Health Physics

0820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br />

1-20-82 .

Analyzed by

Chemistry*

TABLE 1

SALEM ~ VERIFICATION TEST RESULTS

NRC VALUE

LICENSEE VALUE

Results in microcuries per milliliter

(3.62+/-_0.26)E-ll

(4.1+/-_0.2)E-11

(3.62+0.26)E-ll

(5.52+/-_5.2%)E-ll

  • Note:

An effluent charcoal cartridge was not available during this inspection.

COMPARISON

Agreement

Agreement

.. TABLE 1

. SALEM. - VERIFICATION TEST RESULTS

SAMPLE

ISOTOPE

NRC VALUE

LICENSEE VALUE

COMPARISON

Results in microcuries 12er mi 11i1 iter

Gas Decay Tank

Xe-133

(5. 77+0.03)E-3

(6.576+/-_0.26%)E-3

Agreement

1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />

1-19-82

Xe-133m

( 1. 9+0. 7) E-5

(l.29+/-_15%)E-5

Agreement

Kr-85

(3.0+0.B)E-4

(2.25+/-_40%)E-4

Agreement

Xe-13lm

( 1. 6+/-_0. 2) E-4

Not Identified


Results in microcuries 12er mi 11i1 iter

Liquid Rad Waste

I-131

11 CVCMT

(4.4+0.2)E-5

(4.57+/-_7.5%)E-5

Agreement

0430 hours0.00498 days <br />0.119 hours <br />7.109788e-4 weeks <br />1.63615e-4 months <br />

Co-58

(2.19+0.07)E-3

(2. ll+0.4%)E-3

Agreement

1-19-82

Co-60

(3.25+0.03)E-4

(3.12+/-_1.3%)E-4

Agreement

Mn-54

( 1. 88+0. 13) E- 5

(2. 05+11. 5%)E-5

Agreement

Cs-134

(l.25+0.02)E-4

(l.18+3.8%)E-4

Agreement

Cs-137

(l.30+/-_0.03)E-4

( 1. 32+/-_3. 0%) E-4

Agreement

SAMPLE

Unit 2 Reactor

Coolant

1150 hours0.0133 days <br />0.319 hours <br />0.0019 weeks <br />4.37575e-4 months <br />

1-20-82

Unit 2 Reactor

Coolant

1150 hours0.0133 days <br />0.319 hours <br />0.0019 weeks <br />4.37575e-4 months <br />

1-20-82

(recounted the

fo 11 owing day)

ISOTOPE

Results

I-131

I-132

I-133

I-134

I-135

I-131

I-133

I-135

TABLE 1

SALEM~ VERIFICATION TEST RESULTS

NRC VALUE

LICENSEE VALUE

COMPARISON

  • i Ii* rili crocuri es ~er mi 11i1 iter

(4.8.:'.:_0.8)E-4

Not Detected**

No Comparison

(3.8+0.2)E-3

(4.9.:'.:_8.2%)E-3

Agreement

(3.48+0.09)E-3

(2.07+/-_18%)E-3**

Disagreement

(6;3+/-_0.5)E-3

(5.2+/-_7%)E-3*

Agreement

(5~0+0.4)E-3

(5.0+22%)E-3

Agreement

(5.8.:'.:_0.2)E-4

(6.26+5.2%)E-4

Agreement

(3.50.:'.:_0.05)E-3

(3.62+2.8%)E-3

Agreement

( 5. 8+0. 6) E-3

(5.49+/-_29%)E-3

Agreement

  • Note:

I-134 was not reported by the licensee as not detected although the major photopeaks

were present.

See Paragraph 4.

The value compared was hand calculated based on peak

search data from the sample analysis and the licensee's nuclide identification library.

    • Note: The sample was recounted the following day to allow for the decay of short lived nuclides.

This resulted in I-131 being detected and the I-133 being in agreement.

.,

,,

1

'

(

TABLE 1

SALEM ~ VERIFICATION TEST RESULTS

SAMPLE

ISOTOPE

NRC VALUE

LICENSEE VALUE

COMPARISON

Results in microcuries ~er mi 11i1 i ter

Liquid Rad Waste

Sr-89

(1.8~0.8)E-7

1 ess than 2.5E-8

No Comparison

21 CVCMT

1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br />

Sr-90

(O~l)E-8

1 ess than 2.5E-8

No Comparison

12-16-80

H-3

(1.24+0.02)E-3

(1. 78~0.02)E-3

Disagreement

Results in microcuries ~er mi 11 il i ter

Unit 2 Reactor

Cr-51

( 5 . l+O . 7) E- 5

( 8. 0~11. 3%) E-5

Agreement

Coolant Crud

Filter*

Co-58

( 9 . 7 ~O . 3 ) E-5

(1.5~3.4%)E-4

Possible Agreement

0835 hours0.00966 days <br />0.232 hours <br />0.00138 weeks <br />3.177175e-4 months <br />

1-19-82

Zr-95

( 9. 4+ 1. 2) E-6

(1.45~14%)E-5

Agreement

Mn-54

(3.9+0.9)E-6

(3.63~36%)E-6

Agreement

Co-60

(6.7+0.9)E-6

(9.64+14%)E-6

Agreement

Na-24

(3.2+/-_0.4)E-5

(5.0+5.2%)E-5

Agreement

I-133

(6.0+1.8)E-6

(7.17~23%)E-6

Agreement

  • Note:

An airborne effluent particulate filter was not available during this inspection.

'.ii

'

u

j-

Attachment l

Criteria for Comparing Analytical 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

11Resolution

11

,

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

RATIO= NR(-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 - l. 66

0.5 - 2.0

51 - 200

0.80 - 1.25

0.75 - l. 33

0.6 - l. 66

>200

0. 85 - 1.18

0.80 - l. 25

0.75 - 1. 33

11A

11 criteria are applied to the following analyses:

Gamma Spectrometry where principal gamma energy used for identification

is greater than 250 Kev.

Tritium analyses of liquid samples.

Iodine on absorbers

118

11 criteria are applied to the following analyses:

Gamma Spectrometry where principal gamma energy used for identification

is less than 250 Kev.

89Sr and 90Sr Determinations.

Gross Beta where samples are counted on the same date using the same

reference nuclide.

l