ML20004C295
| ML20004C295 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/07/1981 |
| From: | Bores R, Jang J, Kottan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20004C288 | List: |
| References | |
| 50-317-81-06, 50-317-81-6, 50-318-81-06, 50-318-81-6, NUDOCS 8106020514 | |
| Download: ML20004C295 (5) | |
See also: IR 05000317/1981006
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
50-317/81-06
Report No. 50-318/81-06
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50-317
Docket No. 50-318
OPR-53
C
Category
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License No. DPR-69
Priority
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Licensee:
Baltimore Gas and Electric rnmnany
P. O. Box 1475
Baltimore. Maryland 21203
Facility Name:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2
Inspection at:
Lusby, Maryland
Inspection conducted: Februaw 17-20, 1981
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Inspectors:
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J. J. Kottar/, Ryon Laboratory Specialist
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b{7td.C.Jang,'RadiationSpecialist
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Approved by:
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R. J. BorW!i, Chief, Independent Measurements
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and Environmental Protection Section
Inscect1 m Summary:
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Inspection on February 17-20, 1981 (Combined Report Nos. 50-317/81-06; 50-318/81-06)
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 Environ-
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mental Services Laboratory. Areas reviewed included:
program for quality
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control of analytical measurements; performance on radiological analyses of
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split actual effluent samples; and effluent control records and procedures. The
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inspection involved 56 inspector-hours onsite by two NRC regionally based inspectors.
Results: Of the four areas inspected, four items of noncompliance were identified
in one area (failure to follow procedures, paragraphs 4 and 5).
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Region I Form 12
(Rev. April 77)
81060206/4:
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OETAILS
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1.
Individuals Contacted
Principal Licensee Emolayees
- L. B. Russell, Plant Superirtendent
- P. T. Crinigan, Senior Engireer
S. E. Cherry, Principal Technician - Counting Room
- G. E. Brobst, Chemistry Supervisor
J. I. Speciale, Supervisor of Plant Chemistry
The nspector 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
(0 pen) Infraction (317/78-13-01; 318/78-13-01):
Failure to follow procedures-
gaseous effluent totals. The inspector noted the licensee had not calculated
his 12-month average gaseous effluent totals as required and, therefore,
this was a recurrent item of noncompliance. The licensee did, however,
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calculate the 12-month gaseous effluent totals for the period January-
December,1980 prior to the inspector leaving the site. The totals were
within the required limits of the Technical Specifications.
(See Paragraph
5.)
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3.
Laboratory QC Program
The inspector reviewed the licensee's program for the quality control of
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analytical measurements.
The licensee's procedure, RCP 1-103, Rad-Chem QC
Procedure, covers quality control for both reactor coolant chemistry analyses
and radiological analyses of effluent samples.
The QC program includes
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monthly verification of chemical analytical instrumentation calibration
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curves, split sample analyses, recommended periodic inspections, and
reagent control. Also, the operating procedures for the various individual
counting instruments require daily source checks and for gamma spectroscopy
systems, weekly efficiency checks and daily gain checks.
The inspector
reviewed the licensee's QC data for 1980 and discussed Regulatory Guide
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4.15, Quality Assurance for Radiological Monitoring Programs (Normal Opera-
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tions)-Effluent Streams and the Environment, and laboratory quality control
in general with the licensee. No items of noncompliance were identified in
this area.
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4.
Confirmatory Measurements
During the inspection, actual liquid, airborne particulates and charcoal,
and gaseous 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 by the NRC
using the NRC:I Mobile Radiological Measurements Laboratory. Joint
analyses of actual effluent samples are used to determine the licensee's
capability to measure radioactivity in effluent samples.
In addition, a liquid affluent 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 samples are: Sr-89, Sr '. ,, gross alpha, gross beta
and tritium. 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 the gamma isotopic measurement comparisons indicated that:
all of the measurements were in agreement or possible agreement under the'
criteria used for comparing results (see Attachment 1) with the exception
of the gas sample analyses. The licensee used a 500 ml polybottle for
sampling and analysis of waste gas decay tanks. However, the license
used a 500 mi polybottle liquid calibration curve for the gas sample.
without making attenuation corrections.
In addition, the inspector noted
that the licensee's Procedure RCP 1-502, Sampling of Gases foi Activity,
requires that gas samples be taken and analyzed in gas vials. A temporary
change to RCP 1-502 permitted sampling 40 ml of gas in a 500 ml polybottle,
but the temporary change had expired in July, 1980. The present gas
sampling method also involved sampling in the open atmosphere, as opposed
to using a hooded enclosure or recirculating system,'and therefore may
present a radiological health hazard to personnel performing the sampling.
The inspector stated that the failure to follow Procedure RCP 1-502 for
gas sampling was an item of noncompliance (317/81-06-01; 318/81-06-01).
During previous inspections, the licensee's gas. measurements were in
agreement or possible agreement with the NRC gas measurements when'the
licensee used a gas vial. The licensee's gas analyses results using the
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present system were higher than the NRC results. The licensee had not
exceeded any technical specification release limits, however, since the
error was'in a conservative direction.
5.
Records and Procedures
The inspector reviewed the licensee's procedures and records in the areas
of plant chemistry and radiochemistry, and effluent radiochemistry.
Procedure RCP 2-302, Liquid Scintillation System, requires the use of a
quench curve for efficiency determinations.
However, in reviewing the
-liquid scintillation counting data for'1981 to the date of inspection,
the inspector noted that the licensee had not constructed a quench curve
using the external standard channels ratio method and, therefore, was not
determining the efficiency from the quench curve. Also in reviewing the
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records and procedures the inspector noted that Procedure RCP 1-1001,
Radiochemistry Analysis Determination of Gross Beta-Gamma (Alpha) Degassed
Activity, requires the use of a self-absorption factor in determining the
gross beta gamma activity. The inspector reviewed the gross beta gamma
counting logs for 1981 to date and noted that the licensee was using a
self-absorption factor of 1 for all samples.
In discussing the matter
with the licensee the inspector determined that, although the licensee
had self-absorption curves, they were not being used. The inspector
stated that the failure to calibrate the liquid scintillation system.
using a quench curve as required by Procedure RCP 2-302, and the failure
to use the self-absorption factor in beta gamma activity measurements as
required by procedure RCP 1-1001, was an item of noncompliance (317/81-06-02;
318/81-06-02).
The inspector reviewed the calibration of the licensee's computer-baset.
multichannel analyzer systems.
Procedure RCP 2-301.4, Set Up and Calibration
of the Gamma Ray Spectrometer with GE(L1) Detector, requires the use of
three separate standards for each geometry for systematic error estimation,
requires the determination of the overall standard deviation for the
analysis; requires the use of specific log sheets with specific data; and
specifies the geometries to be calibrated. The inspector noted that the
licensee had not followed RCP 2-301.4 in calibrating his systems in that:
three senarate standards were not used for each geometry; the overall
standard deviation for the analysis was not determined; the required log
sheets were not used; and calibrations' for required geomet, ries, specifically,
for the gas vial, were not calibrated. The inspector stated that this
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was an item of noncompliance (317/81-06-03; 318/81-06-03).
In Inspection Report 50-317/78-13, 50-318/78-08 an item of noncompliance
was identified in which the licensee failed to follow Procedure RCP
1-207, Gaseous Waste Releases Specifications and Surveillance, with
respect to calculating the 12 month release rate. The' item recurred
during Inspection 50-317/79-02, 50-318/79-02.
During this inspection the
inspector noted that the licensee again did not have the 12-Month Release
Rate Calculation Sheet completed through December, 1980 as required by
Procedure RCP 1-207.
The inspector stated that this was again a recurring
item of noncompliance (317/81-06-04; 318/81-06-04). The licensee did,
however, calculate the 12-month gaseous effluent totals for the period
January-December,1980 prior to the inspector leaving the site.
The inspector determined that no release limits had been exceeded.
6.
Exit Interview
The inspector' met with the licensee representatives (denoted in Paragraph
1) at the conclusion of the inspection on February 20, 1981.
The inspector
summarized the purpose and scope of the inspection and the inspection
findings, including each item of noncompliance.
The licensee agreed to perform the analyses listed in paragraph 4 and
report the results to the NRC,
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Attachment 1
Criteria for Comoaring 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 " 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
RATIO = 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
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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 47 plied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification
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is greater than 250 Kev.
Tritium analyses of liquid samples.
Iodine on absorbers
"B" criteria are applied to the following analyses:
Ganna 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.
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