ML20005G257

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Responds to NRC Re Violations Noted in Insp Rept 50-312/89-18.Violation a Denied & Violation B Ack.Corrective Actions:Controls for Environ Pollution Reanalyzed I-131 in Water Sample Using Correct Efficiency Factor for Instrument
ML20005G257
Person / Time
Site: Rancho Seco
Issue date: 01/12/1990
From: Keuter D
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Knighton G
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AGM-NUC-89-291, NUDOCS 9001180345
Download: ML20005G257 (8)
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%^ i ^ 'i > SMRAMENTO MUMCFAL UTIUTY DISTRICT b '6201 h Street, P.o. Box 15830, Sacramento CA 95862-1830,(916)'452 3211:l y

l' AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA -

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'Januaryi1?, 1990 b

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" U-S? Nuciear. Regulatory Commission

' Attn:'LDocument Control Desk Washington, DC '20555- '

1 fDocket No.150-312 Rancho-Seco Nuclear. Generating Station.

License No.. DPR-54"

.RESPONSEiTO NOTICE OF VIOLATION 89-18 4

Attent'ionii George Knighton On=Decemberul3,il989, the-Sacramento Municipal Utility District' received a~

. Notice'of Violation.concerning two activities at the Rancho Seco Nuclear.

Generating 2 Station.- -In accordance with 10 CFR 2.201,~the District provides ithe enclosed response.-

s This letter' denies Violation A-and acknowledges Violation-B.

This letter also

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-describes the District's reasons <for denial of Violation A and corrective actions 1 associated with Violation B-

. Members 'of your staff with. questions requiring additional information or clarification may-contact Mr. Bob Jones at '(209) 333-2935, extension'4675.-

$ Sincerely, i

4 iDan R. Keuter

. Assistant' General Manager Nuclear-t

,t Enclosure

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J. B., Martin, NRC Halnut Creek i i./

, g hff gg A.' D'Angelo, NRC,' Rancho Seco j

9001180345 900112

.hDR ADOCK 05000312 i

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RANCHO.SECO NUCLEAR GENERATING STATION D 1444o Twin Cities Road, Herald, CA 95638 9799:(209) 333-2935 g

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DISTRICT RESPONSE TO NOTICE OF VIOLATION 89-18 1

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.NRC STATEMENT OF-VIOLATION r ~,

A,7TSL6.8(reads, sin part:

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'Hritten procedures shall beiestablished, implemented and J

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1 Quality Assurance Program for Effluent Control and

..Env.ironmental Monitoring using the guidance of Ws Regulatory Guide 4.15, Revision 1, February 1979.

. RG 4.15, Ouality Assurance for Radioloaical Monitorina Procrams (Normal b.

Qoerations) - Effluent Streams and the Environment, part C., paragraph

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~6.3.2,-Interlaboratorv Analvses, reads, in part:

Laboratories of licensees or their contractors that perform environmental measurements should participate in the EPA's Environmental' Rad 4 activity Laboratory Intercomparison Studies

-(Cross-check)' Program, or an equivalent _ program.

This pr.rticipation should include all of the determinations-(sample-medium /radionuclide combinations) that are both offered by EPA and: included in the licensee's environmental monitoring

-program.... If the mean result of a cross-check analysis

-exceeds: the control limit as defined by EPA... an investigation should'be made to determine the reason:for this deviation and corrective action should be taken as necessary.

-Contrary'to the above, when the licensee's contract vendor was notified that their results from EPA cross-check analyses performed on 10 February, 17~ February and 31 March 1989 were outside the control limits defined by EPA - the vendor failed to adequately investigate to determine.

the reasons for.the deviations and did not take corrective action.

ThisLis a Severity Level IV violation (Supplement IV).

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TS!6.18~,-Post-accident Samolina, reads, in part:

A program shall be maintained and implemented which will ensure the capability to obtain and ar,alyze reactor coolant, i

radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accideni conditions.. The program shall include the following:

(i)

Training of personnal...

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1 NRC STATEMENT OF VIOLATION :(Continued)-

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RSAP 0219,; paragraph ~5.2,'Trainina, reads, in part

m The plant shall: have 'a minimum of five designated PASS 4 -

equipment. operators to insure the availability of trained in equipment operators to support post <. accident sampling requirements.-

tCont?ary/ o the above, con 9 November 1989 there were only three I

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iPAS.S~ operators employed at the plant.

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This is a' Severity Level IV (Supplement IV).

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- DISTRICT RESPONSE'

  • S VIOLATION A 1 A'.

. Admission or denial of the alleged violation:

g The' District' denies that the above is a violation.

.i 2A.1

-District Position:

1 1

,J As noted in NRC Inspection Report 89-18.-the District has continued to:

-improve -the quality of their Radiological Environmental Monitoring Program (REMP) and. continues to meet the intent of applicable regul atory.' requi rements.

In support of.the REMP, the District has contracted Controls for Environmental Pollution (CEP) to perform; i'

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analyses?on environmental' samples.

In that contract, the District requires-CEP to implement Regulatory Guide 4.15. " Quality Assurance j

for Radiological Monitoring Programs-(Normal Operations) - Effluent s

L Streams and the Environment."

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As. part of their overall quality assurance program, CEP participates 1

in the-EPA's Environmental Radioactivity Laboratory Intercomparison Studies (cross-check) program.

The District acknowledges instances when CEP's-cross-check analyses were outside the. EPA acceptance criterial however, the District was aware of this and was taking i

specific steps to ensure that CEP investigated and corrected the problem.

In May 1989, the District requested CEP to investigate all 1988 analysis results which were outside the EPA acceptance range.

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addition, the District has ceauested CEP to include the results of all m..

EPA cross-check analyses and the results of their own intralaboratory quality control analyses as part of their quarterly report to the District.

This-allows the District to closely monitor CEP's performance and to promptly follow-up on any problems..i; t

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.Hith'regards.to the four' discrepancies noted in NRC-Inspection Report f

89-18, CEP conducted.an investigation to determine the cause of each t

. discrepancy.

In two of: the cases the cause was; identified and

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-corrected. 'In the other two cases a review of the analytical and' L

calibration data-did not reveal ~the cause of the elevated results; h'

however, subsequent analyses (performed after the results were Lsubmitted toithe EPA) yielded results within'the acceptable range.

These discrepancies.are. discussed in more detail' below.

.The specific violation. states, "the vendor failed to adequately investigate to determine'the reasons for the violations and did not take~ corrective actions." The District denies the alleged violation z

because an-investigation was conducted for each discrepancy and 3~

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-corrective. actions taken.when the cause of the discrepancy was

-determined.

- 3A.

Discussion ~of the analysis discrepancies:

.NRC Inspection-Report 89-18 identified four instances where the '

. results.from CEP's EPA cross-check analyses were outside the acceptability range defined by the EPA. One instance involved

gross-beta analysis of an air filter (conducted on March 31, 1989),

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. rtwo' instances involved gamma analysis of a water sample (conducted on February..10; 1989),'and the fourth instance involved Iodine-131 4

. analysis, of:a water sample (conducted on February 17, 1989). -Each instance is discussed individually as follows:

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's Air Filter e"

EPA

,Studyi Acceptable CEP Hean

.Date-Parameter Ranae (DCi/f)

Value DCi/f

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3/31 Gross-Alpha 12.34-- 29.66 13 1-

  • Did not meet EPA acceptance criteria In March 1989, the EPA began submitting a new type of air filter.for their cross-check analysis.

This new filter type is a thick, spongy, styrofoam material and is not the same type or thickness previously submitted.

Due to the type of gross-alpha / gross-beta analysis performed on this sample, a correction factor was applied to account for source / source

. mount self-absorption and backscatter.

Because the type of filter was different, the correction factor used previously was no longer valid.

Thus, the results obtained by applying the old correction factor to the new type of filter sample were incorrect and provided incorrect results..

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The mean of the uncorrected data obtained-from the direct count of the 3

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- n'ew EPA air filter media-was 57 pCi/ filter.

Because the EPA

. acceptable. range 1 for this sample was 53.34f to 70.66 pCi/ filter, CEP's s'

results=would'have been acceptable-had the old correction factor not been applied;-(i.e., self-absorption and backscatter are negligible xM for.the new EPA-filter type).;

The correction factor. is no: longer applicable for the gross-beta analysis of EPA filters and will no longer be used for this analysis.

g, LHith regards to the results of the St-90 analysis, the correction t

factor $s not applicable because St-90 is analyzed using an entirely different' analytical' technique which avoids the problem of self-absorption.

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Gamma'in Water EPA 1

Acceptable CEP Mean

. Study-Ranae (oCi/L)

Value oCi/L Date

. Parameter i.,

J2/10 Chromium-51' 193.43 - 276.57 244 i 15

-Cobalt-60 1.34 - 18.66 14 1 1 Zinc-65 131.29 - 186.71 175 i 15

  • Ruthenium-106 146.82 - 209.18 218 19 L

Cesium-134 1.34 - 18.66 15 1 2 m

  • Did not meet EPA acceptance criteria-g F

Ruthenium-106 g,

An
investigation of the analytical data,: instrument algorithm, and calibration data from the analysis of the Gamma-in Water sample did s

E not determine a cause for the elevated results for Ruthenium-106. CEP did'obtain one result within the EPA acceptable range out of the three results reported (203, 211,-239 pCi/L).

In addition, the June 1989 EPA Gamma = in Water sample had acceptable results for all parameters.

Cesium-137 An investigation of the analytical and calibration data did not indicate the cause of the slightly elevated results obtained for Cesium-137. CEP had been obtaining acceptable results in previous

' studies and no changes were made to the gamma spectrometry system.

It n'

should be noted that all results reported to EPA for Cesium-137 for 1988, were within the acceptable range. A recount of the sample after the final results were presented yielded an acceptable activity concentration of 13 pCi/L.

In addition, the June 1989 EPA Gamma in Hater sample had acceptable results for all parameters.

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Jodine-131 tin Water l

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7 Acceptable.

CEP Mean-Study' Ranae (DCi/L)

Value DCi/L K

Date' Parameter 4

2/17'

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  • Did'not meet EPA acceptance criteria

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The 79lil6 value reported to EPA for Iodine-131 in water sample was obtained by a radiochemical' separation technique. Most Rancho Seco-water samples are analyzed by direct gamma spectroscopy.

The gamma spectroscopy method used for the analysis of Rancho' Seco water samples i

correctly.identifled the Iodine-131 value at 99 1 20'pCi/L.

iAn: investigation determined that a calculation error ' as made-on the w

results:from'the. radiochemical analysis. CEP uses-an iodine absorption curve to determine the efficiency of the instrument-for

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each sample. analyzed.- The individual performing the:calculationi, misread the absorption curve graph and used the factor from the wrong.

curve.

Recalculation of the samples using the. correct efficiency gave-a mean Iodine-131 activity of 95.79=1 7.37 pCi/L which is~within the:

-EPA acceptable range of 86.95 to 125.05 and also agrees with the H

results obtained by gamma spectroscopy.

4A.

Corrective actions taken and results-achieved:

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CEP investigated the four instances (subsequently cited in NRC i

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Inspection Report 89-18)-where their cross-check analysis results were outside the EPA acceptance range. 'Their investigation iidentified and implemented the following corrective actions:

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The 'self-absorption correction factor previously used for gross-beta analysis of EPA filter samples is no longer applicable and will no longer be used.

The results of gross b

beta analysis of the filter samples were acceptable when the correction factor was not used.

CEP reanalyzed the I-131 in water sample using the correct efficiency factor for the instrument.

The reanalysis yielded an acceptable result-of 95.79 1 7.37 pC1/L of I-131.

In order to allow the District to more closely monitor CEP's performance and promptly follow-up on problems, CEP now includes the results of EPA cross-check analyses and the results of their own intralaboratory quality control analyses as part of their quarterly report to the District..,

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VIOLATION B1 n

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Admission or denial of the alleged violation:

Although the District acknowledgesLthat Violation-B occurred, we

. request!the violation beLreduced to Severity Level V.- This request-is!

. based on thejfollowing:.

,3 NRC Inspection Report 89-18 stated:

Licensee' management representatives noted.that the action to consider the PAS program as no longer required-had-been reviewed by the Plant Review Committee and that it was not' felt that maintaining the specified _ number of operators was required as e

their procedure did not require the system to be operable with the plant shutdown..This position would have"been acceptable had the "N

-licensee accordingly amended their procedures to assure systematic conformance to the TS.

At?the time the violation occurred, the plant was in cold shutdown in preparation for permanent defueling-of:the reactor; therefore, PASS was not required to be operational. A Severity Level IV violation would be appropriate if the violation could have led to a more-serious situation.

This violation-should be reduced to Severity Level V because the violation presented no safety or environmental concern.

2B. -

Reason-for the violation:

RSAP-0219." Post Accident Sampling-Program," establishes a program to ensure the capability to obtain and analyze _ reactor coolant, Reactor Building atmosphere, and plant gaseous effluent samples under accident

-conditions. Step 5.4.1.1 of RSAP-0219 states, "The Post Accident Sampling System shall be demonstrated operable at least once per quarter, while the reactor is in hot standby or poder operation."

Because the plant was shutdown in preparation for being permanently defueled, Chemistry supervision determined that it was no longer necessary to maintain the Post Accident' Sampling System (PASS) available. Therefore, when the number of designated PASS equipment operators decreased to less than five individuals (due to either staff reductions or a lapse in requalification training), Chemistry believed that it was not necessary to train additional PASS operators.

In addition, with the plant in cold shutdown, adequate on-the-job training could not be conducted in accordance with current District

-on-the-job training requirements.

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Corrective actions taken.and results achieved:

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DefuelingLof the1 reactor vessel was. completed on December 8,'1989.

Because there is no fuelLin-the reactor vessel, PASS is not' required to be maintained operable and _the requirement to maintain a minimum of five_ designated PASS operators ~ is not applicable.

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lCorrectiveactionstakentoavoidfurtherviolations:

RSAP-0219 will be revised to indicate that'the PASS program is not required when there is no-fueliin the reactor vessel.

. 5Bi.

Date when fullEcompliance will be achieved:

RSAP-0219. will be-revised by April 30, 1990.

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