IR 05000003/1977002
| ML20042B039 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/12/1977 |
| From: | Paperiello C, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042B037 | List: |
| References | |
| 50-003-77-02, 50-247-77-06, 50-247-77-6, 50-286-77-07, 50-286-77-7, 50-3-77-2, NUDOCS 8203240429 | |
| Download: ML20042B039 (16) | |
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Reg I Form 12
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(Rev Feb 77)
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U. S. HUCLEAR REGULATORY COMMISSION M
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0FFICE OF INSPECTION AND ENFORCEMEtU
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REGION I
50-003 50-003/77-02, 50-247/77-06 50-247 IE Inspection Report No:
and 50-286/77-07 Docket No:
50-285 i
UFK-b, UFM-Zb Licensee:
Consolidated Edison Company of New York License No:
and DPR-64 4 Irvino Place Priority:
Unit 1-0, Unit z New York. New York 10003 Category:
and Unit 3-C Safeguards Group:
Location:
Indian Point Nuclear Generatino Facility. Units 1, 2, 3 Unit 1. PWR, 615 MW(t) ~
Type of Licensee:
Unit 2. PWR 2758 MW(t) Unit 3. PWR 3025 (MW(t)
Type of Inspection:
Routine. Unannounced. Indeoendent Measurements Dates of Inspection:
Marct 7-9,1977 Jebruary 2-4, 19// (Unit 1)
Dates of Previous Inspection:
February 24-25,1977 (Units 2 & 3)
Reporting Inspector:
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///77 Dr. C. J// Paperfello, Radiation Specialist DATE Accompanying Inspectors:
DATE DATE DATE DATE Other Accompanying Personnel:
Mr. T. Jackson, Co-op Student DATE Reviewed By:
- / /7. 77 J. P. Sfohr, Chief Environmental and Special Projects DATE
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Section, Fuel Facility and Materials Safety Branch 8203240429 770412 PDR ADOCK 05000003 G
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SUMMARY OF FINDINGS Enforcement Action Violations None Identified.
Infractions 77-07-01:
Gamma Isotopic Analysis of Effluent Samples Appendix B to Facility Operating License No. DPR-64, Environmental Technical Specifications (ETS) Requirements, Section 3.4.1.b requires a sample to be taken from each batch of liquid waste prior to release and analyzed in ac-cordance with Table 2.4-1.
Table 2.4-1 requires that each batch of liquid by analyzed for principle gamma emitters.
Contrary to this requirement, each batch of liquid was not analyzed for principle gamma emitters prior to discharge for the period from December, 1975 to January,1977.
Prior to leaving the site, the inspector verified that the licensee had completed corrective action in this area and has been meeting this require-ment since January,1977.
(Details. Paragraph 5)
Deficiencies e
None Identified.
Licensee Action on Previously Identified Enforcement items (Independent Measurements)
IE Inspection Report No. 50-247/76-03, 50-286/76-05, (Details Items 8 and 9.c)
The licensee's corrective action with regard to steps taken to prevent similar items of noncompliance was in accordance with the actions stated in the licensee's letters dated July 2 and April 27, 1976.
(Details, Paragraphs 6 and 7)
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Design Changes Not Applicable.
Unusual Occurrences None Reported.
Other Significant Findings A.
Current Findings 1.
Acceptable Items
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Licensee's Quality Control Program for Analytical Measure-a.
ments.
(Details, Paragraph 3)
b.
Confirmatory Measurements. (Details, Paragraph 4)
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2.
Unresolved Items The following items have been identified as unresolved.
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a.
77-02-01; 77-06-01; 77-07-02 Possible Plate Out of Cesium after Liquid Sampling.
(Details, Paragraph 4.c)
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B.
Status of Previously Identified Unresolved Items
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The following items have been resolved as noted:
1.
IE Inspection Report No. 50-247/76-03 and 50-286/76-05, (Details, Item 3)
Xe-133 Recalibration.
(Details, Paragraph 9)
2.
IE Inspection Report No. 50-247/76-03 and 50-286/76-05, (Details Item 9.c)
Gross Beta vs. Gamma Isotopic Analysis.
(Details, Paragraph 5)
3.
IE Inspection Report No. 50-247/76-03 and 50-286/76-05, (Details Itsn 9)
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Counter Sensitivity Limits.
(Details, Paragraph 10)
Certain actions have been taken on the following item, but this remains unresolved as notcf.
4.
IE Inspection Report 50-286/77-01-02 Verification of Monitor Calibration Factors and Establishment of a Mechanism for Periodically Verifying the Factors.
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(Details, Paragraph 11)
C.
Deviations None Identified.
Management Interview At the conclusion of the inspection a meeting was held at the site with representatives of the licensee.
Attendees at this meeting consisted of personnel whose names are highlighted (i.e.*) in paragraph 1 of the Details Section of this report.
The inspector summarized the purpose and the scope of the inspection (Details, Paragraph 2), and the results of the j
inspection (as listed in the " Summary of Findings").
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ee managenent representatives
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Additional information was provided by the l censd to the info i
Details of this report.
and commitments were made which relatec Analyses Requiring Wet Chemistry waste tank sample, Sr-89 and Sr-90 will be performed (
d The licensee stated that for the split laun ry A.
analyses for gross beta, tritium andand the results C I office.
4.a)
Possible Cesium Plate Out_ Problem Cs-137 and Cs-134
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B.
The licensee stated that they will analyze a le from the Idaho spiked liquid sample upon receipt of the sampHe h 4.c)
Gamma Analysis of Liquid Releases amma isotopic analysis h
The licensee The item of noncompliance with respect to t e g C.
discussed.
of liquid waste tanks prior to release wasthat their analysis of th d of isotopic gamma stated that they wanted to make it clear t
liquid waste tanks by gross beta analysis ins ea of Table 2.4-1 of theirand that u i
analysis was based on their interpretat on i
Unit 3 Environmental Technical Specificat on;b tation was in error that they immediately started isotopic gamm
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Paragraph S)
ble Gases in Liouid Releases Guidelines for Dissolved and Entrained No lved noble gases in i
D.
The licensee stated that their limit for d ssoliq tion and a need to l
l releases in order to C of Regulatory Guide 1.21 meet the requirements of Section C.3. find a va Effluent and Waste Disposal Report.
He evaluation.
when preparing their Semi-Annual l
hi The inspector stated that he had reviewed t e rIn a follo differed from those
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i stated that the bases f, r their calculat on
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oted that their presenti ed their A used in the past by NRC Headquarters.
versation the licensee stated that they nlimit wo technical specifications.
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DETAILS
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Persons Contacted visor, Con. Ed.
1.
- Mr. Joseph Higgins, General Chamistry Supe ental Services Superintendent, PASNY Director, Con. Ed.
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- Mr. Thomas M. Law, Plant Manager, Con.
- Mr. John M. Makepeace, Technical Engineer Ed.
Ed.
- Mr. Eugene R. McGrath Acting Manager, Con.T. Mor Con. Ed.
Con. Ed.
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- Mr. Stephen W. Profeta, Chemistry Superv so,Wisla, C tr
- Mr. Brendan
- Mr. Stanley licensee's effluent col-General The inspection consisted of a review of thele 2.
rds, quality assurance ting equipment, and per-betwee audit records, certain monitoring and coun i
d by (1) the formance on verification test samples spl tThe verif licensee using his normal method and equipmenite and the NR the NRC:I.
(IHSL). Results of using the NRC Mobile Laboratory at the slabor Joint analyses of the verification sample analyses were compared. test samples with tual effluent samples.epared by IH to measure radioactive material in ac certain other capability test standards, prd his performance in submitted to the licensee for analysis an samples were reviewed.
le was sent to the A split verification test liquid effluent samplater date when These results will be IHSL for analyses requiring wet chemistry.
compared with the licensee's results at aand l tical Measurements i
Report.
Licensee program for Quality Control of Ana y i
that audits The licensee's technical specifications requ re 3.
d under the cognizanceThe in of the facility activities be performeof the N a.
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the " Amended Charter of the Nuclear Facilities Safety Committee" and the Revised Corporate Instruction CI-240-1,
" Quality Assurance Program for Operating Nuclear Plants."
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These documents assign responsibility and authority to conduct independent audits as required by the technical specifications.
They provided for deficiency reports ano corrective action and procedure for recording audit results and procedures for reporting results to supervision and management.
They also provide for the approval and surveillance of vendors.
The inspector reviewed Teledyne Isotopes QA Manual IWL-0032-361.
Teledyne Isotopes is the vendor used by the licensee for
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certain of his radiological effluent measurements.
The inspector reviewed an " Audit of Indian Point Technical Specifications Dealing with Effluent Releases - Radioactive Materials", audit #76-C1, dated December 16, 1976.
This audit was conducted on October 7, 13, 18, 20, 21, 26, 27 and November 3, 9, 12, 17, 1976. The inspector determined that it included both check lists and criteria for acceptance.
The inspector had no additional questions in this area.
b.
The inspector reviewed the licensee's procedures for his laboratory quality control program. These include CAD-3, Rev.
9/1/76 and CAD-4, Rev.12/23/76.
These procedures assign program responsibility, specify the number and frequency for making checks, provide acceptance criteria and specify followup actions.
c.
The inspector selected a number of recent analytical measurement records for review. These included QA/QC samples as required by the licensee's procedures. The inspector noted that they included duplicate and spiked samples in several media as required by the licensee's procedures.
The inspector noted
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that coroarisons were made, and the licensee used the NRC's criteria for accepting measurements. In a telephone conversation on April 6,1977, the inspector stated that the NRC limits on dissolved and entrained gases were those that would be included in the new Appendix I technical specifications.
The inspector stated that in the interim the licensee could use them on any other reasonable value.
The licensee stated that he preferred to use his present limits until they received their Appendix I technical specifications.
The inspector had no additional questions in this area. Since all results were within the acceptance criteria, no corrective actions were required.
The inspector also noted from his review of the analytical measurements that the licensee was meeting the analytical sensitivity requirements of his technical specification _ _ _
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4.
Confinaatory Measurements a.
Sample Splitting The results of the intercomparisons made are presented in
Table 1. These include results for:
1) split liquid, charcoal filter and noble gas effluent samples collected during this inspection and in June,1976, by a representative of the State of New York and 2) a spiked particulate filter paper prepared by IHSL since the licensee's actual filter had insufficient activity to meaningfully compare.
Certain measurements requiring wet chemistry (i.e. gross beta, Sr-89 and Sr-90, and tritium) will be compared when available at a later date.
b.
Sample Results The data presented in Table 1 indicates that 22 results are in agreement or possible agreement and none in disagreement with i
NRC values. The criteria for comparing analytical measurements are enclosed as Attachment 1.
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Possible Plate Out of Cesium after Liquid Sampling; (77-02-01, c.
77-06-01; 77-07-02)
Although none of the results presented in Table 1 are in i
disagreement, the inspector noted what appeared to be a conservative bias in the licensee's results for Cs-137 and Cs-134 for which 3 of the 4 results were in possible agreement. Since the licensee's results were high compared to the NRC results, the possibility of ionic plate out of cesium on the walls of the i
NRC sampling containers was raised.
NRC samples were stored for a longer period than the licensee's.
The inspector stated that in order to resolve this slight discrepancy a spiked liquid sample would be sent to the licensee by IHSL for analysis.
The licensee stated that the sample would be analyzed upon receipt and the results submitted to the inspector for comparison.
The inspector stated that this item was unresolved pending comparison of the results, 5.
Gamma Isotopic Analysis of Effluent Samples (77-07-01)
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Appendix B to Facility Operating License No. OPR-64 Environmental Technical Specifications (ETS) Requirements Section 3.4.1.b requires
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a sample to be taken from each batch of liquid waste prior to release and analyzed in accordance with Table 2.4-1.
Table 2.4-1 requires that each batch of liquid be analyzed for principle gamma emitters.
In a previous inspection (IE Inspection Report 50-
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l 247/76-03; 50-286/76-05, (Detail, 9.a)) an inspector noted that the licensee was performing a gross beta analysis irstead of an isotopic The licensee stated that a footnote to Table 2.4-1 gamma analysis.
permitted gross beta analyses instead of gamma isotopic analyses.
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The inspector referred this question to NRC Headquarters for resolution.
In January,1977, NRC Headquarters informed the Region I office that gamma measurements were required on their liquid effluent and that Consolidated Edison had misinterpreted NRC staff statements in this area.
The inspector stated that licensee's failure to analyze each batch of liquid effluents for principle gamma emitters prior to discharge for the period from December,1975 to January,1977, was an item of noncompliance.
The inspector noted, however, that upon being notified by the Regional office of the NRC's interpretation of the technical specifi-cation requirement, the licensee too.k corrective action in this area. The inspector noted that corrective action was completed and the licensee was presently meeting the technical specification re-quirement.
6.
Procedures Required by Environmental Technical Specifications In a previous inspection (IE Inspection Report 50-247/76-03; 50-286/ 76-05, Detail, 8) the inspector identified as an item of noncompliance the licensee's lack of instrument calibration procedures.
The inspector verified that the licensee had completed the corrective actions specified in his letters dated July 2 and April, 27, 1976, with respect to this item.
The inspector reviewed the following calibration procedures:
a. * IPC-A-100, Operation of TN-ll Computerized Counting Equipment b.
IPC-A-102, Determination of Tritium in Water c.
IPC-A-104, Proportional Counter PCC-11T Calibration d.
IPC-A-105, Radiochemistry Counting and Calibration In addition the inspector reviewed the results of an audit of "3-Unit ETS Requirements for Procedures" made as a result of the licensee's commitment to conduct a detailed review of the requirements for procedures as specified in Appendix B to Technical Specifications.
After reviewing the above procedures and audit results, the inspector had no additional questions.
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Control of Gaseous Effluent Procedures In a previous inspection (IE Inspection Report 50-247/76-03; 50-Detail, 9.c) the inspector identified as an item of 286/ 76-05, noncompliance the licensee's lack of a procedure to ensure compliance with the limiting conditions for gaseous radioactive discharge effluent release limits.
The inspector reviewed procedure IPC-S-039. " Determination of Plant Compliance with Regulatory Limits of Airborne Radioactive Discharges from Indian Point."
This procedure is intended to ensure compliance with the limiting conditions for gaseous radioactive discharge effluent release limits. The inspector reviewed a " Review Report for January,1977" to Mr. Moroney from Mr. J. J. Higgins, which showed that the above procedure was being implemented.
The licensee's audit as reported in detail 6, completes the corrective actions with respect to this item.
Licensee's Criteria for Limits on Dissolved and Entrained Noble Gas 8.
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In the licensee's " Effluent and Waste Disposal" semi-annual report for the period July - December,1976, the licensee states that since there is no limit stated for dissolved nogle gases in 10 CFR 20, they have established a limit of 2.55 x 10- uC1/cc. The licensee identifies a need for a limit for dissolved noble gases because Regulatory Guide 1.21, Table 2A, Section C requires them to report the " Percent of Applicable Limit" for " Dissolved and Entrained Gases."
The inspector noted that ghe licensee's limit was not in agreement with values of 1.25 x 10- uCi/cc for Xe-133 and 4.2 x 10-5 uCi/ml for Xe-135 which were provided as internal NRC guidance to NRC licensing personnel.
The inspector noted that the licensee's limit was based on that concentration of noble gases would which give a 170 mr/ year dose to a swimmer in the discharge canal. The assumption was made that the swimmer spent 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> per year in the water. The do tion was solved for Kr-85 and a concentration of 2.55 x 10 ge equa uC:/cc calculated.
The value calculated by NRC Headquarters was obtained by converting the MPC(a) in 10 CFR Part 20 for submersion doses to a subnersion dose in water.
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The inspector discussed the different limits with the licensee.
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The inspector noted that the licensee's actual release of this type were less than 0.1% of the NRC limit.
The licensee stated that their evaluation and value was established because of the lack of published value together with the requirement to use one in their effluent report.
In a telephone conversation on April 6,1977,
.the inspector stated that the NRC limits on dissolved and entrained gases were those that would be included in the new Appendix I technical specifications. The inspector stated that in the interim the licensee could use them or any other reasonable value.
The licensee stated that he preferred to use his present limits until they received their Appendix I technical specifications.
The inspector had no additional questions in this area.
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Xe-133 Recalibration
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The results of a previous set of verification test samples (IE Inspection Report 50-247/76-03; 50-286/76-05. Details, Item 3) indicated that the licensee's Xe-133 results were not in agreement with NRC results but were high.
After reviewing the current intercomparison results presented in
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Table 1 which showed the licensee's results for this analysis in agreement with NRC results the inspector had no additional questions in this area.
This item is considered closed.
10.
Counter Sensitivity Limits In a previous inspection (IE Inspection Report 50-247/76-03; 50-286/
76-05, Details, Item 9.b) the question with regard to the licensee's requirement to analyze each and every sample in such a fashion as to be able to meet the sensitivity limit ev'n when activity levels were well above the limit was left unresolved.
The inspector noted that the above question was raised relative to gross beta analysis on liquid effluents.
The inspector noted that the licensee was required to perform isotopic gamma and not gross beta on liquid effluents as noted in Item 5.
The inspector also noted that the licensee was meeting the sensitivity requirements on his routine isotopic gamma analysis.
The inspector stated that tais item is considered closed.
11. Verification of Monitor Calibration Factors and Establishment of a Mechanism for Periodically Verifying the Factors (50-286/77-01-02)
In a previous inspection the accuracy of the calibration curves used for some of the Process Radiation Monitors was left unresolved.
At the time the licensee made a commitment to sample monitored streams when there was sufficient activity in them to both make measurements of concentration in the laboratory possible and to get usable readings on the Monitors thenselves.
During this inspection, the inspector.
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reviewed the alarm settings on those monitors on which they were required and noted, using the calibration data supplied by the vendor of the monitors, that the proper alarms would occur assuming the presence of the most likely radionuclides.
The inspector said that this item would remain unresolved, however, pending the completion of the measurements yet to be made by the licensee.
12.
Sampling Line Losses for Plant Stack Particulate Monitors '
t-The licensee is required by his technical specifications to monitor radioactive particulate matter released through the plant stack.
The material is sampled in the stack, pulled through a sampling line and spitt into two streams.
One stream with a flow rate of 10CFM enters a continuous air monitor and the other with a flow rate of l-2CFM passes through glass fiber and charcoal filters.
The licensee assumes that there are no losses in the sampling system.
The licensee measures the radioactivity on the filtering media and divides by the sample volume to determine the airborne particulate concentration.
The licensee uses these data to show compliance with airborne effluent release limits.
The inspector noted the licensee's practice was consistent with the recommendations of ANSI N13.1-1969 " Guide to Sampling Airborne Radioactive Material in Nuclear Facilities."
However, the inspector asked if the licensee had evaluated the effects on sample losses that would be caused by the length of the sampling line, the sampling rate, the turns in the line and the presence of values in the flow stream between the sampling ifne and the monitoring devices. The inspector also noted that the outside lines were not heat traced.
The licensee presented data that was obtained by sampling the stack from a platform on the side of the stack.
In this way the long sampling line was avoided.
Two one week samples were collected from this location and compared to the samples cellected by the licensee's routine sampling system..The samples collected from the platform location showed less activity than those collected at the end of the long sampling line. Both the licensee and the inspector agreed that these data were questionable since one would not expect greater losses in a short sampling line, than a longer line if both particulate collection systems were operating properly. However, the data did indicate the sampling line losses were not a major probl em.
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The inspector acted that the licensee's measured releases of particulate activity with half lives greater than 8 days was very low relative to technical specification limits. The inspector stated that he would review further the general aspects of sampling line losses but that he had no further questions of the licensee in this area at this time.
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TABLE I
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INDIAN POINT - VERIFICATION
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TEST RESULTS
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SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON
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uti/cc fil Waste Distillate Cs-134 (1.09 + 0.03)E-4 (1.37 + 0.03)E-4 A
i Tank Cs-137 (2.95 T 0.08)E-4 (4.74 T 0.02 E-4 PAA i
6/23/76 Co-58 (1.14 7 0.03)E-4 (1.30 T 0.01 E-4 A
Mn-54 (2.9 + 0.1)E-5 (3.51 7 0.07 E-5 A
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Co-60 (1.45'+ 0.04)E-4 (1.52 T 0.01 E-4 A
H-3 (1.45 7 0.01)E-2 (1.28 I ?)E-2 A(In-Plant)
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(1.67 i ?)E-2 A(Vendor)
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Sr-89 (6.2 + 0.6)E-7 (8.4 + 0.7)E-7 A
Sr-90 (1.010.2)E-7 (1.710.2)E-7 A
- 5 Laundry Waste Cs-134 (3.7 + 0.2)E-6 (5.98 + 0.43)E-6 PAA
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Tank Cs-137 (8.2 7 0.3)E-6 (1.23 T 0.06)E-5 PAA 3/8/77 Co-58 (4.9 I 0.2)E-6 (3.72 T 0.35)E-6 A
Mn-54 (1.9 7 0.2)E-6 (2.11 T 0.26)E-6 A
Co-60 (~.12 + 0.04)E-5 (1.1410.46)E-5 A
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Gas Decay Tank Xe-133 (5.02 + 0.01)E-2 (5.92+0.02)E-2 A
3/8/77 Xe-135 (1.44 T 0.07)E-4 (1.35 T 0.07)E-4 A
Xe-133m (2.81 T 0.42)E-4 (2.41 T 0.3)E-4 A
Kr-85 (4.4010.90)E-3 (1.8310.7)E-3 PAA Gas Decay Tank #32 Xe-133 (3.15 + 0.12)E-4 (3.41 + ?)E-4 A
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6/24/76 Gas Decay Tank #23 Xe-133 (2.8 + 0.3)E-5 (2.54 + ?)E-5 A
6/24/76 Kr-85 (8.810.4)E-3 (7.361?)E-3 A
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TABLE I
INDIAN POINT - VERIFICATION TEST RESULTS
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SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON
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utt/cc
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Charcoal Filter I-131 (9.22 1 0.5)E-12 (8.351 ?)E-12 A
6/22/76 TOTAL uti
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Charcoal Filter I-131 (2.87 1 0.04)E-2 (2.58 1 0.03)E-2 A
3/8/77 Spiked Particulate Sb-135 (4.5 + 0.1)E-2 (3.48 + 0.13)E-2 A
Filter Cs-134 (6.0 I 0.3)E-2 t s.65 I 0.19 E-2 A
Ref. Date Ag-110m (2.6 T 0.1)E-2 (2.14 7 0.16 E-2 A
10/28/74 Na-22 (1.11 1 0.04)E-2 (1.00 1 0.06 E-2 A
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Attachment 1
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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.
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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 Conversely, poorer ag'eement must be considered acceptable selective.
r 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 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 applied to the following analysed:
Gamma Spectrometry where principal gamma energy used for identification is greater than 250 Kev.
Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Gamma Spectrometry where principal gamma energy used for identification
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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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