ML20127M709
| ML20127M709 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/14/1985 |
| From: | Kuzo G, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127M680 | List: |
| References | |
| 50-395-85-19, NUDOCS 8507010331 | |
| Download: ML20127M709 (9) | |
See also: IR 05000395/1985019
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION ll
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101 MAR lETTA STREET,N.W.
ATLANTA, GEORGI A 30323
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MAY 151985
Report No.:
50-395/85-19
Licensee:
South Carolina Electric and Gas Company
Columbia, SC 29218
Docket No.:
50-395
License No.: NpF-12
Facility Name:
Summer
Inspection Conducted: April 30 - May 3, 1985
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Inspectors:
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G. B. Kuzo
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Date Signed
Accompanying Per onnel:
J. D. Harris
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Approved by:
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D. M. Montgomeryg SectJ<fn Chief
Date Signed
Emergency Preparedness % nd Radiological
Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope: This routine, unannounced inspection involved 60 inspector-hours on site
in the areas of quality control and confirmatory measurements including review of
the laboratory quality control program; review of procedures and instructions;
review of quality control records and logs; review of the counting room and
chemistry laboratory facilities and results of split samples analyzed by the
licensee and the NRC Region II Mobile Laboratory.
Results: Violation - failure to meet required lower limits of detection (LLD)
for effluent measurements.
0507010331 850515
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ADOCK 05000395
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- 0. S. Bradham, Director, Nuclear Plant Operations
- B. G. Croley, Group Manager, Technical and Support Services
- A. R. Koon, Jr. , Associate Manager, Regulatory Compliance
- J. W. Cox, Associate Manager, Health Physics
- W. F. Bacon, Associate Manager, Chemistry
- G. M. Gowdy, Staff Health Physicist
F. S. McKinna, Associate Manager Station Quality Control
J. Barker, Corporate Health Physics Quality Assurance
J. W. Sowell, Health Physics Supervisor
J. K. Knox, Health Physics Specialist
E. C. Elder, Health Physics Specialist
Other licensee employees contacted included technicians, and office
personnel.
NRC Resident Inspector
- C. W. Hehl
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on May 3, 1985, with those
persons indicated in paragraph I above. One violation concerning failure to
meet lower limits of detection for the analysis of gas samples
(Paragraph 7.c) was discussed.
Two followup items concerning systematic
bias for particulate filter gamma spectroscopy analyses (Paragraph 8.a) and
radiochemical analyses of a NRC spiked confirmatory measurements sample
(Paragraph 8.b) were reviewed.
Licensee management representatives
acknowledged the inspectors' comments and expressed no contrary opinions.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Laboratory Quality Control Program (84725)
The inspectors reviewed selected portions of the Quality Assurance program
with cognizant licensee representatives and determined that organizational
structure and program management had not changed since the previous
inspection
(IE50-395/84-01).
The
inspectors
noted
that program
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implementation met the general guidance of Regulatory Guide 4.15 " Quality
Assurance for Radiological Monitoring Programs," with respect to the
radioactive effluent monitoring program.
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No violations or deviations were identified.
5.
Audits (84725)
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Technical Specification (TS) 6.5.2.8 states audits of unit activities shall
be performed under the cognizance of the Nuclear Safety Review Committee
(NSRC) encompassing conformance of unit operation to provisions contained
within the TSs and applicable license conditions at least once per
12 months; the Radiological Environmental Monitoring Program and the results
thereof, including the performance of activities required by the quality
assurance program per Regulatory Guide 4.15, Rev. 1, February 1979, at least
once per 12 months; and the Offsite Dose Calculation Manual and implementing
procedures at least once per 24 months.
The inspectors reviewed the
following audit reports:
a.
Corporate Health Physics Annual Review of United States Nuclear
Regulatory Commission
Regulatory Guide 4.15 Quality Assurance
Implementation at Virgil C. Summer Nuclear Station, July 1984.
b.
V.
C.
Summer Nuclear Station NSRC Shepherd's Report, Radiological
Environmental Monitoring Program, Offsite Dose Calculation Manual,
Process Control Program, November 1984.
c.
Corporate Health Physics Annual Review of the Radiological Effluent
Release Program at the Virgil C. Summer Nuclear Station, April 1985,
d.
Corporate Health Physics Biennial Review of the Offsite Dose
Calculation Manual, January 1985.
The inspectors noted that chemical and radiological measurements program
areas were audited against applicable sections of the Technical Specifica-
tions, Final Safety Analysis Report (FSAR), Regulatory Guides 1.21, 4.15,
1.109, and 1.111, and approved plant procedures.
No violations or deviations were identified.
6.
Procedures (84725)
a.
Technical Specification 6.8.1 requires written procedures to be
established, implemented, and maintained covering the applicable
procedures recommended in Appendix "A" of Regulatory Guide 1.33,
Rev. 2, February 1978; the Offsite Dose Calculation Manual; and the
effluent and environmental monitoring program using the guidance in
Regulatory Guide 4.15 Rev. 1, February 1979. The inspectors reviewed
selected portions of the following procedures:
(1) HPP-707 Health Physics Actions and Surveillance for Unplanned
Releases, Rev. 2, 4/16/85.
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(2) HPP-709 Release of Radioactive Gaseous Effluents, Rev. 3, 4/2/85.
(3) HPP-710 Release of Radioactive Liquid Effluents, Rev. 4, 1/29/85.
(4) HPP-801 Quality Control Test of LS-7500 System, GM Counters, and
Gas Flow Proportional Counters, Rev. 2, 6/28/83.
(5) HPP-803 Operation of the Tennelec LB5100 Automatic Counting
Systems, Rev. 2, 6/28/83.
(6) HPP-808 Sample Analysis, Rev. 5, 5/20/83.
(7) HPP-810 Sampling of Radioactive Gases & Liquids, Rev. 6, 4/2/85.
(8) HPP-812 Operation and Calibration of the ND-66/HP-9845 Ge(L1)
Spectroscopy System, Rev. 1, 7/5/84.
(9) HPP-813 Quality Control of the ND-66/HP-9845 Ge(L1) Spectroscopy
System, Rev. 3, 11/1/84.
(10) HPP-815 Counting Statistics, Rev. 3, 1/9/85.
(11) HPP-817 Quality Control of Sampling and Sample Analysis Methods,
Rev. 3, 4/2/85.
(12) HPP-818 Operation and Calibration of the LS-1800 Liquid Scintil-
lation Counter, Rev. 1, 1/29/85.
(13) HPP-909 Internal Review and Audits, Rev. 1, 2/21/85.
(14) CP-202 Chemistry Laboratory Safety and Housekeeping, Rev. O,
6/26/84.
(15) CP-304 Determination of Tritium, Rev. 1, 6/13/84.
(16)CP-501 Calibration and Standardization Requirements, Rev. 6,
11/9/84.
(17) Chemistry Group Internal Audits, Rov. 3, 4/19/84.
(18) CP-608 Chemistry Group Quality Control Program, Rev. 6, 1/3/85.
(19) SOP-119 Waste Gas Processing, Rev. 10, 1/10/85.
The inspectors noted that procedures were reviewed and approved in
accordance with established procedures.
No violations or deviations were identified.
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7.
Records (84725)
a.
The inspectors reviewed selected portions of the following records:
(1) Liquid Scintillation Counter (LS-1800) Quality Control Logs for
January - April 1985 including:
1.
Daily Background & Efficiency Determinations
11. Daily Background & Efficiency Trend Charts
111. Chi Squared Value Determinations
iv. Quench Correction Charts
(2) LB-1 Alpha and LB-2 Beta Quality Control Logs for January -
,
April 1984 including:
1.
Daily Background and Efficiency Determinations
11. Daily Background and Efficiency Trend Charts
, 111. Chi-Squared Value Determinations
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iv. Operating Voltage Determinations
v.
Alpha Plateau Curves
(3) Ge(Li) Detector System Nos.1, 2, and 3 Quality Control Logs for
January - April 1985 including:
1.
Daily Centroid Determinations
11. Daily Efficiency Checks
111. Daily Resolution Checks
iv. Weekly Background Data
(4)
1984 Efficiency Calibration Data for Gamma Spectroscopy Detectors
Nos. 1, 2, and 3 including the following geometries: Face-loaded
Cnarcoal Cartridge, 25 cc Gas Bomb,1 L Liquid Marinelli, 47 mm
M1111 pore Filter.
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(5) Standard Radionuclide Source Certificates
(6) Chemistry Calibration Logbook for the following analyses:
Fluorida, Boron, Ammonia, Hydrazine, Conductivity, Total Organic
(7) Primary Chemistry Laboratory QC Logbook Standard results and QC
Charts for the following Analyses:
Total Organic Carbon,
Chloride, Fluoride, Ammonia.
(8) 1984 Intercomparisons Involving V.C. Summer Nuclear Station HP
Count Room and Radiological Environmental Laboratory.
(9) Mixed Gamma Emitter Gas Intercomparisons, 2/11/85.
(10)
1984 Intralaboratory Cross-Check Results.
(11) 1984 - 1985 Waste Gas Decay Tank Relaase Permits.
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Results of the record review were discussed with cognizant licensee
representatives as noted in Paragraphs 7.b - 7.c.
b.
The inspectors noted that limited QC data for the counting room
instrumentation were graphed for trend analyses.
The inspectors
discussed with cognizant licensee representatives the use of QC trend
data in the laboratories' QA programs and noted that the use of
laboratory QC charts
is considered good
practice.
Licensee
representatives informed the inspectors that the increased use of trend
analyses is presently being evaluated for the counting room and
chemistry laboratories.
c.
The inspectors reviewed licensee Lower Limits of Detection (LLD) for
gaseous effluent analyses by gamma spectroscopy analyses.
The
inspectors noted that approved licensee procedures (Paragraph 6) did
not control the time interval between sample collection and analyses to
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ensure that TS LLDs were met. From discussion with cognizant licensee
representatives and review of LLD determinations the inspectors noted
that waste gas decay tank analyses would have to be completed within
approximately 1.25 to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of sampling to meet required TS LLDs
for Xe-138 measurements. From review of waste gas decay tank release
data, the inspectors determined that during 1984 - 1985, there were two
examples of failure to meet the required LLD of 1 E-04 microcuries/cc
for Xe-138 as specified by TS Table 4.11-2.
The inspectors informed
licensee representatives that failure to r:eet the gaseous effluent LLDs
for Xe-138 was a violation (50-395/85-19-01).
Violation - failure to meet Technical Specification LLD requirements for
effluent samples.
8.
Confirmatory Measurements (84725)
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a.
During 'the inspection, reactor coolant and selected liquid and gaseous
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effluent process streams were sampled and the resultant sample matrices
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analyzed for radionuclide concentrations using - licensee and NRC
Region II Laboratory gamma-ray spectroscopy systems. The purpose of
these comparative measurements was to verify the licensee's capability
to measure radionuclides accurately in various plant systems. Analyses
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were conducted utilizing as many of the licensee's gamma spectroscopy
systems as . practicable.
Sa.9pl es included the following:
reactor
coolant sample (RCS); licoid waste, and gaseous waste.
Spiked
particulate 1 filter and charcoal cartridge sample types were provided
~~for analyses in lieu of licensee samples which did not have sufficient
levcis of activity for analysis.
Comparison of licensee and NRC
results are listed in Table 1 with the acceptance criteria listed in
Attachment 1.
Results were in agreement for the reactor coolant,
liqaid waste, and charcoal cartridge samples. All reported results for
the particulate filter analyses ' were systematically higher (15-28%)
than NRC xvalues.
However, further inspection did not resolve the
systematically high values for the filter analyses and licensee
representatives agreed to evaleate the systematic bias. The inspectors
informed licensee representatives that this evaluation would be
considered an inspector followup item and would be reviewed during a
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subsequent inspection (50-395/85-19-02). Gaseous effluent results for
Xe-133 were in disagreement for analyses conducted using gamma
spectroscopy detector No. 3.
Licensee representatives stated that this
detector is not utilized for any effluent analyses.
b.
The inspectors noted that the licensee was provided with a simulated
liquid waste sample by the NRC contract laboratory and was requested to
complete radiochemical analyses for H-3,
concentrations.
Licensee representatives acknowledged receipt of the
sample and informed the inspectors that results from the vendor
laboratory had not been received.
The inspectors informed licensee
representatives that the results of these analyses would be considered
an inspector followup item and would be reviewed during a subsequent
inspection (50-395/85-15-03).
No violations or deviations were identified.
9.
Tour of the Chemistry and Counting Room Facilities (84725)
The inspectors toured the chemistry and counting room facilities.
The
inspectors noted adequate cleanliness and organization in the laboratory.
No violations or deviations were identified,
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TABLE 1
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NRC-LICENSEE SAMPLE COMPARISON
RESULTS OF GAMMA SPECTROSCOPY CONFIRMATORY MEASUREMENTS AT V. C. SUMMER NUCLEAR PLANT
APRIL 30 - MAY 3,
1985
SAMPLE TYPE
ISOTOPE
CONCENTRATION fuCi/Unitl
RESOLUTION
RATIO
COMPARISON
(Licensee Geometry)
LICENSEE
LICENSEE /NRC
(3) Reactor Coolant Sample
1.71 E-3
1.6710.07 E-3
24
1.02
Ag reement
(15 mi vial)
1.07 E-4
1.2910.43 E-4
3
0.83
Ag reement
Co-58
8.87 E-2
9.0910.04 E-2
227
0.98
Ag reement
3.07 E-3
2.9010.08 E-3
'36
1.06
Ag reement
(1) Liquid Waste - WMT
1.09 E-5
1.2110.03 E-5
40
0.90
Ag reement
(1 L Ma rinel l i Beaker)
Co-58
1.77 E-5
1.8710.04 E-5
78
0.95
Ag reemen t
2.95 E-5
3.1210.04 E-5
78
0.95
Ag reemen t
1-131
1.37 E-6
1.7610.15 E-6
12
0.78
Ag reement
(2) Liquid Waste - WMT
1.16E-5
1.2110.03 E-5
40
0.96
Ag reement
( 1 L. Ma ri ne l l i Bea ke r)
Co-58
1.77 E-5
1.6710.04 E-5
47
0.95
Ag reement
2.99 E-5
3.1210.04 E-5
78
0.96
Ag reement
1-131
1.69 E-6
1.7610.15 E-6
12
0.96
Agreement
(3) Liquid Waste - WMT
1.19 E-5
1.2110.03 E-5
40
0.98
Ag reement
(1 L Ma rinel l i Beake r)
Co-58
1.73 E-5
1.8710.94 E-5
47
0.92
Ag reement
2.9) E-5
3.1210.04 E-5
78
0.93
Ag reement
1-131
1.72 E-6
1.7610.15 E-6
12
0.98
Ag reement
(1) Particulate Filter Spike
1.16 E-2
9.9510.20 E-3
34
1.16
Ag reement
(47 mm filter)
1,56 E-2
1.2810.03 E-2
43
1.22
Ag reement
(2) Particulate Filter Spike
1.23 E-2
9.9510.29 E-3
34
1.24
Ag reement
(47 mm filter)
1.60 E-2
1.2810.03 E-2
43
1.25
Ag reement
(3) Particulate Filter Spike
1.19 E-2
9.9510.29 E-3
34
1.20
Ag reement
(47 mm filter)
1.63 E-2
1.2810.03 E-2
43
1.28
Ag reement
(1) Cha rcoa l Ca rtridge -
2.83 E-2
2.8410.06 E-2
47
0.99
Ag reement
Spike ( face-loaded)
3.62 E-2
3.4310.05 E-2
69
1.06
Ag reement
(2) Cha rcoa l Cartridge -
2.87 E-2
2.8410.06 E-2
47
1.01
Ag reement
Spike (face-loaded)
3.64 E-2
3.4310.05 E-2
69
1.06
Ag reement
(3) Cha rcoa l Ca rtridge -
2.71 E-2
2.8410.06 E-2
47
0.95
Ag reement
Spike (face-loaded)
3.47 E-2
3.4310.05 E-2
69
1.01
Ag reement
(1) Gas - WGDT
Xe-133m
1.77 E-4
1.4510.08 E-4
18
1.22
Ag reement
(25 cc Ma rinell i)
1.13 E-2
1.0110.003 E-2
337
1.12
Ag reement
Xe-135
2.69 E-5
2.5710.10 E-5
26
1.05
Ag reement
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SAMPLE TYPE
ISOTOPE
CONCENTRATION fuci/ Unit)
RESOLUTION
ratio
COMPARISQg
',
(Licensee Geometry)
LICENSEE
NRC
LICENSEE /NRC
(2) Gas - WGDT
Xe-133m
1.80 E-4
1.4510.08 E-4
18
1.24
Ag reement
(25 cc MarineIII)
1.17 E-2
1.0110.003 E-2
337
1.16
Ag reement
Xe-135
2.62 E-5
2.5710.10 E-5
26-
1.02
Ag reement
(3) Gas - WGDT
Xe-133m
1.83 E-4
1.4510.08 E-4
18
1.26
Ag reement
. ( 25 cc Ma rine l l i )
1.20 E-2
1.0110.003 E-2
337
1.19
Di sag reenent
Xe-135
2.89 E-5
2.5710.10 E-5
26
1.12
Ag reement
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ND = Not Detected
NC = Not Compa red
(1) Analyzed Using Gamma Spectroscopy System No. 1
(2) Analyzed Using Gamma Spectroscopy System No. 2
(3) Analyzed Using Gamma Spectroscopy System No. 3