ML20127M709

Insp Rept 50-395/85-19 on 850430-0503.Violation Noted: Failure to Meet Required Lower Limits of Detection for Effluent Measurements

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: IR 05000430/2005003 ML20127M678 ML20127M709
References
50-395-85-19, NUDOCS 8507010331
Download: ML20127M709 (9)

See also: IR 05000395/1985019

Text

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pm Kr UNITED STATES

p ^

'o NUCLEAR REGULATORY COMMISSION

y* o REGION ll

g j 101 MAR lETTA STREET,N.W.

• * ATLANTA, GEORGI A 30323

%.....+ 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

Inspectors: .

-

Ma lm f-/4/ @j ~

G. B. Kuzo (f () Q Date Signed

Accompanying Per onnel: J. D. Harris

Approved by: U .

ac% bN'I

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

gDR ADOCK 05000395

PDN

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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.

No violations or deviations were identified. I

5. Audits (84725) l

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

Carbon.

(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 -

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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l a. During 'the inspection, reactor coolant and selected liquid and gaseous

l 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, Fe-55, Sr-89, and Sr-90

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 ,

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 MRC LICENSEE /NRC

(3) Reactor Coolant Sample Mn-54 1.71 E-3 1.6710.07 E-3 24 1.02 Ag reement

(15 mi vial) Co-57 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

Co-60 3.07 E-3 2.9010.08 E-3 '36 1.06 Ag reement

(1) Liquid Waste - WMT Mn-54 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

Co-60 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 Mn-54 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

Co-60 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 Mn-54 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

Co-60 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 Co-60 1.16 E-2 9.9510.20 E-3 34 1.16 Ag reement

(47 mm filter) Cs-137 1,56 E-2 1.2810.03 E-2 43 1.22 Ag reement

(2) Particulate Filter Spike Co-60 1.23 E-2 9.9510.29 E-3 34 1.24 Ag reement

(47 mm filter) Cs-137 1.60 E-2 1.2810.03 E-2 43 1.25 Ag reement

(3) Particulate Filter Spike Co-60 1.19 E-2 9.9510.29 E-3 34 1.20 Ag reement

(47 mm filter) Cs-137 1.63 E-2 1.2810.03 E-2 43 1.28 Ag reement

(1) Cha rcoa l Ca rtridge - Co-60 2.83 E-2 2.8410.06 E-2 47 0.99 Ag reement

Spike ( face-loaded) Cs-137 3.62 E-2 3.4310.05 E-2 69 1.06 Ag reement

(2) Cha rcoa l Cartridge - Co-60 2.87 E-2 2.8410.06 E-2 47 1.01 Ag reement

Spike (face-loaded) Cs-137 3.64 E-2 3.4310.05 E-2 69 1.06 Ag reement

(3) Cha rcoa l Ca rtridge - Co-60 2.71 E-2 2.8410.06 E-2 47 0.95 Ag reement

Spike (face-loaded) Cs-137 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) Xe-133 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) .Xe-133 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 ) Xe-133 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

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