IR 05000261/1985016

Insp Repts 50-261/85-16,50-324/85-13,50-325/85-13 & 50-400/85-17 on 850506-09.No Violations or Deviations Noted. Major Areas Inspected:Preoperational Radiological Environ Monitoring Program at Shearon Harris & QA at Harris Lab

ML20127P017
Person / Time
Site:	Harris, Brunswick, Robinson, 05000000
Issue date:	05/24/1985
From:	Gloersen W, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127P005	List: IR 05000261/1985016 ML20127P002
References
50-261-85-16, 50-324-85-13, 50-325-85-13, 50-400-85-17, NUDOCS 8507020287
Download: ML20127P017 (9)

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NUCLEAR REGULATORY COMMISSION O 'l - REGloN H h, d I 101 MARIETTA STREET, e ATLANTA, GEORGI A 30323

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...../ MAY 2 91985 Report Nos.: 50-261/85-16, 50-324/85-13, 50-325/85-13, and 50-400/85-17 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Docket Nos.: 50-261, 50-324, 50-325, and 50-400 License Nos.: DPR-23, DPR-62, DPR-71 and Construction Permit No. CPPR-158 Facility Names: Harris Energy and Environmental Center H. B. Robinson Nuclear Plant 2, Brunswick, and Shearon Harris Inspection Conducted: May 6-9, 1985 Inspectors:h!/$w' $rA.,4KAJ 5/73/95

'W 3. Gloers n ' U Date Sihned Accompanying Personnel: S. S. Adamovitz Approved by: .[h.[on et hd//lf)~

D. ~ Montgom5tt, Secflion Chief Date Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection entailed 58 inspector-hours on site in the areas of implementation of the preoperational radiological environmental monitoring program at Shearon Harris Nuclear Power Plant and quality assurance at the Harris Energy and Environmental Center's (HEEC) Radiological Environmental Laborator Results: No violations or deviations were identifie DR ADOCK 050

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REPORT DETAILS Persons Contacted Licensee Employees

• J. Harness, Assistant Plant Manager

• B. Webster, Manager, Radiological and Chemical Support Section (RCSS), HEEC

• J. Sipp, Manager, Environmental and Radiological Control

• D. Tibbitts, Senior Specialist, Regulatory Compliance G. Warriner, Unit Head, Environmental, RCSS, HEEC

• D. Cahill, Supervisor, Radiological Environmental Laboratory, RCSS, HEEC

• R. Shearin, Project Specialist, Environmental, RCSS, HEEC B. McFeaters, Meteorological Supervisor, Corporate W. Lei, Senior Specialist, Environmental, RCSS, HEEC M. Walsh, Senior Specialist, Environmental, RCSS, HEEC S. Brown, Project Specialist, Dosimetry, RCSS, HEEC W. Payton, Radiation Control and Test Technician, Environmental, RCSS, HEEC K. Hannah, Radiation Control and Test Technician, Environmental, RCSS, HEEC NRC Resident Inspectors

• R. Prevatte

• Attended exit interview Exit Interview The inspection scope and findings were summarized on May 9, 1985, with those persons indicated in Paragraph The inspector described the areas inspected and discussed in detail the inspection finding Licensee management representatives acknowledged the inspector's comments and expressed no contrary opinions. The licensee did not identify as pro-prietary any of the materials provided to or reviewed by the inspectors during this inspectio . Preoperational Radiological Environmental Monitoring Program Status and Implementation (80521)

The inspectors conducted a detailed review of the radiological environmental monitoring and surveillance program to determine if the status of the program was consistent with the licensee's Construction Permit, Environ-mental Report (Operating License Stage), the respective NRC Final Environ-mental Statements, and the proposed Radiological Effluent Technical Specifications (RETS). The licensee's proposed RETS were based on NUREG-0472, Revision 3, March 1979 (Draft Radiological Effluent Technical Specifications for PWRs).

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The inspector accompanied licensee representatives on a tour of all assigned air monitoring stations, dairies, selected surface water samplers, and TLD stations. Based on this tour the following was noted: (1) the location of air monitoring stations and continuous surface water sampling stations was consistent with program procedures and requirements; (2) the weekly recovery and deployment of air particulate filters and charcoal cartridges was implemented in accordance with respective monitoring program procedures; (3)

the location of four dairies and semi-monthly grab sampling when animals were on pasture was confirmed; (4) the selected licensee TLDs deployed at air monitoring stations was consistent with program requirements; (5)

twenty-nine TLD stations were inspected with six licensee /NRC colocated TLD stations consistent with the deployment scheme defined in the NRC TLD Direct Radiation Monitoring Network Program. Nineteen additional NRC stations were found to be colocated with the licensee's. The inspection disclosed that the radiological environmental monitoring and surveillance program was implemented in accordance with the proposed RET Within the areas examined, no violations or deviations were identifie . Procedures (80521, 80721) The inspectors reviewed and discussed with cognizant licensee representatives the detailed written procedures and administrative instructions established to assure implementation and completion of the preoperational radiological environmental monitoring progra The plant specific procedures detailing the radiological environmental monitoring program for the Shearon Harris Nuclear Power Plant (SHNPP)

were based on the proposed Radiological Effluent Technical Specifi-cations (RETS) which were submitted to NRR for approva The inspectors also reviewed the radiological and radiochemical analytical procedures for Harris Energy and Environmental Center's (HEEC)

Radiological Environmental Laborator Additionally, selected HEEC Emergency Instructions were reviewed. The inspectors reviewed selected portions of the following procedures:

(1) RC-ER-1 Determination of Tritium in Environmental Water and Urine Samples, Rev. 7, 7/31/8 (2) RC-ER-2 Calibration / Operation of the ND4420 Ge(Li) Gamma Spectroscopy System, Rev. 3, 11/26/8 (3) RC-ER-3 Operation and Calibration of SHNPP Environmental Air Samplers, Rev. 2, 11/26/8 (4) RC-ER-6 Determination of Counting Efficiency Factors for the Alpha, Beta, and Gamma Detectors, Rev. 1, 12/15/8 (5) RC-ER-8 Quality Control in the Environmental Radiological Laboratory, Rev. 3, 7/31/8 ,

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(6) RC-ER-12 Determination of Gross Alpha and Gross Beta Activities in Environmental Samples, Rev. 7, 4/10/8 (7) RC-ER-13 Determination of Radioiodine in Milk, Water, and Charcoal, Rev. 6, 10/4/8 (8) RC-ER-19 Reporting Anomalous Results, Rev. 2, 10/16/8 (9) RC-ER-23 Calibration / Operation of the Tennelec LB 5100 and LB 5100 II Low Background Simultaneous Alpha and Beta Counting Systems, Rev. 4, 11/30/8 (10) RC-ER-26 Training Procedure for New Technicians in the Radio-

logical Environmental Laboratory, Rev. 2, 3/7/8 (11) RC-ER-29 Calibration / Operation of the ND 6685 Multichannel Analyzer, Rev. 5, 12/12/8 (12) RC-ER-31 Radiological Environmental Monitoring Program for SHNPP, Rev. 3, 3/22/8 (13) RC-ER-32 Determination of Gamma Activity in Environmental Samples, Rev. 3, 7/31/84.

(14) RC-ER-33 Calibration / Operation of the LKB Rack Beta Model 1211 Liquid Scintillation Counter, Rev. 1, 7/10/8 (15) RC-AD-3 Instructions, Rev. 3, 3/16/82.

i (16) RC-AD-4 Calibration Program, Rev. 2, 12/27/8 (17) RC-EM-14 Sample Control and Analysis at the Mobile Environmental Laboratory.

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(18) RC-PD-07 Personnel Qualifications for Dosimetry, Rev. 6, 12/10/8 (19) RC-PD-19 Calibration of Panasonic UD-710A Automatic TLD Reader, Rev. 7, 3/7/85 (20) RC-PD-26 fanasonic Environmental Dosimetry, Rev. 4, 4/10/8 The inspectors noted the procedures were being reviewed, updated, and approved in accordance with administrative control instruction The inspectors noted that several of the procedures made references to other procedures without speci fying the procedure number thus

introducing the possibility for confusion. For example, RC-ER-1, Step 10 refers the user to calibration / operation procedure of the liquid . _ . _ _ __ . . . , . - _ . . _ - . _ - . -

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scintillation counter with no procedure number provided. RC-ER-4, Step 7 references did not provide a procedure number for calibrating air samplers with a Kurz mass flowmeter. Additionally, RC-ER-31, Step did not make reference to the procedure number for changing cartridge filter The inspectors noted that RC-ER-2, Step 2.1.1 stated that detector dead times should not exceed 20%. The inspectors discussed with licensee representatives that detector dead time limits exceeding 20% would result in inaccurate gamma spectroscopy measurements during calibration or routine counting. Also, Step 7.2 made an incorrect reference to a once per two year efficiency determination cycle for the ND 4420 Ge(Li)

System. The inspectors determined that this system and the other gamma spectroscopy systems had been calibrated once per two years in the past, however in 1984 the licensee revised the calibration program to an annual cycle. The other calibration procedures were consistent with current calibration practice The inspectors noted that RC-ER-13, Appendix 1, Step 1 did not indicate the proper placement of the charcoal cartridge filters on the detector relative to their flow path The inspectors, informed licensee representatives that erroneous placement of the filters during calibration or routine counting could result in inaccurate analyse Licensee representatives acknowledged the inspector's comments and agreed to evaluate the items noted in the above paragraph Within the areas examined no violations or deviations were identifie . Implementation of the Meteorological Monitoring Program (80521)

The inspectors cinermined that the SHNPP Meteorological Monitoring Program was evaluated during the Emergency Preparedness Implementation Appraisal (50-400/85-09) to determine whether the program met the commitments and requirements of Supplement 1 to NUREG-0737 and was in conformance with Regulatory Guide 1.97. The inspector discussed the results of the appraisal with licensee representative Within the areas examined no violations or deviations were identifie . Facilities, Equipment and Supplies (80521)

The inspectors examined the Harris Energy and Environmental Center's Radiological Environmental Laboratory facilities and noted an orderly laboratory with adequate cleanliness. Space and configuration of both the wet chemistry laboratory and counting room and the available analytical equipment allowed for efficient processing and analyzing of environmental samples. Personnel working in the laboratory appeared knowledgeable of their responsibilities and the analytical equipmen Within the areas examined no violations or deviations were identifie .

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7. Documentation (80521, 80721) The inspectors reviewed selected portions of the following records and reports:

(1) Ge(Li) Gamma Spectroscopy Systems Detectors 1, 2, and 3 daily quality control (QC) background checks and daily QC source checks for January 1984 - April 198 (2) Ge(Li) Gamma Spectroscopy Systems 1984 and 1985 efficiency calibrations for the following geometries: 47 mm air filter, charcoal filter, 500 m1 liquid marinelli beaker, soil in 500 m1 liquid marinelli beaker, 1000 m1 liquid marinelli beaker, 1.26 liter gas marinelli, 14.2 cc gas vial, and QC disk and fac (3) NaI Beta-Gated detector I-131 efficiency determinations - 10/4/84 (4) Tennelec LB 5100 II detector numbers 1 and 2 QC logs for January 1984 to March 1985-including:

. Alpha and' beta daily background and reliability (source)

che:ks

. "True" counting rate determinations

. Reproducibility checks

. Alpha and beta air filter efficiency determinations

. I-131 efficiency determinations

. Gross alpha and beta surface water efficiency determinations (5) LKB Rack Beta Model 1211 Liquid Scintillation Counter QC Logs for July 1984 - April 1985 including:

. Daily QC Background and source checks

. Weekly ten point chi-squared tests

. Monthly tritium efficiency determinations

. Annual Fe-55 calibration result (6) Environmental Surveillance Reports January 1,1983 - December 31, 1983, and January 1, 1984 - December 31, 1984 (in draft)

(7) Carolina Power and Light " Gamma Round-Robin" comparisons for 1984 (HEEC Lab only).

(8) EPA crosscheck results for 1984~(HEEC Lab only) including:

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. Tritium, gross alpha and beta, and mixed gamma in water samples

. Sr-89, Sr-90, I-131, and Cs-137 in food

. I-131 in milk

. Laboratory Performance Evaluation - Blind Spikes for: gross alpha and beta, Sr-89, and Sr-90, Co-60, Cs-134, and Cs-13 . Air filters: gross alpha and beta, Sr-90, and Cs-137

. Tritium in urine (9) Harris Environmental TLD Analysis Report (1/3/85-4/1/85)

(10) Robinson Environmental TLD Analysis Report (1/5/84 - 2/7/84, 11/84). The inspectors reviewed the SHNPP Environmental Surveillance Reports for 1983 and 1984 (in draft) and noted that the licensee had accumu-lated two years worth of baseline data to determine the background radiological characteristics of the SHNPP locale. The inspectors discussed with the licensee the required preoperational Environmental Monitoring Report that was in preparation. The licensee stated that this report would be submitted to the NRC approximately six months prior to fuel load and that it would include the data from the 1983 and 1984 Environmental Surveillance Reports and environmental dose calculation The inspectors noted in the Robinson Environmental TLD Analysis Report for November 1984 and the Harris Environmental TLD Report the abnormal TLD readings. The licensee informed the inspectors that recent studies indicated that there was contaminated lead in the affected TLD badge The licensee contacted the vendor who confirmed this finding for a known series of badges. The licensee was still evaluating the anomalous data at the time of this inspectio The licensee's evaluation and resolution to the problem will be reviewed in subsequent inspection Within the areas examined no violations or deviations were identifie . Audits (80521)

The inspectors reviewed selected portions of the following Quality Assurance Audits (QAA) of the SHNPP radiological environmental monitoring program:

. QAA/130-5, 5/18/83

. QAA/130-6, 6/25/84

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Audit reports generally were summarized as " Findings" and " Concerns."

Both " Findings" and " Concerns" were referred to as nonconformance The inspectors noted that the corporate auditors used HEEC Environmental Laboratory procedures, the proposed RETS, Regulatory Guide 4.15, and applicable regulatory requirements to evaluate and determine acceptability of the R& CSS quality assurance program. The inspectors observed that the 1984 audit report identified several nonconformances and noted that adequate corrective actions had been taken. The licensee had an adequate tracking system to followup on " Findings" and " Concerns" and it was noted that management was involved in ensuring that timely corrective actions were performe Within the areas examined no violations or deviations were identifie . Quality Assurance Program (80521)

The inspectors reviewed the licensee's quality assurance program for the l Harris Energy and Environmental Center's (HEEC) Radiological Environmental Laboratory which was the corporate laboratory supporting the operational radiological environmental monitoring programs at the licensee's Brunswick and Robinson facilities and the preoperational radiological environmental monitoring program at the Shearon Harris facility. The inspectors used the guidance contained in Regulatory Guide 4.15 (Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment - February 1979) to evaluate the licensee's progra The licensee's organizational structure as it related to the management and operation of the monitoring programs, including quality assurance policy and functions, was well defined. The duties, responsibilities, and authorities of the positions within the organization were also defined and generally followed. The responsibilities for initiating, writing, reviewing, and approving Radiological and Chemical Support Section (RCSS) procedures were described to the inspector. Additionally, the managerial responsibilities for the review and evaluation of monitoring data and reports were described adequately in the procedure The qualifications of individuals involved in radiological monitoring and analysis activities were specified and documented. The indoctrination and orientation program for new technicians was described in procedure RC-ER-2 Laboratory technicians and analysts became qualified for selected radio-chemical and analytical procedures after a formalized training check-off list was completed. Although requalification of laboratory personnel was not as formalized as the initial training program, management was involved with periodic performance reviews by ensuring that each technician participated in the various EPA cross-check determinations. The licensee maintained records of the various analyses each technician performe The inspectors verified that written procedures were prepared, reviewed, and approved for activities involved in the radiological environmental monitoring program according to administrative control instruction The

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inspectors reviewed the procedures for sample collection, sample preparation and analysis, operation and calibration of radiological analytical equip-ment, use of radioactivity reference standards for quality control checks, '

and evaluation and reporting of dat The inspectors noted that the licensee had a formalized means to review annually the calibration / operation procedures of the various radiological analytical instruments to ensure compliance with program changes by administrative procedure RC-AD- I!owever, a similar mechanism did not exist for a periodic formal review of the noncalibration/ operation procedure The inspectors verified that the operating procedures provided for the documentation of laboratory and environmental sampling activities. The licensee had the ability to track and control various environmental samples by maintaining records for field collection of samples, radioactivity measurements of samples, and instrument background. Quality control records for laboratory counting systems included the results of measurements of radioactive check sources, calibration sources, backgrounds, and blank Daily QC logs were maintained and kept next to the appropriate laboratory counting system. The inspectors noted that generally all records were well organized and easily accessibl The inspectors noted that SHNPP procedures for environmental sample collection have been implemented. Personnel in the Environmental Unit of the Radiological and Chemical Support Section of the HEEC were responsible for SHNPP sample collection activitie The procedures specified sample types, sampling frequency, sample collection, and sample analyse Calibration and maintenance of automatic sampling equipment was the responsibility of RCSS Environmental Unit personne .

The inspectors noted Radiological Environmental Laboratory quality control program included the use of NBS traceable reference standards to determine counting efficiencies for specific radionuclides and to determine counting efficiency as a function of gamma ray energy for gamma-ray spectrometry systems. The licensee also conducted daily performance checks of laboratory counting systems and the results of these measurements were recorded in a log and plotted on a control chart. The licensee tracked the measurements to ensure the measurement value was within the "two-sigma" control limit The inspectors also noted that the licensee's QC program was involved with intralaboratory analyses and interlaboratory cross-check analyses. The interlaboratory program included participation in EPA's Environmental Radioactivity Laboratory Intercomparison studies Program and the licensee's

" Gamma Round-Robin" intercomparisons.