ML20133F480

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Insp Repts 50-266/85-11 & 50-301/85-11 on 850624-27,0703 & 18.Violation Noted:Failure to Make Evaluation (Radiation Exposure Survey) Per 10CFR20.201(b)
ML20133F480
Person / Time
Site: Point Beach  
Issue date: 07/31/1985
From: Holtzman R, Januska A, Schumacher M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133F444 List:
References
50-266-85-11, 50-301-85-11, NUDOCS 8508080299
Download: ML20133F480 (10)


See also: IR 05000266/1985011

Text

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a

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

,

Reports No. 50-266/85011(DRSS); 50-301/85011(DRSS)

?

Docket Nos. 50-266; 50-301

Licenses No. OPR-24; DPR-27

Licensee: Wisconsin Electric Power Company

231 West Michigan

Milwaukee, WI 53201

Facility Name:

Point Beach Nuclear Power Plant

Inspection At:

Point Beach Site, Two Creeks, WI

Inspection Conducted:

June 24-27 and July 3 and 18, 1985

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Inspectors:

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R. B. Holtzman

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Approved By:

M. C. Schumacher, Chief

Independent Measurements and

Date

Environmental Protect!on Section

Inspection Summary

Inspection on June 24-27 and July 3 and 18, 1985 (Reports No. 50-266/85011(DRSS);

50-301/8!.011(DRSS))

-Areas Inspected:

Routine, announced inspection of confirmatory measurements,

including sampling, laboratory quality control, and comparison of licensee

analyses with those of the Region III mobile laboratory.

The inspection

. involved 59 inspector-hours onsite by two NRC inspectors.

Results:

0ne apparent violation was identified (Severity Level IV), Supple-

'

ment IV violation - failure to make an evaluation as required by 10 CFR 20.201(b) - Section 5).

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DETAILS

1.

Persons Contacted

10. Fay, Vice President, Nuclear Power

1,3J. Zach, Manager, Point Beach Nuclear Plant

1R. Link, Superintendent, Engineering, Quality and Regulatory Services

1J. Reisenbuechler, Superintendent, Technical Services

1J. Knorr, Regulatory Engineer

1T. Fredricks, Radiochemist

1,3T. Slack, Specialist, Nuclear Chemistry

IF. Flentje, Supervisor, Staff Services

2E. Hinshaw, Specialist, Nuclear Chemistry

1R. Hague, NRC Senior Resident Inspector

1R. Leemon, NRC Resident Inspector

The inspectors also interviewed other chemistry personnel during the

course of the inspection.

1 Denotes those present at the plant exit interview on June 27, 1985.

2 Denotes those present during a telephone conversation on July 3,1985.

8 Denotes those present during a telephone conversation on July 18, 1985.

2.

Licensee Action on Previous Inspection Findings

(Closed) Open Item (50-266/84-14-04; 50-301/84-12-04): Analyze betas in

liquid and report results to Region III.

The results of the comparisons

are given in Table 1 and the comparison criteria in Attachinent 1.

The

analytical results for H-3, the only disagreement, were examined by the

licensee and by the NRC reference laboratory.

Neither could find an

error in their respective results.

In addition, the licensee made new

st'ndards using NBS traceable material, redistilled a remaining portion

of the sample and reran it using two different scintillation cocktails.

The initial results were reproduced.

This item is considered closed and

.the results of a split made during this inspection will be examined.

3.

Management Controls, Organization, Training, and Qualifications

The inspectors reviewed the licensee's management contrals for.

implementing the chemistry and radiochemistry program. This program

is supervised by the Radiochemist who reports to the Superintendent of

Technical Services, who in turn, reports to the General Superintendent -

Operations and Support.

The Radiochemist supervises the Radwaste

Supervisor, four Specialists - Nuclear, and the Chemistry Supervisor.

The training of the responsible person in Chemistry, the Radiochemist

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meets the qualifications of the position description required by

ANSI /N18.1-1971 (Technical Specifications (T/S) requirement).

The program

appears to have management support adequate to effectively meet plant

chemistry requirements.

Four Specialists - Nuclear, a Chemistry

Supervisor and ten radiochemical technicians (RCTs) provide support for

the chemistry / radiochemistry program.

The RCTs are permanently assigned to the chemistry laboratory.

They are

required to have a minimum training of two years of college; several have

four year degrees, and several have had nuclear Navy ELT experience.

No violations or deviations were identified.

4.

Chemistry Laboratory

The laboratory appeared to have sufficient room.

Although the laboratory

benches were somewhat crowded, the housekeeping was good and the space

was well maintained.

Because the laboratory is located in the

radiologically-controlled area of the plant, the laboratory workers are

required to use minimum protective clothing (head covering, laboratory

coat, and shoe covers).

This additional clothing is inconvenient and

produces some inefficiencies in laboratory usage, as noted by a licensee

representative.

The analytical equipment ranged from adequate to state-of-the-art, such

as an ion chromatograph and a recent model atomic absorption spectro-

photometer.

An extensive review of expiration date on chemical bottles

and reagent containers showed only one to have been past this date, and

this by only a few days.

The gamma-ray spectrometry system consisted of four shielded germanium

(Ge) detectors that ranged in size from 16 to 32% and were controlled by

a Canberra Series 90 multichannel analyzer-computer system.

The RCT

operating the equipment appeared to be knowledgeable about its operation.

Overall the laboratory appeared to be well-supported and wi.71

un.

No problems were identified in this area.

5.

Confirmatory Measurements

Seven samples (an air particulate filter, a charcoal filter, distillate

water, primary coolant, gas, a charcoal spike and a particulate spike)

were analyzed for gamma emitting-isotopes by the licensee and by the

inspectors.

All samples were counted by chemistry personnel on their

Detector 3 and, additionally, a particulate filter and a charcoal

adsorber were counted on Detector 1.

Results of the sample comparisons

are listed in Table 2.

3

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No air particulate activity was observed by the licensee or the NRC

on filter samples taken from the Unit 2 purge exhaust system and the

Unit 2 containment.

As no other sources of airborne particulate matter

were available, the licensee's air particulate standard was treated as a

sample and counted by the licensee and the NRC on each of two detectors

and by the inspectors.

Comparison of the results yielded agreements for

the nine isotopes in the standard.

A gas sample split contained only one isotope, which yielded an agreement.

A liquid waste distillate tank sample split yielded five agreements.

The licensee agreed to count a portion of this sample for gross beta,

H-3, Sr-89 and Sr-90 and to report the results to the Region (0 pen

Item 266/85011-01; 301/85011-01).

Comparisons made on a charcoal sample from Unit 2 containment gave

disagreement for iodine-131 and iodine-133 when counted on licensee

Detector 1; agreement was obtained when counted on licensee Detector

3.

The disagreement (wherein the licensee's value was nonconservative

by a factor of approximately 3) was verified in a recount by both

parties.

An NRC spiked standard also gave disagreements (four lines)

when counted on Detector 3.

The disagreement was traced to an error in the activity value entered

into the computer for the licensee prepared charcoal standard during its

use in calibration of two charcoal geometries on Detector 1.

The

inspectors confirmed that the charcoal cartridge calibrations of the

licensee's remaining three detectors were not affected.

The licensee

immediately amended the computer file to preclude use of the two

affected geometrics and stated that they would be recalibrated before

future use (0 pen Item 266/85011-02; 301/85011-02).

Detector 1 is used by the licensee for a full range of counting activities,

including analysis of charcoal cartridge samples for effluent monitoring

and for personnel radiation protection. This use with improperly cali-

brated charcoal cartridge geometry a violation of 10 CFR 20.201(b) which

requires the licensee to perform evaluations (surveys) necessary to

comply with the regulations of 10 CFR 20 (Violation 266/85011-03;

301/85011-03).

The question of possible violation of regulatory limits or of licensee

administrative limits owing to the use of this detector was not ascer-

tained during the onsite phase of this inspection.

The licensee was to

examine his records to identify dates and conditions of use by July 31,

1985. This is an unresolved item pending further NRC review of the

matter.

(Unresolved Item 266/85011-04; 301/85011-04).

6.

QA/QC of Analytical Measurements

QA weaknesses were a factor in the calibration problem identified in

Section 5.

The detector was new and being calibrated for the first

The

time, so there was no pravious efficiency curve for comparison.

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licensee's procedure did not require comparison of like geometrics

between detectors following calibration.

Such a comparison would have

caught the error in this case by revealing the inconsistency between

detectors.

Licensee representatives stated that appropriate comparisons

would be required in an amended procedure by July 15, 1985.

(0 pen Item

266/85011-05; 301/85011-05).

Another weakness is the absence of a program to periodically confirm the

basic calibrations through appropriate standards provided by a third

party such as an independent laboratory,

The licensee's weekly and

quarterly efficiency and energy checks are important in confirming con-

tinued system operability and stability but check only one geometry and

would not be expected to uncover an error of this type in the basic

calibrations.

The recently initiated cross check with the Kewaunee plant

will provide a useful independent comparison but is, at present, limited

to a single geometry.

Yet another weakness involved the absence of an activity certificate for

the licensee prepared charcoal standard.

When calibrating Detector 1,

the charcoal activity was obtained from an activity certificate applicable

to the 25 m1 solution from which aliquots were taken to spike the charcoal.

This certificate listed not only the activity in the entire 25 mi

solution but also the activities that would be transferred in various

sized aliquots.

The wrong data was chosen when Detector 1 was calibrated

and management review did not identify the error.

The importance of strengthening counting room QA was discussed with

licensee management by telephone on July 18, 1985.

The licensee does have a program to provide blind samples for non-

radiological analysis by all plant RCTs.

Samples are prepared by the

Chemistry Laboratory supervisor from standards provided by the licensee's

corporate office.

The results reviewed by the inspector indicated

satisfactory performance.

A similar program for radiological analyses

would be useful.

No violations were identified.

7.

Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, items of noncompli-

ance or deviations.

An unresolved item disclosed during the inspection

is discussed in Section 5.

8.

Exit Interview-

The inspecticn findings were discussed with licensee representatives

(Section 1) at the close of the inspection on June 27, 1985.

The

inspector identified an apparent unresolved item concerning calibration

of licensee's germanium Detector No. 1.

Licensee representatives agreed

to recalibrate Detector 1 charcoal adsorber geometries before further

5

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use, amend calibration procedures to assure consistency between

detectors, and to examine use records for Detector 1 for possible

regulatory violations.

An additional telephone discussion concerning a previously open item was

-held on July 3, 1985.

On July 18, 1985, the licensee was informed by telephone that use of

Detector 1 in analyzing airborne exposure samr;Ies and airborne effluent

samples was an apparent violation of 10 CFR 20.201(b).

The inspectors discussed the review and evaluation of charcoal samples

-

counted on Detector 1 as an unresolved item.

- During the exit interview, the inspectors discussed the likely infor-

mational content of the inspection report with regard to documents or

processes reviewed by the inspectors during the inspection.

Licensee

representatives did not identify any such documents or processes as

proprietary.

' Attachments:

1.

Table 1, Confirmatory

Measurements Program

Results - 3rd Quarter

1984

2.

Table 2, Confirmatory

Measurements Program

Results - 2nd Quarter

1985

3.

Attachment 1, Criteria

for Comparing Analytical

,

Measurements

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TABLE 1

U S NUCLEAR REGULATORY COMMISSION

OFFICE OF IN5F'ECTION AND ENFORCEMENT

CONFIRMATORY MEASUREMENTS PROGRAM

FACILITY: CALLAWAY

FOR THE 2 OUARTER OF 1985


NRC--

=


L I CENSEE--

---LICENSEE:NRC

SAMPLE

ISOTOFE RESULT

ERROR

RESULT

ERROR

RATIO

RES

T

L WASTE

H-3

2.9E-03

4.OE-05

3.1E-03

0.OE-01

1.1E 00

7.2E 01

A

G BETA

4.0E-07

8.0E-08

4.8E-07

0.0E-01

1.2E 00

5.0E 00

A

SR-89

1.SE-09

7.OE-09

1.5E-08

0.OE-01

1.OE 01

2.1E-01

N

SR-90

0.OE-01

4.OE-09

2.IE-08

0.OE-01

0.OE-01

0.OE-01

N

T TEST RESULTS:

A=AGPEEMENT

D=DISAGREEMEllT

  • = CRITERIA RELAVED

N=fl0 COMPARISON

.

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_ _ _ _ _ _ - _ _ _ - , _ _ _ _ _ _ _ _

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1

TABLE 2

U S NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

CONFIRMATORY MEASUREMENTS PROGRAM

FACILITY: POINT BEACH

FOR THE 2 QUARTER OF 1985


NRC

---


LICENSEE-

LICENSEE:NRC-

=

SAMPLE

ISOTOPE RESULT

ERROR

RESULT

ERROR

RATIO

RES

T

L WASTE

CO-58

5.3E-06

3.1E-07

5.6E-06

2.1E-07

1.OE 00

1.7E 01

A

CO-60

2.2E-06

2.5E-07

1.8E-06

1.5E-07

8.2E-01

8.9E 00

A

DET 3

SB-124

3.OE-06

2.1E-07

2.8E-06

1.7E-07

9.5E-01

1.4E 01

A

CS-134

1.2E-06

1.4E-07

1.2E-06

1.2E-07

1.1E 00

8.3E 00

A

CS-137

2.3E-06

2.5E-07

2.8E-06

1.7E-07

1.2E 00

9.4E 00

A

C FILTER 1-131

2.0E-11

1.5E-12

6.7E-12

2.6E-13

3.4E-01

1.3E 01

D

I-133

1.6E-11

2.5E-12

6.3E-12

3.2E-13

3.9E-01

6.5E 00

D

DET 1

OFF GAS

KR-85

6.0E-03

2.5E-04

6.3E-03

1.0E-03

1.0E 00

2.4E 01

A

DET 3

F SPIKED CO-57

2.7E-03

7.OE-05

2.8E-03

4.5E-05

1.OE 00

3.9E 01

A

DET 1

CO-60

1.9E-02

4.6E-04

1.8E-02

2.7E-04

9.6E-01

4.2E 01

A

HG-203

1.7E-03

1.1E-04

1.6E-03

5.OE-05

9.4E-01

1.6E 01

A

SR-85

5.4E-03

1.8E-04

5.1E-03

9.3E-05

9.5E-01

3.0E 01

A

Y-88

1.5E-02

4.6E-04

1.5E-02

2.1E-04

9.5E-01

3.4E 01

A

CD-109

8.1E-02

1.8E-03

8.1E-02

1.4E-03

1.0E 00

4.4E 01

A

SN-113

8.7E-03

2.4E-04

7.8E-03

1.2E-04

9.OE-01

3.6E 01

A

CS-137

1.9E-02

3.GE-04

1.8E-02

2.1E-04

9.6E-01

4.8E 01

A

CE-139

2.6E-03

8.4E-05

2.6E-03

4.8E-05

1.OE 00

3.1E 01

A

C SPIKED CO-57

7.7E-04

4.7E-05

2.9E-04

7.9E-06

3.8E-01

1.6E 01

D

DET 1

CO-60

1.6E-02

3.6E-04

6.4E-03

8.1E-05

4.OE-01

4.5E 01

D

CD-109

7.8E-02

1.7E-03

3.6E-02

4.8E-04

4.6E-01

4.5E 01

D

CS-137

1.8E-02

3.2E-04

7.8E-03

7.3E-05

4.4E-01

5.5E 01

D

C FILTER I-1.21

2.0E-11

1.5E-12

2.0E-11

7.4E-13

1.0E 00

1.3E 01

A

DET 3

I~133

1.6E-11

2.5E-12

1.9E-11

1.2E-12

1.2E 00

6.5E 00

A

F SPIKED CO-57

2.7E-03

7.0E-05

2.8E-03

3.4E-05

1.0E 00

3.9E 01

A

DET 3

CO-60

1.9E-02

4.6E-04

1.9E-02

1.9E-04

1.OE 00

4.2E 01

A

HG-203

1.7E-03

1.1E-04

1.7E-03

3.6E-05

1.0E 00

1.6E 01

A

T TEST RESULTS:

A= AGREEMENT

D= DISAGREEMENT

  • = CRITERIA RELAXED

N=NO COMPARISON

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TABLE 2

U S NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

CONFIRMATORY MEASUREMENTS PROGRAM

FACILITY: POINT BEACH

FOR THE 2 QUARTER OF 1985

NRC-

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LICENSEE----

---LICENSEE:NRC

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---

SAMPLE

ISOTOPE RESULT

ERROR

RESULT

ERROR

RATIO

RES

T

F SPIKED SR-85

5.4E-03

1.8E-04

5.2E-03

6.4E-05

9.6E-01

3.0E 01

A

Y-88

1.5E-02

4.6E-04

1.5E-02

1.5E-04

9.7E-01

3.4E 01

A

3 Cont'd

CD-109

8.1E-02

1.8E-03

9.OE-02

1.1E-03

1.1E 00

4.4E 01

A

SN-113

8.7E-03

2.4E-04

8.2E-03

8.5E-05

9.4E-01

3.6E 01

A

CS-137

1.9E-02

3.8E-04

1.8E-02

1.5E-04

9.7E-01

4.8E 01

A

CE-139

2.6E-03

8.4E-05

2.9E-03

4.6E-05

1.1E 00

3.1E 01

A

T TEST RESULTS:

A= AGREEMENT

D= DISAGREEMENT

  • = CRITERIA RELAXED

N=NO COMPARISON

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_ ATTACHMENT 1

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CRITERIA FOR COMPARING ANALYTICAL F.EASUREMENTS

.

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.

In these criteria, the judgment limits are variable in relation to the com-

parison of the NRC's value to its associated one sigma uncertainty. As that

ratio, referred to in this program as " Resolution", increases, the acceptability

of a licensee's measurement should be more selective. Conversely, poorer

agreement should be considered acceptable as the resolution decreases. The

values in the ratio criteria may be rounded to fewer significant figures to

maintain statistical consistency with the number of significant figures reported

by the NRC Reference Laboratory, unless such rounding will result in a narrowed

category of acceptance.

RESOLUTION

RATIO = LICENSEE VALUE/NRC REFERENCE VALUE

Agreement

.

<3

No Comparison

-

13 and

<4

0.4 - 2.5

2_4 and

<8

0.5 - 2.0

.28 and

<16

0.6

1.67

-

2_16 and

(51

0.75 - 1.33

251 and

<200

0.80 -

1.25

1200

0.85 -

1.18

L

Some discrepancies may result from the use of different equipment, techniques,

and for some specific nuclides. These may be factored into the acceptance

criteria and identified on the data sheet.

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