ML20133H388
| ML20133H388 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/07/1985 |
| From: | Dan Collins, Cowgill C, Kottan J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20133H385 | List: |
| References | |
| 50-320-85-20, NUDOCS 8510170147 | |
| Download: ML20133H388 (5) | |
See also: IR 05000320/1985020
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report No.
50-320/85-20
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Docket No.
50-320
License No. OpR-73
Priority
Category
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Licensee: Gpu Nuclear Corporation
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P. O. Box 480
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Middletown, Pennsylvania
17057
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Facility Name: Three Mile Island - Unit _2
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Inspection At: Middletown, Pennsylvania
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Inspection Conducted: September 30 - October 2,1985
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Inspectors:
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J. J. Kottan,ladiation Laboratory Specialist
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/ W J- Co ins, Radiation Specialist
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Approved by:
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TMI2 Project Section
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Approved by:
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W. J. Pasciak, Chief, WR'[adio
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Protection Section
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Inspection Summary:
Inspection conducted on September 30-October 2, 1985
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Areas Inspected:
Special, unannounced safety inspection conducted to evaluate
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the Itcensee's method in determining Sr-90 by beta scintillation spectroscopy.
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The inspection involved 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> by two inspectors (one regionally based),
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Results: Two potential violations were identified. The licensee failed to
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properly indicate the Sr-90 content on radioactive material shipping papers and
in one case improperly classified waste as a result.
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DETAILS
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1.0 Individuals Contacted
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Principal Licensee Employees
- F. Standerfer, Director TMI-2
- J. Hildebrand, Radiological Controls Director, TMI-2
- R. Rogan, Ofrector, Licensing and Nuclear Services
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- S. Levin, Site Operations Director, TMI-2
- J. Byrne, Manager TMI-2 Licensing
"L. Edwards, Operational Quality Assurance Monitor
- K. Harner, Chemistry Manager, TMI-2
- W. Heysek, Audit Supervisor, TMI-2
- K. Hofstetter, Radiochemistry Engineering Supervisor, TMI-2
- G. Tomb, Senior Media Representative
- R. Wells, Licensing Engineer. TMI-2
M. Slobodien, Manager Radiological Engineering, TMI-2
W. County, QA Auditor
A. Miller, Assistant Plant Manager, TMI-2
W. Craft, Radiological Controls Field Operations Manager, TMI-2
P. Cooper, Chemistry Supervisor Field Services, TMI-2
D. Mistelske, Chemistry Lab Foreman, TMI-2
U.S. Nuclear Regulatory Commission
- W. Travers, Deputy Director, TMIPO
- R. Bellamy, Chief, Radiological Protection Branch, Division of Radiation
Safety and Safeguards, Region I
- C. Cowgill, Chief, TMI-2 Resident Office Section
- J. Bell, Senior Radiation Specialist, TMIPO
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- R. Cook, Senior Resident Inspector, TMI-2
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- Denotes those present at the exit interview.
2.0 Purpose
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This special inspection was conducted to evaluate the September 20, 1985
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licensee discovery of an error in determining strontium 90 (Sr-90) in
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radioactive material at TMI-2.
The error resulted in Sr-90 sample results
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being underreported by a factor of two for samples analyzed on the TMI-2
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chemistry department beta spectrometer.
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3.0 Evaluation
A.
Instrumentation
The licensee uses a beta spectrometer in order to quantify Sr-90 in
various samples. The spectometer consists of a europium activated
calcium fluoride (CaF (Eu)) detector coupled to the appropriate
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electronics (bias supply, amplifier / discriminator, timer, and scaler)
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so that the system can be used for pulse height discrimination.
The
2.2 MeV (endpoint energy) beta particle of Y-90 is significantly
above the beta particle energies of the other radioactive material
encountered at TMI-2.
(Cs-137 for example, end point energy = 0.5
MeV.) By setting up the system to count only those pulses which are
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equivalent to those from the Y-90, the system is effectively able to
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discriminate against the pulses from lower energy beta particles
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because the output pulses from the detector are proportional to the
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energy deposited in the detector.
The Y-90 is in secular equilibrium
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with the Sr-90, therefore, the Y-90 radioactivity is equal to the
Sr-90 radioactivity. A liquid Sr-90, Y-90 standard, traceable to the
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National Bureau of Standards, is used for calt5 rating the beta spec-
trometer. The standard is diluted and appropriate standard source
geometries are then made which duplicate the counting geometries of
actual samples.
B.
Laboratory QA/QC Program
The licensee's quality control program for the beta spectometer
consists of daily background and standard counts on the system.
The
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daily background and source check results are plotted on monthly
control charts.
Specific actions are required when results exceed
the warning and control limits.
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C.
Sample Types Analyzed
Samples analyzed with this system aret
filter papers (such as
general and personnel air samples), wipe test papers (contamination
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wipes), small granular specimens (such as soil, sand, and scabbling
dust), and small solid samples (such as paint chips and metal
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flakes). No gaseous samples, liqeid samples, or demineralizer resin
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samples are analyzed using the beta spectrometer.
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Records Affected
The records affected are those which record individual exposures to
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airborne Sr-90 (MPC-hours) and those which record radioactive waste
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shipping and classification data. When individuals are exposed to
airborne radioactive materials, regulations require that air samples
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be taken to determine the concentration of radioactive materials and
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how long the individual was exposed.
Protection factors are allowed
for respiratory protective equipment. When combined, these factors
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yield Maximum Permissable Concentration in air hours (MPC,-hours).
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The licensee is required to track and assign results to the indivi-
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dual's dostmetry rocords.
If limits are exceeded, there are required
actions. Where the quantity is very small, specific isotopic MPC-
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hours are not required to be kept.
The licensee's preliminary in-
vestigation indicates that no regulatory limit has been approached.
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Examinations of exposure calculations are in process to review the
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accuracy of the individual records. The licensee plans to correct
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significant error identified, if any.
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The beta spectrometer was also used to analyze samples of radioactive
waste shipments.
The results of the analysis were used to quantify
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the amount of Sr-90 in particular radioactive waste shipments.
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Regulations require that radioactive waste for burial must be clas-
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sified for specific isotopes, including Sr-90.
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4.0 Documents Reviewed
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The inspector reviewed licensee records and procedures related to
calibration and operation of the beta spectrometer as well as records
affected by the inaccurate Sr-90 analyses.
The procedure for operation
of the beta spectrometer, including the original issue and intermediate
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revisions, were reviewed along with laboratory QA/QC procedures.
Records
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reviewed included:
selected laboratory QA/QC data, source calibration
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data, actual sample data, computer program listings, and selected
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shipping manifests. The data and records reviewed covered the period
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1981 through 1985.
5.0 Findings
The licensee's Sr-90 measurements made using the beta spectrometer were
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in error (low) by a factor of two.
The data were in error from July
1981, when the instrument was purchased from an onsite contractor who was
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operating the beta spectrometer, until the error was discovered by the
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licensee on September 20, 1985.
The error was caused because the
licensee assumed the data used to calibrate the counting system would be
the total disintegration rate of Sr-90, Y-90 in equilibrium. The
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standard source disintegration rate was multipted by one-half to correct
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the total disintegration rate to the Y-90 disintegration rate. However,
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only the Sr-90 (or Y-90) disintegration rate of the source was used in
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the calibration calculations. This resulted in an efficiency which was
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too large by a factor of two.
This error persisted for a period of four years for several reasons.
(1)
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The licensee used a computer program written for the chemistry laboratory
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desk top computer to calculate the sample and standard results.
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computer program contained the factor of one-half and the program had not
been documented or verified to reflect the calculations required by the
procedure.
(2) The licensee had no interlaboratory QA/QC program in which
spiked samples from another laboratory were analyzed or actual samples
were sent to another laboratory for analysis af ter counting on the beta
spectrometer for intercomparison of results,
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As a result of this inspection it appears that two apparent violations
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were identified.
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A.
10 CFR 20.311 (b) requires each shipment to a licensed land disposal
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facility to be accompanied by a manifest which indicates the
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radionuclide quantity.
Further,10 CFR 20.311 (d) (1) requires a
licensee to prepare wastes so that the waste is classified according
to 10 CFR 61.55.
Contrary to the above, (1) during the period January 1,1984 through
September 20, 1985, radioactive waste shipments to the U.S. Ecology
burial site were accompanied by a manifest which indicated a
strontium-90 quantity which was non-conservative in that the listed
quantity was one-half the true activity of strontium-90. (2) On
March 29, 1985, waste shipment RS-85-025-II was sent for burial to
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the U.S. Ecology licensed disposal site at Hanford, Washington.
Barrel 85-D-II-39 was incorrectly classified in that the manifest
indicated Class A unstable waste. Barrel 85-0-II-39 contained
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12.22 mC1 of Sr-90 or 0.058 Ci/m , exceeding the Class A waste Itmit
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for Sr-90 of 0.04 C1/m .
B.
10 CFR 71.5(a) requires each licensee who delivers licensed material
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to a carrier for transport to comply with the requirements of the
regulation appropriate to the mode of transport of the Department of
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Transportation in 49 CFR 170 through 189.
49 CFR 172.203(d)(111)
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requires the activity contained in the shipment to be included in
the shipping papers.
Contrary to the above, shipping papers accompanying shipment No.
RS-85-025-II on March 29, 1985, incorrectly listed the Sr-90
activity and, therefore, the total activity of the shipment.
6.0 Exit Interview
The inspector met with the licensee representatives denoted in paragraph 1
at the conclusion of the inspection.
The inspector summarized the pur-
pose, scope, and findings of the inspection. At no time during the in-
spection did the inspector provide written material to the licensee.
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