ML20133H434

Insp Repts 50-348/85-27 & 50-364/85-27 on 850617-20.No Violation or Deviation Noted.Major Areas Inspected:Qc & Confirmatory Measurements,Including Review of Lab QC Program,Qc Records & Logs & Results of Split Samples

ML20133H434
Person / Time
Site:	Farley
Issue date:	07/03/1985
From:	Kuzo G, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133H413	List: ML20133H410 ML20133H434
References
50-348-85-27, 50-364-85-27, NUDOCS 8508090351
Download: ML20133H434 (11)

See also: IR 05000348/1985027

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGloN il

y j 101 MARIETTA STREET,N.W.

• * ATLANTA, GEORGI A 30323

%.....+! JUL 0 51985

Report Nos.: 50-348/85-27 and 50-364/85-27

Licensee: Alabama Power Company

600 North 18th Street

Birmingham, AL 35291

Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8

Facility Name: Farley 1 and 2

Inspection Co ducted: June 17-20, 1985

Inspector: D}AM b o 3'~id CIl9f

G. E. Ku Signed

Da't{

Accompanying Pers el: J. D. Harris

Approved by: (- '

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D. H.l ontgomery, SeVtion Chief

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Date Signed

Emergency Preparedness and Radiological

Protection Branch

Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 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 Laboratory facilities.

Results: No violations or deviations were identified.

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8508090351 850705

PDR ADOCK 05000348

G PDR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• W. R. Bayne, Chemistry and Environmental Supervisor

• D. E. Grissette, Counting Room Supervisor

• M. W. Mitchell, Health Physics Supervisor

• R. D. Rogers, Computer Services Supervisor

• J. Higginbotham, Computer Services Supervisor

W. H. Ware, Supervisor, Safety Audit and Engineering Review

L. W. Drew, Environmental Technician

Other licensee employees contacted included technicians, and office

personnel.

NRC Resident Inspectors

W. H. Bradford

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on June 20, 1985, with

those persons indicated in Paragraph 1 above. Three inspector followup items

concerning gamma spectroscopy detector system No. 3 analyses

(Paragraph 8.b); gaseous effluent measurements (Paragraph 7.b); and Sr-89,

Sr-90 and Fe-55 analysis results (Paragraph 8.c) were discussed. Licensee

management representatives acknowledged the inspectors' comments and

expressed no contrary opinions. The licensee did not identi fy as pro-

prietary any of the material provided to or reviewed by the inspectors

during this inspection.

3. Licensee Action on Previous Enforcement Matters

(Closed) 50-348/78-02-01: discrepancy in surveillance dates between

meteorological station log and administrative record for meteorological

station. From discussions with cognizant licensee personnel and review of

environmental procedures and log books, the inspectors determined that

meteorological instrument surveillarces were being conducted in accordance

with station procedures.

4. Laboratory Quality Control Program (84725)

The inspectors reviewed selected portions of the Quality Assurance program

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with cognizant licensee representatives and determined that organizational

structure and program management had not changed since a previous inspection

(IE 50-348/83-08, 50-364/83-06). 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.

5. Audits (84725)

Technical Specification (TS) 6.5.2.8 states that audits shall be conducted

under the direction of the Alabama Power Company's Manager of Operations

Quality Assurance to determine conformance of facility operations to

provisions contained within Technical Specifications and applicable license

conditions at least once per 12 months. The inspectors reviewed the

following audit reports:

a. FNP 85/6(1) SAER Audit Environmental Monitoring, January - April 1985

b. FNP 84/22(21) SAER Audit Chemistry STPs, September - November 1984.

c. FNP 84/22(6) SAER Audit Chemistry, September - November 1984.

The inspectors noted that chemical and radiological measurements program

areas were audited against applicable sections of the Technical Specifi-

cations and approved plant operating procedures. The inspectors noted that

audits mainly addressed implementation of the chemical and radiochemical

measurements program. Licensee-identified areas of concern included

examples of failure to follow procedures and inconsistencies among various

procedures. All identified items were undergoing licensee action. The

inspectors discussed with cognizant licensee representatives the use of

Regulatory Guide 4.15 " Quality Assurance for Radiological Monitoring

Programs (Normal Operations) - Effluent Streams and the Environment" as

guidance for future audits of licensee and approved vendor programs. The

inspectors noted that aspects of this document will be included in future

chemistry audits. The inspectors discussed with cognizant licensee

personnel the additional review of cross check results to evaluate and/or

ensure the accuracy of analytical measurements conducted in the chemistry

program.

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, November 1972. The inspectors reviewed selected portions of

the following procedures:

(1) FNP-0-RCP-701 Schedule, Effluent Monitoring and Counting Room

Activities, February 26, 1985.

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(2) FNP-0-RCP-706 Gaseous Waste Release Program, March 28, 1985.

(3) FNP-0-RCP-716 Tritium Collection and Analysis Using Liquid

Scintillation Methodology, March 4, 1985.

(4) FNP-0-RCP-728 Operation and Calibration of 8180 Canberra Multi-

channel Analyzer System, April 12, 1985.

(5) FNP-0-RCP-762 Operation of the ADMS ND-66 Multichannel Analyzers.

(6) FNP-0-ENV-17 Meteorological Tower Support Activities.

t.

The inspectors noted that procedures had been reviewed and approved in

accordance with established procedures. Results of the procedure

review were discussed with cognizant licensee representatives as noted

in Paragraph 6.b.

b. The inspectors discussed with cognizant licensee representatives

effluent analysis Lower Limits of Detection (LLD) values required by TS

Table 4.11-2. From a discussion of effluent analysis procedures with

cognizant individuals and from a review of gaseous effluent release

reports the inspectors noted that effluent TS LLD values met TS

requirements.

No violations or deviations were identified.

7. Records (84725)

a. The inspectors reviewed selected portions of the following records:

(1) Liquid Scintillation Counter No. 002 Quality Control Logs for

April - June 1985 including:

1. Quench Correction Results

ii. Daily Standard Background Checks

111. Calibration Worksheet

(2) Internal Proportional Counter Nos. 002, 003, 006 and 007 Quality

Control Records for April - June 1985 including:

1. Alpha Analyses Background and Response Checks

ii. Alpha Calibration Worksheet

iii. Alpha / Beta Plateau Curve Analyses Data

iv. Alpha / Beta Plateau Curves

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(3) 1984 - 1985 Annual Gamma-ray spectroscopy system Nos. 1, 2, and 3

calibration data and efficiency graph for the following

geometries: 1 liter bottle, 25 ml bottle, face-loaded charcoal

cartridge, 14 ml vial, disk, 1 liter liquid marinelli, 1 liter gas

marinelli, 4 liter gas marinelli.

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(4) Ge(Li) Gamma-ray Spectroscopy Systems Nos. 1, 2, and 3 Quality

Control Records for January - September 1984, including:

1. Resolution Results

11. Performance Index - Peak Center, Efficiency and Resolution

Checks

111. Energy Channel Coefficients

(5) NBS Traceable Gamma Emitter Source Data

(6) Radiochemistry Incident Report - RCIR #1-85-010, Tritium Analysis

Calibration Investigation

(7) Radiochemistry -Incident Report - RCIR #1-85-012, Gas Standard

Cross Check

(8) 1984 Waste Gas Decay Tank Release Reports

(9) Chemistry Daily Quality Control Checks (January - June) for the

following analyses:

1. Boron

ii. pH

iii. Conductivity

iv. Hydrogen and Oxygen

(10) Calibration Curves for the following Chemical Analyses:

1. Chloride

11. Fluoride

(11) 1985 Reactor Coolant Chemistry Logs

(12) 1985 Environmental Laboratory Log Book

Results of the record review were discussed with cognizant licensee

representatives.

b. The inspectors discussed validation st.udies of gas geometries described

in Radiochemistry Incident Report No. 1-85-012. The inspectors noted

that validation was only conducted for the 12 cc vial geometry and

requested additional studies be conducted for the larger volume

geometries. The inspectors informed licensee representatives that this

area would be considered an inspector followup item and would be

reviewed during a subsequent inspection (50-348/85-27-01,

50-364/85-27-01).

c. The inspectors discussed with cognizant licensee representatives

quality control results for the gamma-ray spectroscopy systems. The

inspectors noted that data outside of specification limits were

properly evaluated by licensee personnel.

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d. The inspectors noted that a systematic cross check program for

radiological measurements had not been implemented. Licensee

representatives informed the inspectors that corporate auditors were

evaluating a potential vendor and that following satisfactory

completion of their audit a series of cross check samples would be

included in the radiochemistry cross check program. The inspectors

informed licensee representatives that this area would be evaluated

during a subsequent inspection.

No violations or deviations were identified.

8. Confirmatory Measurements (84725)

a. During the inspection, selected liquid and gaseous plant effluent

process streams were sampled and the resultant sample matrices 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. Sample types and counting geometries included

the following: liquid waste - 1 liter marinelli; and gaseous waste - 4

liter gas marinelli. Spiked particulate filter and charcoal cartridge

sample types were provided for analyses in lieu of licensee samples

which did not have sufficient levels 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 liquid, charcoal cartridge, and 4 liter gas marinelli samples. For

particulate filter analysis, results were in agreement for detectors

Nos. 1 and 2 and disagreement for detector No. 3. Results of

particulate filter gamma spectroscopy analyses are discussed in

Paragraph 8.b.

b. The inspectors discussed with licensee representatives the noted

differences for particulate filter analyses for gamma spectroscopy

system No. 3 relative to results for the NRC and licensee Nos. I and 2

systems. Licensee representatives noted that gamma spectroscopy system

No. 3 was not utilized for effluent measurements. The inspectors

reviewed current and previous efficiency calibration records for this

geometry and reanalyzed selected particulate spiked samples. No

significant problems in the efficiency calibrations were found and

results of the reanalyses again were in disagreement. Repeated

analyses of a spiked particulate filter geometry also resulted in

widely varied results. Licensee representatives stated that an

evaluation of the electronics and software for this gamma spectroscopy

system would be conducted. The inspectors informed licensee

representatives that the evaluation and resolution of the differences

among licensee gamma-ray detector systems would be considered an

inspector followup item and would be reviewed in a subsequent

inspection report (50-348/85-27-02, 50-364/85-27-02).

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c. The inspectors noted that the litensee had been provided with a

simulated liquid waste sample by the NRC contract laboratory and had

been requested to complete radiochemical analyses for H-3, Fe-55,

Sr-89, and Sr-90 concentrations. Comparison of licensee and NRC H-3

results were in agreement and are listed in Table 3 with the acceptance

criteria listed in Attachment 1. Licensee representatives stated that

development and verification of analytical procedures for Fe-55, Sr-89

and Sr-90 analyses had not been completed. The inspectors noted that

these items had been identified during a previous inspection

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(50-348/84-25, 50-364/84-25) and had not been completed in a timely

manner. Cognizant licensee representatives committed to completing the

analyses and reporting results to the NRC Region II Office by

October 31, 1985. The inspectors informed licensee representatives

that this item would be considered an inspector followup item and would

be reviewed during a subsequent inspection (50-348/85-27-03,

50-364/85-27-03).

No violations or deviations were identified.

9. Tour of the Chemistry and Counting Room Facilities (84725)

The inspectors toured the counting room facilities. The inspectors noted

adequate cleanliness and organization in the laboratory.

No violations or deviations were identified.

10. Inspector Followup Items (92701)

a. (Closed) 50-348, 364/83-01-01; Identify and correct source of

consistent pump motor failures in air particulate monitor at

environmental monitoring station #1218. Following discussion and

review of records with cognizant licensee personnel, the inspectors

noted that new pump motors had been installed at the environmental

stations. The licensee informed inspectors that the frequency of the

sampling pump motor failures had been reduced significantly,

b. (Closed) 50-348/83-08-02, 50-364/83-06-02; Use of mixed gas standard

for gas geometries. Licensee representatives have completed verifi-

cation of standard calibrations for the 14 ml gas vial. Validation of

the 100 cc gas bomb and 4 liter gas marinelli geometries are to be

i evaluated and tracked as the new inspector followup item detailed in

i Paragraph 7.b.

c. (Closed) 50-348, 364/84-25-01; evaluation of 4 liter marinelli gaseous

effluent measurements, Licensee representatives have evaluated and

changed sample parameters utilized in gaseous effluent measurements

conducted using the 4 liter gas marinelli.

d. (Closed) 50-348, 364/84-25-02; verification tests of H-3, Fe-55, Sr-89,

and Sr-90 analyses. Licensee results were adequate for the recently

I completed H-3 analysis. Licensee analyses for Fe-55, Sr-89, and Sr-90

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have not been completed. Licensee representatives have committed to

the reporting of results by October 31, 1985. This area will be

tracked as the new inspector followup item discussed in Paragraph 8.c.

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TABLE 1

RESULTS OF GAMMA SPECTROSCOPY CONFIRMATORY MEASUREMENTS AT FARLEY NUCLEAR PLANT - JUNE 17-21, 1985

SAMPLE ISOTOPE CONCENTRATION (uCi/cc1 RESOLUTION RATIO COMPARISON

Licensee NRC Licensee /NRC

(1) Liquid - WMT Co-60 7.14E-7 7.321.19E-7 6 0.98 Ag reement

(1 L Marinelli)

(1) Pa rticulate Fil ter Mn-54 4.97E-3 5.070.21E-3 24 0.98 Ag reement

(Disk) Co-60 2.14E-2 2.020.04E-2 50 1.06 Ag reemen t

Cs-137 1.42E-2 1.340.03E-2 45 1.06 Ag reement

Ce-144 1.13E-2 9.330.41E-3 23 1.21 Ag reement

(2) Particulate filter Mn-54 5.19E-3 5.070.21E-3 24 1.02 Ag reement

(Disk) Co-60 2.12E-2 2.020.04E-2 50 1.05 Ag reement

Cs-137 1.46E-2 1.340.03E-2 45 1.09 Ag reement

Ce-144 1.11E-2 9.330.41E-3 23 1.19 Ag reemen t

(3) Particulate Filter Mn-54 6.36E-3 5.070.21E-3 24 1.25 Ag reement

(Disk) Co-60 3.2SE-2 2.020.04E-2 50 1.61 D i sa g reemen t

Cs-137 1.82E-2 1.340.03E-2 45 1.36 D i sag reemen t

Ce-144 1.35E-2 9.330.41E-3 23 1.45 Disagreement

(1) Cha rcoa l Ca rt ridge Ba-133 4.77E-2 3.970.04E-2 99 1.20 Ag reemen t

( Face Load Ca rtridge)

(2) Cha rcoa l Ca rt r idge Ba-133 4.64E-2 3.970.04 E-2 99 1.17 Ag reemen t

( Face-Loaded Ca rtridge)

( 3 ) Cha rcoa l Ca rtridge Ba-133 4.97 E-2 3.970.04 E-2 99 1.25 Ag reement

( Face-Loaded Ca rtridge)

( 1 ) Ga s - WGDT Xe-133m 2.12 E-2 2.300.07 E-2 32 0.92 Ag reemen t

(4 L Marinelli) Xe-133 1.11 E-0 1.240.002E-0 620 0.90 Ag reemen t

Xe-135 1.96 E-1 1.930.02 E-1 96 1.02 Ag reement

ND Not Detected

NC Not Compa red

(1) Analyzed Using Gamma Spectroscopy System No. 1

(2) Analyzed Using Camma Spectroscopy System No. 2

(3) Analyzed Using Gamma Spectroscopy System No. 3

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TABLE 2

RESULTS OF H-3, Fe-55, Sr-89 AND Sr-90 CONFIRMATORY MEASUREMENTS AT FARLEY NUCLEAR PLANT - JUNE 17=20, 1985

SAMPLE ISOTOPE CONCENTRATION (uCi/cc) RESOLUTION RATIO COMPARISON

Licensee MRC Ligensee/NRC

( 1, 2 ) Liquid-Spiked H-3 2.64E-4 2.720.06E-4 45 0.97 Ag reement

Sample Fe-55 NC NC - -

S r-89 NC NC - -

Sr-90 NC NC - -

NC Not Compared

(1) Sample Received by License from NRC Contract Laboratory - March 1985

(2) Licenseee Representatives Committed to Providing NRC Region 11 with Results of

Fe-55, Sr-89 and Sr-90 Ana lyses by Octobe r 31, 1985

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Attachment 1

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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 judgement limits are variable in relation to the compari-

son of the NRC value to its associated 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 must be

considered acceptable as the resolution decreases.

RATIO = LICENSEE VALUE

NRC REFERENCE VALUE

Resolution Agreement

<4 0.4 - 2.5

4-7 0.5 - 2.0

8 - 15 0.6 - 1.66

16 - 50 0.75 - 1.33

51 - 200 0.80 - 1.25

>200 0.85 - 1.18

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