ML20138R403
| ML20138R403 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 12/24/1985 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8512310257 | |
| Download: ML20138R403 (2) | |
See also: IR 05000320/1985020
Text
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DEC 2 41985
,
Docket No. 50-320
GPU Nuclear Corporation
- ATTN
- Mr. F. Standerfer
i Director of TMI-2
!
P. O. Box 480
Middletown, Pennsylvania 17057
Gentlemen:
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Subject: Inspection No. 50-320/85-20
4 j -This refers to your letter dated November 22, 1985, in response to our letter
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dated October 7, 1985.
Thank you for informing us of the corrective and preventive actions documented
l in your letter. These actions will be examined during a future inspection of
your licensed program,
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Your cooperation with us is appreciated.
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Sincerely,
- Original Signed Byr
i
h g/jpyt
i homas T. Martin, Director i Division of Radiation Safety
and Safeguards
cc:
-T. F. Demitt, Deputy Director, TMI-2
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R. E. Rogan,- Licensing and Nuclear Safety Director
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J. J. Byrne, Manager, TMI-2 Licensing
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W. H. Linton, Manager, Recovery Programs
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J.-B. Lieberman, Esquire
A. Miller, Manager, Plant Operations
G. F. Trowbridge, Esquire
S. Levin, TMI-2 Site Operations Director
PublicDocumentRoom(PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
_ Commonwealth of Pennsylvania
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a ,
OFFICIAL RECORD COPY f
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GPU Nuclear Corporation 2 j
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bec:
Region I Docket Room (with concurrences)
W. D. Travers, Director, TMI-2 Cleanup Project Directorate
DRP Section Chief
Michael Masnik, PM, TMI-2
R SS R RSS RI S R SS
Kottan/mmb Pa ciak Bellamy Mar
12/19/85 12/li85 12/U/85
12/l/85
0FFICIAL RECORD COPY
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GPU Nuclear Corporation
P ,:, Nuclear ;;',,o rar8o
Middletown. Pennsylvania 17057-0191
717 944 7621
TELEX 84 2386
Writer's Direct Dial Number:
(717) 948-8461
4410-85-L-0236
Document ID 0362A
November 22. 1985
Office of Inspection and Enforcement
Attn: Dr. T. E. Murley
Regional Administrator
US Nuclear Regulatory Commission
Region I
631 Park Avenue
King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73
Docket No. 50-320
Inspection Report 85-20
During the time period of September 30, 1985, through Octcber 2, 1985, the NRC
conducted a special inspection into the circumstances associated with an
inaccuracy in strontium-90 analyses being performed at TMI-2. The results of
this special inspection led to the following correspondence from the NRC:
1. Confirmatory Action Letter 85-16, dated October 2, 1985.
2. Inspection Report 85-20, dated October 7, 1985.
3. Notice of Violation (Inspection Report 85-20), dated November 5, 1985.
The attachments to this letter provide responses to the NRC requests for
information as contained in items (1) and (3) above.
;
Sincerely,
oc c -
d
7 F. R. Standerfer
Vice President /0irector. TMI-2
FRS/JCA/emi
Attachment
cc: Director - Olvision of Reactor Safety & Safeguards, T. T. Martin f
Acting Director - TMI Program Office, Dr. W. D. Travers f(hgk (
<r
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
_. . ._ _ _ . _ _ . . _ _ . _ _ _ . . . _ . _ - _ - _ - _ __ _ _ . _._ _ _ _ .___
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. ATTACHMENT I
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(4410-85-L-0236)
1
Response to Notice of Violation .
The.NRC Notice of Violation, dated November 5, 1985, identified three (3)
l ltems of non-compliance. These items are listed below along with the GPU
- Nuclear response.
I
VIOLATIONS
1. 10 CFR 20.311(b) requires that each shipment of radioactive waste to a
! licensed land disposal facility be accompanied by a manifest which
- indicates, in part, the identity and quantity of the radionuclide
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! Contrary to the above, between January 1, 1984, and September 20, 1985, k
several radioactive waste snipments made to the U.S. Ecology licensed
i land disposal facility in Hanford, Washington were accompanied by [
manifests which did not indicate the correct strontium-90 content in '
accordance with 10 CFR 20.311(b) in that the quantity was understated in i
each case by a factor of two. E
i j 2. 10 CFR 20.311(d)(1) requires that wastes be prepared such that the waste i is classified in accordance with 10 CFR 61.55. 4
10 CFR 61.55(A)(4)(ii), and Table 2 referenced therein, requires in part, , that any radioactive waste that has a strontium-90 content in excess of
- .04 C1/m1 3 but less than 150 Cl/m13 be classified as Class B waste as
defined in 10 CFR 61.55(a)(2)(11). If the strontium-90 content is less ; than .04 Cl/m1 3, the waste is classified as Class A waste.,
i
Contrary to the above, on March 29, 1985, radioactive waste shipment , j RS-85-025-11 was sent to the U.S. Ecology licensed land disposal
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facility, and Barrel 85-0-11-39, containing .06 Cl/ml 3 of strontium-90,
was incorrectly classified as Class A waste rather than Class B waste.
'
3. 10 CFR 71.5(a) requires each licensee who delivers licensed material to a
, carrier for transport to comply with the requirements of the regulations '
appropriate to the mode of transport of the Department of Transportation
, in 49 CFR 170 through 189. 49 CFR 172.203(d)(lii) requires that the
radioactive activity contained in the shipment to be included on the
shipping papers.
Contrary to the above, between January 1, 1985, several shipments of
] material (including waste and samples) from the facility were accompanied ! by shipping papers which did not indicate the correct strontium-90 3 activity in accordance with 49 CFR 172.203(d)(lit) in that the activity ! was understated by a factor of two. ) 1
These constitute a Severity Level IV problem (10 CFR 2, Supplement V). i
5 4
GPU Nuclear Response
i GPU Nuclear uses a beta spectrometer at TMI-2 to quantify strontium-90 (Sr-90) j in various samples. The beta spectrometer makes use of the fact that $ J i
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ATTACHMENT 1
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l Yttrium-90 (Y-90) is in secular equilibrium with the Sr-90 and that the beta
particle associated with Y-90 is significantly greater in energy than the beta
'
particles of most other radioactive material encountered at THI-2 (the maximum
!.- beta energy of Y-90 is 2.2 MeV). By adjusting the system to count only those
pulses which exceed the I37 C s beta energy, the beta spectrometer is able to
'
discriminate against the pulses associated with lower energy beta emitters.
An NBS 11guld Sr-90 (Y-90) standard is transferred to a filter paper and then
is used to calibrate the beta spectrometer.
The three (3) violations identified were the result of the Sr-90 measurements
being in error (low) by a factor of two. This was caused by the failure, on
,the part of GPU Nuclear personnel, to use the total equilibrium beta
disintegration rate for Sr-90 plus Y-90 in their calculations. Instead, the
Sr-90 (or Y-90) disintegration rate alone was used in the calculations. This
+
resulted in the factor of two error.
Upon discovery of this error, GPU Nuclear took the following actions: 1) the
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NRC, the State of Washington, U.S. Ecology at Richland and the State of
Pennsylvania were notified of the Sr-90 miscalculations; 2) the procedures for
strontium analyses were reviewed to ensure that they were clear and accurate;
; and 3) changes to these procedures were made where appropriate. GPU Nuclear
. reviewed all the documentation for radioactive waste shipments containing j Sr-90 for the period of July 1981 to the present. These radioactive waste
i shipments were reviewed from July 1981 to the present to ensure the proper
4
transportation classification (49 CFR 173.400) and also from December 27, 1983
to the present for the proper waste classification (per 10 CFR 20.311). These ,
, reviews revealed that there were no instances of improper transportation
classification and two (2) instances of improper waste classification. The
l two (2) incorrect waste classifications were: i j 1. 1985 shipment RS-85-025II, Container 85-D-II-39 (SDS Trash)
i 2. 1984 shipment RS-84-033II, Container 83-D-II-128 (Non-compactible Trash)
1 ! These containers were classified as Class "A" waste while, in fact, they 4
should have been classified as Class "B" waste.
1 '
{ GPU Nuclear will notify the State of Washington and U.S. Ecology concerning
' the misclassification of two (2) specific containers by December 6, 1985.
With this notification, full compliance will be achieved.
1
Other actions taken by GPU Nuc. lear as a result of this event are discussed in 1 Attachment 2. l
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. ATTACHMENT 2
j , (4410-85-L-0236) , Response to Confirmatory Action Letter I '
The NRC issued Confirmatory Action Letter (CAL) 85-16 on October 2, 1985.
This letter documented those actions which GPU Nuclear committed to during the ,
, exit meeting for Special Inspection 85-20 conducted at TMI on October 2,
i 1985. The actions identified in CAL 85-16 are listed below along with the GPU
'
Nuclear response to each item. ,
Y
A. Assure that all procedures used for strontium analyses are clear and
, accurate. This action is to be taken by October 11. 1985. i
GPU Nuclear Response
l This action was completed as previously reported to the Director of the
TMIPO via GPUN memorandum 4410-85-M-0807, dated October 8. 1985.
J
1
1
B. Provide the Director, TMIPO with the documented results of your
- assessment of the impact of the inaccurate Sr-90 analyses.
j GPU Nuclear Response l GPU Nuclear has reviewed the following areas to determine the impact of
i the inaccurate Sr-90 analysis. They are:
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o Radioactive Shipment
i o SER's, TER's, and SD's j o Effluent Monitoring Program
o Personnel Airborne Exposure
The results of the assessment of these areas appear below:
o Radioactive Shipment: GPU Nuclear reviewed all radioactive
a' shipments from July 1981 to the present which were potentially
affected by the Sr-90 inaccuracles. For those shipments that were
subject to 49 CFR 173 requirements only (pre December 27, 1983), a
, recalculation of the curie estimates was performed to ensure that
the proper transportation classification had been used. For those
shipments that were subject to 49 CFR 173 and 10 CFR 20.311
'
requirements (post. December 27, 1983), a recalculation of the curie
estimates was performed to ensure that the proper waste
classification /and transportation classification had been used. As
a '
a result of th'is effort, it was determined that two (2) containers
had been misclassified as Class "A" waste. In no case was there an
error in the transportation classification. The twc (2) containers
j which were misclassified as Class "A" waste are:
{ l. 1985 shipment RS-85-025II, Container 85-D-II-39 (SDS Trash)
2. 1984 shipment RS-84-033II, Container 83-0-11-128
(Non-compactible Trash) '
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ATTACHMENT 2
-
(4410-85-L-0236)
GPU Nuclear will notify the State of Washington and U.S. Ecology at
Richland by December 6, 1985, of these misclassifications.
o SER's, TER's, and SD's: GPU Nuclear has reviewed all appropriate
f
Safety Evaluation Reports (SER's), Technical Evaluation Reports '
. (TER's) and Recovery System Descriptions (SD's) to determine the ! potential impact of the inaccurate Sr-90 analysis had on their
analyses or conclusions. As a result of the review, the following
i has been determined:
1. No licensing safety basis provided in the documents reviewed
,
is currently being exceeded due to the incorrect Sr-90
j analysis. i
i 2. Those Recovery Systems Descriptions which were reviewed were
j not affected by the incorrect Sr-90 analysis. I 3. The impact of the incorrect Sr-90 analysis on all licensing i
documents reviewed is minor in nature and effect. Even if
. postulated Sr-90 releases were increased by a factor of two ", (2), the_following would be true: a) Offsite doses due to
normal operations would not exceed limits specified in
;
Appendix 8 to the THI-2 Technical Specifications, and b)
] Offsite doses due to hypothetical accidents would not exceed a
small fraction of 10 CFR 100 limits.
, ,
4. The incorrect Sr-90 analysis does not change the conclusion in
I
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any licensing document as to the acceptability of the
activities with respect to posing. acceptable risk to the
health and safety of the public and TMI workers.
i
, o Effluent Monitoring: Liquid.eff_luent sample results are not ,
affected since such samples are sent to offsite laboratories
j where wet chemical analytical techniques are used to assess 3
the strontium-90 content. Thus, the THI-2 beta spectrometer
j procedures are not used in assessing these samples. i
l Airborne particulate filters from the station vent are counted '
t
using THI-2 beta spectrometry procedures. A review of the
i sample results since July of 1981 has identified only two
filters which had strontium-90 concentrations above the lower
i limit of detection (LLD). Correcting the strontium-90 results 4
had no statistically significant effect on the levels
previously reported in the THI-2 Semi-annua! Effluent
l Monitoring Report. 1 . 1-
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. , ATTACHMENT 2
.. (4410-85-L-0236)
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Breathing zone air samples
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o Personnel Airborne Exposure:
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(BZA's) which are analyzed with the beta spectrometer
equipment are impacted by the strontium-90 analytical error.
However, because of the extremely low airborne levels received
by THI-2 personnel, the impact is minimal. Corrected BZA
sample results will not result in any personnel exposures to
airborne radioactivity exceeding regulatory limits.
Furthermore, it is expected that, with few exceptions, the
. corrected levels will involve airborne exposures of less than
2 MPC-hrs per day and less than 10 MPC-hrs per week.
!
C. Have an independent assessment conducted of your chemistry Quality
! Assurance / Quality Control program and procedures, and provide the
Director, THIPO a copy of this assessment.
'
GPU Nuclear Response
GPU Nuclear contracted with the Oak Ridge National Laboratory (ORNL) in
Oak Ridge, Tennessee, to provide a independent assessment of the
j chemistry Quality Assurance / Quality Control programs and procedures. A '
copy of the complete assessment has been provided to the Director,
TMIPO. Although the audit contains several recommendations, the overall
assessment was favorable. The ORNL report states-that the current <
program to verify proper instr'ument operation and calibration is
adequate. There are no systematic errors in the records system that is ,-
used to process sample data. ORNL found the radioanalytical procedures
to be adequate and that they will yield the expected analytical results.
The logic behind each procedure and the validity of the algorithm used in
the associated calculations were also found to be correct.
I f D. Implement a formalized Quality Assurance / Quality Control program for
laboratory analyses that includes the provisions of Regulatory Guide 4.15.
i
GPU Nuclear Response
i
GPU Nuclear is in the process of implementing a formalized Quality
Assurance / Quality Control (QA/QC) program for laboratory analyses. In
- developing this program, GPU Nuclear used NRC Regulatory Guide 4.15, INPO
Good Practice 83-16.and 83-17 as well as information from THI-1, Oyster
Creek and the recent independent assessment performed by ORNL,
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o-__ _ _._ _ m_m.___ - _ _ _ . _ . _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ . _ _ _ _ _ . . _ _ _ _ . - ___________._________._m______ _._____mm._
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ATTACHMENT 2
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(4410-85-L-0236)
As a result, three procedures (4212-CHM-3011.85, Radiochemistry Round
Robin; 4212-CHM-30ll.86, Radiochemistry Interlaboratory Cross Check, and
'
4212-CHM-3011.87, Radiochemistry Intralaboratory Cross Check) have been
developed to broaden the scc)e of the THI-2 laboratory radiochemistry
. QA/QC program for laboratory analyses. Thse procedures include: 1
1. Varying methods of cross checking (including intralaboratory and
interlaboratory) to assess current procedures, instrumentation,
I techniques and computer software;
, i 2. An acceptance criteria of either 110% of "as analyzed" to actual or i
,
a graded approach similar to that found in the U.S. NRC Inspection
and Enforcement Manual, procedure 84725 dated January 1, 1984; and,
4
3. Frequencies for performing cross checks which were chosen based on
i the references used to develop the program, and plant factors such
as frequency of use, history of equipment, difficulty of analyses,
turn around time, and laboratory / staffing considerations.
These procedures are currently being reviewed within the GPU Nuclear
Organization with a target completion date of January 20, 1986. In the
interim, GPU Nuclear is continuing the daily quality control regimen ,
discussed in Procedure 4212-CHM-3011.82, Instrument Checks. '
Additionally, GPU Nuclear has established a contract with an offsite
laboratory to analyze 50 filter paper samples, supplied by TMI-2, for i
Sr-90 content. These samples have already been supplied to the offsite '
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laboratory and the results obtained will be used as a quality control
check of our present onsite analysis capability. The sample result will
, be compared to those performed by TMI-2 on a statistical basis to. detect :
systematic errors-in onsite methods. '
j
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GPU Nuclear believes that by adding the checks and verifications required
by the above referenced procedures, the accuracy and precision of the
radiochemical analyses will be better defined. In addition, the mixture
of " Intra" and " inter" laboratory work will provide both immediate
feedback and long term Quality Assurance.
i
E. Document all computer software used in laboratory analyses and verify
that the results generated are accurate.
,
GPU Nuclear Response ,
,
All of the computer software used in the chemistry laboratory in the
- production of sample analyses has'been verified, reviewed and documented
,
(documentation of the software used is maintained by the TMI-2 chemistry
section).
The methodology used in the verification of the computer software
consisted of determining which equations were being used, verifying-
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ATTACHMENT 2
-* (4410-85-L-0236)
that the equations were correct and comparing the output of the computer
program to hand calculations. This verification was independently
reviewed by THI-2 Radicchemical Engineering and found to be accurate and
correct.
Additionally, a procedure is being developed to define the controls for
laboratory computer software. The procedure will specify:
1. A method for documenting computer programs.
2. A requirement to verify calculations.
3. Frequency of review of computer software.
4. The method for making modifications to computer software.
5. A security statement.
6. The requirement for a sample run of comparison data to check
results.
T;.e intent of this procedure is to establish controls on computer
software used in the chemistry laboratory so that any changes to the
computer software will be performed in a standardized and controlled
manner. This procedure is currently being reviewed within the GPU
Nuclear organization with a target completion date of February 4, 1986.
,
5
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CD&L
Carolina Power & Light Company '
DEC 2 31985 SERIAL: NLS-85-488
Mr. Harold R. Denton, Director
Office of Nuclear Reactor Regulation
United States Nuclear Regulatory Commission
Washington, DC 205 %
SHEARON HARRIS NUCLEAR POWER PLANT
UNIT NO.1 - DOCKET NO. 50-400
INTEGRATED LEAKAGE RATE TESTING
Dear Mr. Denton:
,
Carolina Power & Light Company (CP&L) will perform Integrated Leakage Rate Testing
(ILRT) on the Shearon Harris Nuclear Power Plant approximately two weeks af ter the
completion of Hot Functional Testing (HFT). We request your concurrence to perform a
reduced duration peak pressure ILRT to satisfy the requirements of 10 CFR 50,
Appendix 3. Justification for this test is discussed in Bechtel Topical Report BN-TOP-1,
" Testing Criteria for Integrated Leakage Rate Testing of Primary Containment
Structures for Nuclear Power Plants, Rev.1."'The containment atmosphere stabilization
criteria of Section 2.3.A of BN-TOP-1 will be used. To determine the duration of the
ILRT, the criteria discussed in Section 2.3 of BN-TOP-1 will be used with the following
exception:
The end of test upper 95% confidence limit for both the least squares fit calculated
leak rate based on Total Time calculations and the least squares fit based on
mass-point calculations, plus penalty leakages, shall be less than 0.75 La.
To support our currer.t schedule for HFT and ILRT, we request your concurrance with the
test method outlined above by January 15,1986. If you have any questions concerning
this subject or require additional information, please contact me.
Yours very truly,
Y -{w
S. R. Zin nerman
Manager
Nuclear Licensing Section
SRZ/ GAS /crs (3125 GAS)
cc: Mr. B. C. Buckley (NRC) Mr. Wells Eddleman
Mr. G. F. Maxwell (NRC-SHNPP) Mr. John D. Runkle
Dr. 3. Nelson Grace (NRC-RII) Dr. Richard D. Wilson
Mr. Travis Payne (KUDZU) Mr. G. O. Bright (ASLB)
Mr. Daniel F. Read (CHANGE /ELP) Dr. J. H. Cepenter (ASLB) i
Wake County Public Library Mr. J. L. Kedey (ASLB) g-
Mr. 3. Huang (NRC) Mr. H. A. Cole l arcs./ggght
anosai (!tr only)
P58 (GAMMILL)
asa (santincta)
8[0 ro g... y,i
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411 Fayetteville street * P. O. Bom 1551 * Ratetgh. N C. 27602
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