ML20207K071

Insp Repts 50-413/86-23 & 50-414/86-25 on 860602-05. Violation Noted:Failure to Follow Procedures for Gamma Spectroscopy Measurements of Gaseous Effluent Process Samples

ML20207K071
Person / Time
Site:	Catawba
Issue date:	06/18/1986
From:	Kuzo G, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207K043	List: ML20207K039 ML20207K052 ML20207K071
References
50-413-86-23, 50-414-86-25, NUDOCS 8607290329
Download: ML20207K071 (8)

See also: IR 05000413/1986023

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  .           Ceco                                     UNITED STATES
                    'o                   NUCLEAR REGULATORY COMMISSION
      [[pO             p                                  REGION 88
      $ ,.
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                       j                          101 MARIETTA STREET.N.W.
       ,               2                           ATLANTA. GEORGI A 30323
        %,*****/                                     JUN 2 6 BBS
       Report Nos.: 50-413/86-23 and 50-414/86-25
       Licensee: Duke Power Company
                       422 South Church Street
                       Charlotte, NC 28242
                                                                     License Nos.:

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       Docket Nos.:         50-413 and 50-414                                           NPF-35 and NPF-48
       Facility Name: Catawba 1 and 2
       Inspection Cond ted g June 2-5, 1986

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       Inspector:         9      s            .                                                            Id
                     G.~B. Tuz'
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                                                                                                   Date Signed
       Approved by:                   7       M                                                        7E
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                         P. GT Steddart? Acting Section Chief                                      Date Signed

j Division of Radiation Safety and Safeguards

                                                        SUMMARY
       Scope:      This routine, unannounced inspection involved review of liquid and
       gaseous radwaste systems; liquid and gaseous effluent sampling, analysis, and
       monitoring; and review of inspector followup items.
       Results: One violation was identified - Failure to follow procedures for gamma
        spectroscopy measurements of gaseous effluent process samples.
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                                       REPORT DETAILS
   1.    Persons Contacted
         Licensee Employees
        *J. W. Hampton, Plant Manager
        *J. W. Cox, Technical Services Superintendent
        *W. P. Deal, Station Health Physicist
        *C. k. Wray, Health Physics Supervisor
        *B.  M. Chundriik, Health Physicist
        *C.  S. Gregory, Maintenance, I&E Superintendent
        *A.  S. Bhatnagar, Performance
        *C.  L. Hartzell, Licensing and Project Engineer
        *F.  P. Schiffley, Licensing Engineer
        *P.  N. McNamara, Health Physicist
         T. Robinson, I&E Engineer
         B. Wrayfield, I&E Specialist
         W. Green, Engineer
         Other licensee employees contacted included engineers,         technicians,
         operators, and office personnel.
         NRC Resident Inspectors
        *P. K. VanDoorn
        *M. Lesser
        * Attended exit interview
   2.    Exit Interview
         The inspection scope and findings were summarized on June 5,1986, with
         those persons indicated in Paragraph 1 above. The inspector discussed the
         following inspector followup items:      inclusion of background limits and
         sensitivity requirements in EMF calibration procedures (Paragraph 6.c.) and
         review of design changes to EMF-50 to ensure proper operability (Paragraph
         7.d.).   One potential violation concerning failure to follow established
         procedures for gamma spectroscopy analyses of gaseous effluent process
          samples was discussed (Paragraph 6.b.).         Licensee representatives
         acknowledged the inspector's comments.      The licensee did not identify as
         proprietary any of the materials provided to or reviewed by the inspector
         during this inspection.
   3.     Licensee Action on Previous Enforcement Matters
         (50-413/85-50-02, 50-414/85-60-02) VIO: Failure to have Adequate Procedures
         to Implement QA Program. The inspector discussed changes to the
          radioanalytical QC program and reviewed selected inter-detector comparison
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         data.    The inspector noted that the high "between detector" variability
         noted in a previous inspection (IE Report No. 50-413/85-50, 50-414/85-60)
         has been reduced. This item is considered closed.
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    4.   Unresolved Items
         Unresolved items were not identified during the inspection.
    5.   Audits (84723,84724)
         a.    Technical Specification (TS) 6.5.2.9 states that audits of unit
               activities shall be performed under the cognizance of the Nuclear
               Safety Review Board (NSRB) encompassing: the conformance of unit
               operation to provisions contained within the technical specifications
               and applicable license conditions at least once per 12 months; the
               radiological environmental monitoring and the results thereof at least
               once per 12 months; the Offsite Dose Calculation Manual and
               implementing procedures at least once per 24 months; and the
               performance of activities required by the Quality Assurance Program for
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               effluent and environmental monitoring at least once per 12 months. The
               inspector reviewed the following audit reports:
                     QA Audit NP-85-8(CN) Technical Services and Operations Activities,
                     April 15 - May 1, 1985.
                     QA Audit NP-85-18(CN) Technical Services and Administrative
                     Services Activities, September 16 - October 2, 1985.
                     QA Audit NP-86-3(CN) Performance Group, January 20 - February 5,
                     1986.
                     QA Audit NP-86-8(CN) Health Physics and Environmental Group
                     Activities, April 1-25, 1986.
               The inspector noted that the licensee audits verified compliance with
               the applicable Technical Specifications, ANSI standards, station and
               corporate procedures, and 10 CFR regulations. The licensee audits did
               not identify any areas of concern in the areas reviewed during this
               inspection.
         No violations or deviations were identified.
    6;   Procedures (84723, 84724)
         a.    Technical Specification 6.8.1 states that written procedures shall be
               established, implemented and maintained covering the applicable
               procedures recommended in Appendix "A" of Regulatory Guide 1.33,
               Revision 2,     February 1978, "Offsite Dose Calculation Manual
                Implementation," and in the Quality Assurance Program for effluent and
               environmental monitoring.

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                        (1) OP/0/A/6500/18- Operating Procedure for the Release of a Waste
;                                   Gas Decay Tank
                        (2) OP/0/B/1001/16:              Operation and Calibration:                        ORTEC ADCAM GAMMA
                                    Analysis System, May 8, 1986.
!                       (3) HP/0/B/1001/12: Technical Specifications Gaseous Waste Sampling
;                                   and Analysis, Rev. 11, December 3, 1985.
                        (4) HP/0/B/1000/03: Correlation of EMF's, June 14, 1984.
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!                       (5) HP/0/B/1001/19:               Counting Room Intrastation/Interstation Cross

Check Program

3 ] (6) TP/1/B/2600/15: Process and Effluent Monitor Test, July 17, 1985.

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                        (7) IP/0/B/3314/14:               Radiation Monitoring System Iodine Activity,
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                                    1 EMF 37 & 40, 2 EMF 37 & 40, May 10,1984.
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                        (8) IP/0/B/3314/13:               Radiation Monitoring System (EMF) Particulate

j Activity Monitor Channel Calibration 1 EMF 35, 1 EMF 38, 2 EMF 35, i 2 EMF 38, March 4, 1985. j (9) IP/0/B/3314/11: Radiation Monitoring System Dual Range Gamma i Activity Monitors, May 8, 1984.

                       (10)         IP/0/8/3314/09: Radiation Monitoring Systen: Dual Range Beta
                                    Channel Calibration, May 4, 1984.

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f                       The inspector discussed results of the procedure review with cognizant
j                        licensee representatives as detailed in Paragraphs 6.b and 6.c.

! b. The inspector discussed with cognizant licensee representatives the

!                       gamma spectroscopy analysis of liquid and gaseous process samples. The                                      ,

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                         inspector noted that HP/0/B/1001/16, " Operation and Calibration: ORTEC                                    '
                        ADCAM GAMMA Analysis System," stated that a count rate is acceptable if
j                       detector dead-time is less than 10%. The procedure further specified
3                       that if detector dead time was greater than 10%, the sample was to be                                       ,
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                        counted at a higher ' level or was to be diluted. Following review of
.                       gaseous waste release reports (Paragraph 7), the inspector noted that -

l the 10% dead-time limit had been exceeded on numerous occasions from

                        January 1986, through May - 1986. The inspector pointed out that as
                        dead-time increases for the gamma spectroscopy system, non-conservative
                         inaccuracies increase for analytical measurements.                                    The inspector
                         informed licensee representatives that the failure to adhere to- the-
                         gamma spectroscopy analysis procedures for process gas analyses was a
;                        potential violation (50-413/86-23-01, 50-414/86-25-01).
                  c.     The inspector discussed effluent monitor calibration - and set point                                        !

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,                        determination procedures with cognizant' lice.nsee representatives. The                                     !
                         inspector noted that the ' sensitivity of the effluent monitors was                                         l
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             affected by background radiation levels.         Approved procedures for

l monitor calibratica and set point determination required technicians to

             record background radiation levels; however, the procedures did not
             provide details to ensure instrument sensitivity limits were met.
             Licensee representatives stated that cognizant licensee individuals
             were aware of the limits and were consulted during monitor calibrations
             and set point determinations.        Licensee representatives agreed to
             provide more detail in the procedures regarding this item.           The
              inspector informed licensee representatives that this issue would be
             reviewed      during   a    subsequent   inspection   (50-413/86-23-02,
             50-414/86-86-25-02).
        Violation (50-413/85-23-01, 50-414/85-25-01) Failure to follow procedures
        for gamma spectroscopy analyses of gas effluent process samples.
        Open Item (50-413/86-23-02, 50-414/86-25-02) Improved detail regarding
        background and sensitivity limits of effluent monitors.
   7.   Review of Records, Logs and Reports (84723, 84725)
        a.   The inspector reviewed selected portions of the following records and
              logs:
              (1) Safety Related Filter Run Time Monitoring, 1985.
              (2) Radiciodine Penetration and Retention Test Reports - Control Room
                     Area (VC) System, 1985-1986.
              (3) EMF-36(L) Unit Vent Noble Gas Monitor 1984-1985
                     (a) Analog Channel Operational Test
                     (b) Instrument Calibration Sheet
              (4) EMF-35(L) Unit Vent Particulate Monitor, 1985

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                     (a) Flow Calibration
                     (b) Channel Calibration
              (5) EMF-49, 1985
                     (a)   Flow Calibration
                     (b) Channel Calibration
              (6) EMF-50, 1984-1986
                     (a) Channel Calibration
                     (b) Flow Calibration
               (7) Liquid Waste Release (LWR)/ Gaseous Waste Release (GWR) Log Book
                     1985-1986
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       (8) Unit Vent Unknown Noble Gas Activity Work Sheet, 1985
       (9) LWR Records, January-May 1986
      (10) WGR Records January-May 1986, for Containment Purge (VP),
             Containment Air Release and Addition System (VG) and Waste Gas
             Decay Tanks for the following analyses:
             (a) Noble Gas Grab Sample
             (b) Charcoal Cartridge
             (c) Particulate Filter
      (11)   1985 Semiannual Effluent Release Reports
       Results of the record review are discussed in Paragraphs 7.b, 7.c and
       7.d, below.
   b.  Technical Specification    6.9.1.7 states that Routine Semiannual
       Radioactive Effluent Release Reports covering the operation of the unit
       during the previous 6 months of operation shall be submitted within 60
       days after January 1 and July 1 of each year.
       The inspector reviewed and discussed the 1985 Semiannual Radioactive
       Effluent Release Reports with cognizant licensee representatives.
       There were no reports of abnormal releases.     Dose estimates from the
       uranium fuel cycle at Catawba Nuclear Station were estimated to be 0.88
       mrem and 2.2 mrem, total body and GI-LLI (maximum organ) respectively.
       The Semiannual Effluent Release report for 1986 was not available for
       review at the time of the inspection.
   c.  The inspector discussed gaseous waste release reports with cognizant
        licensee representatives.    The inspector noted that for noble gas
       analyses using the marinelli beaker, procedural dead timo limits were
       exceeded on several occasions but that dead-time limits were not
       exceeded for any other analyses. Licensee representatives informed the
        inspector that the gas marinelli geometry was calibrated only for one
        sample to detector distance and thus the sample could not be analyzed   .
       at increased distances from the detector surface.        The inspector   I
        informed licensee representatives that when the problem of exceeding    i
        the dead-time limit was first observed, study should have been           l
       conducted to evaluate the effect of increased dead-time on the accuracy  i
       of gaseous effluent process samples.       The failure to follow the
        procedural limits and to conduct a proper evaluation of exceeding the
        specified dead-time limits resulted in the violation noted in           j
        Paragraph 6.b.                                                           l
   d.   The inspector discussed EMF-50, Waste Gas Decay Tank monitor
        calibrations with cognizant licensee representatives.         Licensee
        representatives informed the inspector that selected concerns regarding
       monitor operability had been identified and documented in Intrastation
        Letter CN-215.10, dated May 27, 1986.        These concerns included

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             nonrepresentative sampling, inleakage from multiple gas sources into
             the common discharge header, aspiration and backflow of water into the
             instrumentation, inadequate position of the waste gas control valve,
             and pressure effects regarding setpoint methodology. The inspector
             noted that operability of this system was deferred from Unit 1 to the
             Unit 2 FSAR commitments. The inspector noted that prior to any WGDT
             release, EMF-50 must be operable. Licensee representatives stated that
             corrective actions regarding this monitor are being evaluated. The
              inspector informed licensee representatives that this item will be
              reviewed     during    a   subsequent    inspection   (50-413/86-23-03,
              50-414/86-25-03).
        Open (50-413/86-23-03, 50-414/86-25-03) Review of WGDT noble gas monitor
        (EMF-50) operability.
        No violations or deviations were identified.
   8.   Verification of Effluent Monitor Operability (84724, 84725)
        The inspector toured the control room with cognizant licensee represent-
        atives and verified readouts of all operable effluent process monitors. The
        inspector verified by direct inspection operability of the Liquid Waste
        (EMF-49) and the Unit 1 Vent (EMF-35, -36, -37) effluent monitors. All
        areas were clean and equipment appeared to be properly maintained.
        No violations or deviations were identified.
   9.   Inspector Followup Items (92701)
        a.    (50-413/85-50-01, 50-414/85-60-01):         IFI Review of Radiological
              Effluent Measurement QA Procedures for Changes to Ensure Adequate
              Measurement Capability. The inspector discussed changes to the Quality
              Assurance (QA) Program for radioanalytical measurements. Changes
               included improved review and trending of selected quality control data,
              and the development of a single procedure outlining the Catawba Nuclear
              Station Intrastation and Interstation cross check programs. This item
               is considered closed.
        b.    (50-413/85-50-03, 50-414/85-60-03):          IFI Review of Licensee's
              Evaluation of Alpha / Beta & Beta / Gamma Effluent Measurements. The
               inspector discussed this issue with cognizant licensee representatives
              and noted that corrective actions were in progress.       The licensee had
               initiated a program (1) to define and evaluate drift problems
              associated with the detectors, (2) to correct any identified                  >
              deficiencies in equipment electronics and detector counting gas, and          I
               (3) to define quality control (QC) charts using both the instrument and
              counting standard deviations.       Licensee actions regarding this item
              were detailed in a memorandum,        " Meeting Regarding Instability of
              Tennelec LB-5100 Efficiency," dated January 30, 1986. Th;s item is            ,
               considered closed.                                                           l

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              c. (50-413/85-50-04, 50-414/85-60-04) IFI Review 6f Licensee's Fe-55
                 Analysis of NRC Spiked Samples.   The inspector confirmed that the

i licensee had received the spiked sample from the NRC contract

                 laboratory. Analyses had not been completed at the time of the
                 inspection but licensee representatives stated that results would be
                 provided to the NRC Region II Office by July 31, 1986. This item is
                 considered closed.

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