JAFP-19-0053, Transmittal of 2018 Annual Radiological Environmental Operating Report

Transmittal of 2018 Annual Radiological Environmental Operating Report

ML19135A633
Person / Time
Site:	FitzPatrick
Issue date:	05/15/2019
From:	William Drews Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-19-0053
Download: ML19135A633 (185)

Text

Exelon Generation JAFP-19-0053 May 15, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 William C. Drews Regulatory Assurance Manager James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

2018 Annual Radiological Environmental Operating Report

Dear Sir or Madam:

This letter transmits the James A. FitzPatrick Nuclear Power Plant's (JAF) Annual Radiological Environmental Operating Report, for the period of January 1, 2018, through December 31, 2018. This document is submitted in accordance with the Reporting Requirements of the Technical Specifications Section 5.6.2, and Appendix Hof the Technical Requirements Manual "Offsite Dose Calculation Manual (ODCM)", Part 1, Section 6.1 Annual Radiological Environmental Operating Report. There are no new regulatory commitments contained in this letter. If you have any questions concerning the enclosed report, please contact Brian Cummings, Chemistry Manager, at (315) 349-6331.

Sincerely, f\. \\,wq c!iret,'\-lc" William C. Drews Regulatory Assurance Manager WD/BC/mh

Enclosure:

2018 Annual Radiological Environmental Operating Report cc: Next Page JAFP-19-0053 Page 2 of 2

cc:

NRC Regional Administrator, Region I NRC Resident Inspector NRC Project Manager

Supervisor, Town of Scriba Route 8, Box 382

Oswego, NY 13126

JAFP-19-0053 Enclosure 2018 Annual Radiological Environmental Operating Report (182 Pages)

ANNUAL RADIOLOGICAL ENVIRONMENTALOPERATING REPORT

nX X ii NX

X X nX X ii NX

n i ERROR MEAN ERROR

LLD S bEV Y t

Radioactivity curie microcurie picocurie

BerylliumPotassiumRadium

Not AcceptableNote: TBE 4 th Qtr result passed at 105%. Not acceptableNOTE: TBE's 4 th Qtr result passed at 101%Not Acceptable

(a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation(b) Analytics evaluation based on TBE internal QC limits: A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30

(a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation(b) Analytics evaluation based on TBE internal QC limits:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30

(a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) Analytics evaluation based on TBE internal QC limits: A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30(1) See NCR 18-20(2) See NCR 18-24(3) See NCR 18-21

(a) The Analytics known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation (b) Analytics evaluation based on TBE internal QC limits:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30 (1)(1)(2)(1)135 - 251(1)0.96 - 1.78(a) The MAPEP known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetric measurements made during standard preparation(b) DOE/MAPEP evaluation:

A = Acceptable - reported result falls within ratio limits of 0.80-1.20 W = Acceptable with warning - reported result falls within 0.70-0.80 or 1.20-1.30 N = Not Acceptable - reported result falls outside the ratio limits of < 0.70 and > 1.30(1) False positive test(2) Sensitivity evaluation (3) See NCR 18-09 (4) See NCR 18-25

(a) The ERA known value is equal to 100% of the parameter present in the standard as determined by gravimetric and/or volumetr ic measurements made during standard preparation.(b) ERA evaluation: A = Acceptable - Reported value falls within the Acceptance Limits N = Not Acceptable - Reported value falls outside of the Acceptance Limits(1) See NCR 18-23

-ii- TABLE OF CONTENTS PageLIST OF TABLES ....................................................................................................................... iiiEXECUTIVE

SUMMARY

............................................................................................................ i v I. INTRODUCTION ............................................................................................................1 A. QC Program ........................................................................................................1 B. QA Program ........................................................................................................1 II. PERFORMANCE EVALUATION CRITERIA ...................................................................1 A. Acceptance Criteria for Internal Evaluations ........................................................1 B. QC Investigation Criteria and Result Reporting ...................................................3 C. Reporting of Environmental Dosimetry Results to EDC Customers .....................3 III. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2018.................3 A. General Discussion .............................................................................................3 B. Result Trending ..................................................................................................4 IV. STATUS OF EDC CONDITION REPORTS (CR) ...........................................................4 V. STATUS OF AUDITS/ASSESSMENTS ..........................................................................4 A. Internal ................................................................................................................4 B. External ..............................................................................................................4 V

I. PROCEDURE

S AND MANUALS REVISED DURING JANUARY - DECEMBER 2018...4 VII. CONCLUSION AND RECOMMENDATIONS ................................................................. 4 VIII. REFERENCES ...............................................................................................................4 APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS

-iii- LIST OF TABLES Page1. Percentage of Individual Analyses Which Passed EDC Internal Criteria, January - December 2018 5 2. Mean Dosimeter Analyses (n=6), January - December 20185

3. Summary of Independent QC Results for 2018 5

-iv- EXECUTIVE

SUMMARY

Routine quality control (QC) testing was performed for dosimeters issued by the Environmental Dosimetry Company (EDC) .During this annual period100% (72/72) of the individual dosimeters, evaluated against the EDCinternal performance acceptance criteria (high-energy photons only), met the criterion for accuracy and 100% (72/72) met the criterion for precision (Table 1). In addition, 100% (12/12) of the dosimeter sets evaluated against the internal tolerance limits met EDC acceptance criteria (Table 2) and 100% (6/6) of independent testing passed the performance criteria (Table 3).Trending graphs, which evaluate performance statistic for high-energy photon irradiations and co-located stations are given in Appendix A. One internal assessment and one external audit were performed in 2018.There were no findings identified.

1 of 6 I. INTRODUCTION The TLD systems at the Environmental Dosimetry Company(EDC) are calibrated and operated to ensure consistent and accurate evaluation of TLDs. The quality of the dosimetric results reported to EDCclients is ensured by in-house performance testing and independent performance testing by EDC clients, and both internal and client directed program assessments. The purpose of the dosimetry quality assurance program is to provide performance documentation of the routine processing of EDCdosimeters. Performance testing provides a statistical measure of the bias and precision of dosimetry processing against a reliable standard, which in turn points out any trends or performance changes. Two programs are used: A. QC Program Dosimetry quality control tests are performed on EDC Panasonic 814 Environmental dosimeters.These tests include: (1) the in-house testing program coordinated by the EDC QA Officer and (2) independent test perform by EDC clients. In-house test are performed using six pairs of 814 dosimeters, a pair is reported as an individual result and six pairs are reported as the mean result.Results of these tests are described in this report. Excluded from this report are instrumentation checks. Although instrumentation checks represent an important aspect of the quality assurance program, they are not included as process checks in this report. Instrumentation checks represent between 5-10% of the TLDs processed. B. QA Program An internal assessment of dosimetry activities is conducted annually by the Quality Assurance Officer (Reference 1). The purpose of the assessment is to review procedures, results, materials or components to identify opportunities to improve or enhance processes and/or services. II. PERFORMANCE EVALUATION CRITERIA A. Acceptance Criteria for Internal Evaluations 1. Bias For each dosimeter tested, the measure of bias is the percent deviation of the reported result relative to the delivered exposure. The percent deviation relative to the delivered exposure is calculated as follows: ii i HH 100 Hwhere: i H = the corresponding reported exposure for the i thdosimeter (i.e., the reported exposure)

H i= the exposure delivered to the i th irradiated dosimeter (i.e., the delivered exposure) 2 of 6 2. Mean Bias For each group of test dosimeters, the mean bias is the average percent deviation of the reported result relative to the delivered exposure. The mean percent deviation relative to the delivered exposure is calculated as follows: ii i HH 1 100 Hnwhere: i H = the corresponding reported exposure for the i thdosimeter (i.e., the reported exposure) i H = the exposure delivered to the i th irradiated test dosimeter (i.e., the delivered exposure) n = the number of dosimeters in the test group 3. Precision For a group of test dosimeters irradiated to a given exposure, the measure of precision is the percent deviation of individual results relative to the mean reported exposure. At least two values are required for the determination of precision. The measure of precision for the i th dosimeter is: i HH 100 H where: i H= the reported exposure for the i th dosimeter (i.e., the reported exposure)

H= the mean reported exposure; i.e., i 1 HH nn = the number of dosimeters in the test group 4. EDC Internal Tolerance Limits All evaluation criteria are taken from the "

EDCQuality System Manual," (Reference 2). These criteria are only applied to individual test dosimeters irradiated with high-energy photons (Cs-137) and are as follows for Panasonic Environmental dosimeters: +/- 15% for bias and +/- 12.8% for precision.

3 of 6 B. QC Investigation Criteria and Result Reporting EDCQuality System Manual (Reference 2) specifies when an investigation is required due to a QC analysis that has failed the EDC bias criteria. The criteria are as follows: 1. No investigation is necessary when an individual QC result falls outside the QC performance criteria for accuracy.2. Investigations are initiated when the mean of a QC processing batch is outside the performance criterion for bias. C. Reporting of Environmental Dosimetry Results to EDC Customers 1. All results are to be reported in a timely fashion. 2. If the QA Officer determines that an investigation is required for a process, the results shall be issued as normal. If the QC results prompting the investigation have a mean bias from the known of greater than +/-20%, the results shall be issued with a note indicating that they may be updated in the future, pending resolution of a QA issue. 3. Environmental dosimetry results do not require updating if the investigation has shown that the mean bias between the original results and the corrected results, based on applicable correction factors from the investigation, does not exceed +/-20%. III. DATA

SUMMARY

FOR ISSUANCE PERIOD JANUARY-DECEMBER 2018A. General Discussion Results of performance tests conducted are summarized and discussed in the following sections. Summaries of the performance tests for the reporting period are given in Tables 1 through 3 and Figures 1 through 4. Table 1 provides a summary of individual dosimeter results evaluated against the EDC internal acceptance criteria for high-energy photons only. During this period100% (72/72) of the individual dosimeters, evaluated against these criteria, met the tolerance limits for accuracy and 100% (72/72) met the criterion for precision.A graphical interpretation is provided in Figures 1 and 2. Table 2 provides the bias and standard deviation results for each group (N=6) of dosimeters evaluated against the internal tolerance criteria. Overall,100% (12/12) of the dosimeter sets, evaluated against the internal tolerance performance criteria, met these criteria.A graphical interpretation is provided in Figure 3. Table 3 presents the independent blind spike results for dosimeters processed during this annual period. All results passed the performance acceptance criterion.Figure 4 is a graphical interpretation of Seabrook Station blind co-located station results.

4 of 6 B. Result Trending One of the main benefits of performing quality control tests on a routine basis is to identify trends or performance changes. The results of the Panasonic environmental dosimeter performance tests are presented in Appendix A. The results are evaluated against each of the performance criteria listed in Section II, namely: individual dosimeter accuracy, individual dosimeter precision, and mean bias. All of the results presented in Appendix A are plotted sequentially by processing date. IV. STATUS OF EDC CONDITION REPORTS (CR) No condition reports were issued during this annual period. V. STATUS OF AUDITS/ASSESSMENTS 1. Internal EDC Internal Quality Assurance Assessment was conducted during the fourthquarter 2018. There were no findings identified. 2. External None. V

I. PROCEDURE

S AND MANUALS REVISED DURING JANUARY - DECEMBER 2018No procedures or manuals were revised in 2018. VII. CONCLUSION AND RECOMMENDATIONS The quality control evaluations continue to indicate the dosimetry processing programs at the EDC satisfy the criteria specified in the Quality System Manual. The EDCdemonstrated the ability to meet all applicable acceptance criteria. VIII. REFERENCES 1.EDC Quality Control and Audit Assessment Schedule, 2018.

2. EDC Manual 1, Quality System Manual, Rev. 3,August 1, 2017.

6 of 6 APPENDIX A DOSIMETRY QUALITY CONTROL TRENDING GRAPHS ISSUE PERIOD JANAURY - DECEMBER 2018