IR 05000271/1988012

Insp Rept 50-271/88-12 on 880808-12.No Violations Noted. Major Areas Inspected:Confirmatory Measurements,Procedures & Records Associated W/Program for QC of Analytical Measurements & Staffing & Controls

ML20155C339
Person / Time
Site:	Vermont Yankee
Issue date:	09/30/1988
From:	Kirkwood A, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155C336	List: IR 05000271/1988012 ML20155C331
References
50-271-88-12, NUDOCS 8810100006
Download: ML20155C339 (10)

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U.S. NUCLEAR REGULATORY COMMISSION  !

REGION I ,

Report No. 50-271/88-12  :

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Occket No. 50-271 l License No. OPR-28 Priority -- Category C

Licensee: Vermont Yankee Nuclear power Corporation lib 5, Box Tii9 BrattleboroIVermont 05301 Facility Name: Vermont Yankee Nuclear Power Station

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Inspection At: Vernon, Vermont

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Inspection Conducted: August 8-12, 1998 Inspeetors: C. kh)uMW , #I!30!33'

! A. Kirkwood, Radiation Specialist, ERPS, DRSS date ;

i Approved by: __

. y Ac 9 c W. J. Pi sciak7 Chie V Uiluents Radiation dati

Protehtion Section, DRSS

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Inspection Summary

Inspection on August _8-12, 1988 (Inspection Report

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No. 50-271/88-12) ,

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Areas Inspected: Routine, unannounced inspection of the licensee's radiochemical

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measurements program using the NRC:I Mobile Radiological Measurements Laboratory l

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and laboratory assistance provided by DOE's Radiological and Environmental Sciences t Laboratory. Areas reviewed included: confirmatory measurerents, procedures and i records associated with the program for quality control of analytical measurements

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and management crgenization, staffing and control R_e sul t s : Within the areas inspected, no violations were identifie I

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DETAILS l 1.0 Individuals Contacted

1.1 Principle Licensee Employees i

• R Wanczyk, Operations Superintendent '

i *S. Skibniowsky, Chemistry Supervisor

• $. McAvoy, Chemistry Assistant  ;

The inspector also talked with and interviewed other licensee exployees including members of the chemistry and radiation protection l staff l 1.2 Contractor Employee  !

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• 0. McCurdy, Yankee Atomic Environmental Lab Manager 2.0 Previously Identified Item i

(Closed) Inscector Follow-up Item (50-271/85-03-01): control charts for -

non-radiological chemistry standards. The inspector reviewed control ,

charts for nine analytical standards used in the water chemistry progra ;

A centered mean with two and three sigma limits, typical of standard ,

industry practice, was used. The licensee is now able to identify the '

significanr.e of analytical differences and the development of trend ;

3.0 Confirm _atory Measurements  !

I 3.1 Split Sample Results l

During this part of the inspection, liquid, filter, charcoal cartridge and gas samples were split between the licensee and NRC for the purpose of intercomparison. Where possible, the split !

samples are actual effluent samples or inplant saples which !

duplicate counting geometries used by the licensee for effluent L sample analyses. In addition, a spiked charcoal cartridge standard !

was submitted to the licensee for analysis since radio 10 dine was present on the charcoal cartridge sample in too low an activity for a valid statistical comparison. The samples and standard were analyzed by the licensee using normal methods and equipment, and by ;

the NRC:I Mobile Radiological Measurements Laboratory. Joint t analyses of actual effluent samples are used to verify the !

licensee's capability to measure radioactivity in effluent samples ,

with respect to Technical Specificattuns and other regulatory ;

requirement [

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In addition, a liquid inplant sample was sent to the NRC reference laboratory, Department of Energy, Radiological and Environmental Sciences Laboratory (RESL), for analyses requiring wet chemistr The analyses to be performed on the split sample by the licensee and RESL are Sr-89, Sr-90, Fe-55, gross alpha, and tritium. The results will be compared with the licensee's results when received at a later date and will be documented in a subsequent inspection repor The insper. tor noted that liquid releases were not made from the facility on a routine basi The results of an effluent sample split between the licensae and the NRC:1, during a previous inspection on Octnber 6-10,1986, (!rupec- '

tion Report No. 50-271/26-23) were also compared during this inspectio The results of the sample measurements coyart:en indicated that all of the measurements were in agreement under the criteria used for comparing results. (See Attachment 1) l I

The results of the comparisons are listed in Table In-69m was

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not identified by the licensee on the reactor vessel vater samples,

! although this isotope was present. Zn-69m was not identified and quantified because it was not in the licensee's nuclide identification librar The licensee made an immediate addition to their general isotope llorary to include 2n-69m. On the same comparison, W-187 was noted to have just met comparison criteri The inspector reviewed the licensee library and determined that a less abundant peak er,ergy was used by the licensee to identify W-187 than that used by the NR The licensee again made an immediate 1 change to its library resulting in closer agreement on the esparison. Finally, the licensee was asked to perforin an isotopic gamma analysis on a one-liter marinelli containing demineralized i

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water, for the purpose of determining LLDs as required by Technical Specification limits. The inspector verified that LL0s were met

{ for this geometry.

1 No violations were identified, t i ty Assurance / Quality Control Laboratory _ Qual i

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The inspector performed a selective review of the licensee's program i j for the quality control of the radioanalytical measviements made by l 1 the chemistry group. The review was performed with respect to the i following criteri ; * Principles of Quality Assurance of Chemical Meacurements l

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+ Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Er.vironment" ,

• ANSI N42.14-1978, "American National Standard Calibration and Usage of Germanium Oetectors for Measurement of Gamea-Ray Emission of Radionuclides"

• ANSI N42.15-1980, "American National Stardard Performance

Vec*ification of Liquid - Srintillation Counting Systems" 3.2.1 Procedures The inspector reviewed the following selected licensee effluent l

and inplant analysis procedures:

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• AP 6600, Rev. 3. "Chemistry Laberatory Quality Control Program"

• OP 0631, Rev. 7, "Radiochemistry"

• OP 2610. Rev. 12, "Liquid Waste Disposal"

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• OP 2011, Rev. 18. "Gaseous Radwaste"

AP 6010, Rev. 7, "Inplant Audits"

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• DP 2631. Rev. 11, "Radiochemical Instrumentation"

AP 6025, Rev. 1, "Quality Control / Independent Inspection j *

AF 0645, Rev, 0, "Chemistry Data and Information Logging"

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After reviewing the above procedures against the previously I mentioned criteria, the inspector noted certain instances where methods need to core accurately reflect industry practice and where procedural updates should be more frequent and thoroug ! AP 6600, Chemistry Lab QC, outlines the Quality Control Progra l Section V.B.2., calls for annual performance of lab checks for contractors conducting analyses of s.mples collected to evaluate r i Technical Specification r(quirements. The licensee has recently l changed contractor labs for wet chemistry analyses. A means to

accompitsh the annual performance check on the new contractor i lab had not been thoroughly planned by chemistry management as  ;

evident fro 9 interviews with the chemistry supervisory staff; insufficient documentation readily available onsite to initially reach a conclusion about the new labs ability to analyze plant  !

samples; and a minimum of data relating to licensee subnission

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, a and new contractor lab analyses of spiked samples typical of plant needs. However, during the course of the inspection, )

, nume.ous OAD document,s arrived from the new lab; a confere1ce  !

cal' was held with the senior members of both lab staffs; and  ;

the new lab manager attended the exit interview, all of wSich i l demonstrated a good faith s/ fort to assure that the new lab '

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cortractor was technically able to perform precise and accurate

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metsurements.

1 s j The licensee agreed to document the basis of their QA of the new i cont Netor lab to fulfill the annual performance check required j by AP 660 ;

Procedure AP 6600, Attachments 6600.01 and 6600.02, Chemistry '

Personnel QA Check Sheet and Outside Lab QA Check Sheet, reference  ;

I Appendix C acceptance criteria. These acceptance criteria are t l actually in Appendix A, as accurately referenced in tha body of

! AP 6600. Procedure OP 2611, Rev. 18, Gaseous Radwaste, does not

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reference placen.ent of particulate filters on a spacer as is the practice when counting on the gammt spectroscopy detector The

licensee stated that this is addressed in the counting room on a

list of geometries. The licensee agreed to mentien the particulate '

filter counting geometry in the next revision to a more appropriate l procedure DP 2631. "Radiochemical Instrumentation". Procedure ,

j OP 2631 Rev. 11, details nperational methods, performance checks  ;

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and calibration steps.Section II.A.3 mentions a minimum of  :

1000 seconds counting time for standards while performing a gamma f spectrosenpy efficiency calibration. The inspector discussed i j ANSI N42.14-1978 recomendations, which call for at least 20,000 l j counts in each full energy peak, The licensee agreed to specify  :

j at least 10,000 counts, a standard practice number, in Rev.12 '

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of this procedure. The LSC operating pracedure section of OP  !

2631, Rev. 11, Beckman LS-100C, Liquid Ssi." 411: tion Counter,  !

details in Part A.9. counting a calibration source for 10 minutes or 1000 cpm. The inspector pointed out that ANSI N42.15 - 1980

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j recommends accumulating 100,000 counts for efficiency calibrations l'

and 20,000 counts for daily check source performance verification ,

The licensee agreed to specify minimum counts in Rev. 12. for  ;

] LSC calibrations. Section 5.2.2,4.2 of the standard also recommends j

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chi-square tests of d*.ta determinations to verify a statistically *

normal distribution of data points around a mean (to some specified .

. degree of confidence). This will determine whether the system is  !

operating within allowable limits. The licensee agreed to evaluate i the use of statistical tests for data during calibrations and i control chart preparation, t

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Procedure OP 2610. Rev.12. "Liquid Waste Disposa?" is due to be updated on September 18, 1988. At that time the licensee agreed to replace references to the former contractor's procedures with the new lab contractor's procedures in Appendices A, B and With the exception of the above mentioned items, the procedures reviewed were complete and technically soun .2.2 Records The inspector reviewed the followin9 selected licensee records '

and data associated with the chemistry quality control program:

• Liquid Scintillation Counter, LS1000, Control Charts dated April 20 to August 9, 1988 for the tritium standard (HBR 1709), and a Calibration dated February 24, 1933

• Contractor lab wat chemistry data or. Plant Vent Stack Composite Filters dated April 5 to June 28, 1938

• DP 0631.01, Liquid Standard Accountability File from January 23, 1988

• Weekly Chemistry Schedule Check-Off Sheet for week of July 16 to 22, 1988

• 6600,03, Quality Control Analysis, Gamta Spectroscopy

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System calibration data from April 29, 1938

• 6600.01 Chemistry Personnel QA Check Sheet, data on

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performance of spiked split sample analyses from new

, contractor lab to VY and vendor lab dated February 3, 19S6 and September 14, 1937

• 6600.02, Outside Lib QA Check Sheet, spiked sa?ple results

, for first two quarters of 1938 and last two quarters of

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19S7, on old vendor lab e

MCA control charts f or peak area and FWHM, 30'. HPGe,1 (

liter MB, dated June 1 to August 9, 1933

• Non-rad chemistry control charts dated January to August I S, 1933 for C1, TOC, Silica, B, Cr, Ni, Co, Cu, Fe and Zn l

After review of the above records and data the inspector noted

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instances where supervisory review of trending data at more f requer,t intervals, combined with required actien indicators, j would enhance the Quality and confidence of enemistry l reasurement i

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Quality control checks on the gamma spectroicopy system consist '

of a daily energy performance check utilizing a Eu-152 check l source and control chart plots of peak area (779 kev) and l resolution (FnHM). Source decay has been factored into the two ,

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and three sigma control limits. Also weekly (2000 second count)

and monthly (10,000 second count) backgrounds are done, although ,

this data is not plotted. All three detectors (30*4 and ~ 20*4 l ef ficiency HPGe; ~ 10'$ efficiency gel 1) are source checked :

, dail Procedures detail steps to be taken should problems t I occur, If the technician cannot resolve them, an out of service i j (005) sign is placed on the detector and a supervisor is '

i notified. QC data on the LSC (liquid scintillation counter) ard ,

! accumulated from e tritium sealed source and backgrounds i

prepared in similar quantities and matrices as those routinely i

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analyzed. The inspector reviewed control chart data for the tritium sealed source dated April 20 to August 9, 1933. Data :

from June 10 to August 2,1983 had trended below the negative

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two sigma limit and finally was out of the negative tnree sigma '

limit on August 3 and 4, 1988. Supervisory review of this data

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at frequent intervals could have prevented an unnecessarily long period of suspect equipment reliability. Proceduralized actions at the two sigma limits could have required technician; to a'ert '

supervisors even more rapidl The inspector discussed the use l of statistical probability determinants as an artion limit tool

als The number of measurements expected to fall outside of ;

two sigma over a twenty working day month can be statistically determine If exceeded, this could quickly alert the licensee

to suspect measurement Overall, records were orderly, complete and accurate, with the f exception of "white-out" on control charts, j

i l The inspector stated that the above areas, including improve- ,

I ments in the quality control of Liquid Scintillation Counting !

j measurements discussed in this section, and modifications to '

i procedures and documentation of the basis for 0A of the new l I contractor lab identified in Section 3.2.1, would be reviewed i

during a subsequent inspection (50-271/SS-12-01). l

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No violations were ider.tified.

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! 4.0 Management Controns l

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4.1 3 0 anization and Staffino

Recent changes in the Che'.itstr> Department involve the splitting of !

the RP/ Chemistry technician pool in two. Chemistry technicians are l

! now exclusively assigned to the Chemistry Supervisor. Seven chemistry l r

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technicians are desired and interviewing was being done to fill four positions while the inspector was on sit One contract technician is currently filling a vacancy and two more are being sought until all vacancies can be filled by permanetit employees. Tnis change demonstrates positive steps to improve the quality of chemistry measurements by use of a dedicated workforc The experienced, long term staff is a program strengt .2 Auoits The inspector reviewed tha follow!ng documen*$ with *espect to management control of the chemistry QA progra * AP 6010, Rev. 7, In-Plant Audits

• Audit 87-02, Chemistry /RETS, dated February 9 to 13,1937

• Audit 8S-02, Cnemistry, RETS/00CM and Radiation Environmental Monitoring dated February 1 to 5,1983 Procedure AP 6010, Rev. 7, was reviewed by the inspector and found to be complete and thorough with regard to followup on audit deficier.cies and observations. Audit 88-02 exhibited good technique in that a historical review for recurring items was conducted and noted in a remo of May 16. 1988. Sentor Management attention .nd

followup was noted in a mee,o from the Plant Manager dated July 13, 1953. Audit thoroughness and technical depth were adequat No violations were not9d within the scope of this revie .0 . Exit Interview i

i The inspector met with the licensee's representatives (denoted in Section 1 by an esterisk) at the conclusion of the inspection on August 12, 1988 and summari:ed the scope and findings of the inspection, a

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ATTACHMENT 1 l

CRITE.RIA..FOR CCMpARING ANALYTICAL MEASUREMENTS i

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This attachment provides criteria for comparing results of capability tests  ;

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i and verification measurement The criteria are based on an empirical l

i relationship which combines prior experience and the accuracy needs of this t

l progra I In these criteria, the judgement limits are variable in relation to the

comparison of the NRC Reference Laboratory's value to its associated

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r uncertainty. As that ratio, referred to in this program as "Resolution",

] increases the acceptability of a licensee's measurement should be mere

i i selective. Conversely, poorer agreement must be considered acceptable as the {

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resolution decrease !

i i Resolution 1 Ratio For Agreement?

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.l <3 No ecmparison i

] 4-7 0.5 - 2.0

) 8 - 15 0.6 - 1.66 )

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16 - 50 0.75 - 1.33 l 1 51 - 200 0.80 - 1.25 '

l >200 0.85 - 1.18 L ,

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• Resolution = (NRC Reference Value/ Reference Value Uncertainty) i

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2 Ratio = (Licenn Value/NRC Reference Value)

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