IR 05000321/1986021

Insp Repts 50-321/86-21 & 50-366/86-21 on 860714-18. Violation Noted:Failure to Perform Adequate Surveys for Effluent Releases

ML20212K284
Person / Time
Site:	Hatch
Issue date:	07/31/1986
From:	Harris J, Stoddart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20212K283	List: IR 05000321/1986021 ML20212K279
References
50-321-86-21, 50-366-86-21, NUDOCS 8608190364
Download: ML20212K284 (8)

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UNITE D STATES NUCLEAR REGULATORY COMMISSION

[ n- REGION 11 g j 101 MARIETTA STREET. '* t ATLANTA, GEORGI A 30323

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Report Nos.: 50-321/86-21 and 50-366/86-21

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Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Conducted: July 14-18, 1986 Inspector: h, b. hunh 7- M E b J.p. Harris ~ 0 ate Signed Accompanying Per nel: 4 L. Froemsdorf Approved by: N Yld P7 G. Tto301rt, Acting Section Chief Y[

Date' Signed Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection was in the areas of review of the Radiochemistry Quality Control (QC) program organization and related procedures, QC records, calibration records, and comparison of the results of split samples analyzed by the licensee and NRC Region II mobile laborator Results: One violation was identified - Failure to perform adequate surveys for effluent release i 8608190364 860806 PDR ADOCK 05000321 Q PDR

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REPORT DETAILS Persons Contacted Licensee Employees B. C. Arnold, Chemistry Supervisor

• V. McGowan, Chemistry Supervisor J. M. Bray, Senior Quality Assurance Field Representative D. J. Elder, Senior Quality Assurance Field Representative -

B. Roberts, Laboratory Foreman, Chemistry G. Fuqua, Health Physics Specialist

• L. G. Byrnes, Senior Nuclear Engineer

• W. B. Kirkley, Health Physics / Chemistry Engineering Supervisor

• C. R. Goodman, Regulatory Compliance Engineer

• T. L. Elton, Regulatory Compliance Supervisor

• K. B. Allison, Quality Assurance

• W. H. Rogers, Health Physics / Chemistry Superintendent

• A. Fraser, Quality Assurance Superintendent

• T. Greene, Deputy General Manager Other ifcensee employees contacted included several Health' Physics / Chemistry technician NRC Resident Inspectors

• P. Holmes-Ray

• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 18, 1986, with those persons indicated in Paragraph 1 above. One violation (Paragraph 7)

concerning failure to make adequate surveys for radioactive material . in gaseous releases was discusse The inspector discussed areas for improvement in the laboratory QA program and the licensees commitment to evaluate the QA program. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Radiochemistry Quality Control Program (84725)

The inspector reviewed selected portions of the Quality Assurance Program with cognizant licensee representatives and determined that organizational structure and program management had not changed significantly since the previous confirmatory measurements program (50-321/85-01, 50-366/85-01).

The inspector noted that some improvements in the QA program had been mad The licensee now participates in an interlaboratory comparison program with a vendor laboratory. However, the inspector identified several areas in the QA program that could be improved. The major observation was that the QA e

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program is segmented with no clear mechanism to provide an integrated look at all the elements in the program. The intercomparison studies are handled by one individual, the daily check trends are handled by the gamina spectroscopy computer and only provides warning flags if a parametec is out of bounds, and different aspects of calibrations are handled by different peopl Divisions between QA elements such as these reduce the possibilities of detecting and correcting adverse ~ measurement performance before serious deficiencies aris The inspector noted that calibration records can be difficult to recover from the licensee document / records control system. The data for the current calibrations were recovered but not for the previous calibrations. The inspector found that for some geometries, records showed that confirmations were made of the new detector efficiencie Though not required by the written calibration procedures, such confirmations are considered good laboratory practice and, if done, they should be performed consistently for all possible geometries. The inspector was informed that the QA program is being reviewed by the corporate office to develop a uniform laboratory QA program for Hatch and Vogtle. The licensee agreed to evaluate the current QA program for improvements in regard to the inspector's comments. The results of this evaluation will be- reviewed in a subsequent inspection (IFI 50-321/86-21-01).

No violations or deviations were identifie . Audits (84725)

Technical Specification 6.5.2.8 requires that audits of activities shall be performed encompassing the conformance of unit cperations to provisions contained within the Technical Spacifications and license conditions at least once per 12 months, the Radiological Environmental Monitoring Program at least once per 12 months, and the Offsite Dose Calculation Manual and the Process Control Program at least once per 24 months. The inspector reviewed the following audit reports:

QA Audit 85-SC-1, Qualification / Training Technical Specification Surveillances (Chemistry Program), February 1985 QA Audit 85--SC-2, Sampling, Laboratory Activities, Quality Assurance /

Quality Control Program, May 1985 QA Audit 85-SC-3, Routine Radiochemistry Practices - Laboratory, Count Room, Post Accident Sampling System, September 1985 QA Audit 85-SC-4, Hazardous Substance Control, December 1985 QA Audit 86-SC-1, Quality Assurance / Quality Control Program, Reactor Feedwater Chemistry, Auxiliary Feedwater Chemistry, Records and Reports, April 1986 The inspector noted that the Site QA staff has personnel on the staff with expertise in the subject area. Additional personnel resources are available through the corporate office, other Georgia Power facilities, and contractors. The audits appeared to be thorough and programmatic in natur i f, .

The inspectof discussed the overall audit program and reviewed responses to audit findings with cognizant licensee personnel. The audit program addresses short - tern and long term corrective action Mechanisms and managerhent. support exist for the QA department to pursue additional corrective action if dissatisfied with proposed corrective action No violations or deviations were identifie S. Procedures (84725)

Technical Specification 6.8.1 requires written procedures to be established, implemen t.ed , and maintaine The inspector selectively reviewed the folicwing procedures. All procedures listed had been reviewed and approved as rcquired, CI-0CB-007-0, Internal Gas Flow Proportional Counter (NMC), Rev. O, June 11, 1985 CI-0CG-008-0, Well Counter System, Rev. O, June 11, 1985 P.CI-0CG-010-0, Grmma Spectrometer System Ge(L1), Rev. O, June 11, 1985 CI-0CB-021-0, EC&G Ortec Model 576 Dual Alpha Spectrometer, Rev. O, June 11, 1985 CH-SAM-010 0, Routiae Reactor Coolant Grab Sanipling, Rev. O, June 1, 1985 G2Cll-SAM-Oll-0, Routine Reactor Coolant Diluted Grab Sampling, Rev. O, June 1, 1985 CH-Salt-012-CS, Routine Drywell Atmosphere Grab Sampling, Rev. 1, March 1, 1986 CH-SAM-013-OS, Routine Drywell Atmosphere Diluted Grab Sampling, Rev. O, March 1, 1986 C,4-SAM-014-0, Post Accident Reactor Coolant Diluted Grab Sampling, Rev. O, June 11, 1985 CH-SAM-015-05, Post Accident Reactor Coolant Grab Sampling, Rev.1,

,luly 1, 1985 CI-CAL-002-0N, Laboratory Instrument Calibration and Preventative Maintenance, Rev. 1, November 18, 1985 CI-0PS-004-0, Gas Vial Sampler, Rey. O, June 11, 1985 CH-QCX-001-05, Quality Centrol for Chemical Analysis, Rev. 2, <

Febroary 28, 1986 CH-RCL-001-0, Strontiun Determination, Rev. O, June 11, 1985 m

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4 CH-RCL-002-0, Iodine and Particulate Release Monitoring, Rev. 1, November 29, 1985 CH-RCL-003-0, Gaseous Release of Tritium, Rev.1, December 5,1985 CH-RCL-005-0, Preparation of Samples for Counting, Rev. O, June 11, 1985 CH-RCL-013-0, Gaseous Waste Sample Analysis, Rev.1, November 29, 1985 CH-SAM-002-0, Sampling of Process Streams for Laboratory Analysis, Rev. O, June 11, 1985 CH-RCL-015-0, EPA Crosscheck Program, Rev. O, June 11, 1985 HI-0CB-064-0S, Tennelec LB 5100-1 and APC System Operation and b Calibration, Rev. O, April 14, 1986 CH-CAL-003-0, Radioactive Standards Preparation, Rev. O, December 5, 1985 CI-0CB-036-0S, Nuclear Data Gamma Spectrometer System, Rev. O, July 1, 1986 No violations or deviations were identifie . Records (84725)

The inspector reviewed selected portions of the following reccrds: Tennelec LB 5100 No. D31-N139, Daily Calibration Data for January -

July 1986 including:

(1) Alpha / Beta Performance Checks (2) Alpha / Beta Trend Charts (3) Alpha / Beta Background Data NMC Internal Gas Flow Proportional Counter No. D31-N003 Daily Calibration Data for January - July 1986 including:

(1) Alpha / Beta Source Checks (2) Alpha / Beta Background Data (3) Efficiency Determination (4) Dead-time Test Results (5) Alpha Results Well Counter Nos. D31-N121 & 031-N122 Daily Calibration Data for i January - July 1986 including:

(1) Daily Calibration Checks (2) Background Checks

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W 5 , Gamma Spectroscopy Detector System Nos. 1, and 2 1986 Efficiency Calibration Records for the following geometries: 14 cc gas vial, 47 mm millipore filter, charcoal cartridge, 50 mi bottle, and liter marinelli beaker, Gaseous Release Permits December 1985 - July 1986 No violations or deviations were identifie . Confirmatory Measurements (84725)

During the inspection, reactor coolant and selected plant effluent / process streams were sampled and analyzed for radionuclide concentrations using the licensee and NRC Region II Mobile Laboratory gamma ray spectroscopy system ,

The purpose of these comparative measurements was to verify the licensee's ability to measure radionuclides accurately in various plant systems and effluent streams. Licensee's counting geometries studied included the following: 1000 cc liquid marinelli, 1000 cc gas marinelli, 14 cc gas vial, -

50 mi bottle, 47 ml millipore particulate filter and charcoal cartridg Comparisons of licensee and NRC results are listed in Table 1 with the acceptance criteria given in Attachment The results showed agreement for the 50 m1 bottle, particulate filter, 14 cc gas vial, and 1000 cc liquid marinelli geometry. Three of five isotopes showed agreement for the 50 m1 bottle geometry, but a review of the calibration data and other validation checks indicate that the calibration was adequate. The inspector noted that there was some difficulty with the sample split s For the charcoal cartridge geometry, the inspector noted a high bias (>20%)

in the analysis for both detectors with one detector system in disagreemen This discrepancy could not be accounted for during the inspector's revie The results for the 1000 cc gas marinelli was in disagreement, biased high compared to the NRC results. Upon investigation, the inspector questioned the volume used for this geometry and requested the licensee to verify the volume for this geometry and the 14 cc gas vial. The licensee informed the inspector that 1000 cc had been used for approximately one year. The licensee's volume verification indicated an actual volume of approximately 1250 cc. This accounts for some of the problems noted in the disagreement between the licensee's measuremetits using this geometry, versus the NRC's measurement The inspector informed the licensee that this would be considered a violation; failure to make adequate surveys (50-321/86-02, 50-366/86-02). The inspector also noted that though agreement was obtained with the 14 cc gas vial geometry, the licensee used a 14 cc volume when the verified volume was approximately 14.5 c One violation was identified - failure to make adequate survey .

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TABLE 1 RESULTS OF CAMMA-SPECTROSCOPY CONFIRMATORY MEASUREMENTS AT E. 1. HATCH NUCLEAR POWER PLANT JULY 14-18, 1986 CONCENTRATION RATIO

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SAMPLE ISOTOPE LICENSEE NE RESOLUTION LICt NSEE/NRC COMPARISON (2) Reactor Coolant 1-132 8.81 E-4 1.33 .082 E-3 16 .66 D i sa g reement (50 mi bottle) 1-133 3.38 E-4 5.19 i .374 E-4 14 .65 Ag reemen t 1-134 2.56 E-3 5.91 i .516 E-3 12 .43 D i sag reemen t Tc-99m 1.27 E-2 1.44 i .008 E-2 180 .88 Ag reement Mn-56 2.08 E-3 2.77 i .110 E-3 25 .75 Ag reement (2) Liquid Waste 1-131 3.58 E-7 4.57 i .613 E-7 7 .78 Ag reemen t (1 L Ma ri ne l l i ) 1-133 7.42 E-7 9.16 1 1.26 E-7 7 .81 Ag reemen t Cs-137 8.38 E-7 7.74 i .780 E-7 10 1.08 Ag reemen t (1) Spiked Ba-133 5.26 E-2 4.00 t .031 E-2 129 1.32 D i sag reement Cha rcoa l Ca rt ridge (2) Spiked Ba-133 4.78 E-2 4.00 t .031 E-2 129 1.20 Ag reement Cha rcoa l Ca rt ridge (1) Spiked Co-60 9.32 E-3 9.12 i .184 E-3 50 1.02 Ag reemen t Pa rticulate Fil ter Cs-137 1.36 E-2 1.28 i .017 E-2 75 1.06 Ag reement (2) Spiked Co-60 8.7 E-3 9.12 i .184 E-3 50 .95 Ag reemen t Pa rticulate Filter Cs-137 1.24 E-2 1.28 i .017 E-2 75 .97 Ag reemen t (1) Pretreatment Cas K-87 1.40 E-3 2.28 1 .096 E-3 24 .61 *

D i sag reement 14 cc vial K-88 7.23 E-4 9.19 i .689 E-4 13 .79 Ag reemen t Xo-135 9.94 E-4 8.96 i .228 E-4 39 1.11 Ag reemen t (1) Post-t rea tment Ca s Xe-133 3.37 E-3 2.09 ! .097 E03 22 1.62 D i sa g reement 1250 cc Ma rinelli Xo-135 7.43 E-3 3.37 1 .075 45 2.20 D i sa g rooment

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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 progra In these criteria, the judgement limits are variable in relation to the comparison of the NRC's value to its associated uncertainty. As that ratio, referred to in this program as " Resolution," increases, the acceptability of a licensee's measurements should be more selective. Conversely, poorer agreement must be considered acceptable as the resolution decrease RATIO = LICENSEE VALUE NRC REFERENCE VALUE Resolution Agreement

<4 0.4 - .5 - .6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25

>200 0.85 - 1.18

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