IR 05000341/1989009

Insp Rept 50-341/89-09 on 890306-10.No Violations Noted. Major Areas Inspected:Plant Chemistry & Radiation Protection Organization,Mgt Controls,Qa,Confirmatory Measurements for in-plant Radiochemical Analysis,Audits & Environ Monitoring

ML20248B280
Person / Time
Site:	Fermi
Issue date:	03/27/1989
From:	Bocanegra R, Januska A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248B242	List: IR 05000341/1989009 ML20248B236
References
50-341-89-09, 50-341-89-9, NUDOCS 8904100364
Download: ML20248B280 (10)

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V. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/89009 (DRSS)

Docket No. 50-341 License No. NPF-43 Licensee: The Detroit Edison Company 6400 North Dixie Highway Newport, MI 48166 Facility Name: Fermi 2 Inspection At: Fermi Site, Newport, Michigan l

Inspection Conducted: March 6-10, 1989 Inspector:

%R. Bocanegra #

8 h M9 Date Q . fhbe+YM A. G. Januska Date Approved by:

YW M. Schumacher, Chief W g}p/pp Radiological Controls Date and Chemistry Section Inspection Summary Inspection on March 6-10, 1989 (Report No. 50-341/89009(DRSS))

Areas Inspected: Routine unannounced inspection of confirmatory measurements including: plant Chemistry and Radiation Protection organization, management controls, quality assurance, confirmatory measurements for in plant radiochemical analysis, audits, and environmental monitoring (IP 84750 and '

IP 84725); training and qualifications (IP 83723) and review of action taken on open items (IP 92701).

Results: Laboratory quality contrc.1 and confirmatory measurements results were good. An inspector's concern regarding an expired calibration standard was quickly resolved. Some reorganization of responsibilities has occurred including the assignment of radiological effluents responsibilities to Radiation Protection (Radioactive Effluents Group). Chemistfy and Radiation Protection personnel involved in radiological effluents are properly trained and qualified to perform their responsibilitie No violations or deviations were identified.

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k 8904100364 890327 R l PDR ADOCK 05000341 l O PDC '

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• a DETAILS Persons Contacted 2R. Anderson, Radiation Protection Manager 2P. Anthony, Compliance Engineer 2S. Bartman, Principal Engineer,' Radiological Effluents 1S. Catola, Vice President, Nuclear Engineering and Services 2R. Eberhardt, Superintendent, Radiation Protection 2P. Fessler, Director, Plant Safety 20. Gipson, Plant. Manager

• L. Goodman, Director, Nuclear Licensing ,

J. Heins, Auditor, Quality Program. Ass'urance 2E. Kokosky, Supervisor, Radiation Protection R. Nearboof,' Chemistry Specialist 2S. Orser, Vice President, Nuclear Operations j

'T. Riley, Supervisor, Compliance- i K. Shields, Chemist R. Smerigan, Senior Environmental Technician  !

2F. Sventhovitch, Assistant to Plant Manager l 2W. Rogers, NRC Senior Resident Inspector

'S. Staseck, NRC Resident Inspector 2Present at the entrance or exit meeting . Licensee Action on Previously Identified Findings (IP 92701)

(Closed) Open Item (50-341/87032-01): Analyze a liquid waste sample ,

for H-3, Sr-89, and Sr-90 and report the results to Region II !

Results of sa mle comparisons are given in Table-1; the comparison  !

criteria are ,iven in Attachment 1. Agreement resulted for H-3 and Sr-89. The results for Sr-89 were not compared due to poor counting statistic This item is closed.-

(Closed) Open Item (50-341/87032-02): Determine appropriate gas absorption correction factors and recalibrates if necessary by August 21, 1987. .The licensee employed a number of techniques to determine the cause of the gas disagreements. They also examined studies performed to compare.absorptior ' actors between gas and simulated gas measurements. Their findings, t ied on the independent studies and

- comparing foam standard results with the results of a newly acquired calibration gcs standard, indicate that attenuation in the low density foam standard is not a significant contribution to the disagreements, but that the differences in vial shape probably did contribute to the l disagreement The validity of their current calibration was verified

. by comparisons made during this inspection. This item is close '

(Closed) Open Item (50-341/87032-03): Investigate the causes of disagreements in the discrepant geometries by July 28, 1987, and recalibrates as necessary by July 31, 1987. Calculations performed by

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the licensee showed that the calibrations in question were accurate, but

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a technical problem in the licensee's software, specifically APS.LIBEDT, was found on a backup dis This disk had been used to rebuild the main disk after a head crash. The program was corrected, installed, and tested on August 7, 1987 and procedures were changed to require tests for backup disk (Closed) Open Item (50 341/87032-04): Review liquid waste results back to June 1,1987 and make necessary corrections. The licensee reviewed effluent surveillance performed between June 1 and August 7, 1987, the period in which the deficient software was operating and found no instances where the software errors had any effect on the dat '

3. Organization and Training (IP 84750; 83723)

The inspectors reviewed changes in Chemistry organization since the last confirmatory measurements inspection in July,198 Responsibility for radiological effluents was transferred from Chemistry to Radiation Protection (Radioactive Effluents Group) in August 1988. Chemistry's responsibility is now limited to sampling i radioactive liquid effluents and other non effluent counting. The Radiation Protection Instrumentation Group is responsible for radioactive liquid effluent analysis, and radioactive gaseous effluent sampling, analysis, and initial review of results. Final review of results for all radioactive effluents is performed by the Radioactive Effluents Grou The inspectors reviewed qualification documents for 20 Chemical Technicians, a Radiation Protection Supervisor, and the Principal Engineer, Radioactive Effluents, and found them to be qualified in accordance with ANSI-N18.1-197 No violations or deviations were identifie . Confirmatory Measurements (IP 84750; 84725) Quality Assurance The inspectors reviewed the radioactivity measurements laboratory quality assurance oroaram 1.1cluding the physical facilities, laboratory operations, and procedures. Housekeeping was generally good; laboratory and counting room working space was

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i ample. A Radiation Protection Technician and a Chemistry Technician were observed and evaluated on sample acquisition, preparation, analysis, and general laboratory practices. The technicians appeared to be knowledgeable, followed proper laboratory procedures, and took appropriate precautions when <

handling radioactive material !

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Instrument quality control involves plotting daily check source I results, yearly recalibrations, and participating in an  !

inter-laboratory comparison program. The inspector. reviewed a sampling of germanium detector calibration records and instrument control charts for 1988. The inspector also reviewed selected  ;

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procedures including Radiochemistry Procedure NPP-76.000.05 Rev. 6,

" Operation of the Chemistry ND-6685", Administrative Procedures NPP-CHI-02 Rev. 0, " Chemistry Quality Verification",

NPP-MT1-01 Rev. O, " Measuring and Test Equipment Program", and POM 71.000.10 (SQ) Rev. 5, " Calibration of Chemistry Equipment".

During the record review, the inspectors noted that Health  ;

Physics Detector 1 had been calibrated on February 9,1989 using '

an expired calibration source. The licensee had counted the calibration source for a longer period than normal to attain the number of counts recommended.in ANSI 42.14-1978 Section.4.2. Further investigation revealed that Procedure 64.000.208,

" Efficiency Calibration of the ND-6685 Gamma Spectroscopy System" failed to address or caution against the use of old or l expired sources. The inspectors found that the superseding '

procedure, NPP-66.000.220, " Efficiency Calibration of the ,

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NO-6685 Gamma Spectroscopy System" effective 3/6/89 was also 1 inadequate and requested the licensee to take corrective actio Before the end of the inspection, the licensee produced documents that showed Procedure NPP-66.00.220 had been revised, reviewed, approved, and was in place in response to the inspectors' concern The confirmatory measurements part of this inspection verified that measurements performed using the detector in question produced results within the acceptance criteri The licensee participates in an intercomparison cross-check program with an outside vendor. The-inspectors examined portions of the 1987 and 1988 intercomparison results for Chemistry and Health Physics. Chemistry Group had a small percent of disagreements in 1987 The inspectors noted that appropriate corrective action was taken and that the results had improved to 100% agreement in the last three quarters examined. The Radiation Protection Group also had very few disagreements in 1987. By the 1st Quarter 1988 the results had improved to nearly 100% agreement The causes of disagreements was found and corrected in all case The inspectors also reviewed a sampling of 1987 and 1988 results of technician proficiency testing'for various radiological analyse The results reviewed showed that all technicians passed on the first attemp The Lower Limit of Detection (LLD) is the smallest concentration of radioactive material in a sample that will yield a detectable net coun The licensee is required to meet LLD limits found in Technical Specification 3/4 11. At the inspector's request, an LLD was determined by the licensee for the one liter liquid marinelli geometry using vendor supplied software. Then, a hand calculation was performed for comparison and found to agree with the vendor's software valu _ _-- ______ _ __- __ ___ -____-__ - _ _ - _ . _ _ _ _ _ . _-_ _ _ _ _ - - _ - - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

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. Sample Split Seven samples (particulate air filter, spiked particulate air filter, charcoal adsorber, reactor coolant, liquid waste, crud filter, and gas standard) were analyzed for gamma emitting l nuclides by the licensee and in the Region III Mobile Laboratory '

on sit Comparisons were made with the licensee's two chemistry detectors and two health physics detectors. The licensee achieved 50 agreements in 53 comparisons as listed in Table 2; the comparison criteria are given in Attachment l Of the 53 nuclides compared in the seven samples, the reactor l coolant and liquid waste samples accounted for all three disagreements. The reactor coolant sample analysis produced disagreements for Ce-141 and Ce-144 on Chemistry Detector 1 when the licensee's system failed to identify these nuclides. The inspectors reviewed the NRC's and licensee's instrument software I and hardware parameters to try to resolve the disagreements. A I line by line inspection of a hard copy of the licensee's analysis spectrum indicated that poor peak shape, due to low activity levels, was the cause of the disagreements. The liquid waste sample analysis yielded a disagreement for Mn-54 on Health Physics Detector 2; again, the licensee failed to identify the nuclide. The same sample had earlier been analyzed on Health Physics Detector 1 and Mn-54 had been correctly identified and quantified. After investigating, the inspectors concluded that the licensee had failed to identify Mn-54 because of settling and plate-ou A portion of a liquid waste sample will be analyzed for gross alpha, H-3, Sr-89, Sr-90, and Fe-55 by the licensee and the results reported to Region III for comparison with an analysis by the NRC reference laboratory on a split of the sample. (0 pen i Item 50-341/89009-01)

' Audits The inspectors reviewed QA audit number QA 88-0022 conducted March 21-31, 1988 dealing with the performance, effectiveness, and adequacy of Chemistry and Radiochemistry Programs, and QA 88-0181 conducted September 19-30, October 6,7, and 11, 1988 dealing with the activities that affect the performance of Fermi's environmental protection program. Both of the audits were performance oriented and comprehensive. The auditors appear to j be qualified for the audits performed and technical input is used in the report Environmental Monitoring The inspectors examined the 1987 Annual Radiological Environmental Operating Report. The report indicates that the program is being implemented properly and that the results do not indicate a significant contribution to the environment due to plant operatio c__-___________ _ ._ _

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An inspector. accompanied the Environmental Technician while he exchanged-air particulate and charcoal filter samples in the fiel The technician conducted himself very well during.the inspection and demonstrated that he was very knowledgeable of the. details of the entire program. A'REMP Filter Log Book used by the Technician was examined by'the inspector. It contained data sheets,

!: procedures, pertinent Technical Specifications, and other materials related to exchanging environmental air filters. The log-book is well organized and a good reference for the person i performing the filter exchang No violations or deviations were identified.

1 Open Items-l Open Items Open items are matters which have been discussed with the-licensee, which will'be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Section . Exit Meeting (IP 30703) I The inspectors met with licensee representatives denoted in Section 1 at the conclusion of the inspection on March 10, 1989. The scope and findings of the inspection were discussed including the good results of the confirmatory measurements that reflects the efforts put into the radiochemistry program since the last inspection in 1987.' The inspector also discussed a problem regarding a' detector calibrated using an expired calibration source and noted that an Open Item would not be initiated since the geometry in question was confirmed during this inspection, and corrective action had been prompt and appropriat The inspector discussed the likely informational content of.the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee representatives did 7.ot identify any such documents or procedures as proprietar L Attachments: . Attachment 1, Criteria for l Comparing Analytical j Measurements Table 1, Confirmatory Measurements Program Beta Analysis Results, (

3rd Quarter 1987 ' Table 1, Confirmatory Measurements Program Results,1st Quarter 1989

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ATTACRMENT1 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 )

i In these criteria, the judgment limits are variable in relation to the comparison l of the NRC's value to its associated one sigma uncertainty. As that ratio, referred to in this program as " Resolution", increases, the acceptability of a i licensee's measurement should be more selective. Conversely, poorer agreement l should be considered acceptable as the resolution decreases. The values in the ratio criteria may be rounded.to fewer significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement

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15 0.6 - 1.66 '

16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25 200 - 0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides. These may be factored into the acceptance criteria and identified on the data shee .

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TAB'LE 1 U.S.. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT l

CONFIRMATORY MEASUREMENTS PROGRAM l

FERMI 2 DATE: 3rd QUARTER 1987 l

SAMPLE NUCLIDE NRC VAL. NRC ER LIC. VAL. LIC. ERR. RATIO RESOL. RESULT

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FLOOR H-3 3.37E-04 9.OOE-06 2.84E-04 0.OOE+00 0.84 3 A DRAfN SR-90 6.90E-08 1.20E-08 5.89E-08 0.OOE+00 0.85 A l

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TABLE 2 U S NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREME TS PROGRAM FACILITY: FERMI-2 f FOR THE 1 OUARTER OF 1989

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LICENSEE---- ---LICENSEE:NRC-ERROR RESULT ERROR RATIO RES T SAMPLE ISOTOPE RESULT CR-51 2.0E-02 6.9E-05 2.2E-02 8.3E-05 1.1E GO 2.9E 02 A FRIMARY MN-54 5.8E-05 2.3E-06 6.0E-05 2.3E-06 1.0E 00 2.6E 01 A CN'2 CO-58 2.5E-04 3.7E-06 2.6E-04 d 4E-06 1.0E 00 6.8E 01 A 5.8E-05 2.5E-06 1.1E 00 2.7E 01 A CO-60 5.?E-05 1.9E-06 .

1.1E 00

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l ZN-65 2.eE-04 5.8E-06 2.9E-04 7.3E-06 4.5E 01 A j

! AS-76 2.6E-04 8.1E-05 4.2E-04 8. 6E--05 1.6E 00 3.3E 00 A l AG-110M 2.0E-05 1.7E-06 2.4E-05 0.0E-01 1.2E 00 1.2E 01 A (

NA-24 2.6E-03 3.3E-04 2.1E-03 3.0E-03 8.3E-01 7.8E 00 A j RCS FILT CR-51 1.EE-03 5.4E-06 1.8E-03 8.5E-06 1.0E 00 3.3E 02 A MN-54 2.8E-05 4.1E-07 2.6E-05 5.2E-07 9.5E-01 6.7E 01 A C H- l FE-59 5.1E-05 8.5E-07 4.8E-05 1.1E-06 9.3E-01 6.1E 01 A CO-58 3.6E-05 4.8E-07 3.4E-05 5.SE-07 9.3E-01 7.5E 01 A Grems CO-60 2.3E-05 3.6E-07 2.3E-05 5.4E-07 1.0E 00 6.4E 01 A ZN-65 2.9E-05 7.0F"07 2.7E-05 8.4E-07 9.6E-01 4.1E 01 A AS-76 9.8E-05 1.0E-05 9.6E-05 1.4E-05 '9.9E-01 9.8E 00 A ZR-95 1.5E-05 5.0E-07 1.5E-05 6.3E-07 9.7E-01 3.0E 01 A SB-124 1.0E-06 1.8E-07 1.2E-06 2.5E-07 1.2E 00 5.7E 00 A CE-141 9.3E-07 2.1E-07 0.0E-01 0.0E-01 0.0E-01 4.4E 00 D CE-144 3.0E-06 6.9E-07 0.0E-01 0.0E-01 0.OE-01 4.4E 00 D C FILTER I-131 1.1C-12 1.3E-13 1.1E-12 1.0E-13 1.1E 00 8.1E 00 A H P- l 1-133 5.0E-12 9.1E-13 3.3E-12 3.2E-13 6.7E-01 5.4E 00 A :

P FILTER NA-24 2.1E-11 2.0E-12 2.1E-11 1.4E-12 1.0E 00 1.1E 01 A H P-l i C FILTER I-131 1.1E-12 1.3E-13 1.2E-12 9.5E-14 1.2E 00 8.1E 00 A H P- .OE-12 9.1E-13 5.2E-12 4.6E-13 1.0E 00 5.4E 00 A G SP1KED CO-57 7.1E-03 1.0E-04 2.6E-03 1.5E-04 8.6E-01 3.0E 0' A c H CD-109 1.7E-01 3.6E-03 1.dE-01 4.2E-03 8.8E-01 4.8E 01 A SN-113 1.1E-03 2.3E-04 1.1E-03 3.7E-04 9.9E-01 5.0E 00 A

T TEST RESULTS:

A= AGREEMENT D= DISAGREEMENT

• = CRITERIA RELAXED N=NO COMPARISON

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U S NUCLEAR REGULATORY COMMISSION  !

OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENT 5 PROGRAM i FACILITY: FERMI-2 ,

FOR THE 1 QUARTER OF 1989 )

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SAMPLE ISOTOPE PESULT ERROR RESULT ERROR RATIO RES T G SPIKED CE-139 6.3E-04 1.2E-04 7.7E-04 1.3E-04 1.2E 00 5.3E 00 A L WASTE NA-24 1.5E-04 1.5E-06 1.7E-04 1.4E-06 1.1E 00 9.9E 01 A i CR-51 1.3E-04 2.2E-06 1.4E-04 1.7E-06 1.1E 00 5.8E 01 A HPl MN-54 7.9E-07 2.ie-07 4.7e-07 1.2E-07 5.9E-01 3.eE 00 A CO-58 6.6E-07 1.8E-07 7.6E-07 1.1E-07 1.2E 00 3.7F 00 A )

ZH-65 3.3E-06 6.8E-07 3,4E-06 3.7E-07 1.0E 00 4. 9i 00 A 1 AS-76 8.7E-06 5.6E-07 8.2E-06 3.6E-07 9.4E-01 1.55 01 A {

I-131 3.7E-07 1.5E-07 3.4E-07 9.2E-JS 9.1E-01 2.5E 00 A l

I-133 4.0E-06 3.6E-07 3.7E-06 2.1E-07 9.3E-01 1.1E 01 A G SPIKED CO-07 3.1E-03 1.0E-04 2.9E-03 1.4E-04 9.3E-01 3.0E 01 A ,

CD-109 1.7E-01 3.6E-01 1.5E-01 4.0E-03 8.7E-01 4.8E 01 A Mme C b"! SN-113 1.1E-03 2.3E-04 1.1E-03 3.0E-04 9.7E-01 5.0E 00 A =

CE-139 6.3E-04 1.2E-04 5.5E-04 1.2E-04 8.8E-01 5.3E 00 A J L WASTE NA-24 1.5E-04 1.5E-06 1.7E-04 1.7E-06 1.1E 00 9.9E 01 A g CR-51 1.3E-04 2.2E-06 1.5E-04 2.3E-06 1.1E 00 5.8E 01 A j MN-54 7.9E-07 2.1E-07 0.0E-01 0.0E-01 0.0E-01 3.8E 00 D !

CO-58 6.6E-07 1.8E-07 8.8E-07 1.5E-07 1.3E 00 3.7E 00 A ZN-65 3.3E-06 6,8E-07 3.2E-06 5.2E-07 9 6E-01 4.9E 00 A i

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AS-76 S.7E-06 5.6E-07 8.1E-06 5.5E-07 9.2E-01 1.5E 01 A I-131 3.7E-07 1.5E-07 4.7E-07 1.2E-07 1.3E 00 2.5E 00 A I-133 4.0E-06 3.6E-07 4 OE-06 2.7E-07 1.0E 00 1.1E 01 A F SPIKED CO-57 2.2E-03 4.8E-05 2.3E-03 3.9E-05 1.0E 00 4.7E 01 A CO-60 1.4E-02 2.7E-04 1.3E-02 1.9E-04 9.6E-01 5.2E 01 A H P-l CD-109 2.2e-01 2.le-03 2.4e-01 0.0E-01 1.1E 00 1.0E 02 A CS-137 2.8E-02 3.2E-04 2.7E-02 2.1E-04 9.7E-01 8.7E 01 A l CE-139 2.7E-04 3.8E-05 2.4E-04 2.4E-05 9.1E-01 7.0E 00 A T TEST RESULTS:

A=AGREEMEN~

D= DISAGREEMENT

+= CRITERIA RELAXED N=NO COMPARISON

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