IR 05000324/1982009

IE Insp Repts 50-324/82-09 & 50-325/82-09 on 820322-26 & 30-31.Noncompliance Noted:Stack Gas Samples Not Collected Per Approved Procedure from 810601-820324

ML20054G736
Person / Time
Site:	Brunswick
Issue date:	04/22/1982
From:	Evans C, Montgomery D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20054G707	List: BSEP-82-1068, Responds to NRC Re Violations Noted in IE Insp Repts 50-324/82-09 & 50-325/82-09.Corrective Actions: Rotameter Float Installed Correctly & Drawing Posted Showing Correct Point to Read Flow Level IR 05000324/1982009 ML20054G706 ML20054G712 ML20054G725 ML20054G728
References
50-324-82-09, 50-324-82-9, 50-325-82-09, 50-325-82-9, NUDOCS 8206220252
Download: ML20054G736 (10)

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+ UNITED STATES o,,

8 n NUCLEAR REGULATORY COMMISSION E REGION 11

$ S g 8 101 MARIETTA ST N.W.. SulTE 3100 9 s ATLANTA, GEORGIA 30303

Report Nos. 50-325/82-09 and 50-324/82-09 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Brunswick 1 and 2 Docket Nos. 50-325 and 50-324 License No. DPR-71 and DPR-62 Inspection at Brunswick site near Sout:5 ort, NC Inspector: ). /

C. D. Evans

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Date Signed j (/

Accompanying Personnel: P. C. McPhail Approved by: / , ~ )[ ric < // -D-V)-

D. H. Montgomer'y) Sect)on Chief, EPPS Branch 'Date Signed SUMMARY Inspection on March 22-26 and March 30-31, 1982 Areas Inspected This routine, unannounced inspection involved 86 inspector-hours on site in the areas of quality control and confirmatory measurements including: review of the laboratory quality control program; review of chemistry and radiochemistry procedures; airborne effluent accountability; and comparison of the results of split samples analyzed by the licensee and the NRC RII Mobile Laborator Results Of the four areas inspected, no violations or deviations were identified in three areas; one violation was found in one area (failure to follow approved proce-dure for sampling stack gas, paragraph 6f).

8206220252 820609 PDR ADOCK 05000324 O PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• G. J. Oliver, Environmental and Radiation Control Manager

• R. D. Pasteur, Environmental and Chemistry Supervisor

-*J. A. Kaham, E&C Foreman

• C. E. Robertson, E&C Project Specialist

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R. M. Poulk, Regulatory Compliance Specialist

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C. Dietz, Plant Manager R. E. Morgan, Plant Operations Manager Other licensee employees contacted included one technicia NRC Resident Inspector L. W. Garner

• Attended exit interview Exit Interview

The inspection scope and findings were summarized on March 31, 1982, with those persons indicated in paragraph I abov The violation disclosed herein was discussed. The Environmental and Radiation Control (E&RC)

, Manager acknowledged the violation and stated that an appropriate response

{ would be made to the Notice of Violation. The inspectors requested that an area with appropriate electrical power outlets be provided for the RII

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Mobile Laboratory. The licensee representatives agreed to provide these

facilities and inform the NRC by May 17, 1982 as to the location and date when the facilities would be available. In response to the inspector's request for an evaluation of the unresolved item in paragraph 8c, the j E&RC Manager agreed to provide a written response by May 17, 198 . Licensee Action on Previous Inspection Findings l

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(Closed) Infraction (324/80-38-01, 325/80-41-01) Failure to run annual

[ efFciency curves during the period of January 1978 to September 1980 as l required by Procedure 2201. The inspector noted that efficiency curves had l been performed for 1981 and that efficiency recalibrations were in process for 1982.

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(Closed) Infraction (324/80-38-01, 325/80-41-01) Failure to include the chemistry analytical balances in a calibration program as required by Chapter 6 of the Corporate Quality Assurance Manua The inspector noted that procedure RCT 301 requires annual calibration of the chemistry analytical balances by a certified NBS traceable calibration standard and QA qualified vendo _ _ _ _ _ _ , . - - , _ . _ - _

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(Closed) Infraction (324/80-38-08, 325/80-41-08) Failure . to adequately sample and analyze airborne particulate activity in samples from the Reactor Building roof -vents. The inspector noted that procedure RCT 2000 had been changed to ensure that a check of proper operation and condition of the particulate - charcoal sampling assembly at each changeou The-gamma spectral analysis program for the charcoal cartridge has also been changed to include identification of any particulate activity that may have by passed the filte . Unresolved Items Unresolved items are matters about which more _information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragrar.h 8 . Laboratory Quality Control Program The inspector reviewed the licensee's Quality Control Program for chemical and radiochemical measurements in the following areas:

(1) Assignment of Responsibility and Authority to Manage and Conduct the QC Progra The Radiation Control and Test Foreman is responsible for quality control associated with chemistry, radiochemistry, and the counting room. Specific quality control procedures are carried out by technicians under the supervision of the RC&T forema (2) Provisions for Audits / Inspections The RC&T Foren.an reviews the results of quality control docu-mentation associated with instrumentation to ensure that the QC program is being carried ou In addition, a plant surveillance program is conducted according to Procedure 0QA-2, " Conduct of Plant Surveillance Prog-am." Routine surveillances are performed monthly and include the environmental and effluent monitoring progra (3) Methods for Assuring Deficiencies and Deviations in the Program are Recognized, Identified and Corrected Specific quality controi checks with acceptance criteria are provided in the operat;ng procedures for the chemistry and counting room instrumentatio Items that are discovered during plant surveillances and need corrective action are brought to he attention of the Director - Nuclear Safety and QA. Action items are established to ensure corrective action is accomplished according to plant procedures. Follow-up on outstanding action items are performed to assure that corrective action has been take "

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(4) Quality Control of Purchased and Contracted Analyses No chemical or radiochemical analyses are contracted to outside vendors. Analyses of liquid eff?uent samples for_ radiostrontium are performed by CP&L's Harris Energy and Environmental Cente Vendors supplying radioactive standards are' required to be on an approved vendor list -as determined by a Corporate . Quality Assurance audit, The inspector noted that _ the licensee was participating in the Gamma-Round Robin Counting Program coordinated through CP&L's Harris Energy and Environmental Center. The licensee's-results of. the last round robin sample were determined to be within the acceptance criteria for agreemen This closes a previously identified inspector followup item (324/80-38-04, 325/80-41-04). Review of Chemistry and F.adiochemistry Procedure The inspector reviewed the following procedures:

(1) RC&T 2201, Calibration / Operation of the ND 6600 Multichannel Analyzer, 12-4-8 (2) RC&T 2202, Operation and Calibration of Packard Liquid Scintillation Counter, 4-28-8 (3) RC&T 2020, Stack and Building V<,t Radioactive Gaseous Release Setpoints, 12-4-7 (4) RC-EP-6, Determination of Counting Efficiency factors for the -

Bect nan Widebeta II Proportional Counter,1-30-8 (5) RC&T 1215, Analysis For Strontium-Yttrium, 12-27-7 (6) E&RC 1210, Determination of Radioiodine,1-27-7 (7) E&RC 1211, Analysis for Radioiodine in Iodine Collection Cartridges, 12-11-8 (8) RC&T 1212, Gaseous Marincili Beaker and Serum Vial Standard Preparation for GeLi-Detection Calibration, 4-6-8 (9) RC&T 1230, Tritium Analysis of Liquid Effluents,12-4-7 (10) RC&T 1231, Tritium Analysis of Airborne Ef fluents,12-4 -8 (11) E&RC 2000, Radioactive Airborne Effluent Releases and Reports, 12-23-8 (12) RC&T 1520, Analysis of Drywell and Torus Gas Samples for Hydrogen, Oxygen and Nitrogen by Gas Chromatography, 9-7-8 .

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(13) RC&T 1200, Radioactive Liquid Waste Analysis, 3-25-8 (14) RC&T 2203, Calibration and Operation . of Particulate. Counters, 9-7-8 The results of the procedure review were discussed with licensee representatives as noted in paragraphs 6b.-6 The inspector noted that the background determination and the MDA formulas in procedure RC&T 1270, " Minimum Detectable Activity", had been changed to reflect accepted practice. This closes a previously identified item (324/80-38-06, 325/80-41-06). The inspector reviewed procedure RC&T 2203, " Calibration and Operation of Particulate Counters", and noted that it had been changed to specify Cs-137 as the radionuclide to be used for the particulate counter efficiency calibratio This closes a previously identified item (324/80-38-07,325/80-41-07).

The inspector reviewed RC-ER-6, " Determination of Counting Efficiency factors for the Beckman Widebeta II Proportional Counter", and a letter of agreement between CP&L's Harris Energy and Environmental Center and -

the plant manager requiring plant approval on all procedures used _ by the Harris Center for radiostrontium analysi The inspector had no further questions. This closes a previously identified item (324/80-38-05,325/80-41-05). The inspector noted that procedure RC&T 1200, " Radioactive Liquid Waste Analysis", hed been changed to include sample preservation for aliquots of liquid we.ste sent to the Harris Energy and Environmental Center for radiostrontium analysis. This closes a previously identified item (324/80-38-03,325/80-41-03). The inspector noted that procedure RC&T 2201, " Opera tion and Calibration of the ND 6600 Multichannel Analyzer", had been changed to include performance checks with acceptance criteria for the Ge(Li)

gamma spectroscopy system. The inspector verified that the performance checks are being implemented as required by procedure. This closes a previously identified item (324/80-38-02, 325/80-41-02), The inspector observed that sampling for stack off-gas had been changed from the use of a marinelli beaker to the use of a gas syringe for sample collectio The approved procedure RCT 2000, " Radioactive Airborrie Effluent Releases and Reports", specifies the collection of stack off-gas by connecting a marinelli beaker inline between the inlet and outlet quick disconnects, establishing flow, and then isolating the marinelli beaker by removal from quick disconnects. The change to the procedure deleted the gas marinelli beaker as the sample collector, and permitted extraction of stack off-gas with a syringe injected into tygon tubing between the quick disconnects. The gas syringe is then injected into an evacuated 14 ml gas vial for counting. The inspector was

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informed by licensee representatives that the change in sampling technique had been_ .in effect since June 1981, and had been made to reduce detector dead time and to change to a better calibrated gas geometry; however, the approved procedure had not been modified to reflect the changes in sampling technique. The inspector expressed concern that comparisons conducted by the-licensee of the two sampling techniques showed that the gas syringe technique was forty percent lower for all noble gases. The inspector informed licensee representa-tives that failure to collect samples in accordance with approved procedures was a violation of Technical Specification Licensee representatives acknowledged the violation. The inspector requested that an evaluation of the differences in the two sampling techniques be performed and be included in the response to the violation (324/82-09-01, 325/82-09-01). Review of Instrument Records and Logs The inspector reviewed selected portions of the following records and logs:

(1) GeLi Detector Reliability Checks, February - March 198 (2) GeLi Detector Resolution Checks, February - March 198 (3) GeLi Detector Efficiency Calibration Records,198 (4) Gaseous Release Records for Unit 2 Reactor Building Vent, March 1-22, 198 (5) Gaseous Release Records for the Stack, March 1-22, 198 (6) Iodine and Particulate Release Records for Unit 2 Reactor Building Vent, March 1-22, 198 (7) Iodine and Particulate Release Records for the Stack, March 198 The inspector discussed the record review as noted in paragraph 7 _ The inspector noted that the gas geometry calibrations had been performed with a Xe-127 gas standard which does not provide a sufficient number of calibration points to cover the energy range of interes This apparently resulted in an inaccurate efficiency calibration curve at the lower energy range. Examination of the ef ficiency calibration curves for the 1260 ml gas marinelli indicated that Xe-133 releases from the Reactor Building and Turbine Building Vents would have been overestimated. Licensee representatives stated that recalibration of the gas geometries would be carried out as soon as possible with mixed NBS gas standard of Xe-127, Xe-133, and Kr-8 The gas geometry recalibrations will be reviewed in a subsequent inspection (324/82-09-02, 325/82-09-02).

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8. Confirmatory Measurements Liquid and gaseous samples were collected during this inspection and counted by the licensee and the NRC RII Mobile Laboratory to verify the licensee's capability to measure radionuclides in effluent and reactor coolant samples. Samples were analyzed by gamma ray spectroscopy and included: a floor drain collector tank sample, a stack particulate filter, two stack charcoal cartridges, a stack off gas sample, and a reactor coolant sample. An aliquot of the liquid sample was sent to the NRC contract laboratory for tritium and radiostrontium analyse The results will be compared to licensee results in a subsequent inspection report (324/82-09-03, 325/82-09-03). The comparisons of licensee and NRC results are presented in Tables I with acceptance criteria in Attachment 1. The results show agreement for all samples except the stack charcoal cartridge collected on March 22, 1982 and the stack off gas sample which are discussed respectively in paragraphs 7b and 7 The comparison of stack gas samples shows agreement or possible agreement for all radionuclides except Kr-85m. 'he inspector noted that the licensee's spectral analysis had overest. mated the net area

, for the Kr-85m and Kr-87 photopeaks; and that the overestimate of the

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photopeak areas was caused by the failure of the software to distin-guish between multiplet photopeaks. The inspector requested licensee representatives to to reanalyze the data using modiried parameters to allow for greater resolution of multiplets. The recalculated results are in parentheses in Table 1, and illustrate the improvement seen by the peak parameter modification. A licensee representative agreed to l evaluate and optimize the peak parameter settings. This area will be i reviewed in a subsequent inspection after recalibration of the detectors with NBS mixed gas standard (324/82-09-04, 325/82-09-04).

l The results of the comparison between the NRC and the licensee for the i stack charcoal cartridge collected on March 22, 1982 showed that the licensee values were fifty percent lower for all radiciodine The i inspector determined that the difference was attributable to counting l the charcoal cartridge with the side containing the deposited activity away from the face of the Ge(Li) detector. The licensee had assumed that the side of the charcoal cartridge marked by an arrow as the inlet side was correct when it was not. The error was caused by the improper placement of the outlet face of the charcoal cartridge into the inlet side of the particulate-charcoal sampling assembly during the preceding changeout of the charcoal cartridg Examination of the stack particulate-charcoal sampling assembly by the inspector on March 25, 1982 also revealed improper placement of the charcoal cartridge. The l inspector expressed concern that this problem may not have been an isolated occurrence, but may have been repeated by one or more technicians. The inspector also noted that the measured flow rate is I not corrected for differences in pressure at the particulate-charcoal l sampling assembly and at the stack discharge. The pressure at the particulate-charcoal sampling assembly was measured at 23 inches Hg on a

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uncalibrated vaccum gauge. Failure to correct for pressure difference could result in over estimating sample flow rate and under reporting particulate and radioiodine release This item shall remain unresolved pending further investigation by the licensee to determine the extent of the improper placement of charcoal cartridges, the correction factor for flowrate, and the effect of both concerns on effluent accountability (324/82-09-05, 325/82-09-05). A second comparison of a stack charcoal cartridge was made with the licensee counting the side of the charcoal cartridge containing the deposited activity towards the face of the detector. All radioiodines were in agreement when the charcoal cartridge was counted in the correct orientatio This closes a previously identified item concerning charcoal cartridge calibration (324/80-38-10, 325/80-41-10).

The inspector reviewed licensee results for H-3 and Sr-89 and Sr-90 analyses of a floor drain storage tank collected during the previous inspection. The comparison of licensee and NRC analyses are given in Table 1, with acceptance criteria in Attachment 1. The comparisons shows agreement for H-3, but radiostrontium levels were to low for a meaningful comparison. This closes a previously identified inspector followup item (324/80-38-09, 325/80-41-09).

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Unit 2 Reactor H 0 Co-60 1.85 E-03 1.21 E-03 1.52 12 Ag reemen t

• Mo-99 8.31 E-03 7.38 E-03 1.12 9 Ag reemen t Tc-99m 1.53 E-01 2.041.02 E-01 .75 102 Possible Agreement .

1-131 2.71 E-03 2.54 E-03 1.06 25 Ag reemen t 1-133 3.50 E-02 2.731.02 E-02 1.28 58 Possible Agreement floor Dra in Co-58 4.14 E-06 4.4' .31 E-06 .93 14 Ag reement *

Storage Tank-B Co-60 3.56 E-05 3.39 .09 E-05 1.05 42 Ag reemen t Mn-54 2.29 E-05 2.97 E-05 .77 37 Agreement fe-59 8.48 E-06 9.81.88 E-06 .86 11 Ag reemen t Cr-51 9.91 E-05 9.581.45 E-05 1.03 21 Ag reemen t 1-131 1.77 E-06 1.781.26 E-07 .99 7 Ag reemen t Stack Pa rticulate Cs-137 2.29 E-12 2.841.47 E-12 .80 6 Agreement Ba-140 4.29 E-12 4.69i.05 E-12 .92 100 Ag reemen t Stack Offgas kr-85m 4.68 E-05 2.551.11 E-05 1.83 23 Disagreement (3.75 E-05) (1.47) ( Possible Agreement)*

Kr-87 8.94 E-05 5.81127 E-05 1.54 21 Possible Ag reement (7.73 E-05) (1.33) ( Ag reement)*

Kr-88 9.81 E-05 6.991.42 E-05 1.40 16 Possible Agreement Xe-133 4.64 E-05 3.791.33 E-05 1.22 11 Ag reemen t Xe-135 1.79 E-04 1.16 .02 E-04 1.55 48 Possible Agreement Xe-135m 3.00 E-05 2.441.20 E-05 1.22 12 Ag reement Xo-138 1.06 E-04 7.96 .35 E-05 1.33 23 Ag reemen t Stack Cha rcoa l 1-131 5.20 E-10 1.041.002E-09 .50 97 D i sag reemen t**

Ca rtridge No. 1 1-133 3.66 E-10 6.75 .05 E-10 .54 21 D i sa g reeme n t **

Stack Cha rcoa l 1-131 7.15 E-7 6.941.03 E-07 1.03 231 Ag reemen t* **

Cartridge No. 2 1-133 1.19 E-7 9.281.05 E-06 1.09 186 Ag reement***

Floor Dra in H-3 3.41 E-4 3.391.02 E-4 1.00 169 Ag reement Storage Tank S r-89 3.5 E-8 S r-90 1.1 E-8 112 E-9 * The values in pa rentheses a re the results of the analysis af ter a change in the peak pa rameter settin ** The Cha rcoa l Ca rt ri dge

• • • The Cha rcoa l Ca rt ri dge N.C. - No compa ri son N.D. - Not detected

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Attachment 1 I

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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.a 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

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j needs of this progra In these criteria, the judgment limits are variable in relation to the ,

comparison of the NRC Reference Laboratory's value to its associated I uncertainty. As that ratio, referred to in this program as " Resolution",

increases, the acceptability of a licensee's measurement should be more ,

selective. Conversely, poorer agreement must be considered acceptable as the resolution decrease LICENSEE VALUE

" NRC REFERENCE VALUE Possible Possible Resolution Agreement Agreement A Agreement B

<3 .5 0.3 - No Comparison 4-7 .0 0.4 - .3 - .6 - 1,66 0.5 - .4 - .75 - 1.33 0.6 - 1.66 0.5 - .80 - 1.25 0.75 - 1.33 0.6 - 1.66

>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33

"A" criteria are applied to the following analyses:

Gamma Spectrometry where principal gamma energy used for identification is greater than 250 Ke Tritium analyses of liquid sample "B" criteria are applied to the following analyses:

Gamma Spectrometry where principal gamma energy used for identification is less than 250 Ke Sr and 'OSr Determination Gross Beta where samples are counted on the same date using the same reference nuclid .