IR 05000010/1975008
| ML19340A561 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/02/1975 |
| From: | Jorgenson B, Pagliaro J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A557 | List: |
| References | |
| 50-010-75-08, 50-10-75-8, 50-237-75-13, 50-249-75-11, NUDOCS 8008270818 | |
| Download: ML19340A561 (11) | |
Text
.
-
.-.
-.
._,
.
--
_.;
.
-
.
.
.
.
.
..
,
,
,
A
-
.
.
_
.
.
I ('
.
_
t
.
U. S. NUCLEAR REGULATORY COWIISSION i
0FFICE OF INSPECTION AND ENFORCEMENT
REGION III
<
.
.
Report of. Environmental Protection and Confirmatory Measurements Inspection IE Inspection Report No.
IE Inspection Report No. 050-237/75-13
-
'
IE Inspection Report No. 050-249/75-11
]
Licensee: Commonwealth Edison Company
!
P. O. Box 767 Chicago, Illinois 60690 Dresden Station Units 1, 2 and 3 License No. DPR-2 Morris, Illinois License No. DPR-19
,
License No. DPR-25
-
,
Category:
C Type of Licensee:
BWR-(CE)
i
,
Type of Inspection:
Routine, Announced Dates of Inspection:
May 9, 13 and 14, 1975 Dates of Previous Inspection: April 21-24,1975 (Operations)
1
fS
-
,y Principal _ Inspector:
B. Jnrg.cusen
.
!
(Date)
Accompanying Inspectors: None Other Accompanying Personnel: G. Wright
-
'
K. Knock Illinois Department of Public-llealth I
Reviewed By:
. A. Pagl o,
J 7d'
,
,
Senior Inspector (Ifate)
k.
Radiological and Environmental
'
-Protection Branch
'
8008270 ?/{
j
,
-
.-
-.-
. -. - - -
. -
--
---
_.
-
.
.
.
-
.
'
'. -
-
,
.
,
.
,
- <
,
,
-
.
i
-
,
SUMMARY OF FINDINGS
,
Enforcement Action:
None.
.
Licensee Action on Previously Identified Enforcement Matters Licensee action pertaining to one item of noncompliance identified during a previous inspection,l/
concerning the requirement for supple-mental environment t1 monitoring whenever certain airborne effluents
,
exceed 1/3 of their technical specification limits, was examined by the inspector.
The licensee has developed and implemented an air monitoring procedure to define appropriate actions as required by the Technical Specifications.
In addition, the licensee has initiated a request to delete this Technical Specification requirement in the future. The inspector has no further questions concerning this item. (Paragraph 5, Report Details)
Unusual Occurrences
-
None within the scope of this inspection.
Other Significant Findings A.
Current Findings This inspection included examinations of the licensee's non-radiological effluent and radiological and non-radiological enviromental monitoring programs, and an examination of the licensee's program for quality control in analysis of radiolegical effluents.
No items of noncompliance nor. unresolved items were identified.
In a confirmatory measurements comparison, the licensee's results yielded 92% Agreements or Possible Agreements and 8%
Disagreements when compared to the results of the NRC reference laboratory.
B.
Status of Previously Reported Unresolved Items No previously reported unresolved items within the scope of this
_
inspection.
Management Interview A management interview was conducted with Messrs. Butterfield, Bergen, Borzym and Stone at the completion of the inspection on May 14, 1975.
1/
R.O. Inspection Reports No. 050-010/74-04; No. 050-237/74-06 and No. 050-249/74-06
-
-
-2-
.
- ~
_ _ _
.
-
-
.
,
,
-
.
-
.
- ('s
.
.
The following items were discussed with the licensee representatives.
.
A.
The NRC inspector discussed the scope of this inspection. (Paragraph
-
2.a and 2.b Report Details)
B.
The inspector discussed his review of changes and clarifications
-
made pertinent to environmental monitoring program management.
-
(Paragraph 3.a Report Details)
C.
The inspector discussed the status of licensee review of contractor procedures and quality control manuals.
(Paragraph 4, Report Details)
D.
The inspector noted that examination of program implementation had yielded no instances of noncomplia'nce, and discussed the results of additional followup on unreported meteorological aata and licensee actions pertaining to a previously reported item of noncompliance.
(Paragraph 5, Report Details)
E.
The inspector discussed the results of comparative analysis of radiological effluent samples pertinent to this inspection.
The single result yielding an " Unacceptable" coraparison was reviewed.
(Paragraphs 7 and 8, Report Details)
-
-3-
.
e
.
_ _. _ _ _ _
-___
.
-
--
.
.
L.
.
.
-
.-
,
.
.
.
.
.
(%
.
,
REPORT DETAILS
.
1.
Persons Contacted D. Butterfield, Administrative Assistant
D. Adam, Radiation Protection - Chemistry Supervisor
'
G. Bergen, Plant Chemist L. Noreng, Plant Chemist R. Stone, Quality Control Engineer T. Borzym, Quality Control Inspector R. Crandall, Health Physicist T. DeVlieger, Rad-Man J. Golden, Administrator for Environmental Monitoring Programs (CECO)
H. Bernhard, Staff Biologist (CECO)
R. Coley, Chemical Engineer (CE Technical Center)
2.
General a.
Environmental Monitoring The environmental monitoring portion of this inspection
-
consisted of an examination of the licensee's non-radiological effluent and radiological and non-radiological environmental monitoring programs, including sampling techniques and procedures, sampling equipment, operability and locctions, and program results. l..nagement control aspects examined included organ-izational structure, assignment of responsibility and authority, and administrative control. Ine licensee's Technical Specifica-tions were used as the primary inspection criteria, where applicabic.
b.
Confirmatory Measurenients The confirmatory measurements portion of this inspection
,
consisted of an examination of the licensee's programs,and
,
procedures for quality control of analysis of radiological ef fluent samples and an independent analysis of selected effluent samples for verification of licensee results.
3.
Management Controls a.
Environmental Monitoring The licensee's management control of the environmental moni-toring programs, the meteorological program, and the effluent monitoring program were examined.
The licensee has effected-4-
_
.
l
-
-
.
,-
.
.
,
.
.
.
~
'
,w
,
some changes and clarifications in management of the radio-
.
,
logical environmental monitoring program since' the previous
~
inspection.2/ Specifically, the office of Administrator for Environmental Monitoring Program's within :the Commonwealth Edison Production Department has been designated f or detailed program administration, including coordinating contractor
-
activities, developing and recommending changes to program
'
content, auditing, and reporting program results.
This office
,
has the same functions with respect to meteorological monitoring. -
The non-radiological environmental monitoring program is ad-ministered by the Commonwealth Edison Environmental Affairs Department through an assigncd Staff Biologist. Contract management, informal auditing, and reporting responsibilities are included.
b.
Effluent Monitoring Though ultimate responsibility is with the Station Superin-tendent, the radiological effluent analysis program is routinely administered by those members of the Technical Staff at the station under the Radiation Protection-Chemistry Supervisor.
Each nuclear unit has a designated Plant Chemist.
Detailed
-
program functions are generally divided into union staff and management staff duties.
4.
Quality Control of Analytical Measurements
'
a.
Environnental Monitoring The licensee possesses and is currently revieuing the Field Sampling and Analytical Procedures documents and the Quality Assurance Manual of the contractor laboratory performing the radiological environmental monitoring pr'ogram.
The licensee's representative stated that it is the intent of the licensee to formally approve these documents when they have been satisf acto-rily developed and the review process is completed. This item will be examined further during a subsequent inspection.
The licensce's program for auditing contrator activities has been carried out by the Administrator for Environmental Monitoring Programs and by Technical Staf f personnel at the station.
Some of these functions are in the process of being transferred or are expect 6d to be transferred to the Commonwealth Edison Quality Assurance Department. This item will be examined at a subsequent inspection.
2/
lbid.
-5-
.
_.
_
_
_
_
. _- -
i
'
.
-_
,
l
'
.-
-
,
.
.
.
.
.
.
.
.
l cm
.
,
The licensee has completed review of the quality control
,
manual of the contractor utilized in carrying out the
'non-radiological environmental monitoring program.
This document will be examined at a subsequent inspection, when the conduct of this program has been incorporated into the License Technical Specifications.
The licensee possesses and is reviewing the quality assurance-manual of the contractor utilized in performing meteorological monitoring at the site. The contractor is presently preparing a detailed procedures manual.
The licensee se.ated that the procedures manual will also be reviewed for formal approval.
,
The licensee stated their intent to adhere to the guidelines
'
of Regulatory Guide 1.23 for meteorological monitoring at the new site meteorological tower, but indicated that,ll data recover-primarily due to occasional severe weather conditions, overa l
ability of 90% has been difficult to achieve.
'
b.
Effluent Monitoring The Dresden Nuclear Power Station Technical Staff has developed
-
and is continuing to develop. procedural controls for sampling and anal sis of radiological effluents.
Those activities carried aut by management staff are being supplemented and expanded.
The Technical Specifications do'not presently delineate calibration and maintenance schedules for the equip-ment utilized in performing these analyses,-nor is a specified
,
schedule rigidly adhered to by plant personnel.
Calibration
'
checks are specified in the Laboratory Procedurcs manual.
'
Selective examination of licensee ' records yielded no instances of variation from existing procedural controls. The licensee stated that current planning ic for full calibration of the GeLi gamma spectrographic system on an approximate annual basis with quarterly preventative maintenance by the equipment vendor.
Only calibration checks are currently planned for other instru-mentation.
The NRC Confirmatory Measurements program is the only independent verification program in which the station presently-participates.
The Commonwealth Edison Central Chemical Centrol Group within the Production Control Efficiency Department, is currently atto.mpting to develop standarized procedures and an overall ~
radioanalytical quality control program for all Commonwealth
~
Edison nuclear stations.
Detailed and overall strategy and
-
scheduling have not been established at present, pending formal adoption by Company management of official policy in this area.
'
-6-
-
-
.
'
.., -
,
- -,
,
.. ~ ~ -
- -,
-
-r
-
..
~
. - -
.
.
.
-
.-
-. --
,
,
.
'
-
- w
,
5.
Implementation of the Environmental Monitoring Program
.
The results of the. licensee's radiological and meteorological monitoring for calendar year 1974 were examined.
Only the radiological program is addressed in the current Technical Specifications. The licensee is also carrying out non-radiologi-cal environmental monitoring as a baseline for programs expected to be incorporated into the Technical' Specifications at a later date.
Data from this program were not in published form at the time of this inspection. This program vill be examined further following adoption as a Technical Specification requirement.
,
The inspector noted that ceteorological monitoring results were incompletely reported during the period of examination.
The licensee stated that overall data recoverability for the period was approximately 50% due to continuing equipment malfunctions which eventually necessitated removal and return of the equipment to the manufacturer for repair. The licensee indicated that the meteoro-logical contractor services and maintains the equipment, and currently possesses an adequate inventory of replacement parts.
The failed equipment was a new type of combination instrument for which replace-ment parts were not then available.
The licensee further stated that
-
a detailed analysis of the difficulties experienced, along with comparative data and calculations of the missing data using information recovered f rom two other tower levels, had been submitted to' the Division of Reactor Licensing as part of the submittal for a full-term license.
No unresolved anomalous results or unusual trends were identified in the inspector's revieu of the radiological environmental monitoring results, nor.wcre discrepancies from the specified monitoring require-ments noted. The inspector noted that the minimum sensitivit'y for analysis of I-131 in milk is currently 4 pCi/ liter.
The licensee stated that the proposed Technical Specification currently under consideration by the NRC Division of Reactor Licensing would specify a sensitivity of -0.5 pCi/1 (at time of sample collection) fo.r weekly analysis to be performed during the " pasture season."
The inspector discussed with the licensee actions which had been taken to correc.t and eliminate recurrence of an item of noncompliance noted at a previous inspection.3/ The licensee determined that
-
supplemental environmental monitoring had not been carried out, as noted in the previous report, due to,the lack of a procedure which would assure notification to the contractor of the need for the supplerental samplings.
Such a procedure has been prepared and was 3/
Ibid-7--
.
.
., _ -
, - - - -
i
.
-
-
.
. " -
.
,
,
-
.
.
~
.
.,.w.
examined by the. inspector.
No recurrences of missed supplemental
.
samplings ucre noted in the inspector's review of monitoring results.
The licensee representative stated that their analysis of the value of this supplemental monitoring requirement had led them to request an amendment to the Technical Specifications which would eliminate the requirement.
This change had not been approved at the time of
.
this inspection.
The inspector has no further questions concerning this item.
The inspector examined and verified the location and operability.
of selected radiological environmental sampling stations.
Sampling and operability check procedures were not available at the stations.
The licensee indicated that the contractor personnel servicing the stations carry such procedures with them when visiting the stations.
6.
Non-Radiological Effluent Releases The Technical Specifications do not currently contain limits for non-radiological effluents.
Such limits are contained in the sub-mittal under review by the Division of Reactor Licensing in the form of usage limits.
The licensee is currently inventorying selected chemicals and monitoring thermal conditions preparatory to implementation as regulatory limits.
-
7.
Comparative Analytical Results The Confirmatory Measurements portion of this inspection showed sone of the licensce's, measurements on these samples are acceptable under the test criteria used by the Office of Inspection and Enforcement for comparing measurements results (see the Attachment.)
llowever,
some of the licensee's measurements are not acceptable under the test criteria. The types of samples tested and results of measurements were:
a.
Type of Sample: Liquid Waste (1/75)
(Results in units of uCi/ml)
Acceptable Radionuclide NRC Reference Measurement Licensee's Measurement gross p-1.97'i 0.02 E-05 3.0 E-05 Cs-134 1.8 + 0.1 E-06 2.6 E-06 Cs-137 4.7 I 0.2 E-66 7.0 E-06
~
H-3 2.20 1 0.02 E 03 1.9 1 0.2 E-03 Sr-89 8 i
E-08 1.80 i 1.45 E-07 Sr-90'
3.0 1 0.4 E-08
< 7.5 E-08-8-
.
.
._
-
-
.,
..
~
.
-
-
.
_
,
,
.
.
.
.
- 3
.
,
.
Not Acceptable
_
Radionuclide NRC Reference Measurement Licensee's Measurement t
Co-60 2.14 1 0.07 E-05 4.0 E-05
.
b.
Type of Sample:
Gaseous Waste (1/75)
(Results in units of uCi/ml)
Acceptable Radionuclide NRC Reference Measurement Licensee's Measurement Xe-133 2.16 1 0.08 E-01 2.9 E-01 Not Acceptable: None c.
Type of Sample:
Particulate Filter (1/75)
(Results in units of uCi/ sample)
-
Acceptable Radionuclide NRC Reference Measurement Licensee's Measurement 1-131 4.9 1 0.2 E-03 3.3 E-03 Ba-lta 9.7 1 0.4 E-03 6.7 E-03 Cs-137 1.6 1 0.1 E-04 1.0 E-04 Co-60 1.5 1 0.2 E-04 1.1 E-04 Not Acceptable:
None
,
d.
Type of Sample:
Charcoal Adsorber (1/75)
(Results in units of uCi/ sample)
,
Acceptable Radionuclide NRC Reference Measurement Licensee's Measurement 1-131 8.3 1 0.4 E-03 1.2 1 0.3 E-02 Not Acceptable:
Nonc
_9_
.
e e
.
,
n -
..
-
.,
_
__
.
..
.
.
-
,
g
,
.
.
.
.
.
. '
.
s
,,
- ,x
.
.
.
8.
Samples Not Meeting Acceptance Criteria
.
The licensee's reported result on analysis of a liquid waste sample for Co-60 has yielded a comparison in the " Disagreement" category.
The licensee's result is conservative by a fcetor of about two.
If this difference is real and representative of routine analysis, the
'
licensee could have overreported releases of this nuclide near the time of this comparison. The inspector discussed potential causes
'
for the disparity with licensee representatives.
The licensee reported one result yielding an acceptable comparison and one similarly conservative result yiciding an unacceptable comparison (both for this nuclide and media) at a previous inspection.,4_/ The conservative result was the more recent. A re-calibration of the equipment used in this analysis occurred between the two most recent results. The licensee indicated that the heavy suspended material content of these two samples may have affected counting due to non-random distribution of the Co-60 activity. A sample of clean, low-conductivity water was split for the next verification comparison. This item will be re-examined at a subsequent inspection.
ff IE Inspection Reports No. 050-010/75-02, No. 050-237/75-03, and
-
No. 050-249/75-03.
.
Attachruent:
Attachment 1
-
.
e
- 10 -
.
O
.. -
-.
_
---,.-
.
.
,
^
.
.
,
-
J.
.
.
,
/
,,'
.
-
o
.
.
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 program.
.
In these criteria, the judgement limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated uncertainty.
As that ratio, referred to in this program as " Resolution",
increases the acceptability of a licensce's measurement should be more selective.
Conversely, poorer agreement must be considered acceptable as the resolution decreases.
RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE
-
Possible Possible Ay,reement Agreement A Agreement B 3.0 No Comparison
0.4
- 2.5 0.3
-
2.5
- 0. 3 -
3.0 4 - 7 0.5 -
2.0 0.4
-
2.0 0.4
-
2.5
0.6
-
1.66 0.5
-
-
16 - 50 0.75 -
1.33 0.6 -
1.66 0.5 -
2.0 51 - 200 0.80 -
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 followin'g analyses:
Gamma Spectrometry where principal gamma energy used for identifi-cation ic greater than 250 Kev.
Tritium analyses of liquid samples.
"B" criteria are applied to the following analyses:
Gamma spectrometry where principal gamma energy used for -
identification is less than 250 Kev.
89Sr and 90Sr Determinations.
Gross Beta where samples are counted on the same date using the same reference nuclide.
-
-
6