IR 05000334/1985013

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Forwards Safety Insp Repts 50-334/85-13 & 50-412/85-11 on 850513-17.No Violation Noted
ML20127B028
Person / Time
Site: Beaver Valley
Issue date: 06/18/1985
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Carey J
DUQUESNE LIGHT CO.
Shared Package
ML20127B033 List:
References
NUDOCS 8506210331
Download: ML20127B028 (2)


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JUN 181985 Docket Nos. 50-334 50-412 Duquesnr 3.ight Company ATTN:

J. J. Carey President

, ear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen:

Subject: Inspection Report No. 50-334/85-13 and 50-412/85-11 A routine safety inspection was conducted by Dr. Richard K. Struckmeyer of this office on May 13-17, 1985 at the Beaver Valley Power Station, Units 1 and 2 of activities authorized by NRC License Nos. OPR-66 and CPPR-105.

Areas that were reviewed included the operational radiological environmental monitoring program for Unit I and the preoperational radiological environmental monitoring program for Unit 2.

Particular emphasis was placed on the manage-ment controls for these programs and the implementation of the quality control program for environmental radiological measurements.

Within the scope of this inspection, no violations were observed.

No reply to this letter is required. Your cooperation with us in this matter is appreciated.

Sincerely, Original Signed ByI c

Division of Radiation Safety and Safeguards

Enclosure:

Combined NRC Region I Inspection Report Number 50-334/85-13; 50-412/85-11

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G PDR OFFICIAL RECORD COPY CIR BV 85-13/11 - OU01.0.0 Dj 06/07/85 l

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Duquesn2 Light Company

REGION I==

50-334/85-13 Report No.

50-412/85-11 50-334 Docket No.

50-412 DPR-66 C

License No.

CPPR-105 Priority

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Category A-2 Licensee: -Duquesne Light Company P.O. Box 4 Shippingport, PA 15077 Facility Name: Beaver Valley Power Station, Units 1 & 2 Inspection At:

Shippingport, PA Inspection Conducted: May 13-17, 1985 Inspectors:

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9[C Richard K. Struckmeygf, Radiation

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Specialist J

Approved by: M bM,,MM/

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Mohamed M."Shanbaky, Intfief, PWR RPS

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' Inspection Summary: Inspection on May 13-17, 1985 (Combined Inspection Report No. 50-334/85-13; 50-412/85-11 Areas Inspected:

Routine, unannounced inspection of the operational radio-logical environmental monitoring program for Unit 1 and of the preoperational

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radiological environmental monitoring program for Unit 2, including: licensee action on previous inspection items; management controls; the licensee's program for quality control of analytical measurements; and implementation of the radiological environmental monitoring program. The inspection involved 28 inspection hours onsite by one region-based inspector.

Results: Within the areas inspected, no violations were identified.

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DETAILS 1.

Individuals Contacted R. Cavaliere, Computer Engineer, I&C R. Dinello, Field Representative, Teledyne Isotopes

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R. Druga, Manager, Technical Services

  • D. Hunkele, Director, QA Operations
  • J. Kosmal, Manager, Rad Control
  • W. Lacey, Plant Manager
  • V. Linnenbom, Reactor Control Chemist F. Lipchick, Senior Compliance Engineer
  • A. Lonnett, Health Physics Specialist J. McIntire, Environmental Coordinator
  • A. Mizia,. Senior QA Engineer
  • D. Mortimer, Health Physics Associate
  • W. Wirth, Director, Radiation Safety Programs The inspector also spoke with other licensee personnel in the course of the inspection.

2.

Licensee Action on Previous Inspection Findings (Closed) Inspector Followup Item (334/84-19-01):

Effectiveness of licensee's control to ensure completeness of semiannual radioactive effluent reports. A mechanism for ensuring timely reporting of data was begun in 198!

The licensee maintains a log of required sample analyses.

The log incit. des the types of samples and the analysis completion date for each required sample. Copies of this log are sent as reminders to depart-ment heads with responsibilities pertaining to the effluent reports. The inspector reviewed both Semi-annual Effluent Reports for 1984 and found that all required data were reported, and that they were submitted by the required date.

(Closed) Unresolved Item (334/84-19-02):

Review effluent radiation monitor calibration records to ensure proper completion of required data and signatures. The inspector reviewed the corrective actions taken by the licensee. Memoranda were sent to Radeon personnel to inform them of the requirement for signing the briefing sheet in the calibration procedure, and for filling in all data. The inspector also reviewed the record of a subsequent calibration and found that it contained the required information.

(Closed) Unresolved Item (334/84-19-03):

Review licensee's actions concerning expired and improperly controlled temporary chemistry procedures.

The licensee did not use the temporary procedures again.

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Instead, a review was undertaken to determine which of these procedures should be made permanent, and the manual of chemistry procedures was revised as necessary to incorporate the changes.

(Closed) Unresolved Item (334/85-02-03):

Review tritium release calculations contained in semi-annual radioactive effluent release reports; licensee reported error in model used. During the preparation of the semi-annual effluent report for the second half of 1984, the licensee discovered an error in the monthly volume conversion factors for continuous tritium releases via the three gaseous effluent pathways.

These factors are used for converting the volume released from units of

~ cubic feet per minute to cubic centimeters per month. They were underestimated by as much as a factor of 1000 beginning with the second quarter of 1976.

The licensee recalculated all the affected tritium release data and reported the corrected results in a letter to the NRC (Region I) dated March 27, 1985. The inspector reviewed the data and calculations and determined that the tritium release data now appear to be correct. The licensee stated that its 10 CFR 50 Appendix I dose estimates were not affected because the volume conversion factors are used only in the calculation of the quantity (curies) of tritium

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released.

The Appendix I dose estimates are based on information contained in the licensee's gaseous effluent release permits, and do not involve the use of the volume correction factors.

3.

Management Controls The inspector reviewed the licensee's management controls for the Radiological Environmental Monitoring Program (REMP), including assignment of responsibility, program audits, and corrective actions for identified inadequacies and problem areas in the program, a.

Assignment of Responsibility The inspector reviewed the organization and administration of the Radiological Environmental Monitoring Program (REMP). The program is the responsibility of the Environmental Coordinator, who reports to the Director - Environmental and Radiological Safety Programs.

Sample collections and analyses are performed by a contractor laboratory.

The Environmental Coordinator is responsible for interfacing with contractor personnel to ensure that program objectives are met.

b.

Licensee Audits Section 6.5.2.8.a of the Technical Specifications requires the licensee to perform audits encompassing "the conformance of facility operations to provisions contained within the Technical Specifica-tions and applicable license conditions at least once per 12 months."

To meet this requirement, the licensee has developed an audit plan, including a master list of auditable items, from which selected items

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are audited each year. Currently, the. licensee selects 25% of the items per year, thereby covering all auditable items every four

. years. The. items are primarily contained within Sections 3 and 4 of the Technical. Specifications, i.e., the Limiting Conditions for Operation and the Surveillance Requirements.

The inspector reviewed tne audits of the radiological environmental monitoring program for 1984.

These audits covered the requirements of Section 3/4-12, and included the contractor's field sampling and laboratory analyses.

The inspector noted that Sections 6.9.1.10 and 6.9.1.11 of the Technical Specifications cover the reporting requirements for the annual Radiological Environmental Report.

These sections are not specifically included in the licensee's audit plan, and apparently were not covered in the audits performed in accordance with Section 6.5.2.8.a.

The licensee stated that it has not routinely audited Section 6.9 (Reporting Requirements) because these requirements were presumably covered by the audits of Sections 3/4..The licensee stated that the audit plan will be reviewed to determine to what' extent the requirement of Technical Specification 6.5.2.8.a has been met. The-inspector stated that the issue of whether this requirement has been met is unresolved pending the

' licensee's investigation and subsequent review by the NRC.

(334/85-13-01).

4.

Licensee Program for Quality Control of Analytical Measurements-The. licensee stated that it maintains a multi part assurance program for radiological environmental monitoring.

Samples from various monitoring stations are split between two laboratories. The licensee eviews these data, as well as the results of the laboratorie's internal yC programs and the results of the EPA Interlaboratory Cross-Check program, in which these laboratories participate.

In addition, on a quarterly basis, a third, independent laboratory prepares milk and water samples spiked with low levels of specific radionuclides. These are split three ways and analyzed by each laboratory.

The inspector reviewed selected records of the QC program for 1984 and noted that the results of split and spiked samples were generally in~ agreement. The inspector discussed with the licensee the criteria for determining whether QC intercomparison data are in The licensee stat'd that this determination was basically a agreement.

e subjective judgement based upon knowledge of the type of samples compared

.and upon past experience.

The inspector stated that objective criteria, such as statistical tests, should be employed in order to more effectively utilize the intercompar-

.ison data. The licensee stated that it would develop an objective rationale for determining whether QC intercomparison data are in agree-ment. This will be reviewed in a future inspection (334/85-13-02).

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5.

Implementation of the Radiological Environmental Monitoring Program a.

Direct Observation The inspector examined selected air sampling and TLD monitoring stations.

The inspector determined that the examined stations wn e located as required by the Offsite Dose Calculation Manual and were operating at the time of the inspection.

The inspector also noted that the air samplers and dry gas meters were maintained and calibrated as required, b.

Review of Annual Reports The inspector reviewed the annual report for 1984, and determined that the licensee has complied with the Technical Specifications'

requirements for sampling frequencies, measurements, analytical sensitivities, and reporting schedules, c.

Thermoluminescent Dosimeters (TLDs)

The U.S. Nuclear Regulatory Commission (NRC) Direct Radiation Monitoring Network is operated by the NRC (Region I) to provide continuous measurement of the ambient radiation levels around commericial nuclear power plants throughout the United States.

Each site is monitored by arranging approximately 30 to 50 thermo-luminescent dosimeter (TLD) stations in two concentric rings extend-ing to about five miles from the power plant.

The monitoring results are published in NUREG-0837 quarterly.

One of the purposes of this program is to serve as a basis of comparison with similar programs conducted by individual utilities which operate nuclear power plants. Therefore, several NRC TLDs are co-located with licensee TLDs.

During this inspection the monitoring results of co-located TLDs were compared and the results are listed in Table 2.

Table 1 describes the NRC TLD locations around the Beaver Valley Power Station.

All NRC exposures are normalized to a 90-day quarter and reported in units of milliroentgens (mR), and uncertainties are the total uncertainty (random and systematic uncertainties). The licensee reports monitoring results only with random uncertainty.

Most of the licensee's monitoring results are slightly lower than the NRC's results as shown in Table 2, but results are generally in good agreement.

It must be emphasized that the Co-located TLDs are not necessarily monitoring at the same station; two-tenths of a mile apart is not unusual.

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6.

Meteorological Monitoring The inspector examined the licensee's meteorological monitoring system, including the onsite meteorological tower, the recorder charts in the equipment house at the base of the tower, and the control room recorder charts. The meteorological tower is equipped with redundant wind speed and wind direction sensors at the 35, 150, and 500 foot elevations.

There are also redundant temperature sensors at these elevations. The redundant sensors are not required by Technical Specifications; the minimum operable channels are any 2 out of 3 wind speed, any 2 out of 3 wind direction, and either 1 of 2 AT channels.

The inspector compared the strip chart recorders in the equipment house with those in the control room. At the time of observation (between 1340 and 1350 EST on 5/14/85), there were some apparent discrepancies in the wind direction data at 150' and 500', as summarized in the followi.1g table:

Sensor Reading in Reading in Elevation Equipment House Control Room 35'

210 - 330 210 - 330 150'

240 - 300 270 - 360 500'

240 - 300 210 - 330 The above data do not indicate any discernable trend.

The inspector noted that the licensee was using incorrect chart paper for the wind speed and direction recorders in the control room; this may contribute to the apparent discrepancies.

The licensee representative stated that these recorders are old and that the correct chart paper could no longer be obtained.

Furthermore, the licensee is presently evaluating available options concerning the method of meteorological data display and/or retrieval in the control room; one option is to eliminate the strip chart recorders and use only a computer-based system.

Presently, the me..eorological data is available via a computer terminal in the control room, in addition to the strip charts.

The licensee stated that the computer terminal is its primary system for retrieval of the data.

The status of the meteorological data strip chart recorders, as well as the availability of data, will be reviewed in a future inspection (334/85-13-03).

The licensee currently calibrates meteorological instrumentation quarterly, thereby exceeding the Technical Specification requirement of twice yearly calibration.

The inspector reviewed calibration procedures and records fcr the first quarter, 1985 calibrations of the meteorological instrumentation and found them to be adequat.

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Preoperational Radiological Environmental Monito~ ring Program - Unit 2 The licensee stated that the REMP for the operating units serves as the preoperational REMP for Unit 2.

The existing program was reviewed against the criteria in the USNRC Radiological Assessment Branch Technical Position (Rev. 2, November 1979).

It was determined that most of the suggested types and quantities of samples are collected at the frequencies specified. The Branch Technical Position provides for variations in the number, media, frequency and location of sampling, depending on site-specific factors. One such variation at the Beaver Valley site concerns. ground water monitoring, which is not required because the hydraulic gradient is in the direction of the Ohio River; i.e., station effluents into the river do not affect local wells and ground water sources in the area.

8.

Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during this inspection is discussed in Paragraph 3.

9.

Exit Interview The inspector met with licensee representatives (denoted in Section 1) on May 17, 1985. The inspector summarized the purpose, scope, and findings

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of the inspection. At no time during this inspection was written material provided to the licensee by the inspector.

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l Table 1. Co-located TLD Stations NRC Nearest Licensee Station Location Station Location *

E, 97,

8.0 mi.

E, 8.0 mi.

E, 91*,

2.4 mi.

E, 2.2 mi.

WSW, 264, 5.6 mi.

WSW, 5.8 mi.

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SW, 232*,

2.4 mi.

SW, 2.6 mi.

WNW, 294*, 3.4 mi.

WNW, 0.3 mi.

SW, 220*,

1.3 mi.

SW, 1 5 mi.

SSE, 190, 2.2 mi.

SSE, 2.4 mi.

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Table 2. Environmental TLO Monitoring Results, 1984 (mR/std. qua rter i random uncerta inty; total unce rta i n ty)*

Station Number Moni torino Period

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Licensee 1st 2nd 3 rd 4th

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No.

9%r QLt

_Qtt RLE 7'

17.7 1 0.6; 3.1 17.0 1 0.8; 3.7 17.0 1 0.8; 3.7 19.3 1 0.7; 5.5

16.6 1 2.1*

15.9 i 3.0 15.8 i 2.0 14.9 1 1.8

18.6 1 0.7; 3.2 17.0 1 0.8; 3.7 17.0 1 0.8; 3.7 20.0 1 0.7; 5.5 45.

.14.4 t 1.7'

16.4 i 1.6 13.8 i 0.8 14.9 1 1.3

17.2 1 0.6; 3.0 16.5 1 0.8; 3.7 15.7 1 0.7; 3.6

15.1 1 0.2 17.3 1 1.2 15.7 1 1.0 15.8 1 0.8

16.7 1 0.6; 2.9 18.1 1 0.8; 3.9 16.4 1 0.8; 3.6 19.1 t 0.7; 5.5

13.9 1 0.8 15.2 1 0.8 13.8 1 0.5 15.3 1 0.7

15.3 1 0.6; 2.7 14.1 1 0.7, 3.4 14.2 1 0.7; 3.4 17.8 1 0.7; 5.3

12.3 1 0.5 12.2 1 0.5 12.7 i 0.9 12.1 1 0.6

16.2 1 0.6; 2.9 15.8 1 0.8; 3.6 15.9 1 0.7; 3.6 18.9 1 0.7; 5.4

13.5 1 0.7 14.6 1 0.8 13.1 1 1.2 14.9 1 1.3

18.1 1 0.6; 3.1 17.5 1 0.8; 3.8 16.7 i 0.8; 3.7 19.8 1 0.7; 5.5

15.7 0.8 18.1 1 0.5 17.2 1 1.7 14.7 1 1.5

Licensee's results as reported in this table are the averages of two dosimeters per location. The licensee reports only random

' uncertainty.

Missing or damaged dosimeter.

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