IR 05000334/1988027

Insp Repts 50-334/88-27 & 50-412/88-21 on 881017-21.No Violations Noted.Major Areas Inspected:Licensee Radioactive Effluent Controls,Radwaste & Transportation & Radiological Environ Monitoring Programs

ML20196A512
Person / Time
Site:	Beaver Valley
Issue date:	11/28/1988
From:	Davidson B, Kottan J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20196A500	List: IR 05000334/1988027 ML20196A496
References
50-334-88-27, 50-412-88-21, NUDOCS 8812060027
Download: ML20196A512 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No /88-27 50-412/88-21 Docket No License No DPR-66 Priority -

Category C NPF-73 l Licensee: Duquesne Light Company

P. O. Box 4  ;

Shippingport, Pennsylvania

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Facility Name: Beaver Valley Power Station, Units 1 and 2 Inspection At: Shippingport, Pennsylvania Inspection Ccaducted: October 17-21, 1988

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Inspectors: / Mfo _ 2 __ ////,!9j27 B~atry ~S avidson, Radiation Specialist pate /

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'Jimes J. Kottan,/ Laboratory Specialist '

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Approved by: _l_ h W1ter J. Pasc b l _

b lt M ak, Chief, Effluents Radiation

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/ dap ProtectionSe31on,FRSSB,DRSS /

i Inspection Summary: Inspection on October 17-21, 1988 (Combined Inspection Report Nos. 50-334/88-27: 50-412/88-21 Areas Inspected: Routine, unannounced inspection of the licensee's radioactive effluent controls, radioactive waste and transportation, and

, radiological environmental monitoring programs.

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Results: No violations were identifie '

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CB12060027 801128 "

gDR ADOCK 05000334 '][

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DETAILS 1.0 Individuals Contacted During the course of this routine inspection, the following personnel were either contacted or interviewe Principal Licensee Personnel

• W. Brady, Health Physical Specialist

• J. Breslin, Eealth Physics Specialist i

• A. Castagnacci, Senior Health Physics Specialist i

• D. Girdwood, Director, Health Physics Operations - Unit One

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• J. Kosmal, Manager, Radiological Controls

• S. LaVie, Senior Health Physics Specialist

) *A. Lonnett, Senior Health Physics Specialist

} *D. Roman, Quality Assurance Supervisor j *B. Sepelak, Compliance

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• J. Sieber, Vice President, Nuclear Operations

• J. Vassello, Compliance

• R. Vento, Director, Radiological Engineering J. McIntire, Senior Health Physics Specialist T. Zyra, Director of Testing and Plant Performance K. Winter, Senior Health Physics Specialist

• Denotes those individuals who were present at the exit meeting on October 21, 198 .0 Purpose The purpose of this routine inspection was to review the licensee's program in the following areas:

• The licensee's ability to control and quantify radioactive solids, liquids, gases and particulates during normal and emergency operations;

+The licensee's ability to implement its radiological environmental monitoring program during normal and emergency operations; and

• The licensee's ability to properly ship low-level radwaste for disposal and transport licensed radioactive material .0 Review of Previously Identifiec" Items 3.1 (Closed) Follow-up Item (50-334/88-09-01; 50-412/88-05-01) Review assignment of responsibility for radwaste supervisory cosition The inspectors reviewed the assignment and determined that the

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Manager of Radiological Controls was clearly responsible for conducting transportation of radioactive waste shipments. This item is close .2 (Closed) Violations (50-334/88-09-02) and (50-334/88-09-03). The inspector reviewed two procedures - Radcon Procedure 3.6, "Radio-active Shipments": and 3.2.9, "Inspection of Radioactive Material Packaging Prior to Shipment". These procedures were revised following the problems associated with shipment Number 095 Corrective actions included additional reviewed signoffs in Form 6.34 and inclusion of all hand generateo data as permanent records even if computerized data were used to generate waste manifests. This item is close .3 (0 pen) Inspector Follow-up Item 87-15-01. This item consisted of eleven sub-items. The status of these items follows:

-01- Reactor Coolant Sampling: Inspector review found hot leg sampling at low pressure, representative sampling, purge time and dissolved gas concerns were adequately resolve Containment Air: Inspector review indicated correction factors for rotometers were adequate to correct natural gas calibrations to elevated pressure Demonstrate analytical capabilities over expected range of variables: Inspector review indicated that the licensee's ability was within required accurac Develop procedures for Chloride and Boron analyses: Inspector review of these procedures also indicated that appropriate statements for interference and procedures for offsite shipment of samples were provide Demonstrate pH analytical capabilities: The licensee demonstrated these to the inspector's satisfactio Develop post accident sample system spare parts, calibration and maintenance program, evaluate GDC-19 Criteria doses during sampling; develop emergency response facility initiation procedures: Licensee procedure REOP 1.2 was developed in 1985. It adequately addresses the calibration 'id maintenance program and includes emergency response facility initiation procedures. The inspector requested additional information on extremity dose (1cm) GDC-19 criteria and the PASS spare parts progra Noble Gas Monitor. De/elop grab sample and isotope mixture procedure: Procedure REOP-1.2, 2/13/85 addresses this area adequatel '

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v-08- Iodine Sa.nOi , capab: ty: Concerns regarding source term and representative 33 were ac-quately addressed. Pressure drop

• corrections need to be evaluated after the licensee installs its mass flow sampling system (DCP-605).

-09- Inspector recommendations and concerns: Inspector evaluation of the licensee's efforts to address these concerns determined that the licensee's actions were thoroug .;0- Datector Qualificatio This item should be reviewed in an EQ inspectioi1 under Test Report Number 46880- Noble gas purging of iodine sample Licensee uses silver zeolite cannisters for iodine sampling. The use of silver zeolite in lieu of charcoal is acceptable as noble gas retention is very lo Of the above items reviewed, the sub-items closed are: 1,2,3,4,5, 7, 9, 1 Sub-items 6, 8 and 10 remain ope .0 Liquid and Airborne Radioactive Effluents 4.1 Program Changes Since the last inspection in this area the licensee has reorganized the Radiological Controls Department. Four Directors: Radiological Engineering, Radiological Operations (one for each unit),

Radiological Health Services, and Industrial Safety now report to the Manager of Radiological Controls who in turn reports to the General Manager of Nuclear Operation Liquid and airborne radioactive effluent control programs are located under the Director of Radiological Engineerin .2 Rec,ords and Reports The inspector reviewed the licensee's latest Semi-Annual Effluent Release Report for the period January 1 - June 30, 1988. No obvious mistakes, anomalous measurements, omissions or trends were note In addition, current effluent release data for the period July 1, 1988 to the present including gaseous and liquid discharge permits, were reviewe The l' ensee has in place a computerized system for implementing ODCM methooology to control liquid releases and gaseous batch releases from the facilit Formerly all of these calculations were performed by hand. The inspector reviewed ERS-SFL-87-032, the documentation for LIQDIS (the liquid effluent release software) and ERS-SFL-87-037, the documentation for GASDIS (the batch gas effluent release sof tware).

The inspector also reviewed calculation package numbers ERS-ATL-87-033 and ERS-ATL-87-038 which were test cases used to verify and validate the liquid and gaseous software, respectivel Preparation, testing, and revisions to the effluent control software were controlled by the following procedures:

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REAP-1.130, Control of Engineering Calculations; REAP-1.104, Engineering Software Control; and REAP-5.101, Control of AREARAS and MIDAS Software. The inspector noted that the licensee's procedures in this area appeared to be thorough and complete, and the effluent control software development and testing was a noted strength of the licensee's program. Furthermore, the inspector performed a hand calculation for a gaseous waste discharge, Gaseous Waste Release Permit RWDA-G-00944, and compared the hand calculations to the computer calculations. The results were:

Whole Body Dose Skin Oose Gamma Air Beta Air Isotope Rate (mrem /yr) Rate (mrem /yr) Dose (mrad) Dose (mrad)

Kr-85 7.404E-8 1.683E-7 2.165E-10 1.258E-10 Licensee 7.39E-8 1.68E-7 2.16E-10 1.26E-10 NRC Xe-133 3.925E-8 6.423E-7 1.125E-9 5.302E-12 Licensee 3.93E-8 6.42E-7 1.13E-9 5.31E-12 NRC TOTAL 1.133E-7 8.106E-7 1.342E-9 1.311E-10 Licensee 1.13E-7 8.10E-7 1.34E-9 1.31E-10 NRC These results indicated good agreemen The inspector had no further questions in this are No violations were identifie .3 Instrumentation The inspector reviewed the surveillance tests and calibrations for the containment purge exhaust gross activity radiation monitor and the Supplementary Leak Collection and Release System (SLCRS)

radiation monitors, including the extended range noble gas monitor Specifically, the following procedures were reviewed: Maintenance Surveillance Procedure MSP 43.59, Radiation Process Monitor RM-VS110 SLCRS Calibration; Maintenance Surveillance Procedure MSP 43.16, Radiation Process Monitor RM-VS104A Containment Purge Exhaust Gross Activity Calibration; and Maintenance Surveillance Procedure MSP 43.72, Radiation Process Monitor RM-VS107 Rx BLOG/SLCRS Rotameter Quarterly Test. Procedure MSP 43.59 was performed on April 14, 1988 and Procedure MSP 43.16 was performed on March 18, 1988. The above calibrations included radioactive source calibrations, alarm calibrations, and where applicable, flow calibration The inspector observed the read out of the above monitors in the control room and noted that the monitors appeared to be operatirig properly. The inspector also noted that the licensee routinely records effluent radiation monitor re3oings during gaseous and liquid

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batch releases from the site. However, no comparison of the actual monitor reading to an expected reading is performed. The inspector discussed this with the licensee. The licensee stated that in the future they would compare the effluent monitor readings to the expected monitor results from the laboratory sample measurements to ensure that the monitors respond acceptably. The inspector had no further questions in this are .4 Air Cleaning System The inspector reviewed records of tests of the air cleaning systems including both in place tests of HEPA filters and iodine adsorbers, and laboratory tests of iodine absorber The fo'. lowing tests and results were reviewed: BVT 1.16.1, Supplementary Leak Collection and Release System (VS-FL-4, 5, 6) Filter Bank, performed September 21, 1988; BVT 1.5-1.16.6, Supplementary Leak Collection and Release System (VS-FL-4, 5, 6) Filter Efficiency Test, performed September 23, 1988; BVT 2.1-1.16.1, Supplementary Leak Collection Filter Bank-Train A Flow Test, performed October 3,1988; BVT ?.1-1.16-6, SLCRS Train "A" Filter Efficiency Test, performed October 4, 1988; and BVT 2.1-1.16.8, Main Filter Bank Charcoal Test Canister Removal performed September 28, 198 The above tests included air flow, pressure drop, in place DOP and Freon, and CH3 I Laboratory tests. The licensee is meeting Technical Specification requirements in this are .5 Audits The inspector reviewed Audit No. BV-C-88-15, Effluent Monitoring, which was performed on April 26-May 17, 1988. This audit of liquid and gaseous effluents included sampling, analyses, effluent control, dose calculations, and radiation monitor surveillances. The inspector noted that the audit appeared to be of sufficient depth and detail to adequately assess the quality of the licensee's program and probe for programmatic weaknes The inspector further noted that the audit team included a technical specialist in the area being audited. In addition, the audit addressed a recent NRC Information Notice about "Disposal of Sludge From Onsite Sewage Treatment Facilities at Nuclear Power Stationn". Corrective actions to audit findings were timely and appeared co be technically soun The inspector also reviewed the master auiit schedule and noted that the radioactive effluent controls area wi. on the master audit schedule. The inspector had no further questions in this are No violations were identifie .0 Radiologic _al Environmental Monitoring Program Program Changes Since the last inspection in this area a reorganization in the l Radiological Controls Department has resulted in the inclusion of

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the Radiological Environmental Monitoring Program (REMP) under the Radiological ;ngineering Director within the Radiological Controls Department (See Section 4.1.) This change has resulted in the irdividuals with similar and overlapping areas, radioactive effluent and environ.1 ental responsibilities, including the ODCM and meteorology, residing in one organization. Previously the REMP was outside tF e Radiological Controls Department Organizatio E.2 Records dnd Reports The inspector reviewed the licensee's latest submittal of the Annual Er<ironmental Monitoring Report for the period January 1 -

secember 31, 1987. This review was conducted with respect to 00CM and Technical Specification requirements for sampling locations, monitoring and measurement frequencies, land use census, and interpretation and evaluation of dat No obvious mistakes, anomalous measurements, or observed biases were observe The inspector also reviewed the results of the environmental monitoring program conducted by the Commonwealth of Pennsylvania around the Beaver Valley site under a cooperative agreement with the NR This program consists of co-located sampling stations for some media, such as air sampling, and split or independent sampling for other media such as milk or fish. The data reviewed indicated generally good agreement between the Pennsylvania and licensee sample measurement result Additional data reviewed included 1988 to date QC and air flow calibration data, status summary logs, and weekly reports to manage-ment by the Senior Health Physics Specialist conducting the progra The results of TLDs co-located with the NRC were reviewed. The data indicates agreement within about 40%, with NRC values consistently higher than licensee values. The data are presented in Table I. No violations were identified in this are .3 Meteorological Monitoring Program The inspector verified the operation of the licensee's meteorological instrumentation by observing the terminal in the control room which displays the data from the meteorological monitoring tower. In dddition the inspection reviewed the results of Maintenance Surveil-lance Procedure MSP 45.17, Meteorological Monitoring System Test Calibration, and Maintenance Surveillance Procedure 45.17A, Redundant Meteorological Monitoring System Calibration. Both surveillance procedures were conducted during July, 1988. The inspector also reviewed the results of additional tests from Radiological Engineering procedures REAP 5.306, Calibration Check of Meteorological Data Collection Inputs, and REAP 5.307, Supplementary calibration check of Meteorological Input .

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Both tests were also performed in July,1988. The test review indicated that the meteorological monitoring instrumentation was librated as require .4 REMP QA Program The inspector reviewed the licensee's REMP QA program in order to verify that the QA program provides adequate control with regard to sampling, processing, and analyzing samples; and in evaluating dat, obtained in the REMP. The licensee's REMP is implemented by a contracto This includes sample collection, analyses, and data reporting. The licensee uses an independent laboratory for split samples as a check an the contractor laboratory. A third independent laboratory is utilized by the licensee to prepare spiked milk and water samples for the licensee's contractor and QC laboratories. The inspector reviewed 1980 to date QC data and noted that the licensee uses a set of criteria for comparing the results of split and spiked samples, that the results were compared promptly, and that disagreements were followed up in a timely manner. In addition, the licensee maintains a status summary log of contractor activities and generates weekly reports of contractor activitie .5 Audits The inspector reviewed the following audits of the licensee's REMP:

Audit No. BV-C-88-33 conducted September 28-29, 1988 of the QC laboratory; Audit No. BV-C-83-27 conducted July 26-28, 1988, of the contractor laboratory; Audit No. BV-C-88-26 conducted July 25 -

August 17, 1988 of the contractor field program; and Audit No. BV-C-88-18 conducted June 8-10, 1988 of contractor activities related to calibrations of the meteorological monitoring instrumenta-tion. The inspection noted that the audit teams included a technical specialist, and the audit teams used detailed checklists to cover the stated objectives of the audit In fact, the audit teams developed detailed comments regarding each checklist item. Again, as in the effluent area, the audits appeared to be of sufficient depth and detail to adequately access the quality of the contractor's progra The audit of the contractor that performs the meteorological instru-mentation calibration includes a surveillance of the calibration activitie ,0 Transportation and Solid Radwaste 6.1 Organization The organizational relationships and structure of the licensee's management control of solid radwaste processing, preparation, packaging and shipping activities were reviewed. The Beavec Valley Power Station Operations Support group has responsibilities for

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resin transfer / dewatering, evaporator bottoms solidification, and mechanical filter radwaste processing operations. Processing and packaging of dry active waste (DAW) is performed by the Radiological Controls (Rad Con) staff who report to the Manager, Rad Con (MRC).

The operations staff report to the Nuclear Operating Supervisce, Operations Support, who reports to the Plant Manager. Both Managers report to the Senior Manager, Nuclear Operations, who reports to the Vice-President, Nuclea An in-house computer code is used to generate classification under 10 CFR 61.55, LSA, Type "A" and "B" determinations under 10 CFR 71 and reportable quantity determinations under 49 CFR 171.8. The licensee also maintains a comprehensive list of all radwaste in storage at B','P This is updated monthly to inform licensee management of unit status relative to short-and long-term goals of generated volumes, volume reduction effectiveness and system operabilit The Site Quality Control group inspects packages on receipt and during shipments. Comprehensive audits of the radwaste program are made by the Quality Assurance grou .2 Procedures Procedures germane to the transportation of radwaste that were reviewed against criteria in 10 CFR 20.311, 10 CFR 71.5, 10 CFR 71.12, Technical Specification 6.8 and 10 CFR 50, Appendix B, Criterion V included:

'Radeon Procedure 3.6, "Radioactive Shipment Record"

'Radcon Procedure 3.29, "Inspection of Radioactive Material Packaging Prior to Shipment"

'Radcon Procedure 3.11, "Shipping Radioactive Material for Burial Drums"

• Radeon Procedure 3.12 "Shipping Radioactive Material for Burial-Liners"

• Radcon Procedure 3.32, "Radioactive Waste Shipment Manifest Requirements" 6.3 Shipping and Transportation The inspector reviewed records of shipments made by the licensee between February 29, 1988 and October 21, 1988. During this period of time, the licersee made sixteen shipments of radwaste comprising approximately 14.7 curies of activity in 5140 cubic feet of wast The inspector selected a sample of four of these shipments and reviewed the licensee's implementation of their 10 CFR 71, Subpart H, Quality Assurance requirements and found that the licensee was effectively controlling and using NRC licensed transport packages, including quality aspects contained in procurement documents, receipt inspection, cask handling and securing casks on vehicles,

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During the inspection, the inspector reviewed shipment Number 1087, in which fourteen drums of radwaste were sent to the burial site in a CNSI 14-170 cas The inspector noted that proper radiat'en surveys and vehicle placarding, shipping paper documentation, pa .ge marking and labeling, blocking and bracing were mad The combined shipping papers / waste manifests for shipment Nos. 1080, 1081 and 1082 were reviewed for proper implementation of 10 CFR 20.311 requirements to assure ccmpliance with 10 CFR 61.55 and 10 CFR 61.56 for waste classification and shipment labeling, and waste form and characterization, respectivel The licensee's delivery of the transportation packages of the four shipments to carriers was reviewed against criteria in 10 CFR 71.5, 49 CFR 177 and procedural requirement The licensee's performance relative to these requirements was evaluated by review of records discussions with personnel, and by witnessing of the performance of shipment Number 1087. Within the scope of this review, no violations were note .4 Audits Audits of Transportation Under the licensee's QA program, ar odit of radwaste preparation, packaging and shipping activities, 'omoer BV-88-09 was performed from February 29 to March 16, 1988. The audit and audit checklist were reviewed and found adequate; in addition, comments describing amplification of review of audit attributes were eviden Within the scope of this review, no violations were foun .0 Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on October 21, 1988. The inspector summarized the purpose, scope, and findings of the inspectio E' *

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TJ :,: E I Comparison of Co-located TLD Results l

,TLD Location Monitoring Period NRC Licensee 1985 1986 1987 7 78.6 .5 .01 .5 .1 missing data 75.0 .3 .1 .7 .6 .5 missing data 78 2 15 45.6 .81 .5 .5 .0 t2 13 53 3 51 2 51.7 .0 .2 .4 missing data 78 2 10 55.9 Notes:

1, Results are in units of mR/ year The NRC uncertainty is the random uncertainty at one standard deviatio . The licensee uncertainty is the standard deviation of the mean result.