IR 05000346/1976005
| ML19319B428 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/07/1976 |
| From: | Januska A, Pagliaro J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B424 | List: |
| References | |
| 50-346-76-05, 50-346-76-5, NUDOCS 8001150997 | |
| Download: ML19319B428 (10) | |
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U. S. NUCLEAR REGULARUTY COMMISS 9N
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OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
Report of Preoperational Environmental Protection Inspection IE Inspection Report No. 050-346/76-05 Licensee:
Toledo Edison Company Edison Plaza 300 Madison i
Toledo, Ohio 43652 Davis,-Besse Nuclear Power Station License No. CPPR-80 Unit 1 Category : B Oak Harbor, Ohio Type of Licenn.ee:
PWR (BW) 2623 Mwt Type of Inspection:
Routine, Announced Dates of Inspection:
April 12-14, 1976 4.I 3.[g., L k
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A. G.
nuska Principal Inspector:
(Date)
Accompanying Inspector: None Other Accompanying Pe so el: None
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N Reviewed By:
A. Pagli o, Chief
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Environmental and Special (Date)
J Projects Section
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I SUMMARY OF FINDINGS Inspection Summary Preoperational environmental protection inspection on April 12-14 (76-05):
Rwamination of Davis-Besse preoperational environmental monitoring program and implementation; visits with plant personnel; review of documentation; review of previously reported unresolved items. Two deviations were noted relating to the licensee's failure to comply with commitments of the radio-logical portion of the environmental monitoring program in Revision 6 of their FSAR.
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Enforcement Items None.
Licen,see Action Previously Identified Enforcement Items No previously identified enforcement items within the scope of the inspection.
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Other Significant Items
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A.
Systems and Components d
A potential environmental air sampling problem noted during a previcus inspection 1/ has been corrected. However, a leakage problem in the threaded air sampling piping was noted whereby there would be a potential f or the licensee to report nonconservative airborne concentrations.
(Paragraphs 4.f and 7, Report Details)
B.
Facility Items (Plans and Procedures)
The environmental contractor's thermoluminescent dosimeter results show a large variation within a given set of dosimeters.
The licensee is currently conducting a comparative study between the environmental contractor's results, another contractor's TLD
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system results and TLD results from a system being processed onsite.
(Paragraph 10, Report Details)
l C.
Managerial Items None.
D.
Noncompliance Identified and Corrected by Licensee I
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None.
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RO Inspection Report No. 050-346/74-08.
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E.
Deviations
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Contrary to Table ll-56a, Revision 6 of the FSAR, radium determinations in groundwater samples have not been performed.
(Paragraph 3.a, Report Details)
Contrary to Revision 6 of the FSAR, specific analyses for precipita-tion samples and required sampling of other media have not been performed.
(Paragraph 6, Report Details)
Management Interview The following items were discussed on April 14, 1976, with Mr. J. Evans and members of his staff:
A.
The scope of the inspection.
(Paragraph 2, Report Details)
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B.
Status of Unresolved Items from a previous inspection /.
(Paragraph
3, Report Details)
C.
Apparent deviations identified during this inspection.
(Paragraph 6, Report Details)
D.
Implementation of the radiological and non-radiological environmental monitoring program.
(Paragraphs 4.c, d, e, f, 6.a, b, c, 7, 8, and 10.
Report Details)
E.
Management control.
(Paragraph 5, Report Details)
F.
Meteorological program.
(Paragraph 9, Report Details)
l 2.
Ibid.
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REPORT DETAILS 1.
Persons Contacted J. Evans, Station Superintendent D. Briden, Chemist and Health Physicist L. Stalter, Technical Engineer F. Kebker, Chemistry and Health Physics Tester 2.
General This inspection consisted of an examination of the licensee's preoperational radiological and non-radiological environmental
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monitoring programs including sampling techniques and procedures, sample collection equipment and locations, and program results.
Management control aspects including responsibilities and autho-rities, and administrative controls were also examined.
The licensee's Construction Permit, the preoperational radiological
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environmental monitoring program described in Revision 6, Chapter 11 of the FSAR and a tacitly approved revised non-radiological environ-
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mental monitoring program submitted in a letter dated August 6, 1974, were used as a primary inspection criteria.
The inspection did not include an examination of the licensee's contract laboratory personnel equipment or procedures.
The licensee utilized NALCO, formerly known as Industrial Bio-Test Laboratories, Northbrook, II.1.inois, to provide' laboratory services for analysis of the radiological environs monitoring samples collected on and surrounding the Davis-Besse site. Sample collections are perforned by station personnel (except for some outlying sites which are serviced by personnel contracted to NALCO).
The non-radiological portions of the environmental monitoring program are conducted by the Center for Lake Eric Area Research, Ohio State University, Columbus, Ohio (aquatic monitoring) and the Environmental Studies Center, Bowling Green State University, Bowling Green, Ohio
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(terrestrial monitoring).
3.
Resolution of Unresolved Items The following unresolved items identified during a previous inspection 1/
have been examined.
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Ibid.
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a.
Groundwater Samples
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The licensee failed to retrieve and perform radium analyses
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on well water samples containing in excess of three picoeuries per liter gross alpha activity.
The licensee therefore failed to comply with commitments of Table II-56a of Revision 6 of their FSAR which require that radium determinations be performed when gross alpha activity exceeds three picoeuries per liter.
b.
Precipitation Samples The contractor was unable to substantiate the performance of gamma spectral analyses on precipitation samples con-taining in excess of ten picoeuries per liter gross beta activity.
4.
Resolution of Open Items The following open items identified during a previous inspectionN have been examined. The actions with respect to items a,b, e and d were incomplete and will be re-examined during a subsequent inspection.
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a.
Formal Procedures The licensee has completcd formal procedures defining the environmental monitoring program except for procedure ST 5099.03 entitled " Radiological Environmental Monitoring Procedures." This procedure will cover the collection of
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all types of samples and will have an attachment that will defina samples to be. collected each month.
b.
Non-Radiological Environmental Monitoring The non-radiological environmental monitoring programs which were started in 1972 are scheduled to continue to commencement of plant of rations and subsequently for two to five years there-after, ac which time the programs will be evaluated for their continuing usefulness, c.
Clam Samples The licensee intends to revise the FSAR to reflect the avail-
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ability of clams in order to satisfy the requirement of gathering
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sufficient preoperational data.
d.
Wild Life collection The licensee stated that the monitoring program as specified in the FSAR would be revised in order to reflect the current program.
4)
Ibid.
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e.
Milk Monitoring
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The milk monitoring program has been changed to (1) increase the sample frequency at the nearest dairy farm from monthly to weekly during the seasons that the milking animals are on pasture and (2) improve analytical sensitivity for the iodine 131 analyses to 0.5 picoeuries per liter at the time of sample collection.
f.
Airborne Samplers The licensee has remounted charcoal filters such that the
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air flow through the charcoal is in a downward vertical direction thereby reducing any possibility of air channeling.
5.
Management Control Administrative procedures AD 1843.00 entitled " Environmental Radiological Monitoring" and AD 1843.01 " Aquatic and Terrestrial Monitoring" describe the administrative controls which have been established to implement the environmental monitoring requirements of the Davis-Besse Nuclear Power Station environmental technical specifications and are therefore not applicable during the preoperational monitoring period. Management control of the
[-~s environmental monitoring programs during the preoperational phase
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is the responsibility of the Plant Chemist and Health Physicist.
Other station personnel are involved in certain facets of the program and station management is made aware of any problems that arise. There are no formalized procedures for management control of the preoperational phase of the environmental monitoring programs.
Quality Assurance of the environmental contractor's program will be implemented after the TECo QA Department reviews and approves the NALCO Quality Assurance document.
Surveillance of the environ-mental contractor will be conducted in accordance with Paragraph 5.2.1 of administrative procedure AD 1843.00 and Paragraph 5 of the administrative procedure AD 1843.01. The licensee expects to have the environmental monitoring program put on the surveillance schedule by August 1976.
6.
Radiological Environmental Monitoring Environmental monitoring reports from July 1974 through December 1975 were selectively reviewed by the inspector. The licensee has not updated his FSAR to reflect the current program which has been
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modified in order to conform with the proposed technical specifica-(
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tion program.
Some discrepancies between the semiannual report and the monitoring program as contained in the FSAR are noted below:
a.
Precipitation samples were not gamma scanned when gross beta activity was detected in quantities greater than 10 picoeuries
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per liter for the second half of 1974, the first half of 1975, and approximately 80% of the samples collected during the second half of 1975.
The licensee representative stated that he had intended to modify the program with respect to gamma scanning of precipitation samples as the result of previous inspection findings /,
i b.
The FSAR requires that bottom sediment samples be collected
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during the second, third and fourth quarters. No samples were collected for the third quarter of 1974, and for the third
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quarter of 1975.
Two sets of samples were collected during the fourth quarter of 1975 in order to. meet the intent of collecting two samples during the last half of the year.
c.
Fish, clam, fruit and vegetable, and wildlife samples were
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similarly not collected in accordance with the FSAR program.,
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'Some of these discrepancies are due to the fact that the current program is being modified and is not in agreement with the FSAR.
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The licensee therefore failed to comply with commitments of the radiological monitoring program specified in Chapter 11, Revision 6 of the FSAR for failure to perform 1) the required specific analyses and 2) required sampling.
Examples are given in paragraphs 6.a, 6.b and 6.c.
Two generic problems were noted during this inspection.
The
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licensee has changed the program as specified in the FSAR and
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has not kept the FSAR up-to-date, therefore, this inspection has
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revealed omissions in the sampling when the current revision of the FSAR is used as the criterion.
It is also noted that the environ-mental contractor has not adequately identified the reason for missing
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results and those results which are determined from inadequate data.
7.1 Air Sampling Stations Five random sampling sites were visted during this inspection:
three onsite and two offsite.
Inspection of the sampling units
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showed that (1) the running time meter of Unit No.1 had not been fully cancelled during the previous filter-change and had not been
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recording since the time of the previous filter change' (2) the charcoal filter had been chang'ed from a horizontal to a vertical position based on discussions during a previous inspection $/
(3) the filter position for station T-1 requires that the threaded piping of the system be disturbed in order to exchange the filter on a weekly basis, (4) blanking off the systems at the quick dis-
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connect fitting revealed nenuniform vacuum gauge readings thereby j
indicating leakage and (5) a.very slight pressure on the intake portion of one of the systems indicated loose threaded fittings.
The inspector commented on the low vacuum gauge readings and the loose fittings which have a potential for leakage and underreporting
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of concentrations. The licensee acknowledged the inspector's
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comments and stated that immediate corrective actions would be
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taken to eliminate these leakage potentials and that procedure
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ST 5099.03 will incorporate a field leak test.
A licensee representative stated that difficulty had been experienced' -
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in running the pumps of.these systems on a continuous basis.
The licensee is currently exchanging three spare pumps weekly in order to achieve a quarterly maintenance schedule.
Pumps are exchanged by
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the Chemistry and Health Physics Group at the time the filter.is l
normally changed.
Carbon vanes are replaced by the Maintenance Section
and calibration of the rebuilt units performed by the Instrument and Calibration department. These systems will be re-examined during a
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subsequent inspection.
8.
Air Sampling Data Air particulate data sheets are initiated for each air particulate and charcoal filter change on a weekly basis. The data on these
sheets includes date and time on, vacuum gauge readings on and off i
for each of two vacuum gauges employed, running time meter readings, -
and any notations pertinent to the specific station in question.
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These data sheets accompany the-filter sent to the environmental contractor. A sample data sheet is also enclosed-to summarize the samples collected. The data sheets are returned from the
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environmental contractor periodically.
One data sheet was observed
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to have the following discrepancies:
(1) the date the unit was run-did not agree with the date indicated in the semiannual report from the licensee's contractor, (2) the sheet indicated that
.there was no electrical power at T-27 and further that the system
was not started for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the normal starting date, (3) no initial vacuum gauge data had been recorded, (4) there was no running time meter on this unit at that time.
Based on the available data sheet information,_the licensee's environmental contractor
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. reported-a concentration and an air volume.
This concentration was based on an initial vacuum gauge and a total run time assumption
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which could not be accurately determined, and did not agree with the
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The environmental contractor
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was contacted and stated that apparently a calendar from the wrong year had been used as opposed to utilizing the dates on the data sheet.
The inspector discussed the importance of identifying 1) the reason for missed samples and 2) those results that are determined using assumed valuec.
.te licensee's representative acknowledged the' inspector's commentr$
and stated that these would be brought to the attention of the environmentav contractor at a meeting that was scheduled for April 19, 1976. The inspector further stated concern that the environmental contractor's reports are not being audited for completeness and accuracy.
A review of some of the data sheets indicated that this may have been an isolated case with respect to air particulate and charcoal data.
9.
Meteorological Program The meteorological program is handled under contract to the Nuclear Utility Services who maintain the tower, perform quarterly calibra-
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tions on instrumentation and are responsible for the reduction of the data.
Instrument and Calibration department personnel perform daily and weekly surveillance on the meteorological tower equipment and instrumentation.
Surveillance sheets are completed in accordance
with procedure ST 5099.02, and sent to NUS.
Defects noted are brought '
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to the attention of NUS by phone who usually are able to respond within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Daily and weekly surveillance sheets for the O
period of this inspection were not available at the site.
A discussion with a licensee representative in the Power Engineering Division revealed that NUS has generated two years of meteorological data which is for licensing considerations. The new meteorological tower was built to comply with Regulatory Guide 1.23.
An additional one year study was required to correlate data from the old and new tower. The report has been sent to licensing.
The TECo QA Department has audited the NUS program twice.
The meteorological program will be turned over to station personnel
prior to plant operation.
10.
Thermoluminescent-Dosimeter Program Direct radiation is measured by means of the environmental contractor's lithium floride dosimeters at various monitoring stations. The environmental exposures are determined by using control TLD's that are shipped with the exposed dosimeters to correct for exposures received during transportation.
The contol TLD's are stored in a lead shield located at the guard post during the monitoring stations environ-mental exposure period.
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There is a large reported variation between certain stations.
For the annual period July 1974 through June 1975 Stations T1, T2, and T3 averaged 23% below the annual average of all stations and Station
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T14 was a f actor of 1.3 higher than the ave *. age of the stations.
The licensee representative stated that he had observed the fact
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that stations T1, 2, and 3 were low but was not aware of the reason
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for these stations being low or Station T14 being high.
The licensee is currently conducting a study at three sampling sites (T1, T2 and TS)
and comparing results of three TLD systems. A report for one period showed a 40% variation between two of the three systems being strdicd.
The analytical environmental contractor's results and results of the study being conducted by Davis-Besse personnel will be examined during a subsequent inspection.
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