IR 05000346/1980024
| ML19332B395 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/18/1980 |
| From: | Essig T, Oestmann M, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19332B391 | List: |
| References | |
| 50-346-80-24, NUDOCS 8009260665 | |
| Download: ML19332B395 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-346/80-24 Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, OH Inspection Conducted-July 21-25, 1980
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Inspectors:
M. P. P llips b'O~O W/z ANN?A S-r~
3/i(p M.
. Oestmann e Ov
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LC-tu L4 T. H. Essi I /[ [O f h h ttf L
Approved B T. H. Edsig, ' Chief N
Environmental and Special Projects Section Inspection Summary Inspection on July 21-25, 1980 (Report No. 50-346/80-24)
Areas Inspected: Routine, unannounced inspection of:
(1) Environmental Protection, including evaluation of reportable occurrences 78-072-04-T-0, NP-09-78-03, NP-09-80-01, and NP-11-80-01; the licensee's program for quality control of analytical measurements; program management and implementation; review of program results; inspection of proper installation and operability of selected sampling stations; (2) Emergency Planning - review of coor-dination with offsite support agencies; emergency tests and drills; and (3) Confirmatory Measurements program for quality assurance and quality control of analytical measurements. The inspection involved 74 inspector-hours onsite by three NRC inspectors.
Results: Of the seven areas inspected, no apparent items of noncompliance or deviations were identified in six areas; four apparent items of noncom-
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pliance (deficiencies) were found in one areausT in excess of Technical
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Specification limits, Paragraph 5.a; (failure to report exceeding Technical Specification limiting conditien of oper, lon, Paragraph 5.a; failure to perform required sulfate monitoring at a required interval, Paragraph 5.b; and failure to perform required ichthyoplankton monitoring at a required interval, Paragraph 5.c).
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DETAILS
1.
Persons Contacted T. Murray, Station Superintendent
- B. R. Beyer, Assistant Station Superintendent
- D. Huffman, Administrative Coordinator
- D. Briden, Head, Chemistry and Health Physics Department xC. J. Greer, Oparstions Quality Assurance Supervisor
- B. Geddes, Operations Quality Assurance Representative
- J. Hirsch, Emergency Planning and Preparation Supervisor
- J. Scott-Wasilk, Assistant invironmental Technologist R. Scott, Chemistry and Radiochemistry Supervisor M. Horn, Health Physics Supervisor J. Sullivan, Head, Environmental Activities Offsite Agencies K. Gyde, Carroll Township Maintenance Supervisor
- Denotes those present at the exit interview.
2.
Review of Reportable Occurrences (Closed) Reportable Occurrences NP-09-78-03 and NP-09-80-01: Discharge temperature for station liquid effluents in excess of Environmental Technical Specifications limit. The inspectors discussed the reported corrective actions for this item of noncompliance with the license. A review of documentation indicated that both sets of corrective actions had been completed. The inspectors have no further questions regarding this item.
(Closed) Reportable Occurrence 78-072-04-T-0: Chlorine discharge in excessofETSljpit. This item had been discussed in a previous in-spection report-and left open pending the completion of corrective action.
The inspectors reviewed documentation and verified the comple-tion of the corrective action. The inspectors have no further questions regarding this item.
(Closed) Reportable Occurrence NP-11-80-01: Tritium concentration greater than control by a factor of ten.
The inspectors reviewed the tritium sampling procedure and verified that it had been changed to require monthly instead of quarterly sampling at the beach well. All results were well below 10 CFR 20 limits for water in unrestricted areas. Th2 inspectors have no further questions regarding this item.
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3.
Action on Previous Inspection Findings
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(Closed) Unresolved Item (050-346/78-22): Water Quality Measurements during 1977. The inspectors reviewed the Environmental Technical Specifications and determined from the date of commercial operation that these measurements were not requiled by the Technical Specifica-tions at that time.
4.
Management Controls Mr. D. Briden, Chemist and Health Physicist, has responsibilities for overall direction of the nouradiological and radiological enviromental monitoring programs at the site. The radiological e' litoring program is performed for the licensee by Hazleton Environmental Sciences, Northbrook, Illinois. The nonradiological environmental ronitoring program is performed by the Center for Lake Erie Area Research (CLEAR),
Ohio State University, Columbus, Ohio and the Bowling Green State University Environmental Studies Center, Bowling Green, Ohio. Overall management of contracts is under the corporate responsibility of Mr. J. Sullivan, Environmental Activities.
No items of noncompliance or deviations were identified.
5.
Nonradiological Monitoring Frogram The following results of the licensee's nonradiological environmental monitoring program were examined for compliance with monitoring and reporting:
a.
Maximum Discharge-AT The inspectors discussed monitoring of discharge temperatures, ambient lake temperatures and the subsequent computation offiT.
Temperatures are scanned and temperature differential is computed j
once per minute, stored hourly, and recorded daily on the control
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computer. A review of daily.oT results between January 1,1980, i
and June 30, 1980, indicated five days (January 6, 7, 8, 16'and February 20) when the dT limiting condition of operation of 20'F was exceeded. This constitutes an item of noncompliance with Environmental Technical Specifications Section 2.1.1.
Of the above five instances when the4T limit was exceeded, the licensee reported four of these occurrences in Licensee Event Report No. NP-09-80-01, however, no report was made of the fifth occurrence (February 20, 1980). This constitutes an item of noncompliance with Environmental Technical Specifications Section 5.4.2.
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b.
Chemicals and Chemical Use
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The inspectors reviewed records of chlorination, pH, sulfate ion concentrations, and chemical usage for the period January 1, 1978, through July 22, 1980. All measurements were within Technical Specifications limits. Records were also checked for monitoring frequency requirements. Daily results were available for the entire period for pH and chlorine measurements. Sulfate ion concen-trations over the period were measured on an average of about twice per week with one exception. Weekly sulfate monitoring fcr the weeks of February 11-17, 1979, and February 18-24, 1979, were performed on February 12, and February 23 (11 day interval),
respectively; however, Section 1 of the Environmental Technical Specifications defines weenly as once every seven days with a maximum allowable extension of 25%. Exceeding this time a period constitutes an item of noncompliance with Environmental Technical Specifications Section 2.3.3.
c.
Aquatic Monitoring Plankton, benthic and fisheries population studies, as well as ichthyoplankton, fish egg and larvae entrainment, and fish im-pingement results for 1978 and 1979 were reviewed by tg7 nspectors.
i The sections described in a previous inspection report-that were submitted to the Director of the NRC Regional Office as a supple-mentary report were also reviewed. The results of this monitoring indicated numerous interpretation problems existed between the licensee and their contractor (Center for Lake Erie Area Research).
These are described in part beiaw:
1.
Contractor interpreted 30 day sampling frequency to mean once a month, hence sample collection dates of May 11, 1978, and i
June 29, 1978 (49 day interval), and October 17, 1978 and j
November 1, 1978 (18 days).
2.
For ichthyoplankton monitoring, although Environmental Technical Specifications requires 30 day sampling frequency from September through November, contractor report states that sampling was terminated on September 1, 1978, and August 15, 1979.
Both of the above problems were identified by the licensee's Quality Assurance Department in an audit of the aquatic environmental monitor-ing program and corrective actions have been completed to prevent recurrence.
Ichthyoplankton monitoring results for 1979 indicated that no sampling of Toussaint Reef had been performed during June 1979, with no reason given. This was identified by the inspectors and constitutes an item of noncompliance with Environmental Technical Specifications Section 3.1.2.a.4.
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d.
Water Quality Analyses
The inspectors reviewed records of water quality analyses for CY78 and CY79. The licensee uses the sere contractor to perform this program as the Aquatic Monitoring Program described in Paragraph 4.c. above. The same problems described in Paragraph 4.c. in regards to sampling frequency were found by the licensee's Quality Assurance Department to exist in the Water Quality Monitoring Program. The inspectors verified that correct ive actions had been completed to prevent recurrence.
e.
Terrestrial Monitoring The inspectors reviewed records of the 1978 and 1979 aerial vegeta-tion surveys.
It was noted that the 1979 survey was done on September 10, rather than during July or August due to severe weather.
No deviations or further items of noncompliance were identified in the above areas.
6.
Implementation of the Radiological Environmental Program (REMP)
The inspectors examined the REMP results far CY1978 and CY1979 and up to June 1980 for compliance with the requirements of Section 3.2, particularly Table 3.2-1 and Section 5.4.1 of Appendix B Technical Specifications. The examination included a review of the results in the Annual Operating Report
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and Data Tabulations and Analysis report on detailed specific analytical results prepared by the licensee contractor, Hazleton Environmental Sciences Corporation. No unusual trends or results ascribable to plant i
operations were observed in this review.
The licensee did report elevated radioactivity levels found in milk due to atmospheric weapons testing by the Republic of China during the fall of 1977 and spring of 1978. The licensee utilizes indicator nuclides to discriminate weapons fallout from plant effluent effects and provide for a referenced analysis for each determination where quantifiable levels of radioactivity were observed in environmental media.
Review of sample collection and shipment logs established that samples had been collected and analyzed in accordance with Table 3.2-1.
The licensee also provid'ed explanations for missing samples such as pump failure resulting in no particulate samples collected for a period of three weeks at sampling station T-27 during January 1978. The licensee explained the causes of pump failure and the difficulties to repair the pumps because of severe weather conditions.
Examination of the domestic meat and wild'ife species samples indicated thatthesesampleswerecollectedsemiannuallyinaccordagyewithTable 3.2-1.
This item was discussed in a previous inspection.-
The inspectors have no further questions regarding this item.
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No items of noncompliance or deviations were identified.
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Sampling Stations and Equipment The inspectors toured several environmental sampling stations and examined air sampling equipment and thermoluminescent dosimeters. All equipment was operable, properly calibrated, and in good working order.
A test was performed by the inspectors that revealed no apparent leakage in the air sampling system.
The inspectors toured the nonradiological environmental monitoring contractor's (Center for Lake Erie Area Research) office in Port Clinton, Ohio, and examined equipment used for the collection of sediment and water samples, solar radiation measurements, fish collection, and storage of samples.
No items of noncompliance or deviations were identified.
8.
Quality Assurance and Quality Control of Analytical Measurements The inspectors discussed with licensee representatives the QA/QC of analytical measurements taken in the REMP. The licensee's contractor has prepared the following documentation pertaining to QA/QC for the REMP.
a.
Quality Assurance Manual b.
Quality Control Procedures Manual c.
Sampling Procedure d.
Analytical Procedures All procedures were deemed technically adequate and had been implemented.
Air sampling equipment examined had been maintained and calibrated in accordance with the procedures listed above.
The licensee's contractor also performs duplicate analyes on 20% of the samples collected and participates in the U. S. Environmental Protection Agency's cross check program. The contractor's program results for milk and water for CY 1975-78 and for ILD's for CY 1976-77 were examined by the inspectors and appeared to be within acceptable ranges of comparison with the EPA's results.
No items of noncompliance or deviations were identified.
9.
Confirmatory Measurements Licensee Program for Quality Assurance / Quality Control of Analytical Measurements a.
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The inspector discussed the assignment of responsibility and
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authority for management control of analytical measurement.
Responsibility and authority for control of those measurements rests with the Chemist and Health Physicist. The management control for the program progresses down through supervisors and foremen.
b.
Nonradiological Analysis of Reactor Coolant The inspectors reviewed selected licensee procedures and records relating to nonradiological analyis of reactor coolant. Procedures reviewed covered analysis of chloride, dissolved oxygen, ammonia, boron (high and low range), cation conductivity, conductivity, sulfate, phosphate, pH, and spectrometric analysis of various metals.
These procedures were current (most having been revised in 1978-1979)
and were deemed technically adequate. However, improvements are needed for the procedures to contain criteria for accepting measurement results and requiring notification when deficiencies are noted. This item will be examined in a future inspection.
The inspectors toured the licensee's cold chemistry laboratory and observed that all laboratory instruments appeared to be functional, i
and that calibration stickers current. Records of maintenance, calibration, and daily operations were reviewed and found to be satisfactory. The inspectors did note that cheetcal solutions made up by laboratory technicians had not been dated. This item will be examined during a subsequent inspection.
c.
Training of Chemistry Laboratory Personnel The inspectors discussed the training program that the licensee implements for training chemistry personnel on the job. Such training involves performing various chemical analyses and includes supervisor observation of analytical measurements. The inspectors determined that although all plant chemistry personnel appear to be adequately trained, no formal training program was established.
No documentation was available indicating types, frequencies, or curriculum of training activities. Also, no formal acceptance criteria were established to determine if a techcician was properly trained. The licensee representatives stated that the present program needs strengthening. This item was discussed at the exit interview and will be examined during a future inspection.
d.
Quality Control of Laboratory Practices The inspectors discussed QC of laboratory practices with licensee representatives. The licensee does not have any formal program for checking the quality of analytical measurements of nonradio-
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logical reactor plant chemistry. In particular, no program has-8-
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been established to check the laboratory technicians results, e.g.,
no QC checks, spikes or blind samples of these measurements were conducted. Although the licensee is not required to conduct such a program, the inspectors discussed the need for one with licensee representatives. This item will be examined during a future inspection.
No items of noncompliance or deviations were identified.
10.
Tests and Drills The inspectors reviewed the documentation of the exercise conducted in October 1979 involving the licensee, State of Ohio, local agencies, and the licensee's contractor, Radiation Management Corporation (RMC). A critique followed the drill and a series of recommendations were proposed with due dates and persons responsible to accomplish the recommendations.
The majoriy of recommendations have already been completed with about three outstanding. These pertain to the need for headsets for phones, availability of audio communications equipment with various common frequencies, and an improved method to assist the Radiation Monitoring Teams in checking out equipment during initial stages of an incident or event. These items will be examined duriu a subsequent inspection.
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I RMC supplied a critique to both the station and to the licensee's offsite hospital. Training on emergency handling of contaminated victims was also provided.
j No items of noncompliance or deviations were identified.
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Emergency Planning Coordination with Offsite Support Agencies
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The inspectors discussed cor dination of emergency planning activities between the licensee and offsite agencies with licensee personnel.
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Currently, the licensee has established formal Letters of Agreement (LOA)
l with the following agencies: Detroit Edison, Consumers Power, United States Environmental Protection Agency, Radiation Management Corporation, Ottawa County District Board of Health, Ottawa County Sheriff, National Oceanic and Atmospheric Administration, Department of Energy, Magruder Hospital, and the Carroll Township Emergency Medical and Fire Service.
All LOA's were prepared in 1980, however, the National Oceanic and Atmosphe~ric Administr + tion had requested additional information, and no written reply had yet been issued by the licensee.
The inspectors discussed the Carroll Township Emergency Medical and Fire Services LOA with Mr. K. Gyde. The inspectors determined from this dis-cussion that adequate emergency arrangements exist between the licensee and the township, however, a misunderstanding might be present regarding such phrases in the LOA as " protect attendants from exposure to radiation" and " completely decontaminate all equipment." This was discussed at the exit interview.
No items of noncompliance or deviations were identified.
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Licensee's Internal Audits
The inspectors questioned licensee representatives regarding the conduct of internal audits which included the Environmental Monitoring Program.
The licensee's Quality Assurance Department audited the Hazleton Laboratory in April 1977 and identified five findings requiring corrective actions.
The inspectors determined that the corrective actions had been accomplished on all five items by January 1978.
The QA Department also conducted an audit of chemistry and radiochemistry in March 1980 and identified seven findings. Corrective actions have been completed on four items and initiated for the other three items. An audit conducted in May 1979 identified one item pertaining to the conductivity meter in the chemistry laboratory. This item was closed out in October 1979. The Nonradiological Environmental Monitoring Program was audited in November 1979 against requirements in the Environnental Technical Specifications. Fourteen findings were identified.
Corrective actions were completed on all items by June 1980.
The inspectors reviewed minutes of the Station Review Board and Company Review Board.
The minutes showed that the annual reports for 1978 and
1979 had been reviewed prior to their issue, and that changes to en-vironmental procedures had been reviewed.
Station Review Board minutes showed that all Licensee Event Reports (LER's) had been reviewed as required, but no mention was made in the minutes of the Campany Review Board that LER 's for 1980 had ever been reviewed. A discussion with Company Review Soard members indicated that the current procedure for LER review is to distribute them to each individual member of the board, however, no mention of this is made in the minutes of the Company Review Board. The inspectors recommended that some documentation of this review be included in the meeting minutes. This was discussed at the exit interview.
No items of noncompliance or deviations were identified.
13.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on July 25, 1980. The inspectors summarized the scope and findings of the inspection.
The licensee made
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the following remarks in response to certain of the items discussed by the inspectors:
a.
Acknowledged statements by the insrectors with respect to the items of nonce,pliance.
(Paragraph 5.a, !,.b, and 5.c)
b.
Agreed to respond to the National Cceanic and Atmospheric Adminis-tration and clarify the Letter of Agreement with the Carroll Township Emergency Medical and Fire Service.
(Paragraph 11)
c.
Agreed to look into the possibility of dr umenting LER reviews by the Company Review Board in the minutes of their meetings.
(Paragraph 12)
d.
Agreed to develop a formal training program for chemistry laboratory personnel.
(Paragraph 9.C)
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