IR 05000346/1986021

Insp Rept 50-346/86-21 on 860723-24.No Violation or Deviation Noted.Major Areas Inspected:Open Items,Selected IE Info Notices & Methods of self-identification & Correction of Programmatic Weaknesses Re Radiation Protection Program

ML20212H354
Person / Time
Site:	Davis Besse
Issue date:	08/08/1986
From:	Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212H346	List: IR 05000346/1986021 ML20212H339
References
50-346-86-21, IEIN-85-006, IEIN-85-042, IEIN-85-043, IEIN-85-092, IEIN-85-42, IEIN-85-43, IEIN-85-6, IEIN-85-92, IEIN-86-022, IEIN-86-023, IEIN-86-043, IEIN-86-046, IEIN-86-22, IEIN-86-23, IEIN-86-43, IEIN-86-46, NUDOCS 8608140044
Download: ML20212H354 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/86021(DRSS)

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 (DBNPS)

Inspection At: DBNPS, Oak Harbor, OH Inspection Conducted: July 23-24, and August 7, 1986

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Inspector: D. E. Miller #/#/#4>

Date Approved By: L. R. Greger, Chief Facilities Radiation Protection 8/886 Date Section Inspection Summary

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Inspection on July 23-24, and August 7, 4986 (Report No. 50-346/86021(DRSS))

Areas Inspected: Routine unannounced inspection of open items, selected IE Information notices, and methods of self-identification and correction of programmatic weakness relative to the radiation protection progra Also reviewed was licensee action in response to weaknesses identified by the Performance Appraisal Tea Results: No violations or deviations were identified 8608140044 DR e60811 ADOCK 05000346 PDR

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DETAILS Persons Contacted

• D. Briden, Director, Chemistry and Health Physics

• R. Cook, Acting Compliance Supervisor D. Erickson, Assessment Manager, C and HP

• B. Geddes, Associate QA Auditor R. Scott, Chemistry Superintendent

• R. Snyder, Nuclear Plant Systems L. Storz, Plant Manager J. Sturdavant, Licensing Specialis,t D. Kosloff, NRC Resident Inspector The inspector also contacted several other licensee personne * Denotes those present at the exit meetin . General This inspection, which began at 9:00 a.m. on July 23, 1986, was conducted to examine open items, licensee response to selected IE Information Notices, and the licensee's methods of self-identification and correction of programmatic weaknesses in the radiation protection program. Also reviewed was licensee actions in response to weaknesses identified by the Performance Appraisal Tea . (0 pen) Open Item (346/83-22-01): Dosimetry quality assurance. The licensee performed a TLD/SRD reading comparison study and found that recorded SRD readings are higher than TLD analysis readings by up to 50 percent for low total doses during a badge period, and up to 25 percent for higher (greater than 500 mR) total dose. The licensee believes that the bias is mainly caused by individual wearers conservatively reading the 0-500 mR SRDs that are routinely issued, even for low dose-rate work. The licensee is implementing a program to replace 0-500 mR dosimeters with 0-200 mR dosimeters for lower dose tasks, and to have all ERDs read, and the readings recorded, by the health physics staff. After the new program is fully implemented, the TLD/SRD reading comparison study will be redone, acceptable deviation limits will be established, and a program will be initiated to require investigation of deviations greater than established limits. Implementation will be further reviewe (Closed) Open Item (346/84-24-01): Inoperable fit t'est equipmen The equipment has been altered to use DOP instead of Nacl as the test atmosphere. The equipment is operational. No further operational problems have been experienced.

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I (Closed) Open Item (346/84-24-02): Dilution flows used to calculate population doses from liquid releases. The licensee now uses total dilution flow, instead of dilution flow during planned releases, when calculating population dose. The new method complies with guidance provided by the Effluent Treatment Systems Section of NRR. No further problems were note (Closed) Open Item (346/84-30-01): Calibration of normal range noble gaseous effluent monitor. The monitor was calibrated using plant gases, collected from a waste gas decay tank, in early 1985. The determined efficiencies compared favorably with the manufacturer supplied calibration curve (Closed) Open Item (346/84-08-04): Re-evaluation of Post Accident Sampling System (PASS) containment sample piping. The dose to persons collecting PASS containment gaseous, particulate, and radioiodine samples was re-evaluated. The re-evaluation indicated that the dose was higher than previously calculated but within required design criteri (0 pen) Open Item (346/84-08-02): Energy response determinations for post accident noble gaseous effluent monitors. Some in-house work was completed. However, the results do not appear to mirror determinations made by other stations with similar monitors. The licensee stated that this matter would be investigated and that preliminary revised determinations, if appropriate, will be completed by December 1,198 (0 pen) Open Item (346/84-30-02): Stack sample return line. The licensee submitted a letter, dated May 30, 1985, to NRR concerning the stack sample stream that does not return to the source, but instead is released from the side of the turbine building; the licensee requested that the line be permitted to remain as installed. No response has been received by the licensee to date. The licensee stated that NRR would be contacted again to resolve this matter. The licensee stated that this matter would be resolve by December 1, 198 (Closed) IE Bulletin (346/79-08-BS): " Radiation Levels From Fuel Element Transfer Tubes." This Bulletin was re-reviewed to assure adequate follow-up was completed by the licensee. The inspector verified that additional shielding had been constructed in potentially occupiable areas

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near the fuel element transfer tube. No outstanding items remain.

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The inspector reviewed onsite and offsite audits of the radiation i protection program conducted from December 1984 to dat Extent of audits, qualifications of auditors, and adequacy of corrective actions i were reviewed.

l Two annual station audits of compliance with selected radiation protection procedures were conducted. One deficiency was identified concerning processing of paperwork for portable radiation detection survey instruments sent offsite for calibration. The deficiency was responded to and closed.

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One quality assurance station audit of chemistry included compliance with radiation protection sampling procedures; there were no findings in the radiation protection area. One audit of the TLD badge vendor was performed; the audit was performed at the vendor's facility. There was one finding concerning the vendor's procedures for processing Davis-Besse badges; the finding has since been close One annual station audit of radwaste management was performed. The audit included compliance with selected 00T and NRC requirements; there were three findings. One finding concerned two radwaste organizational positions not having responsibilities described by procedures, one concerned missing data on some gaseous release permits, and one concerned distribution of semiannual effluent reports. The findings have been responded to and are considered by the station quality assurance auditors to be close The inspector reviewed the 1985 INP0 audit including the licensee's response to a finding concerning the effectiveness of control of work involving radiation exposure and contamination. The licensee adequately responded to the finding by revising the radiation work permit (REP)

program so 4t enij one job, work order, or facility change request is covered by cn REP 4 Ser than routine surveillances); communicating the new REP program, oortance of reviewing job requirements before covering the job, . health physics technicians; and revising the general orientation a. , ac:iation controls training program, given to raciation workers, to stress ALARA practices, contamination controls, and REP requirement The extent of audits and qualifications of auditors appears adequate; corrective actions appear goo No violations or deviations were identifie . Performance Appraisal Inspection (50-346/84-19)

The Performance Appraisal Section (PAS) of the Division of Reactor Programs performed an appraisal inspection of the licensee on July 30 through August 10, and August 20-24, 1984. The inspection included an examination of radiation protection procedures and records, observations of radiological work activities, and interviews with management personnel. Two potential enforcement findings (PEFs) were identified concerning radiochemistry counting equipment, and station review board procedure reviews; these PEFs are discussed in Inspection Report No. 50-346/85024(CRSS). In addition to the PEFs, there were two radiation protection program weaknesses identified during the appraisal; these weaknesses are discussed belo One weakness concerned an apparent lack of implementing procedures for tritium bioassays. The PAT noted that no procedure existed that specified frequency or quantity of samples to be collected, or who should be sampled. General procedures for radiochemical analysis of tritium bioassays were inplace, however, and had been reviewed by RIII prior to initial criticality. Under these procedures the licensee routinely collected urine samples each quarter from selected persons

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who worked in controlled areas. The sampling urinalysis program was conducted to assess need for more extensive sampling; no such need has been indicated based on results of analysis of collected sample Although the licensee's program appears to have been adequate, the licensee responded to the PAT criticism by generating and implementing (January 1985) a procedure for urine collection for bioassay which resolved the PAT criticism. The PAT criticism has been adequately addressed by the license The second weakness concerned an apparently inadequate visitor dosimetry program. The visitor dosimetry program was reviewed by RIII preoperationally and was determined to be acceptable and in compliance with regulations. Further review during this inspection confirmed the previous RIII determination. This PAT weakness does not appear to be significant; no licensee corrective actions were take No violations or deviations were identifie . IE Information Notices The inspector reviewed the licensee's internal responses to selected IE Information Notices. The licensee's evaluations, conclusions, and corrective actions appear appropriate and adequate. T:e following notices were reviewe No. 85-06: Contamination of Breathing Air Systems. The licensee's review concluded that adequated procedures exist to preclude temporarily connecting breathing air lines to contaminated systems, cross-connecting contaminated to clean air systems, and use of the breathing air system without prior verification that the system has not become contaminate For the case where a permanent cross-connection may be installed, a safety review is required, in the Facility Change Request System, to address precautions to be taken to ensure separation integrit No. 85-42: Loose Phosphor in Panasonic 800 Series Badge TLD Element The licensee does not use the subject badge No. 85-43: Radiography Events at Power Reactors. The licensee's procedure HP 1607.05, Industrial Radiography, establishes radiation safety and surveillance requirements for use of radiographic devices at the station. The procedure appears to address the concerns ,

described in the notic No. 85-92: Surveys of Wastes Before Disposal From Nuclear Reactor Facilitie In response to the notice, and to supplement the operational contamination monitoring program, the licensee has ordered a large surface area scintillation survey instrument to be used to ensure that materials leaving the radiologically controlled area have been adequately surveyed before releas No. 86-22: Underrespon;e of Radiation Survey Instrument to High Radiation Fields. The licensee has/uses the subject instrument (meter)

but does not, and does not intend to, use the HP-290 gamma probe with the

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meter. The meters are being returned to the factory for modification to eliminate any chance of meter overresponse should the HP-290 probe be used at some later dat No. 86-23: Excessive Skin Expo;ures Due to Contamination with Hot Particles. The licensee investigated methods of protective clothing use and laundering at stations experiencing problems with skin exposures to highly radioactive particles. The licensee believes that Davis-Besse's methods of laundering, segregation of used clothing, and more extensive use of paper and plastic suits as outer garments when work is performed on highly contaminated equipment, diminishes the probability of experiencing problems with Iot particles. The licensee is also pursuing use of more efficient laundry monitoring equipmen No. 86-43: Problems with Silver Zeolite Sampling of Airborne Radioiodines. The licensee responded that they will not use silver zeolite for post accident sampling, and do not use silver ziolite for routine sampling of gaseous systems where quantification of iodine is required; charcoal canisters are used. Silver zeclite is used for off-site sampling where there is no free hydroge No. 86-46: Improper Cleaning and Decontamination of Respiratory Protective Equipment. The licensee does not use Freon to clean respirators, does not use the MSA ultra-twin respirator which is subject to cracking, and does not strip paint from cylinders. According to the licensee, respiratory equipment is cleaned and maintained in accordance with the manufacturers' recommended practice . Exit Meeting The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on July 24, 1986, and by telephone on August 7, 1986. The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviesed by the inspector during the inspection. The licensee identified no such documents / processes as proprietary. In response to certain items discussed by the inspector, the licensee: Stated that preliminary revised energy response corrections for effluent mid and high range gaseous monitor's response to post accident gaseous mixes would be completed by December 1, 1986 (Section 3). Stated that NRR would be recontacted about the licensee's letter, dated May 30, 1985, to NRR concerning routing of the stack sampling return lina. The licensee anticipates resolution by December 1, 1986 (Section 3).

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