IR 05000346/1989004
| ML20245J089 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/24/1989 |
| From: | Gill C, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20245J072 | List: |
| References | |
| 50-346-89-04, 50-346-89-4, NUDOCS 8903060163 | |
| Download: ML20245J089 (12) | |
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3, U.S. NUCLEAR REGULATORY: C0'MMISSION1
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REGION III
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. Report No.- 50-346/89004(D'RSS)
License No.'NPF-3 Docket No. 50-346--
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- Licensee:' Toledo Edison. Company Edison Plaza 300 Madison Avenue Toledo, OH 43652-Facility'Name:
Davis-Besse-Nuclear Power Station
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Inspection At:
Davis-Besse' Nuclear Power-Station, ~ 0ak Harbor, Ohio
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Inspection Conducted: January 23 through February 6,1989 O& &
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Inspector:
C. F. Gill
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~ Approved-B.
W.'G. Snell, Chief 7Y 8/
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Emergency Preparedness and Date /
Effluents Section
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Inspection Summary q
- Inspection on January 23 through February 6, 1989 (Report No. 50-346/89004(DRSS))
Areas Inspected:
Routine, unannounced inspection of the, radwaste/ transportation program, including:
organization and management controls (IP 83750, 84750),
training and qualifications (IP'83750, 84750), gaseous radwaste (IP 84750, 84724), liquid radwaste (IP 84750,-84723), solid radwaste (IP 83750,84750),
radioactive material shipping and transportation activities (IP 83750), audits and appraisals (IP 83750,84750), effluent reports (IP 84750), inoperable RETS equipment (IP 84750), effluent control instrumentation (IP 84750, 92700, 93702), primary and secondary coolant radiochemistry (IP 84750), air cleaning systems (IP 84750), and licensee actions on previous inspection findings.
Results:
The' organizational structure, management controls, staffing levels and upper management' support for the radwaste/ transportation program appeared adequate.
One violation was identified (failure to identify and quantify an abnormal gaseous radioactive effluent release in the semiannual radioactive effluent release report - Section 11).
Also programmatic weaknesses were identified in the radioactive effluent monitoring program (Sections 4, 8 12,
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and'13).
8903060263 890224
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DR ADDCK 05000346?
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1.
Persons Contacted
- R. Coad, Radiological Protection Supervisor
.#*J. Doiron, Radiological Control Assessor-
-# L. England,-Environmental. Compliance Supervisor
- J.. Feckley, Radiological Control Supervisor
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- R. Flood, Operations / Duty Plant Manager
- R. Gaston, Licensing Engineer B. Geddes, Senior Radiological Control Specialist W. Haney, Radiological Training Coordinator
- R. Honma, Compliance Supervisor, Nuclear Licensing R. Hovland, RMS System Engineer
- J. Polyak, Radiological Control Manager
- K. Prasad, Staff Engineer, Nuclear Engineering.
R. Scott, Chemistry: Superintendent
- P. Strahm, Radwaste/Decon General Supervisor J. Wissner, I&C Maintenance Coordinator F. Zurvalec, HVAC System Engineer
- P. Byron, NRC Senior Resident Inspector
'*D. Kosloff, NRC Resident Inspector The inspector also contacted other licensee employees.
- Denotes those present at the onsite exit meeting on January 27, 1989.
- Denotes'those contacted by telephone during the period January 30 through February 6, 1989.
2.
General This inspection was conducted to review the radwaste/ transportation program, including organization and management controls, training and qualifications, gaseous radwaste, liquid radwaste, solid radwaste, radioactive material transportation, secondary and primary coolant radiochemistry, and licensee actions on previous inspection findings.
Tours of licensee facilities did not identify any significant problems.
However, interviews with licensee personnel and documentation reviews identified programmatic weaknesses in the semiannual radioactive effluent release reporting program (Section 11) and the radioactive effluent monitoring program (Sections 4, 8, 12, and 13).
3.
Licensee Action on Previous Inspection Findings
(0 pen) Open Item (346/84008-02):
Energy response of PASS noble gas high range detector.
As discussed in Inspection Report No. 50-346/87021(DRSS),
a' facility change request was initiated in October 1986 to implement a vendor detector enhancement modification, an onsite isotopic calibration, l
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and.other changes.
The licensee stated that system modification is
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The inspector discussed with the i
licensee at the exit meeting the apparent slow progress made in making-j
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needed modifications, q
i (Closed) Open Item (346/84030-02):
Stack sample return line.
During a plant tour, the inspector confirmed that the sample return line had been rerouted. This matter is closed.
4.
Organization and Management Controls (IP 83750, 84750)
The inspector reviewed the licensee's organization and management controls for the radwaste/ transportation program including organizational' structure',
staffing, effectiveness of procedures and other management techniques used to implement the program, and experience concerning self-identification and correction of program implementation weaknesses.
The overall management of the radwaste/ transportation program is the responsibility of the Radiological Control Manager, who reports directly to the Plant Manager.
The implementation of the program is the responsibility of the Radwaste/ Decontamination General Supervisor; his
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group includes-the Radwaste Supervisor, six senior health physics servicemen,.four health physics servicemen, and six' temporary contracted servicemen. Technical support and radiation protection coverage are supplied by the Radiological Protection Supervisor and the Radiological Control General Supervisor, respectively..The radwaste-systems are operated by the operations department; the responsibility for the effluent radiation monitoring system is shared between the radiological control,. instrumentation and control, operations, and system engineering.
departments.
The organization and management controls for the radwaste/ transportation program appear adequate with the possible exception of the licensee's abilitytoensureoperabilityoftheradioactiveeff1centmonitoring systems (see Sections 8, 12, and 13).
It appears that the licensee s management controls need to be strengthened in this area to assure that shared responsibility for these systems is understood by all appropriate departments, that department interfaces are well defined in appropriate procedures, and that any identified system problems are more aggressively pursued and resolved than many of those previously identified.
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matter appears to be a programmatic weakness, was discussed at the exit
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meeting, and will be reviewed further during a future inspection.
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(0 pen Item 346/89004-01).
No violations or deviations were identified.
5.
Training and Qualifications (IP 83750,84750)
The inspector reviewed the training and qualifications aspects of the licensee's radwaste/ transport & tion program, including:
changes in responsibilities, policies, programs and methods; qualifications of newly-hired or promoted personnel; and provisions for appropriate radwaste/ transportation training for station and contracted personnel.
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i The inspector reviewed the training and qualification requirements and sele'cted' qualification documentation for station and contracted health physics servicemen; no significant problems were noted.
A selected review of the resumes of the profession staff did not identify any significant education or experience weaknesses.
Altnough it appears-that the training department may be having some difficulty maintaining accurate and current records of servicemen training and qualifications, the Radiological Training Coordinator is developing an independent verification system to ensure that the training and qualification records are correct for all radiological control personnel and that personnel are not assigned duties for which they have not been formally qualified.
No violations or deviations were identified.
6.
Gaseous Radioactive Waste (IP 84750, 84724)
The inspector reviewed the licensee's gaseous radwaste management program, including changes in equipment and procedures; gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesses.
Sampling and release methods and procedures, records, and reports appear
'3 generally adequate with some exceptions which are delineated in Sections 12 and 13.
The inspector selectively reviewed gaseous radioactive batch release permit documentation for 1988; no problems were noted.
The licensee stated that, in response to previous inspector concerns (0 pen Item No. 346/87021-02(DRSS)), the flow rate for containment pressure relief releases is now being measured by the flow meter on the j
hydrogen analyzer sk'id; this enables the licensee to more accurately
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assess the activity releases and estimate the associated offsite dose.
The inspector reviewed summary records of gaseous releases made for 1987 and 1988.
There were 40 gaseous radioactive waste batch releases during 1987 (three containment purges, 13 waste gas decay tank releases, and 24 containment pressure reliefs) and 16 during 1988 (one containment purge, 12 waste gas decay tank releases, and three containment pressure reliefs).
The 1987 noble gas activity release, gamma, and beta air dose (percent of T/S limit) totals were 380 curies,.08%, and.12%, respectively; corresponding 1988 totals were 108 curies,.031%, and.035%, respectively.
The 1987 I-131, tritium, and particulate (> 8 day half-life) activity release and critical organ dose (percent of T/S limit) totals were 9.3 curies and.16%, respectively; during 1988, the corresponding totals were 49.9 curies and.086%, respectively.
The gaseous release data i
indicates that the licensee is continuing the offsite dose reduction trend begun in 1986.
The inspector identified only one abnormal gaseous effluent release during the 1987-1988 time period; this release was not identified by the licensee in the semiannual radioactive effluent release report (see Section 11).
This abnormal release occurred on January 20, 1988, between
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1840 and 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br />, when a tygon tube used for sampling the gas space of the Clean Waste Receiver Tank (CWRT 1-1)-became dislodged from its
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fitting within the local isolation valve.
As a result, noble gases
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(primarily Xe-133) were released into the CWRT 1-1 area (Room 124, auxiliary building,:545-ft. level)< The noble gases migrated through the lower levels of the auxiliary building and were exhausted by the Auxiliary Building Radwaste Area Ventilation system.
The radwaste area-ventilation radiation monitor (RE 5405A) alarmed at 100,000 cpm at 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />.
Immediate corrective action taken included:
(1) starting the Emergency Ventilation System following isolation of the Radwaste Area Ventilation System; (2) evacuating the auxiliary building, except for necessary operations and radiological control personnel; and (3) discovery and correct 4n of the tygon tubing problem.
The tygon tubing arrangement was a iamporary sampling connection which had existed for at least four years. On January 19, 1988, Work Request No. 88-0226 was submitted to correcf. L e chronic problems associated with difficulty of obtaining and maintaui"] a tight connection.
Just before the release incident on January 20, 1288, a technician sampled CWRT 1-1 and reconnected the sampling tubing to the isolation valve; however, he was unaware that the valve had become unconnected from the tygon tubing attached to the tank.
The licensee estimated that approximately one curie of Xe-133 was released resulting in an offsite dose of less than 0.001 millirem.
The inspector interviewed personnel and selectively reviewed the closure package (PCAQR No.88-044) for this incident to verify that the hard piped sampling modification had been completed and that no other similar tygon sampling arrangement existed; no significant problems were noted.
No violations or deviations were identified.
7.
Liquid Radioactive Waste (IP 84750, 84723)
The inspector reviewed the licensee's liquid radwaste management program, including changes in equipment and procedures; liquid radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesses.
Sampling and release methods and procedures, records, and reports appear generally adequate with some exceptions which are delineated in Sections 12 and 13.
The inspector selectively reviewed liquid radioactive batch release permit documentation for 1988; no problems were noted.
The inspector also reviewed summary records of liquid releases made for 1987 and 1988.
There were 143 and 135 liquid radioactive waste batch releases during 1987 and 1988, respectively.
The 1987 whole body and maximum organ dose totals were 4.33% and 1.81% of the Technical Specification dose limits, respectively; the corresponding 1988 totals were 2.08% and 0.85%, respectively.
The total liquid tritium and fission / activation products (without tritium, gases, alpha) releases for 1987 were 246 and
.065 curies, respectively; the 1988 totals are 35 and.13 curies, respectively.
The liquid release data indicates that the licensee is
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continuing the offsite dose reduction trend begun in 1986.
The licensee l
. had no identified abnormal liquid release in 1987 and 1988.
L No violations or deviations were identified.
8.
Solid Radwaste (IP 83750, 84750)
The inspector reviewed the licensee's solid radwaste management program, including changes to equipment and procedures; processing, control, and storage of solid wastes; adequacy of required records, reports, and notifications; implementation of procedures to properly classify and characterize waste, prepare manifests, and mark packages; and experience concerning identification and correction of programmatic weaknesses.
The inspector reviewed selected portions of the licensee's solid radwaste processing, storage, and shipping records for 1987 and 1988.
The licensee generated approximately 3200 and 4400 cubic feet-of radwaste in 1987 and 1988, respectively.
Although the licensee met the 1988 solid radwaste generation goal of less than 5000 cubic feet, there are still areas where volume reduction techniques need improvement.
Of the 6100 cubic feet of radwaste shipped to a burial site in 1988, 4600 cubic feet were dry active waste (DAW).
In response to a 1987 industry audit finding, the licensee revised procedures to require segregation of wet material, such as mop heads, and to ensure that plastic containers are free of water before DAW compaction, thereby avoiding the potential free standing water in the DAW shipment containers.
Also, reusable items such as tools, equipment, and respirators are now segregated before compaction.
Although the licensee obtained a DAW sorter / shredder several months ago, the system is not yet fully operational and the licensee has not developed an effective program to encourage plant workers to segregate potentially contaminated and " clean" trash.
Once the DAW segregation /
sorter / shredder / compaction program becomes effective, the licensee may realize approximately a 50% reduction in DAW generated. The licensee, however, has not been timely in implementing this improvement program.
The licensee has completed the interim low level radwaste storage facility (LLRSF) and is making effective use of the facility; however, the LLRSF radiation monitoring system (RMS) is not yet operational.
It is desirable for the licensee to more aggressively pursue RMS operability.
The Duratec demineralized system replaced the NUS system in March 1988; however, the inspector was informed that the Duratec system had been onsite since 1985.
The delays in implementing the LLRSF RMS and the new demineralized system appear to represent less aggressive than desirable licensee response to resolution of technical issues.
Revision 3 of the Davis-Besse Radioactive Waste Process Control Program
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was issued on January 27, 1989.
This revision of the PCP was written primarily to include the replacement of the contractor-supplied filtration /
demineralization system with an in plant system for miscellaneous waste monitor tank processing.
The PCP was last revised on May 21, 1986.
The inspector reviewed the draft PCP revision and discussed the PCP with appropriate licensee personnel; no problems were noted.
The licensee does
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.not.have a solidification system; however, the spent resin resulting from
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, miscellaneous waste monitor tank processing is required to be dewatered ol'
.in accordance with approved procedures in order to demonstrate compliance with the free-standing liquid requirements of 10 CFR 61.56.
The spent resin resulting from condensate polishing demineralized holdup tank-(CPDHT) processing is processed by a contractor supplied system.
The generation of CPDHT spent resin radwaste is expected to increase significantly due to the need for more secondary system demineralization because of recently identified primary-to-secondary leakage.
No violations or deviations were identified.
9.
Transportation Activities (IP 83750)
The inspector reviewed the licensee's transportation of radioactive materials program, including determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and 00T regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses.
The inspector selectively reviewed portions of the radwaste shipment records for 1987 and 1988.
The information on the shipping papers appears' to~ satisfy NRC, DOT, 'and burial-site requirements.
The licensee shipment classification and manifest preparation has been aided by a computer software program (RADMAN) since December 15,-1988.
A selective review of computer outputs, software package descriptions, and the Radiological Control Administrative Instruction for computer software administrative control (RCAI-013-0, approved December 9, 1988) and interviews with appropriate personnel identified no problems.
The licensee had five shipments in 1987 and 11 shipments in 1988 l
consisting of 3000 and 6100 cubic feet, respectively.
Eight (4100 cubic feet) of the 1988 shipments were in December to take advantage of lower shipping and burial site fees and to reduce the radwaste storage inventory.
At the end of December 1988, the radwaste inventory was 920 cubic feet of DAW, 162 cubic feet in the spent resin storage tank, and 3500 gallons of contaminated oil.
The licensee is investigating options for disposal of the contaminated oil, including consideration of incineration at an offsite licensed facility.
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i No violations or deviations were identified.
10.
Audits and Appraisals (IP 83750, 84750)
The inspector reviewed reports of audits and appraisals conducted for or-by the licensee including audits required by Technical Specifications.
Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesses.
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Th'e. inspector' selectively reviewed portions of QA audit and surveillance reports..for 1988.
The licensee's QA audit / surveillance program appears-adequate to assess technical performance,' compliance with req /uirements, and personnel. training / qualification relating to the radwaste transportation program.
Interviews with radiological control' personnel indicate that responses to_ audit findings are generally thorough, timely, and technically sound.
No violations or deviations were identified by the inspector.
11.
Effluent Reports (IP 84750)
The inspector selectively reviewed radiological effluent analysis results
.to determine accuracy of data reported in the_ Semiannual Radioactive-Radiation Effluent Release Reports for 1987 and the first half of 1988.
Technical Specification 6.9.1.11 states.that the format and content of these reports shall be in accordance with Regulatory Guide 1.21 (Revision 1) dated June-1974.
Appendix B, Section A.6 of the aforementioned regulatory guide specifies the reporting of abnormal liquid and gaseous radioactive releases to the environment.
The inspector identified an abnormal gaseous radioactive release which occurred on January 20, 1988 (see Section 6) but which was not reported by the licensee in the Semiannual Radioactive Effluent Release Report for the period from January 1 through June 30, 1988.
This is a violation of Technical Specification 6.9.1.11.
(Violation 346/89004-02)
One' violation was identified.
12.
Inoperable RETS Equipment (IP 84750)
Technical Specification'3.3.3.9 and 3.3.3.10 require that the~1icensee, with less than'the minimum radiological effluent technical-specification (RETS) monitoring instrumentation' channels operable, exert best efforts to return the instruments to operable status'within 30 days and, if unsuccessful, explain in the next Semiannual Radioactive Effluent Release Report why the inoperability was not corrected in a timely manner.
The inspector reviewed the entries for the effluent reports for 1986, 1987, and the first half of 1988 and the draft effluent report for the second half of 1988.
The number of inoperable instruments appears somewhat high (14 inoperability incidents in three years) and potentially-implies that the licensee has not always exerted best efforts to return the instruments to service in a timely manner.
The inspector also selectively reviewed related Licensee Event Reports (LERs), Potential Conditions Adverse to Quality Reports (PCAQRs), and the licensee radiation monitoring system (RMS) setpoint determination program (see Section 13).
The reviews and associated licensee personnel interviews indicate that the licensee's management controls need to be strengthened to better ensure operability of the effluent RMS (see Section 4).
No violations or deviations were identified.
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Effluent Control Instrumentation (IP 84750, 92700, 93702)
j The inspector reviewed the records for effluent' control instrumentation surveillance / operability and setpoint. determination.
In addition to reviewing the semiannual effluent! reports lrogarding RETS equipment operability problems-(Section 12), the inspector. also selectively reviewed PCAQRs and LERs and interviewed licensee personnel from several technical departments to ascertain the extent of the licensee's apparent weaknesses in maintaining radioactive: effluent monitoring system operability.
The-inspector also'noted that the NRC resident inspectors identified RMS operability problems in Inspection Reports No. 50-346/88021 (regarding PCAQRs 88-0618 and 88-0621), No. 50-346/88026 (regarding LERs87-009'and 88-018), and No. 50-346/88039 (among the examples of the generic problem with the licensee's lack of attention to detail).
In addition to reviewing and discussing the above documented events with appropriate licensee-personnel and the NRC resident inspectors, the inspector also ' reviewed and discussed the effluent RMS inoperability events described in PCAQRs 87-0194, 88-0451, 88-0618, 88-0621, 88-0795, 88-0888, 88-0909, 88-0966, 88-0967, 88-0968, and 88-1010.
As discussed at the exit meeting, the above delineated reviews and interviews led to the perception that the recent history of significant problems regarding effluent RMS operability was due partly to the separation of responsibility for these systems being divided between the operations, radiological control, instrumentation and control, and system engineering departments without sufficient overall management oversight and coordination.
It is highly desirable for the licensee to establish better administrative and procedural controls to prevent recurrence of what seems to be a preponderance of effluent RMS operability problems.
The licensee hired a consultant to analyze each RMS and make setpoint recommendations; the consultant's report was completed June 1, 1988.
The licensee determines and controls RMS setpoints by procedure and records the established setpoints in the RMS Setpoint Manual.
The licensee has not yet reviewed the consultants report in sufficient detail for possible needed corrections to current RMS setpoint methodology.
The inspector's review of the consultant's report indicates that some of the recommended setpoint methodologies may be too simplistic and ignore the guidance of Regulatory Guide 1.105.
As discussed at the exit meeting, it appears that the licensee should be more aggressive in reviewing and implementing, as appropriate, modifications to RMS setpoint methodology by considering the consultant's recommendations and the guidance of Regulatory Guide 1.105.
The effluent RMS program has a number of apparent weaknesses including the need to be more aggressive in achieving RMS operability in the interim low-level radwaste storage facility (Section 8), in maintaining
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RETS equipment operable (Sections 12 and 13), and in making appropriate setpoint corrections (Section 13).
Because these programmatic weaknesses seems to require improved management controls, the matter is discussed further in Section 4.
No violations or deviations were identified by the inspector.
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Primary and Secondary Coolant Radiochemistry (IP.84750)
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' The-inspector selectively reviewed the~ licensee's reactor coolant and
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secondary chemistry and radiochemistry results for 1987 and 1988 to-determine' compliance with Technical Specification requirements for chemistry and radiochemistry limits and licensee administrate _ve
. guidances. The selective review and discussion with licensee personnel indicated that all parameters for both primary and secondary systems-remained less than applicable Technical Specification limits throughout
.the review period.
No violations or deviations were identified.
15.
Air Cleaning Systems (IP.84750)
Technical Specifications (T/S) require filter testing of the hydrogen purge (T/S 3/4.6.4.4), emergency ventilation (T/S 3/4.3.6.5.1),and control room emergency ventilation (T/S 3/4.3.7.6.1) systems.
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in place leakage test criterion specified both for 00P testing of HEPA filter and for freon testing of charcoal adsorbers is equal to or less than one percent penetration.
The laboratory test criterion for carbon sample removal efficiency for methyl iodide is equal to or greater than
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99 percent.
A selective review of surveillance test data for 1987 and 1988 showed that the surveillance for the above ventilation systems had been timely and met test acceptance criteria with the exception of June 1988' laboratory methyl iodide efficiency tests on charcoal adsorber samples from the hydrogen purge system (72.497%), emergency ventilation system
. train 1, bank 1 (96.86%), and control rcom emergency ventilation system train 1 (96.40%) and train 2 (97.21%).
Interviews with plant personnel and documentation reviews showed that the charcoal failing the laboratory test was replaced by new charcoal which subsequently passed the in place freon bypass test criteria.
The replaced charcoal thus was unable to pass the stringent methyl iodide test protocol recommended by NRC Information Notice No. 87-32 and implemented by the licensee and their testing vendor (see Section 3 of Inspection Report No. 50-346/88016(DRSS)).
No violations or deviations were identified.
16.
Exit Meeting (IP 30703)
The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection on January 27, 1989, and by telephone through February 6, 1989.
Further discussions were conducted with the Radiological Control Manager and others on February 10, 1989.
The inspector summarized the scope and findings of the inspection.
The inspector also discussed the likely informational content of the inspection report with regard to documents and processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents or processes as proprietary.
The following matters were discussed specifically by the inspector:
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'a.". The failurelto identify and quantify lan abnormal gaseous radioactive -
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' effluent release in the semiannual radioactive'. effluent releaset-
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report.
0n February,.6;- 1989,Lthe: licensee?. issued:PCAQR:No.:89-0077'
to investigate this. violation of T/S:6.9.1.11 andmto identify and L--
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-implement-correD,ive.. actions to prevent-recurrence'..'(Section"11).
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The" perceived' weak'nesses;inthe radio' active mffluent! monitoring-'
program. '(Sections ~4, 8, 12,"and;13).
y (The-apparent slow progress in making'needed' system modifications.
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,;(Section'3)
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