IR 05000346/1993025
| ML20059B939 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/21/1993 |
| From: | Mccormickbarge, Steven Orth, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059B929 | List: |
| References | |
| 50-346-93-25, NUDOCS 9401040296 | |
| Download: ML20059B939 (8) | |
Text
.
.
=-
_
_
.
.
-
-
-
.
.
.
'
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
J Report No. 50-346/93025(DRSS)
License No. NPF-3
Docket No. 50-346 Licensee: Toledo Edison Company
}
>
Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Name:
Davis-Besse Nuclear Power Station Inspection At:
Davis-Besse Site, Oak Harbor, Ohio i
Inspection Conducted: November 29 - December 3, 1993
,
Inspectors: M N4 wk b
iM -U
'
R. A. Paul
/
Date
/
mjff
.
Aik? in a/u /93 g,/ K. Orth Date
,
b
/2 2/-PJ'
Approved By: d
%s J. W. McCormick-Barger, Thief Date
Radiological Programs Section 1 i
i Inspection Summary
'
Inspection on November 29 - December 3.1993 (Report No. 50-346/93025(DRSS))
Areas Inspected:
Routine announced inspection of the licensee's radiation protection program including organization and management controls (Inspection Procedure (IP) 83750), liquid effluent releases (IP 84750), audits and appraisals (IPs 84750 and 86750), solid radioactive waste and transportation i
(IP 86750), and licensee actions on previous inspection findings.
Results: One non-cited violation was identified concerning the inappropriate i
transfer of radioactive material (Section 8). The licensee's liquid effluent (Section 6) and solid radioactive waste programs (Section 7) continued to be well conducted.
Several problems were identified associated with the recent radiation protection reorganization (Section 4). Because the newly appointed department head did not meet Technical Specifications requirements as a radiation protection manager, another member of the staff was temporarily named to this position. A morale problem among staff members was also attributed to the reorganization.
9401040296 931221,
i PDR ADOCK 05000346 G
PDR.
_
_
.
.,
.
,
.
.
DETAILS
!
"
1.
Persons Contacted
- J. Dillich, Manager of Radiological Protection (Department Head)
- B. Humphrey, Auditor, Nuclear Assurance L. Bonker, Supervisor, Radiological Health
- R. Greenwood, Supervisor, Health Physics (Radiation Protection Manager)
,
- J. Priest, Health Physicist
'
- L. Bowyer, Supervisor, Radioactive Waste
- A. Antrassian, Associate Engineer, Regulatory Affairs
- J. Rogers, Manager, Maintenance J. Polyak, Manager, Radiological Controls
- P. Smith, Supervisor, Compliance
'
- S. Stasek, Senior NRC Resident Inspector The inspectors also contacted other licensee personnel in the course of the inspection.
- Denotes those present at the onsite exit meeting on December 3, 1993.
2.
General This inspection was conducted to review the radiological controls, liquid effluent, and solid radioactive waste and transportation t
programs. Tours of the Auxiliary and Radwaste Buildings were made to
review radiological and contamination controls and worker performance.
Housekeeping was generally good; however, several examples of improper
storage of protective clothing in the Auxiliary Building were identified.
.
3.
Licensee Action on Previous Inspection Findinas (IP 83750)
(Closed) Inspection Follow-Un Item (IFI 50-346/92009-01):
Evaluation of containment neutron flux.
The inspectors reviewed the licensee's calculation of the quality factor
,
(QF) used in personnel neutron dose assessments. The licensee's
,
evaluation, as prepared by a vendor, reported an average distribution of containment neutron energies of about 30 percent at <1 electron Volts
!
(eV), 60 percent at 1 eV - 10 kev and 10 percent at >10 kev. The vendor
determined the average energies of fast neutrons (i.e. those greater
than 10 kev) to be between 22 and 34 kev. Based on the above distribution and the comparison between thermoluminescent dosimeters and tissue equivalent proportional counter measurements, the licensee calculated a weighted average QF of about 2.2, which was in good agreement with the inspectors' calculations. The licensee revised its dosimetry results using the new, calculated QF. Since a QF of~11 was
>
previously used, this adjustment did not significantly reduce estimated doses.
>
-
-,
.
,
LQoen) Deviation _from a licensee Commitment (DEV 50-346/92001-03):
Failure to install the Safety Evaluation Report (SER) prescribed detector on the effluent monitoring system in the Low-Level Radwaste Storage Facility (LLRWSF),. and failure to calibrate the installed monitor.
The licensee has installed and calibrated a monitor with the prescribed beta scintillator detectors. The detectors were operable, but the licensee had not developed operating procedures.
In addition to procedure development, personnel will be trained in the calibration and j
maintenance of the system. This matter will be reviewed at a future inspection.
,
(0 pen) Inspection Follow-Vo Item (IFI 346/91003-03) and (346/92009-04):
Final disposition of contaminated soil from a pipe break and a spill of
,
reactor coolant water onto the ground.
t i
The US NRC Office of Nuclear Reactor Regulation is reviewing this matter and intends to provide guidance in the near future. This item remains open pending the implementation of this guidance.
.
4.
Chanaes (IP 83750)
l The health physics staff remained stable; however, several
!
organizational changes have occurred. The most significant changes were
>
the appointment of a new manager-radiation protection, the deletion of
the general supervisor-radiation operations position, and the reorganization of the department into four major sections, which were headed by a respective supervisor. The role of the radiological assessor was performed by the two corporate health physicists.
With the exception of the manager-radiation protection, the radiation protection (RP) staff appeared qualified in accordance with the ANSI N18.1 - 1971 qualification criteria. The newly appointed manager-radiation
protection did not meet the Technical Specification -(TS) qualification for his position due primarily to his limited commercial nuclear power radiation protection experience. As a result, the licensee assigned several oversight responsibilities of.the radiation protection manager (RPM) to the supervisor-health physics, who met the TS qualifications of
'
Regulatory Guide 1.8, September 1971. Although the supervisor-health physics will provide assistance and oversight of the Radiological Control Program in accordance with the licensee's directive, the inspectors expressed concern that no formal written description of the RPM's responsibilities existed. This matter was discussed at the exit
.
'
interview and the licensee stated the description would be written.
The formal description of the RPM's responsibilities will be followed as an j
inspection followup item (IFI) and will be reviewed during a future i
inspection.
(IFI 50-346/93025-01)
j As a result of the reorganization, the inspectors attempted to assess
.
the effects of the new organization on the conduct of the program and-i the performance of the staff. Based on discussions with radiation staff, it appeared that worker morale was adversely affected, but the RP
.
p
program continued to be properly implemented. The inspectors discussed concerns related to worker morale and the potential for program degradation with senior plant management and at the exit meeting. This matter will be reviewed during a future inspection.
(IFI 50-345/93025-02)
,
Since the previous inspection, one member of the technical staff qualified in the first part of the Board of Health Physics certification and was awaiting the results of the examination for the second part.
Another member had also taken both parts of the certification and was l
awaiting the results. Additional staff members had recently taken the
'
examination for membership into the National Registry of Radiation Protection Technologists (NRRPT) certification. The licensee continued to encourage the health physics staff to participate in both
-
certification programs, through in-house training. With the exception i
of the newly appointed manager-radiation protection's level of experience, the health physics organization was sufficiently staffed with experienced and technically qualified personnel.
No violations or deviations were identified.
5.
Audits and Aooraisals (IP 83750)
The inspectors reviewed quality assurance audits conducted in June 1993 and April 1992 which evaluated the effectiveness of the radiation protection, chemistry, effluents, and solid radwaste programs. The audits were conducted in good depth and addressed important, performance based aspects of the programs.
,
Audit findings were generally positive.
Corrective actions for prior audit findings were appropriately reviewed, and those areas were evaluated in subsequent audits. However, the audits did identify weaknesses in radiation monitor setpoint bases (Section 6),
'
configuration of the Water Treatment Building, and minor problems with
'
shipping documentation. The shipping documentation problems were corrected, and the licensee was reviewing concerns with the Water Treatment Building.
No violations or deviations were identified.
i 6.
Liouid Radioactive Wastes (IP 84750)
The inspectors reviewed the licensee's liquid radioactive waste (radwaste) program including monitor alarm setpoint calculations, discharge batch releases, and the Semiannual Effluent Reports for the last half of 1992 and the first half of 1993.
Liquid batch release calculations continued to be based on sample analyses, and releases were i
monitored.
Releases were initiated from the monitoring tank, passed through two TS radiation monitors, and were discharged at the collection box after dilution and final monitoring.
l l
~
.
The licensee evaluated the effluent monitor setpoints, along with other,
various radiation monitors, in response to 1993 audit findings.
In this evaluation, the licensee confirmed that there were no problems with the monit ar setpoints and developed bases documents for each setpoint.
Revisions to these setpoints required approval of the health physics supervisor.
l The licensee released 38 and 49 liquid batches in the last half of 1992 and the first half of 1993, respectively. A total of 29.1 and 39.7 millicuries (mci) (1.08 and 1.48 gigaBecquerels) of activity were released, respectively, excluding tritium, gases, and alpha radio-activity. The inspectors reviewed selected discharge documentation
,
packages, including the alarm setpoint calculations. The documentation packages were assembled as required by the licensee's procedures and
.
conformed to the methodology of the Offsite Dose Calculation Manual
!
(0DCM).
The inspectors noted that the basic setpoint and the specific alarm
-
setpoint equations found in the ODCM were not of the same basis. The licensee acknowledged that the basic setpoint equation was based i
directly on maintaining the effluent concentration below the 10 CFR 20 limits but that the specific alarm setpoint calculation was a function of the monitoring tank activity, as determined by' radiochemical analysis. The alarm setpoint calculations in the effluent discharge
'
packages were conservatively based on the basic setpoint equation and the limits of 10 CFR 20. The licensee agreed to review the ODCM and provide the necessary text to explain the differences and the proper uses of the equations.
The licensee continued to make efforts in reducing radioactive effluent releases. A subcommittee of the radwaste reduction committee was developed to evaluate and implement possible liquid radwaste reduction initiatives, including better planning and scheduling of maintenance /
operations activities. The licensee was also monitoring liquid radwaste input drains to better evaluate the liquid radwaste sources. The progress of these initiatives will be reviewed in future inspections.
No violations or deviations were identified.
7.
Implementation of the Solid Radioactive Waste and Transportation Proaram fIP 86750)
.
The inspectors reviewed the licensee's program for the processing and shipping of solid radwaste-and the low-level radwaste storage facility (LLRWSF). The licensee conducted activities as described in the Process Control Program and administrative procedures.
a.
Waste Generation and Processina Primary waste streams included dry active waste (DAW), solid mechanical filters and spent resin from the primary coolant side,
.
.
- -
I
.
secondary ion exchange media (Powdex), and liquid radwaste processing systems (DURATEK).
The licensee continued to implement its " Green is Clean" waste segregation policy. The waste was segregated into the clean collection bins, monitored, and frisked prior to free release.
The licensee released about 2500 to 3000 cubic feet (ft') (71 to 85 cubic meters (m')) of clean materials year to date..The program resulted in a decrease of comp' acted DAW from about 160 ft'
(4.5 m') in 1991 to about 25 and 30 ft (0.71 and 0.85 m') in 1992 and 1993, respectively.
The licensee has not made any changes in the processing of spent resin and Powdex. Spent resin was dewatered and shipped offsite for burial, and Powdex was processed offsite by a vendor. The licensee shipped DURATEK offsite for burial.
Mechanical filters continued to be stored in the specially designed high integrity container (HIC) described in Inspection Report No. 50-346/92009 (DRSS). The licensee indicated that the exposures from processing filters were reduced through the use of this HIC, but the actual dose assessment will not be evaluated until the HIC is processed for shipment.
b.
Waste Characterization. Packaaina. and Shippina The licensee made a single shipment of about 100 ft' (3 m') of spent resin to burial sites, this year, and anticipated an equivalent, additional shipment in December 1993.
The licensee analyzed an aliquot of the resin and applied the appropriate radwaste correlation factors to calculate the total activity. The inspectors reviewed shipping documentation of selected shipments; no problems were identified.
The inspectors reviewed the licensee's database of radwaste correlation factors. As new correlation factors were evaluated by an offsite vendor, the licensee entered the factors into a database which either included the factors into a historical average or, if changes in waste streams occurred, initiated a new database.
c.
Interim Waste Storaae The inspectors reviewed the storage of interim radwaste and radioactive materials in the LLRWSF. The licensee updated a comprehensive inventory of radioactive waste and materials stored in the facility and determined that approximately 580 ft' (16 m')
of the 48,000 ft" (1360 m') of radioactive materials was radwaste.
Although 40 percent of the storage cells and 20 percent of the floor space above the cells remained available for storage,' the licensee anticipated an increase in storage capacity based on the removal of unnecessary materials and waste in early 1994. The
E
,
' '
licensee indicated that this initiative would provide ample
'
storage space through at least the year 2000.
The licensee discussed plans to implement onsite, dry fuel storage. Currently, the licensee had capacity for complete core
,
offload capability until 1996 in the spent fuel pool. Once the
!
appropriate reviews are completed and approvals are obtained, the
>
licensee planned to purchase three dry fuel storage modules, two of which would be filled when received. Additional storage modules would be purchased and filled as needed. The licensee discussed the anticipated radiation monitoring program for the
,'
site and indicated that additional reviews were still pending.
.
No violations or deviations were identified.
8.
Potential Condition Adverse to Ouality Reports (PCA0Rs) and Radiation Awareness Reports (RARs) (IPs 83750. 84750. and 86750)
The inspectors reviewed selected PCAQRs and RAR documents concerning
radiological control problems identified during the current year to
~
determine if programmatic problems exist and if deficiencies were
<
adequately corrected. The majority of those reviewed involved dosimetry / training, personal contaminations and contamination control, and radiation controls. The reports appeared well investigated with t
good root cause analyses and appropriate corrective actions taken.
There were 83 RARs issued during the 1993 refueling outage, 23 of which c
were written by contract radiation protection technicians, and the
'
remainder by plant staff.
Based on discussions with plant staff, it appears that in most cases they were encouraged to write the reports; however, they expressed concern that the final results of the investigation were not discussed with them. Additionally, personnel were encouraged to correct minor problems, as found, instead of creating a report and extending the corrective actions. There was no indication that workers felt intimidated or feared management repercussion when they issue the reports.
These matters were discussed with the licensee
-
at the exit meeting.
The inspectors reviewed PCAQR number 93-0241 concerning the unauthorized transfer of radioactive material offsite. The licensee received notice on April 15, 1993, that material shipped to an offsite laboratory had
!
fixed contamination at about 2000-3000 disintegrations per minute (dpm)
over areas of 16 square centimeters. Although the offsite laboratory was licensed by the NRC to receive the radionuclides (i.e. Co-60, Cs-137, and Cs-134) contained on the components, the shipment was not identified as radioactive material, nor did it contain appropriate documentation and survey information. The licensee determined that the incident was not reportable to the NRC and obtained the components from
.
the laboratory.
j The licensee performed a thorough investigation of the occurrence.
Although there was no survey / release documentation available for the
i I
.
.
.
.
.
~
components, the licensee attributed the occurrence to personnel error. in operating the tool contamination monitor (TCM), which was the primary monitor for such components. The proper use of the TCM, i.e.
positioning of the TCH detectors, would have enabled proper identifi-cation of the contamination. However, the licensee demonstrated that incorrect positioning of the monitor's detectors would not always detect the contamination because of the small size of the components. The
licensee corrective actions included additional training on the TCM and several discussions with radiation protection testers regarding this
-
PCAQR.
,
The inadequate survey of the components sent offsite is a violation of'
10 CFR 20.1501(a). Since the violation would have been categorized at Severity Level V and the licensee's corrective actions appeared to be
adequate, the violation meets the non-citing requirements of Section l
VII.B.1 of 10 CFR 2, Appendix C.
One non-cited violation was identified.
-
9.
Exit Interview i
The scope and finding of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on December 3,1993, and discussions were held with licensee
.
representatives concerning neutron spectral analysis on December 8, 1993. One non-cited violation was identified during this. inspection.
-
No documents were identified as proprietary by the licensee.
The following matter were specifically discussed by the inspectors:
,
Actions taken as a result of the neutron spectral evaluation I
e (Section 3)
!
The qualification of the Manager-Radiation Protection (Section 4)
j e
The issue of radiation protection staff morale (Section 4)
e The results of the PCAQR and RAR review, including the non-cited
'
.
'
violation concerning the transfer of radioactive material (Section 8).
.
l l
,
,
,
.