IR 05000346/1999002

Insp Rept 50-346/99-02 on 990202-05.No Violations Noted. Major Areas Inspected:Aspects of Licensee Program for Controlling Operational Chemistry & External & Internal Exposures

ML20207D448
Person / Time
Site:	Davis Besse
Issue date:	02/25/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207D439	List: IR 05000346/1999002 ML20207D435
References
50-346-99-02, 50-346-99-2, NUDOCS 9903090356
Download: ML20207D448 (14)

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U.S. NUCLEAR REGULATORY COMMISSION l

REGION lil Docket No: 50-346 i

~ License No: NPF-3 Report No: 50-346/99002(DRS)

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Licensee: Centerior Service Company  !

Facility: Davis-Besse 44uclear Power Station  ;

i Location: 5503 N. State Route 2 Oak Harbor, OH 42449 i l

Dates- February 2-5,1999 Inspectors: Wayne Slawinski, Senior Radiation Specialist Nirodh Shah, Radiation Specialist l Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety  ;

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EXECUTIVE SUMMARY Davis-Besse Nuclear Power Station NRC Inspection Report 50-346/99002 This was a routine inspection to review aspects of the licensee's programs for controlling operational chemistry and extemal and intemal (including respiratory protection) exposure The as-low-as-is-reasonably-achievable (ALARA) controls for an "at power" coritainment entry to inspect and clean the containment cooler fans was also reviewed. No violations of NRC requirements were identified during this inspectio .

Plant Support

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The licensee's 1998 non-outage dose was higher than expected due to emergent activities which required several "at power" containment entries. Althoug h well planned and controlled, these entries resulted in the neutron dose total being the highest recorded in the last several years at the site. The licerisee's extemal dosimetry quality control program was effectively implemented and identified a bias in the vendor's processing algorithm for mixed beta / gamma radiation fields,' which was corrected by the vendor (Section R1.1).

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Overall, the licensee had an effective program for monitoring and controlling intemal exposure. Specifically, internal dose assessments and assigned doses were properly

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performed and recorded, and respiratory protection devices and fit test equipment were well maintained. While the inspectors identified that the licensee did not have a formal maintenance program for the portable filter units and identified a deficiency with a related procedure, these units were maintained in good physical condition (Section R1.2).

- Primary and secondary water chemistry parameters were well controlled and were consistent with industry guidel:nes. A potential fuel defect was appropriately identified and was being closely monitored by the chemistry staff. Chernistry procedures were of

_ good quality (Section R1.3).

• - The licensee was taking proper actions to minimize steam generator corrosion as stated in their Strategic Water Chemistry Plan. A contract study concluded that the June 1998, resin intrusion event did not ,, pear to have an adverse affect on steam generator integrity. Licensee planned actions to remove residual resin still entrained in the generator were technically sound (Section R2.1).

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.a Chemistry instrurnentation was well maintained and the chemistry staff effectively implementsd the quality control program. Licensee performance in inter and intralaboratory cross check programs was good, although biases were noted in the ,

analyses results for lithium and hydrazine. These biases remained within the applicable acceptance band and were being appropriately addressed by the chemistry staff (Section R2.2).-

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The licensee used effective ALARA controls d ag an "at power" containment entry to clean boric acid deposited onto the containmer, 'an coolers from a leaking overhead pressurizer isolation valve (Section R4.1).

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Chemistry sampling and analyses were well conducted and laboratory housekeeping was good. Some problems were identified with the radioactive labeling of laboratory '.

glassware and tools which the licensee was addressing (Section R4.2).

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Chemistry self-assessments were thorough and self-critical. Several assessments )

identified procedural deficiencies similar to those identified during recent NRC inspections of the radiation protection program. These deficiencies were being addressed by the licensee (Section R7.1).

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Report Details

,IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R Extemal Dose Performance and Controls

- Insoection Scooe (Insoection Procedure (IP) 83750)

The inspectors reviewed the licensee's extemal dose performance for 1998, and aspects of the as-low-as-is-reasonably-achievable (ALARA) program and the quality control program for thermoluminscent dosimeters (TLDs). Observations and Findinas As stated in NRC Inspection Report Number (No.) 50-346/98016(DRS), the 1998 refueling outage dose total was well managed and within the expected goal. However, the non-outage dose total (approximately 8.4 rem) exceeded the respective goal by l about 25% due primarily to emergent work late in 1998. This work consisted of multiple ( containment entries to repair leaking valves and to clean the containment air cooler These containment entries and others made earlier in the year for sump repairs

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produced the station's highest recorded neutron dose (1.1 rem) in the last several years.

l The inspectors discussed the ALARA plan and controls for containment entries in 1998 l to repair a leaking letdown isolation valve (valve no. MU-1 A). This job was well l

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controlled and included several good ALARA initiatives. For example, the letdown system was isolated for short periods (i.e., half-hour segments) which significantly reduced the radiation fields from nitrogen-16 in the work area The licensee switched dosimetry vendors beginning the last quarter of 1998, because the previous vendor which the licensee used for many years no longer provided dosimetry services. The licensee's TLD quality control program continued to be implemented during the vendor transition and included spiked TLDs sent to the eaw vendor to test processing capabilities. In the fourth quarter of 1998, the spiked TLD program identified a 35 percent bias in the new vendor's processing algorithm for mixed beta / gamma radiation fields. This problem was satisfactorily resolved after the vendor revised the algoriti .m. The inspectors reviewed other TLD qualtiy control data and l identified no other problems.

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!- Conclusions l' ' The licensee's 1998 non-outage dose was higher than expected owing to emergent

activitie:: which required several "at power" containment entries. Although well planned and controiled, these entries resulted in the neutron dose total being the highest recorded in the last several years at the site. Tha licensee's extemal dosimetry quality control program was effectively implemented and identified a bias in the vendor's

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processing algorithm for mixed beta / gamma radiation fields, which was corrected by the vendo R1.2 Monitorina and Control of Intemal Exoosure

' Inspection Scooe UP 8375m

The inspectors reviewed the licensee's program for performing intemal dose assessments, and reviewed the calibration, maintenance and testing program for respiratory protection devices, fit test equipment, station breathing air sources and portable high efficiency particulate air filter (HEPA) unit Observations and Findinos Overall, the intemal dose monitoring and control program was well implemented. The ,

inspectors selectively reviewed 1998 intemal dose assessment data, and determined I that assessments were performed in accordance with station procedures and were l consistent with industry guidance. Assigned doses were appropriately calculated and !

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recorded. The inspectors interviewed selected RP staff and station workers to verify that i the program requirements were well understoo l Since the implementation of the revised 10 CFR Part 20, the station has seen a decline in respirator use. Notwithstanding the reduced use of respirators, the respiratory

protection program continued to be well implemented, consistent with industry guidance.

Specifically, workers certified in respirator use were qualified, adequately trained and

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medically certified; respiratory protection equipment (including emergency and control room respirators) were properly stored and maintained; and quality testing of station 4 breathing air and the air compressors (for filling self-contained breathing apperati) was completed as required and met industry air quality standards. Radiation protection staff l responsible for program maintenance were knowledgeable of requirements and recommended industry practices and provided good program oversight. Overall, the j inspectors concluded that the licensee maintained excellent control of this progra !

Portable HEPA units were maintained operable and were generally in good physical condition. Station procedures required that these units be maintained consistent with the manufacturer's recommendations. However, the inspectors identified that the licensee had no formal maintenance program and that the manufacturers' manuals for these units contained no maintenance recommendations. The inspectors concluded that these problems did not negatively impact the program as the licensee serviced each unit and conducted an operability check prior to outage use. The licensee planned to develop a formal maintenance program and to contact the vendor to obtain the specific requirement Conclusions Overall, the licensee had an effective program for monitoring and controlling intemal exposure. Specifimily, intemal dose assessments and assigned doses were properly

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performed and recorded, and respiratory protection devices and fit test equipment were well maintained. While the inspectors ident!fied that the licensee did not have a formal maintenance program for the portable filter units and identified a deficiency with a related procedure, these units were maintained in good physical conditio R1.3 Primarv and Secondarv Water Chemistry Insoection Scooe (IP 84750)

The inspectors reviewed the licensee's. managemant of primary and secondary water ( chemistry. Specifically, the inspectors reviewed selected chemistry procedures, primary and secondary water chemistry trend charts from July 1998 through February 3,1999, and compared the results to the Electric Power Research Institute (EPRI) Pressurized Water Reactor water chemistry guideline Observations and Findings Primary and secondary water chemistry parameters were well controlled and were i consistent with the EPRI guidelines. The inspectors reviewed the licensee's trend charts and observed no significant problems. On December 3,1998, the licensee initiated a Condition Report to investigate an unexpected drop in primary water lithium concentration (2.04 parts per million (ppm)) below the eperational limit of 2.05 pp ,

Although the licensee was unable to identify the cause, the inspectors noted that the event had not recurred ad had not produced any operational concems.

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[ On November 17,1998, the licensee identified a potential fuel defect in one of their l ' Cycle 12 fuel assemblies, based on an ; increasing trend in both xenon-133 and iodine-131 activity in primary water. Between June 1998 and February 3,1999, xenon and lodine activity had increased from 1.0E-2 to 2.0E-1 microcuries per cubic centimeter l (uCi/cc) and from 8E-4 to SE-3 uCi/cc, respectively. Because the lodine levels remained below the Action Level i value (6.0E-3 uCi/cc) specified in the fuel integrity monitoring procedure (No. DB-NE-10200), the licensee planned no action other than to continue to closely monitor the primary water parameters. The inspectors reviewed the licensee's isotopic data and the fuel monitoring procedure and concluded that the licensee's approach was reasonabl Overall, chemistry procedures were of good quality. However, the inspectors identified a deficiency with the Action Level I value for hydrazine as stated in station procedure n DB-CH-06900 (revision (rev.) 4), " Operational Chemistry Control Limits." Specifically, this procedure required that hydrazine concentration remain 2 3 times the secondary

, water dissolved oxygen (DO) concentration (in parts per billion (ppb)) with a minimum j value of 20 ppb. However, the procedure required action only if the hydrazine j concentration dropped below 3 times the DO concentration, and did not require action

relative to minimum DO values. The licensee agreed with the inspectors' observations and planned to review the procedure.

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. Conclusions Primary and secondary water chemistry parameters were well controlled and were consistent with industry guidelines. A potential fuel defect was identified and was being appropriately monitored by the chemistry staff. Chemistry procedures were of good l i qualit l

! R2 Status Of RP&C Facilities and Equipment i

R2.1 Steam Generator Corrosion Protection Inspection Scope (IP 84750)

The inspectors reviewed tt.a licensee's program to mitigate corrosion in the steam generator and other secondary side component Observations and Findinaq The licensee's program for prot Aing the secondary side systems was described in the ,

Davis Besse Strategic Water Chemistry Plan (rev.1). This plan required that during !

normal operation, secondary water pH be > 9.3 at 25 degrees centigrade and that elevated morphaline addition be used to control steam generator fouling. Additional controls consistent with EPRI guidelines were required for startup and shutdown chemistry. For example, during each outage the generators were maintained in wet layup for as long as possible and were fiiied, soaked and drained to remove contaminant As stated in Section R1.3, secondary side water chemistry parameters were well controlled and were maintained within the industry and the strategic water plan guidelines. The chemistry staff indicated that circulating water intrusions were minimal and that primary to secondary leakage remained < 1 gallon per da In June 1998, the licensee observed that cation and anion resin from the condensate polishing demineralizers had intruded into the feedwater system and the steam generators. The specifics of this event were discussed in NRC Inspection Report N /98016(DRS). Subsequently, the licensee had an offsite contractor (Framatone Technologies) evaluate the condition of the steam generators and recommend corrective action The contractor concluded that the steam generators were in good condition cod recommended several actions to further remove entrained resin. These recommendations were consistent with the licensee's corrective actions, including a planned chemical cleanup of the steam generator during the 1999 midcycle outag However, the contractor recommended that other pH control amines be used instead of morpholine, due to its potential for forming organic acids in the generator. Although no adverse affects were observed from the uce of morphaline, this recommendation was being rvaluated by the chemistry staf . - . . ~ - . . - .-. . -. .. -. - . - . . . -

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The licensee was taking proper actions to minimize steam generator corrosion as stated j in their Strategic Wate Chemistry Plan. A contract study concluded that the June 1998, !

resin intrusion event dti not appear to have an adverse affect on steam generator i

integrity. Licensee plar ned actions to remove residual resin still entrained in the i generator were technicolly soun ! R2.2 Chemistry Instrumentation and Laboratorv Quality Control k . insoection Scoos (IP 847 M) l

The inspectors reviewed the quality control program for the cheinistry laboratory, which

- included a review of chemi stry instrumentation (including inline) and the ' inter and 1 i intralaboratory cross check program !

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[ Observations and Findinas I i l l; The inspectors observed tha control charts for laboratory instruments were well i maintair ed and that trends w tre documented and resolved as required by procedur l j_ Chemistry testers were familiar with the instrumentation and properly performed quality l 1 control checks and calibrationt. Instrument maintenance histories were well maintained l and necessary repairs were pt rformed as needed by either licensee or vendor l personne .

, The inspectors performed a wat down of the primary and secondary water sample

] panels and noted no operability oncems. Routine comparisons of the inline monitor

readings and the grab sample as alysis resuKs were performed by tne chemistry staf !

i These comparisons indicated tha t with the exception of the pH meter, the inline monitors l

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I were in good agreement with the iample analyses. The variance with the pH readings

was attributed to localized chemis ty effects in the region of the inline probe due to the 4 elevated morphaline used for stean generator corrosion control. The inspectors also

}: verified that the licenses was addressing year 2000 compliance issues with the

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chemistry instrumentation and/or acsociated softwar ;

The inspectors reviewed inter and intrataboratory cross check data from June 1998 to February 3,1999, and selected tabulated results back to 1995. Cross check samples were provided by a vendor and analyzed by the licensee. The licensee's results were then retumed to the vendor for comparison with the actual values. Overall, the

, licensee's performance in this program was good, but the most recent results indicated a positive bias with the lithium analyses and a continuing (i.e., since 1995) negative bias with the hydrazine analyses. However, both cross check results were marginally within the upper and lower control bands, respect!vely. These issues had not adversely affected the overall chemistry performance and were being addressed by the chemistry staf . . - -..- -..- - . - . - - - - . - . . . - - . . - - - ... -..-. - - _ - - -

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' Conclusions L Chemistry instrumentation was well maintained and the chemistry staff effectively implemented the quality contre! program. Licensee performance in inter and L intralaboratory cross check programs was good, although biases were noted in the analyses results for lithium and hydrazine. These biases remained within the applicable

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acceptance band and were being appropriately addressed by the chemistry staff.

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l R Staff Knowledge,and Performance in RP&C I R Containment Entries .

l . inspection Scope (IP B3750)

The inspectors reviewed the ALARA planning and controls for an "at power" containment l ~ entry to clean the containment air coolers. Specifically, the inspectors attended the

- prejob ALARA briefing for an entry, reviewed the radiological work permits (RWP No (rev. 0) and 1999-2002 (rev. 0)) and observed one of the work crews in containment while coolers were cleane Qbservations and Findinas l- Since November 1998, the licensee made periodic containment entries (approximately l every 10 days) to clean boric acid deposited onto the fan coolers from a leaking l overhead pressurizer isolation valve. The licensee planned to repair the valve during the l- . acheduled midcycle outage in May 1999, and to continue the "at power" entries in the l Interim. As of February 4,1999, collective worker dose from these entries was about rem.

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t l 'On February 5,1999, an inspector observed a work crew cleaning these coolers inside I

containment. Dose rates in the work area were relatively low (10-30 millirem per hour

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(mrem /hr) gamma; 15 mrem /hr neutron), but access required traversing near higher dose fields. Workers were required to wear a full set of protective clothing and

- faceshields. However, the contamination _ levels (20,000-80,000 disintegrations per ;

minute per 100 square centimeters) did not warrant the use of respiratory protection

. equipment, which the licensee documented in an appropriate assessmen Overall the job was well planned and conducted. The workers were rroperly equipped and were accompanied by an RP tester that provided close oversight of the work cre The tester continually monitored the work area dose rates and worker Integrated doses to ensure exposures remained ALARA. Low dose work paths, heat stress concems, and stay times were discussed during the ALARA briefing. The inspector observed all

! workers using good radiological work practices during the job and identified no concerns, i'

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., Conclusions The licensee used effective A1. ARA controls during an "at power" containment entry to

[ clean boric acid deposited onto the containment fan coolers from a leaking overhead

[ . pressurizer isolation valve.

I l R4.2 Observa.tions of Chemistry Activities '

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1. Insoection Scope (IPs 83750 and 84750) .

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The inspectors observed routine chemistry activities including sampling and analysis of primary and secondary systems, and the storage and control of chemistry standards,

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reagents, and radioactive sources.

L 3 Observations and Findinas During sampling and analyses, the chemistry staff used proper laboratory techniques -

and exhibited good radiological work practices. Current procedures were maintained in

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housekeeping was good and chemistry standards, reagents, and radioactive sources

~were stored and used in accordance with station procedure The inspectors observed several examples of laboratory glassware or tools, located in posted contaminated areas, that eithet had faded or tom radioactive labels. Although sufficient information was retained on these labels to wam personnel, their condition indicated that the chemistry staff was not being proactive in correcting this deficienc .

Additionally, the inspectors observed several laboratory tools stored in contaminated '

areas that were not labeled. This was allowed by plant procedures as all items used inside the radiological posted area (which included the chemistry labore'"!) was considered potentially contaminated. However, the chemistry staff cs v . that these

~ tools could be used and inadvertently left in non-contaminated areas of the laboratory, -

causing a potential spread of contamination. The chemistry staff planned to address the

. inspectors' observatio . Conclusignjii Chemistry sampling and analyses were well conducted and laboratory housekeeping was good. Some problems were identified with the radioactive labeling of laboratory glassware and tools which the licensee was addressin R7 Quality Assurance in RP&C Activities R7.1 : ' Review'of Chemistry Self-Assessments (IP 92904)

The inspectors reviewed selected chemistry self-assessments performed since the last

. quarter of 1993 and noted that they were thorough and self-critical. Several of the' audits identified problems with procedural clarity or examples where actual practice differed 10-a 1

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L from the procedural guidance. These findings were similar to that identified in Sections .

l~ R1.2 and R1.3 of this report and in previous NRC radiation protection program inspections. Although the licensee's overall performance was good, these procedural ,

problems were a precursor to declining performance in several other industry p! ant '

L .The licensee was aware of this concern and planned to continue evaluating the overall program and develop corrective action ; R8 Miscellaneous RP&C lssues (IP 92904)

'R {Qiosed) Violation 50-346/98010-01: Failure to audit the Process Control Program l (PCP) and radioactive waste processing activities at required intervals. On July 21, l

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1998, the licensee issued a special, PCP audit report which concluded that the program .

was being run effectively and identified no significant findings. Additionally, the Quality Assessment group verified inat all other Technical Specification audit commitments were met in the 1997 and 1998 audit schedule. To ensure future compliance, the licensee  !

developed an audit matrix that cross-referenced all audit frequency commitments as  !

described in the Technical Specifications, NRC regulations, Unified Safety Analysis l Report, and other pertinent documents. The inspectors reviewed these and several l other licensee actions (such as training of audit staff, etc) taken to prevent recurrence of  !

this violation; no problems were identified. Therefore, this item is close ]

V. Management Meetings l

l XI ' Exit Meeting Summary The inspectors presented the preliminary inspection findings to members of licensee management on February 5,1999. The licensee acknowledged the findings presented and did not identify any of the documents reviewed as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED L. Bowyer, Supervisor, Radwaste Operations

, R. Coad, Superintendent, Radiation Protection R. Edwards, Chemistry Technologist I G. Gillespie, Superintendent, Chemistry J. Lash, Plant Manager

D. Lockwood, Supervisor, Regulatory Affairs

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J. Sankovich, Chemistry Supervisor R. Scott, Manager, Radiation Protection 1

INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure l IP 84750 Radioactive Waste Treatment, and Effluent arid Environmental Monitoring )

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ITEMS OPENED AND CLOSED Ooened

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There were no new items opened during this inspectio ,

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Closed )

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50-346/98010-01 VIO Failure to audit the PCP and radioactive waste processing j activities at required intervals (Section R8.1).

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LIST OF ACRONYMS USED F

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ALARA As-Low-As-Is-Reasonably-Achievable C : Curie i DO Dissolved Oxygen EPRI Electric Power Research Institute HEPA High Efficiency Particulate Air .  ;

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inspection P ocedure  ;

mrem /hr millirem per ilour PCP- Process Control Program  ;

' ppb ' parts per billion i l ppm' parts per million

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rev Revision j RP&C- Radietion Protection and Chemistry l- uCi/cc Microcur!e per Cubic Centimeter 1 i

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PARTIAL LIST OF DOCUMENTS REVIEWED

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. Station Procedure Nos:

DB-CH-00001 Chemistry Program Administration, rev. 5 DB-CH-00010 . Chemistry Quality Control Program, rev. 3 DB-CH-00013 Radiochemistry Quality Control Program, rev. 3 DB-CH-000 . Reagent Control,' rev. 4 DB-NE-10200 Fuel Integrity Monitoring. rev. 2 : .

NG-EN-00318 . Nuclear Fuel Integrity Program, rev. 2 DB-HP-0180 ALARA Review, rev. 04 DB-HP-01308 Respiratory Protection Equipment & Maintenance, rev. 03 DB-HP-00002 Intemal Dose Monitoring Program, rev. 03 -

l- . DB-HP-01101 Containment Entry, rev. O DB-HP-0_1210 Neutron Dosimetry: Issue, Use and Dose Calculation, rev 02

_Qq_ndition Reoorts No Fuel defect in Cycle 12 core (dated November 17,1998)

98-1334 1998 Feedwater Resin Intrusion Evant (dated June 29,1998)

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Operations' Policy statement no,'GP-15, rev. 3, "Once Through Steam Generator Tube Leak l1 l Actions" L

I FTl Document No. 51-5002447-00, Report of Davis Besse Site Chemistry Visit, Framatome Technologies, (dated October 14,1998)

Root Cause Analysis Report for 1998 Feedwater Resin Intrusion Event (dated November 4,

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Davis Besse Strategic Water Chemistry Plan, rev.1 I

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