ML20135A140
| ML20135A140 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/22/1985 |
| From: | Januska A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20135A132 | List: |
| References | |
| 50-346-85-24, NUDOCS 8509100019 | |
| Download: ML20135A140 (7) | |
See also: IR 05000346/1985024
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-346/85024(DRSS)
Docket No. 50-346
License No. NPF-3
Licensee: Toledo Edison Company
300 Madison Avenue
Toledo, OH 43652
Facility Name:
Davis-Besse Nuclear Power Plant, Unit 1
Inspection At:
Davis-Besse Site, Oak Harbor, OH
Inspection Conducted: August 6-9, 1985
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Inspector:
A. G.
anuska
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Approved By:
M. C. Schumacher, Chief
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Independent Measurements and
Date
Environmental Protection Section
Inspection Summary
Inspection on August 6-9, 1985 (Report No. 50-346/84024(DRSS))
Areas Inspected:
Routine, announced inspection of confirmatory measurements
including a liquid sample split and laboratory quality control; followup of
Performance Appraisal Team findings regarding review of procedures and
adherence to procedures;.and licensee followup on items identified in previous
inspections.
The inspection involved 33.5 inspector-hours onsite by one NRC
inspector.
Results: One apparent violation was identified (Severity Level V, Supplement I
violation - failure to implement a written procedure - Section 5).
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DETAILS
1.
Persons Contacted
- L. Storz, Plant Manager
- W. O'Connor, Operations Superintendent
- T. Murray, Assistant Vice President, Nuclear
- S. Smith, Maintenance Supervisor
- M. Beier, Quality Engineering Supervisor
- S. Widman, Senior Licensing Specialist
- R. Scott, Chemistry and Radiochemistry Supervisor
- M. Horne, Health Physics Supervisor
J. Ferguson, Health Physics Specialist
W. Armstrong, Chemistry and Health Physics Foreman
W. Widenheft, Chemistry and Health Physics Group Leader
R. Edwards, Senior Chemistry and Rad Tester
R. Rogers, Senior Chemistry and Rad Tester
W. Frazer, Emergency Planning Supervisor
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings
a.
(Closed)UnresolvedItem(50-346/84-19-20):
Failure to perform
procedure specified actions for counting equipment that exceeded
control limits on daily performance checks.
Investigation of this
item resulted in issuance of a citation as discussed in Section 5.
b.
(Closed) Unresolved Item (50-346/84-19-21):
Failure of Station
Review Board (SRB) to review certain procedures used for analyses of
liquid and gaseous effluents.
Review of this matter with licensee
representatives indicated that controlling and safety-related
radiological procedures receive detailed review by the SRB.
Other
more detailed procedures, such as the ones in question, are regarded
as instructions in the sense used in Regulatory Guide 1.33.
Such
procedures receive review by the Section Head (an SRB member) who
forwards them to the SRB for decision as to the need for further SRB
review.
The statica has maintained a computer listing of procedures
and their SRB review status since preoperation.
This practice
appears to satisfy the licensees technical specifications and avoids
overburdening the SRB with unnecessary detail,
c.
(Closed) Open Item (50-346/84-21-01):
Insure airflow in laboratory
fume hoods is adequate.
Th_e licensee repaired the hoods, made face
velocity measurements, and ' reported the results to Region III.
During the inspection, the inspector noted that the hoods are marked
specifying the maximum opening allowed during use.
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(Closed) Open Item (50-346/84-21-02):
Analyze liquid sample for
H-3, Sr-89, Sr-90 and report results to Region III.
Comparative
results are presented in Table 1 and comparison criteria are
outlined in Attachment 1.
The inspector noted that the Sr-89 and
Sr-90 results received from the licensee were reported as lower
limit of detection (LLD) values that were higher than those allowed
by Technical Specifications.
Investigation into the reason for
these results and the consequence of their use, performed during the
inspection, revealed that (1) the size of the sample was much smaller
than normal for this type of an analysis which will increa:e the LLD
and (2) the results were not used for T/S related reporting.
Further review of release data for 1984 and 1985 to date supplied
by the licensee's analytical contractor verified that all liquid
composite results reported were in compliance with T/S requirements
in Table 2.4-1.
e.
(Closed) Open Item (50-346/84-05-01):
Prepare procedure defining
responsibilities for implementation of 10 CFR 61 requirements.
The
inspector reviewed procedure AD 1842.00.6.
Section 4.4.4 states "The
Radwaste and Decon Supervisor is responsible for supervising
radwaste disposal activities and ensure compliance to state and
federal regulations pertaining to radwaste shipments."
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f.
(Closed) Open Item (50-346/84-05-02):
Train auditors in area of
10 CFR 61 prior to conducting audits.
Quality Assurance has a fully
qualified auditor to perform radwaste audits. The individual
appears to be qualified due to previous nuclear experience,
certification in the Nationai Pegistry of Radiation Protection
Technicians and has attended a " Transportation Disposal Workshop"
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given by a waste disposer.
g.
(Closed) Open Item (50-346/84-05-03):
Prepare procedure for the
tracking of shipments to burial site and investigation of lost
shipments. A major modification of HP 1607.01 " Shipping Radioactive
Materials" was made which addresses requirements of 10 CFR 20.311
retracking of shipments and investigation of lost shipments.
3.
Confirmatory Measurements Sample Split
A sample of a Detergent Waste Drain Tank was split with the licensee.
The licensee agreed to analyze his portion for gamma emitters, gross
beta, H-3, Sr-89 and Sr-90, and report the results to Region III (0 pen
Item 50-346/85024-01).
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No violations or deviations were identified.
4.
Audits
The inspector reviewed TED QA Audits No. 1370 and No. 1407 dealing with
compliance of the licensee's analytical contractor to his QA manual and
radwaste management. All audited areas appeared to be acceptable.
No violations or deviations were identified.
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5.
QA/QC of Analytical Measuraments
An unresolved item reported as the result of a Performance Appraisal
(PAS) inspection regarding Quality Control was investigated during this
inspection. A review of daily instrument check log sheets and the
graphic presentation of source counts for Beta Counter No. 2.7.61
substantiated that during the period of April.17 and June 27, 1984 the
licensee failed to (1) perform recounts on 11 of 13 occasions after
source counts were outside the i 3s boundary and (2) tag out the
instrument for checkout or recalibration when a count could not be
obtained that fell within the i 3s boundary.
This appears to be a
violation of licensee procedure RC 4528.00.3, " Efficiencies for Radiation
Detectors," and, thereby, with Technical Specification 6.8.1.a which
requires adherence to procedures for control of measuring and test
equipment.
(Violation 50-346/85024-02)
Daily instrument check log sheets from August 1984 to date for Beta
Counter No. 2.7.61, and an alpha, a beta and a liquid scintillation
counter in the counting room were selectively reviewed.
Since the PAS
inspection very few instances of not plotting a daily test were noted and
in no case was a value > 1 3s not plotted.
In addition the gamma
spectroscopy system QC data was reviewed.
A daily energy check is
performed for nine energy lines from 121 to 1407 key in accordance with
RC 4502.00 and net count areas for 344 and 1408 key are plotted.
Both-
tests have limits which require recalibration or direct the analyst to
"stop measurement." All data examined was current and complete.
A Senior Chemistry and Rad Tester assigned the QC overview performs a
daily verification of QC checks and arranges for repair and calibration
of equipment when needed.
Discussion with this individual and an
examination of the daily QC review' indicate a positive effort has been
made to prevent a recurrence of the above reported violation.
The licensee revised RC 4528.00.3 to strengthen the ' requirement to
complete definite actions if a result fails outside the 1 3s boundary.
The inspector discussed the benefit of dividing this procedure into an
efficiency and a QC procedure and expanding the QC procedure to describe
the QC review.
Also discussed was a method of communicating to an
analyst who finds and notes an instrument beyond i 3s the steps taken to
return it to service. The licensee acknowledged the inspectors comments.
The licensee participates in a quarterly cross check program for gross
alpha, gross beta, H-3, Sr-89, Sr-90 and gamma emitters in liquid with a
contractor.
As a result of two consecutive nonconservative disagreements
for Ce-141 in 1984 an instruction dealing with multiplet resolution of
Ce-141 was issued and no further disagreements occurred.
Gross alpha
and gross beta analyses have had instances of repetetive disagree.. tents
but the last result examined (second quarter 1985) contained all
agreements.
One violation was identified in this ared.
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6.
Exit Interview
The inspection findings'were discussed with licensee representatives
(Section 1) at the close of the inspection on August 9, 1985.
The
inspector discussed the investigation of an unresolved item now
considered an apparent violation of T/S 6.8.1.a which was identified
in a 1984 PAS inspection.
The QC program since the PAS inspection was also discussed and comments
made by the inspector acknowledged.
During the exit interview, the inspector. discussed the likely informational
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content of the inspection report with regard to documents or processes
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reviewed by the inspector during the inspection.
Licensee representatives
did not identify any such documents or processes as proprietary.
Attachments:
1.
Table 1, Confirmatory
Measurements Program
Results - 3rd Quarter
1984
2.
Attachment 1, Criteria
for Comparing Analytical
Measurements
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TABLE 1
U S NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
CONFIRMATORY MEASUREMENTS PROGRAN
FACILITY: DAVIS =BESSE
FOR THE 3 OUARTER OF 1984
NRC--
-
LICENSEE----
---LICENSEE:NRC--
SAMPuE
ISOTOPE RESULT
ERROR
RESULT
ERROR
RATIO
T
s
L YASTE
1.7E-01
1.0E-03
1.SE-01
0.0E-01
1.1E 00
1.7E 02
A
SR-89
2.1E-07
1.6E-08 42.2E-07
0.0E-01
1.1E 00
1.3E 01
A
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1.5E-06 '5.0E-09
<3.4E-07
0.0E-01
2.2E 01
3.0E 00
N
T TEST RESULTS:
A= AGREEMENT
3=DISAUREEMENT
- = CRITERIA RELAXED
i
N=NO COMPARISON
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ATTACHMENT 1
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CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS
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This attachment provides criteria for comparing results of capability tests
and verification measurements. The criteria are based on an empirical
relationship which combines prior experience and the accuracy needs of this
program.
In these criteria, the judgment limits are variable in relation to the com-
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parison of the NRC's value to its associated one sigma uncertainty. As that
ratio, referred to in this program as " Resolution", increases, the acceptability
of a licensee's measurement should be more selective. Conversely, poorer
agreement should be considered acceptable as the resolution decreases. The
values in the ratio criteria may be rounded to fewer significant figures to
maintain statistical consistency with the number of significant figures reported
by the NRC Reference Laboratory, unless such rounding will result in a narrowed
category of acceptance.
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RESOLUTION
RATIO = LICENSEE VALUE/NRC REFERENCE VALUE
Agreement
<3
No Comparison
- 13 and
<4
0.4
2.5
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2,4 and
<8
0.5
2.0
-
- tS and
<16
0.6
i~.67
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2J6 and
<51
0.75 - 1.33
251 and
<200
0.80 - 1.25
- 1200
0.85 - 1.18
Some discrepancies may result from the use of different equipment, techniques,
and for some specific nuclides. These may be factored into the acceptance
criteria and identified on the data sheet.
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