Text

Forwards IE Inspec Rept 50-346/78-22 on 780821-23 & Notice of Violation
	ML20147C035
Person / Time
Site:	Davis Besse
Issue date:	09/08/1978
From:	Davis A; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jeffery Grant; TOLEDO EDISON CO.
Shared Package
ML20147C039	List: IR 05000346/1978022; ML20147C035; ML20147C043;
References
	NUDOCS 7810110263
	Download: ML20147C035 (2)
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SEP 0 81978

Docket No. 50-346

Toledo Edison Company

ATTN: Mr. James S. Grant

Vice President - Energy

Supply

Edison Plaza

300 Madison Avenue

Toledo, OH 43652

Gentlemen:

This refers to the inspection conducted by Mr. A. G. Januska of this

office on August 21-23, 1978, of activities at the Davis-Besse Nuclear

Power Station, Unit 1 authorized by NRC Operating License No. NPF-3

and to the discussion of our findings with Mr. Green and others of

your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas

examined during the inspection. Within these areas, the

inspection consisted of a selective examination of procedures

and representative records, observations, and interviews with

personnel.

During this inspection, certain of your activities appeared to be

in noncompliance with NRC requirements, as described in the enclosed

Appendix A. With regard to the first item of noncompliance, the

inspection showed that action had been taken to correct the identi-

fied noncompliance and to prevent recurrence. Consequently, no

reply to that item of noncompliance is required and we have no

further questions regarding this matter at this time.

This notice is sent to you pursuant to the provisions of

Section 2.201 of the NRC's " Rules of Practice," Part 2, Title

10, Code of Federal Regulations. Section 2.201 requires you

to submit to this office within twenty days of your receipt

of this notice a written statement or explanation in reply,

including for each item of noncompliance: (1) corrective

action taken and the results achieved; (2) corrective action

to be taken to avoid further noncompliance; and (3) the date

when full compliance will be achieved. '

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Toledo Edison Company -2- SEP 0 81978

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In accordance with Section 2.790 of the NRC's " Rules of l

Practice," Part 2, Title 10, Code of Federal Regulations, a l

copy of this letter, the enclosures, and your response to l

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this letter will be placed in the NRC's Public Document Room, I

except as follows. If the enclosures contain information

that you or your contractors believe to be proprietary, you

must apply in writing to this office, within twenty days of

your receipt of this letter, to withhold such information

from public disclosure. The application must include a full

statement of the reasons for which the information is con-

sidered proprietary, and should be prepared so that proprietary

information identified in the application is contained in an

enclosure to the application.

We will gladly discuss any questions you have concerning this I'

inspection.

Sincerely, I

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A. B. Davis, Chief ;

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Fuel Facility and Materials

Safety Branch

Enclosures: ;

1. Appendix A, Notice of

Violation

2. IE Inspection Rpt No.

50-346/78-22

cc w/encia: )

T. Murray, Station l

Superintendent

' Central Files

Reproduction Unit NRC 20b

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NRC Form 3180 (RIn )(178) NRCM 0240 .u. s ooVERNMENT PRINilNG OFFaCEt 19 79-25 3'a l ?

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Appendix A

NOTICE OF VIOLATION

Toledo Edison Company Docket No. 50-346

Based on the inspection conducted on August 21-23, 1978, it appears

that certain of your activities were in noncompliance with NRC require-

ments, as noted below. Both are infractions.

1. Section 2.3.1 of the Appendix B Environmental Technical Specifi- I

cations limits " total residual chlorine in the effluent from the l

collection box . . . " to "A daily average concentration of 0.2 l

mg/l free available chlorine and a daily maximum concentration

of 0.5 mg/l free available chlorine."

Contrary to the above, the 0.5 mg/l limit was exceeded between

July 7, 1978 and July 10, 1978.

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2. Section 5.1.1 of the Appendix B Environmental Technical Specifi-

cations requires in part that the Station Review Board's review

responsibility will include .... results of the Environmental

Monitoring Programs prior to their submission in each Environ-

mental Operating Report.

Contrary to the above, the Station Review Board did not review

the first Annual Environmental Operating Report for the Davis-

Besse Nuclear Power Station Unit 1.

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U. S. NUCLEAR RECULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-346/78-22

Docket No. 50-346 License No. NPF-3

Licensee: Toledo Edison Company

Edison Plaza

300 Madison Avenue

Toledo, OH 43652

Facility name: Davis-Besse Nuclear Power Station, Unit 1

Inspection at: Davis-Besse Site, Oak Harbor, OH

Inspection conducted: August 21-23, 1978

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Inspector: C. anuska Y/ 7/76

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Approved by: T. H. Essig, lef 'l f1f78

Environmental and Special

Projects Section

Inspection Summary

Inspection on August 21-23, 1978 (Report No. 50-346/78-22)

Areas Inspected: Routine, unannounced environmental protection inspection,

including evaluation of reportable occurrences78-017, 78-031, and

78-072-04-T-0; the licensee's program for quality control of analytical

measurements; evaluation of the licensee's analytical results of plant

effluent samples obtained during a previous inspection; collection of

plant effluent samples for future comparative analyses; program management

and implementation; review of program results. The inspection involved

23.5 inspector-hours onsite by one NRC inspector.

Results: Of the six areas inspected, no items of noncompliance or deviations

were found in four areas; an apparent item of noncompliance (infraction)

was found in each of two areas (discharge of chlorine in excess of T/S

limits, Paragraph 4d; and failure to review results of Environmental

Monitoring Programs, Paragraph 4c). -

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DETAILS

1. Persons Contacted

B. Beyer, Assistant Station Superintendent

D. Briden, Chemist and Health Physicist

W. Green, Administrative Coordinator

W. Mills, Chemical and Radiation Protection Engineer

J. Buck, Operations Quality Assurance Supervisor

D. Hitchens,16C Engineer

F. Kebker, Senior Chemical and Radiation Tester

D. Eldred, Technical Assistant

J. Sullivan, TECo Environmental Activities Department

K. Mauer, TECo Environmental Activities Department

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Der.stes those present at exit int e rview

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2- Review of Reportable Occurrences

(Closed) Reportable Occurrences78-017 and 78-031: Meteorological

Tower inoperative and failure to record channel check on Control l

Room Ventilation Air Intake Chlorine Detectors, respectively. The

inspector discussed reported corrective actions and reviewed docu-

mentations where available and has no further questions regarding

these items.

(0 pen) Reportable Occurrence 78-072-04-T-0: chlorine discharge in

excess of ETS limit. The inspector discussed the reported corrective

action. As the corrective action is not complete and this is an

apparent item of noncompliance, this item will be reviewed and closed

out during a subsequent inspection.

3. General

The inspection consisted of an examination of the licensee's

nonradiological environmental monitoring program, including

implementation and program results. Environmental occurrence

reports were reviewed. The licensee's program for quality control

of analytical measurements including chemical (nonradiological) l

measurements of reactor coolant water quality and results of plant

effluent samples collected during a previous inspection were examined.

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Plant effluent samples were collected for future comparative analyses.

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4. Nonradiological Monitoring Program

The following results of the licensee's nonradiological environmental

monitoring program for 1977 were examined for compliance with

monitoring and reporting:

a. Water Quality Analyses

The inspector reviewed records of water quality analyses and

noted that solar radiation measurements had not been made

(1) for the three required stations in April and November

(2) at station 1 for May through October and (3) at stations 8

and 13 in July and August. In addition, random dissolved oxygen,

temperature, and conductively measurements were missing during

the required sampling period. As the contractor did not identify l

the reason for these missing results, this matter is considered

unresolved.

b. Unreported Studies

Plantkton, benthic and fisheries population studies as well

as ichthyoplankton were to be received by Toledo Edison in

early April and subsequently reported to the Director of the

NRC Regional Office as a supplementary report as required by

Environmental Technical Specifications 5.4.1.A. To date,

only the fisheries population study has been received by

Toledo Edison. The inspector discussed the necessity of

timely reporting with licensee representatives who, in turn,

acknowledged these comments. These sections will be reviewed

upon receipt and the results covered in a subsequent inspection.

c. Environmental Monitoring Programs Review

A review of audits of the environmental monitoring program was

conducted by the inspector. The Quality Assurance Department

has audited a portieu of the program. The remainder will be I

audited by section.., although no schedule had been established

at the time of the inspection.

The inspector's review also revealed that the Station Review

Board had not reviewed the results of the Environmental Monitoring

Programs prior to their submission in each Environmental Operating

Report. This constitutes an item of noncompliance with Environ-

mental Technical Specification Section 5.1.1.

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d. Chemicals

The inspector reviewed records of chlorine, pH and sulphate

ion concentrations. Except for one instance of chlorine,

all concentrations were within the Technical Specification

limits. The licenee reported that between July 7 and

July 10, 1978 free available chlorine in excess of 0.5 mg/l

was in the collection box effluent from the circulating

water blowdown. This constitutes and item of noncompliance

with Environmental Technical Specification Section 2.3.1.

5. Licensee Program for Quality Control of Analytical Measurements

The inspector discussed the assignment of responsibility and

authority for management control of analytical measurements.

Responsibility and authority for control of those measurements

rests with the Chemist and Health Physicist. The management

control for the program progresses down through supervisors and

foremen.

The inspector reviewed records for daily checks of applicable

counting equipment and procedures associated with radiological

measurements of effluents and nonradiological measurements of

reactor coolant water quality.

The licensee's procedures do not contain criteria for accepting

measurement result and requiring notification when deficiences ,

are noted. A licensee representative stated that personnel counting l

samples are aware of what steps to take if anomalous results or

deficiencies are encountered. The inspector reviewed a memo

posted in the counting room which addresses steps to be taken if

the daily source check is not within the prescribed range. In

addition, a source check that was unacceptable and the subsequent

actions taken by the individual who ran the check was reviewed and

found to be acceptable. The inspector had no further questions

regarding this item.

6. Results of Comparative Analyses

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Results of comparative analyses performed on effluent samples split

at the site in February 1976 are shown on Table 1. The criteria

for comparing measurement results are given in Attachment 1. For

eleven sample comparisons, t he licensee's results yielded ten

agreements. The licensee failed to properly quantify gross beta

activity in the analysis of liquid waste. No reason for this

discrepancy was apparent after a review of both the licensee's

and the NRC Reference Laboratory's data.

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7. Effluent Sampling

Samples of liquid and gaseous waste were obtained for future comparison.

8. Unresolved Items

Unresolved items are matters about which more information is required

in order to ascertain whether they are acceptable items, items of

noncompliance, or deviations. An unresolved item disclosed during

the inspection is discussed in Paragraph 4a.

9. Exit Interview

The inspector met with the licensee representatives (denoted in

Paragraph 1) at the conclusion of this inspection on August 23,

1978. The purpose, scope and findings of the inspection were

discussed. In response to certain remarks made by the inspector,

the licensee agreed to:

a. Put a trace on the replacement parts needed to put the

recorder and computer alarm point associated with the

automatic chlorine analyzer at the beach sample station

back into good ',ocking order.

b. Expedite the installation of the replacement parts

discussed in Paragraph 9a as soon as they are received.

c. Obtain documentation f rom the nonradiological environmental

contractor regarding the samples which were missed (Paragraph 4a).

Attachments:

1. Attachment 1, Criteria for

Comparing Analytical Measurements

2. Table 1, Confirmatory Measurements

Program, Davis-Besse

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ATTACIIMENT 1 '

CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS l

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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. :

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In these criteria, the judgment limits are variable in relation to the j

comparison of the NRC Reference Laboratory'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 mcasurement 1

should be more selective. Conversely, poorer agreement should be con-

sidered acceptable as the resolution decreases. The values in the ratio

criteria may be rounded to fewer significant figures to maintain

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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. The acceptance category reported will

be the narrowest into which the ratio fits for the resolution being used.

RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE

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Possible Possible )

AJ reement J ryement "A"

A Agreeable "B"

<3 No Comparison No Comparison Fo Comparison

>3 and <4 d.4 - 2.5 0. 3 -

3.0 No Comparison

T4 and <8 0.5 - 2.0 0.4 -

2.5 0.3 -

3.0

78 and <16 0.6 - 1.67 0.5 -

2.0 0.4 - 2.5

T16 and <51 0.75 - 1.33 0.6 -

1.67 0.5 -

2.0

351 and <200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.67

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__200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33 l

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"A" criteria are applied to the following analyses:

Gamma spectrometry, where principal gamma energy used for identifi-

cation is greater than 250 kev.

Tritium analyses of liquid samples.

"B" criteria are applied to the following analyses:

Gamma spectrometry, where principal gamma energy used for identifi-

cation is less than 250 kev.

Sr,-89 and Sr-90 determinations. '

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Gross beta, where samples are counted on the same date using the

same reference nuclide.

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1ASLE I

U S FUCLEAR FEGULATORY COMMISSION

OFFICE OF INSPECTION A ND E NF O R C E ME NT

CONFIRMATORY ME ASUREMEN T S PROGR A M

FACILITY: DAVIS 4 ESSE

F 0 f, THE 1 OUARTER 0F 1975

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SAMPLE ISOTOPE RESULT EREGE hESULT ERROR KATIC 'EE S T

'0 F F GAS XE 133 2 0E-04 1 1 E -0 5 3 7E -0 4 00 1 3E+0C 2 6E+01 A

LtWASTE BETA 1 5E-05 1 0E-06 4 2E -35 00 2 8E+00 1 5 E + 01 0

H 3 5.3E-02 1 0E-04 5 8E-D2 0.0 1 1E+00 5 3E +02 A

I 131 4.0F-06 7 5E-07 5 8E -Db 00 1 2E+00 6 5E +00 A

CG SR 9 0E-05 2 6E-06 8 2 E -05 00 9 1F-01 3 5E + 01 A

MN 54 1.1E-US 3 8E-07 1 0 E -0 5 00 9 1 E -01 2 9 E + 01 A

F SPIKED r3 57 2' d?E -03 1 61-04- 6 45-03' ).7 1 3E+00 5. J E +C l A

CS 134 1: 1E-02 4 0E-OL 1 e 2E -0 2 00 1 1E+00 2 7E+01 A

CS 137 6 6E-03 3 0E-04 7 9E-03 00 1 2E +00 2 2 E + 01 A

CO 60 8 1E-03 4 0E -04 9 8 E -0 3 00 1 2E+00 2 0E +01 A

C SPIKE 0 BA 133 8.9E+04 4 8E +0 3 8 4E+04 00 9 4 E -01 1.9 E + 01 A

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SEP 181978

University of Notre Dame du Lac License No. 13-01983-15

ATIN: Dr. John W. Lucey, Chairman

Radiation Control Committee

Notre Dame, IN 46556

Gentlemen:

This refers to the inspection condue.ted by Mr. S. R. Lasuk of this

office on August 22-23, 1978, of activities authorized by NRC Fv-

product Materials License No. 13-01983-15 and to the discussion of

our findings with you and Messrs. E. Riley and R. Zerr at the

conclusion of the inspection.

The inspection was an examination of activities conducted

under your license as they relate to radiation safety and

to compliance with :Se Commission's rules and regulations

and with the conditions of your license. The inspection

consisted of a selective examination of procedures and !

representative records, observations, and interviews with

personnel.

The inspection also included a review of the actions described in ,

your letter dated April 19, 1976, regarding the apparent item of

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noncompliance found during our March, 1976 inspection and your in-

ventory control system. We have no further questions on this matter.

During this inspection, certain of your activities appeared

to be in noncompliance with NRC requirements, as described

in the enclosed Appendix A.

This notice is sent to you pursuant to the provisions of

Section 2.201 of the NRC's " Rules of Practice," Part 2, Title

Section 2.201 requires you

10, Code of Federal Regulations.

to submit to this of fice within twenty days of your receipt

of this notice a written statement or explanation in reply,

including for each item of noncompliance: (1) corrective

action taken and the results achieved; (2) corrective action

to be taken to avoid further noncompliance; and (3) the date

when full compliance will be achieved.

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University of Notre Dame -

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du Lac

We will gladly discuss any questions you have concerning this

inspection.

Sincerely,

A. B. Davis, Chief

Fuel Facility and Materials

Safety Branch

Enclosure: Appendix A,

Notice of Violation

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Central Files

Reproduction Unit NRC 20b

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Appendix A

NOTICE OF VIOLATION

University of Notre Dame du Lac License No. 13-01983-15

' Based on the inspection conducted on August 22-23, 1978, it appears

that certain of your activities were in noncompliance with NRC

requirements, as noted below. The following item is an infraction.

Condition 19 of your license requires that licensed material be

possessed and used in accordance with statements, representations,

and procedures contained in certain applications and letters. The

application dated August 8, 1975 included a copy of your Radiation

Safety Manual.

Contrary to the requirements of this manual (item 2, page 20), on

August 23, 1978, food was stored in a radioisotope laboratory (Lab 364,

Nieuwland Science Hall).

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ML20147C035

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