IR 05000346/1978022

IE Inspec Rept 50-346/78-22 on 780821-23 During Which 2 Items of Noncompliance Were Noted:Discharge of Chlorine in Excess of Tech Specs Limit & Failure to Review Results of Environ Monitoring Progs

ML20147C063
Person / Time
Site:	Davis Besse
Issue date:	09/07/1978
From:	Essig T, Januska A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20147C039	List: IR 05000346/1978022 ML20147C035 ML20147C043
References
50-346-78-22, NUDOCS 7810110270
Download: ML20147C063 (7)

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report N /78-22 Docket N License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue l Toledo, OH 43652 Facility name: Davis-Besse Nuclear Power Station, Unit 1 I Inspection at: Davis-Besse Site, Oak Harbor, OH Inspection conducted: August 21-23, 1978 k On w Inspector: A. anuska 'f/7!76

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Approved by: T. H. Essig, ef 9 76 Environmental and Special I Projects Section l

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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 cot.parative analyses; program management and implementation; review of program results. The inspection involved 23.5 inspector-hours onsite by one NRC inspecto Resules: 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 Persons Contacted Beyer, Assistant Station Superintendent

• D Briden, Chemist and Health Physicist

• Green, Administrative Coordinator

• Mills, Chemical and Radiation Protection Engineer

• Buck, Operations Quality Assurance Supervisor D. Hitchens, I6C Engineer

• F. Kebker, Senior Chemical and Radiation Tester D. Eldred, Technical Assistant

• Sullivan, TECo Environmental Activities Department

• K. Mauer, TECo Environmental Activities Department

• Denotes those present at exit interview Review of Reportable Occurrences (Closed) Reportable Occurrences78-017 and 78-031: Meteorological .

Tower inoperative and failure to record channel check on Control !

Room Ventilation Air Intake Chlorine Detectors, respectively. The inspector discussed reported corrective actions and reviewed docu-l mentations where available and:has no further questions regarding these item j (0 pen) Reportable Occurrence 78-072-04-T-0: chlorine discharge in !

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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 I out during a subsequent inspection, j General The inspection consisted of an examination of the licensee's i 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)

measurements of reactor coolant water quality and results of plant effluent samples collected during a previous inspection were examine l Plant effluent samples were collected for future comparative analyse '

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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 i monitoring and reporting: 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 Augus In addition, random dissolved oxygen, temperature, and conductively measurements were missing during the required sampling period. As the contractor did not identify the reason for these missing results, this matter is considered unresolve l 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 l 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 i Toledo Edison. The inspector discussed the necessity of

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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, i Environmental Monitoring Programs Review A review of audits of the environmental monitoring program kas conducted by the inspector. The Quality Assurance Department has audited a portion of the program. The remainder will be audited by sections, although no schedule had been established at the time of the inspectio j The inspector's review also revealed that the Statien 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. %

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D Y 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. . Licensee Program for Quality Control of Analytical Measurements

The inspector discussed the assignment of responsibility and authority for management control of analytical measurement 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 foreme The inspector reviewed records for daily checks of applicable i counting equipment and. procedures associated with radiological j measurements of effluents and nonradiological measurements of ;

I reactor coolant water qualit 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 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 rang In addition, a source check that was unacceptable and the subsequent actions taken by the individual who ran the check was reviewed and ,

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found to be acceptable. The inspector had no further questions regarding this ite . Results of Comparative Analyses Results of comparative analyses performed on effluent samples split at the site in February 1978 are shown on Table The criteria for comparing measurement results are given in Atta.chment 1. For eleven sample comparisons, the 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 dat _

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, Effluent Sampling Samples of liquid and gaseous waste were obtained for future compariso , 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 4 . Exit Interview

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The inspector met with the licensee representstives (denoted in i 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: Put a trace on the replacement parts needed to put the recorder and computer alarm point associated with the

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automatic chlorine analyzer at the beach sample station 1

, back into good working orde Expedite the installation of the replacement parts discussed in Paragraph 9a as soon se they are receive . Obtain documentation f rom the nara tdiological environmental contractor regarding the samries wnich were missed (Paragraph 4a),

l Attachments: I

) Attachment 1, Criteria for Comparing Analytical Measurements Table 1,. Confirmatory Measurements  ;

Program, Davis-Besse

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ATTACIMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

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This attachment provides criteria.for comparing reculte of capability

- tests and verification measurement The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of~this progra In these . criteria, the judgment limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated one signa uncertainty. As that ratio, referred to in this program as

" Resolution", increases, the acceptability of a licensee's measurement should be more selectiv 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 statistical consistency with the number of significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a

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narrowed category of acceptance. The acceptance category reported will be the narrowest into which the ratio fits for the resolution being use RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE ' i Possible Possible Agreement Agreement "A" Agreeable "B"

<3 No Comparison No Comparison No Comparison

>3 and <4 d.4 - . 3 - No Comparison I4 and <8 .0 .5 .0 T8 and <16 0.6 - 1.67 .0 .5 I16 and <51 0.75 - 1.33 .67 .0 I51 and <200 0.80 - 1.25 0.75 -

1.33 .67 3200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33

"A" criteria are applied to the following analyses:

Gamma spectrometry, where principal gamma energy used for identifi-cation is greater than 250 ke Tritium analyses of liquid sample l

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B" criteria are applied to the following analyses:

Gamma spectrometry, where principal gamma energy used for identifi-cation is less than 250 ke Sr,-89 and Sr-90 determination .

Gross beta, where' samples are counted on the same date using the same reference nuclic *

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t TA9LE I U. S NUCLEAR F E G'UL A10k Y . C OMMI S S 10 h 0FFICE OF INSPECTION AND E NF OR CE ME NT l CONF IR M A TOR Y ME ASUREMENTS PROGR A M FACILITY: .0 AVIS 4 ESSE FOR THE 1 QUARTER.0F 1978 ,

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NRC------- ---L I C E N SE E ----- ---NRC: LICENSEE----

SAMPLE ISOTOPE RE SUL1 ERh0E hESULT ERROR RATIO TES T

'0 F F GAS XE 133 2 0E-04 1 1 E -0 5 3 7E -04 00 1 3E+00 2 6E+01 A0

- 1. *. W A S T E BETA 1 5E-05 1 0E-06 4 2E-05 00 2 8E+00 1 5 r, + 01 o H E-02 1 0E-04 5 8E-02 00 1 1E+00. 5 3E+02- A -]

I 1 31 4.0F-06 7 5E-07 5 8E-06 00 1 2E+00. 6 55+00 A- l CO 59 MN 54 9 0E-05-1 1E-05 2 6E-06 8 2E -05 00 9 1E-01 3 5E + 01 A[

3 8E-07 1 0 E -0 5 00 9 1 E -01 2 9E+C1 A l l

F SPIKED f3 57 :Lel?!-03 .1 65-04' 6.4!-03' ).1 ~ 1 3E+JD 5. J E +0 i . A CS 134 1:1E-02 4 0E-04 1 e 2 E -0 2 00 1 1E+00 2 7E+01 A CS 137 6 6E-03 3 0E-04 7 9E-03 E+00 2 2 E + 01 A CO 60 8 1E-33 4 0E -04 9 8 E -0 3 00 1 2E+00 2 0E +01 A C SP IKE0 LA 133 8.9E+04 4 8E+03 8 4E+D4 E -01 1.9E+01 A

- T = TBS 1 EISULTSt .

A = A C R E E ME N T D=0IS AGRE EME NT P=POSSIB.LE AGCEEMEili N=NO COMP AR IS0h

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