IR 05000334/1986025

Insp Repts 50-334/86-25,50-412/86-34 & 70-3008/86-02 on 861020-24.No Violations Noted.Major Areas Inspected:Program for Receipt,Handling & Control of New Fuel.Administrative Weaknesses in Radiation Work Permit Records Noted

ML20214V281
Person / Time
Site:	Beaver Valley, 07003008
Issue date:	11/26/1986
From:	Lequia D, Mcfadden J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214V248	List: IR 05000334/1986025 ML20214V246
References
50-334-86-25, 50-412-86-34, 70-3008-86-02, 70-3008-86-2, NUDOCS 8612090605
Download: ML20214V281 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-34/S6-02 Docket N /50-412/70-3008 License N DPR-66/CPPR-105/SNM-1954 Priority --/--/-- Category C/B/--

Licensee: Duquesne Light Company Post Office Box 4 Shippingport, P Facility Name: Beaver Valley Power Station, Units 1 & 2 Inspection At: Shippingport, P Inspection Conducted: October 20-2.4, 1986 m > )

Inspectors: , MA II['t6[/988 f r>y J. McFadden R iation pecialist date h

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D. LeQuia, Radiation Speiialist 11dateJa hnt Approved by: m _M ///24[PS M. Shanbaky, Chief, Facifities ~ d.it'e Radiation Protection Section Inspection Summary: Combined inspection on October 20-24,1986,(Inspection Report Numbers 50-334/86-25; 50-412/86-34; and 70-3008/86-02)

Areas Inspected: Unannounced in plant radiation protection inspection includ-ing status of previously-identified items (BV-1), of preoperational activities (BV-2), and of the program for receipt, handling, and control of nev fuel (BV-2). Two regionally-based inspectors were onsite for this inspectio Results: No violations were identifie However, administrative weaknesses in Radiation Work Permit and vehicle survey records were noted and are discus-sed in section m20;gggttagg4 G

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DETAILS 1.0- Persons Contacted During the course of this inspection, the following personnel were contac-ted or interviewed:

1.1 Licensee Personnel R. Freund - Health Physics Foreman

• Girdwood - Director, Radiological Controls

• J. Godleski - Senior Test Engineer

• D. Hunkele - Director, QA-OPS

• J. Johns - Supervisor, QA Surveillance J. Kosmal - Manager, Radiological Controls

• C. Schulte - PRC Chairman

• R. Swiderski - Startup Manager

• R. Vento - Director, Radiological Engineering

• D. Weitz - Senior Health Physics Specialist 1.2 NRC Personiel

• L. Tripp - Chief, Reactor Project Section 3A

• J. Beall - Senior Resident Inspector

• A. Asars - Rasident Inspector

• Attended exit interview on October 24, 198 Additional licensee personnel were contacted or interviewed during this inspectio .0 Purpose The purpose of this in plant radiation safety inspection was three-fold as follows:

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To review the status of two previously-identified items at BV-1 (Docket No. 50-334).s

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To review the preoperational preparations at BV-2 (Docket No. 50-412)

in the following areas:

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Organization and management controls;

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Selection, training, and qualification of personnel;

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External exposure and personnel dosimetry;

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Internal exposure control and assessment;

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Control of radioactive materials and contamination, surveys, and monitoring;

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Facilities and equipment;

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The ALARA program; and

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To review the program for receipt, handling, and control of new fuel at BV-2 (Docket No. 70-3008).

3.0 Status of previously-Identified Items-3.1 (Closed) Unresolved Item 83-30-03 During Inspection No. 83-30, the following matter was identifie Licensee personnel periodically enter noble gas atmospheres to perform work. However, the licensee could not provide a complete evaluation to demonstrate that personnel skin dose, resulting from beta radiation exposure during these entries, was being properly monitored or that the beta radiation was effectively shielded by protective clothing worn. Licensee representatives indicated that the beta radiation was shielded by protective clothing and that an evaluation of this would be documente During Inspection No. 84-10, this item was reviewed and left ope Review of the licensee's preliminary efforts and scope of the beta radiation evaluation appeared acceptable. The licensee planned to use the data base from NUREG/CR-1918 in the dose assessment progra This program will define a finite distance cloud for photons and a

, semi-infinite cloud for beta dose calculations. The program will also provide for shielding allowances for the thickness of protective clothing. By December 1984, the licensee also intends to evaluate beta radiation exposures using the Panasonic 812 badge which will be calibrated for beta radiatio During this inspection (No. 86-26), this item was further reviewe The licensee's calculation package (ERS-RMV-85-055) documented a mathematical determination of the electron-dose rate to the basal layer of the skin under the following conditions:

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With no intervening shielding material;

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Under a single layer of anti contanination coveralls (anti-Cs);

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Under a single layer of anti-Cs plus a cotton undergarment; and

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Under atmospheric and under subatmospheric conditions.

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The licensee used methodology from NUREG/CR-1918 in their calcula-tions. The results of thirty-one air samples were analyzed to determine specific radionuclides present and their mean concentrations. Based on these calculated mean concentrations, the mean shallow (skin-of-whole-body) dose-rates from the eight most-commonly-occurring radionuclides were determined. The licensee found that Xe-133 was the predominant electron-dose contributo ... .-- . - - _ - - . . - - - . . - .

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Based on this finding, the licensee's Radiological Control Procedure 5.4, " Electron Shallow (Skin) Dose Assessment for Containment Entries," states the following:

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Containment gas samples will be taken anu analyzed for Xe-133 concentratio Individual dose assessments will be performed taking into account the concentration, the atmospheric pressure in contain-ment, and whether a respirator was removed during entr Individual cumulative doses will be tracked and, if anyone exceeds 75 mrad per quarter, this dose will be entered in the individuals radiation exposure history file. This is added to the shallow dose from the individual's TLD which is worn during containment entr The inspector verified that this procedure was being implemente The licensee stated that the current containment air samples were being reviewed at two levels for any significant differences in types or quantities of radionuclides from the data on which the procedure was base The inspector, in his review, observed that the data, on which the procedure was based, contained concentration values for I-135 and Kr-88 which appeared low. This would not appear to be significant based on normal relative concentrations and relative electron-dose-rate-conversion factors between I-135, Kr-88, and Xe-13 The licensee is presently using the Panasonic TLD badge systen. The licensee's TLD dosimetry system was reviewed during NRC Inspection No. 85-15, and no negative findings were identifie Based on these findings this matter is considered resolved and close .2 (0 pen) Unresolved Item 83-30-05 The adequacy of the licensee's airborne effluent monitoring system to collect representative samples was examined during previous inspections. The licensee's progress in this area was reported in NRC Inspection Report Nos. 50-334/84-10 and 50-334/85-1 During this inspection (No. 86-25), this item was again update The licensee clarified some NRC questions concerning items in the following documents:

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Licensee Radiation Monitor Study / Summary Evaluation Report /

December 198 .

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Licensee Radiation Monitor Study / Particle Distribution Evalua-tion / June 198 The clarifications concerned the following items:

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Conversion of percent negative bias to a correction factor in a form which can be used to convert obtained data to corrected data by multiplicatio Values and methods of determination for licensee's conservative correction factors used for effluent release Comparison of iodine and particulate correction factors (multi-plication-type) obtained from the study data to the present correction factors used for effluent release The licensee stated that the clarifications would be documented and submitted to the NRC within two month This matter will remain unresolved pending receipt and review of the licensee's clarification .0 Preoperational In-Plant Radiation Protection Program (BV-2)

The operational readiness of the licensee's program in this area was reviewed against criteria contained in:

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10 CFR 20, Standards for Protection Against Radiation;

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Licensee Proposed Technical Specification 6.0, Administrative Controls; and

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BV-2 Final Safety Analysis Report, Chapter 12, Radiation Protectio The licensee's performance relative to these requirements was reviewed by the following:

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Discussions with Radiological Control personnel;

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Several tours of the reactor containment and of the fuel, auxiliary, waste handling, and condensate polishing buildings;

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Observation of Radiological Control preoperational activities; and

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Review of documentatio Within the scope of this review, no violations were identifie l l

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4.1 -Organization and Management Controls The Radiological' Control group is represented on the Operational Readiness Review Team (ORRT) as a member of one of the interdisciplinary working groups. As a member of the ORRT,the Radiological Control group generated a list of radiation protection-related open items based on differences between the two onits and on changes due to dual-unit operation. These items have been assigned to individual Radiological Control personnel for resolution, and completion dates have been established. The status of each of these open items is being tracke The licensee has instituted a color-coding system to indicate the applicability of procedures, i.e. one color for procedures common to both plants, another color for Unit 1 procedures, and a third color for Unit 2 procedure The licensee intends to have a Radiological Control group common to both units and has already set up a personnel-rotation schedule'for radiation technician Physical presence and involvement of Radiological Control personnel at Unit 2 started in early August of this year, and, at the time of this inspection, there were ten individuals assigned to Unit 2 (two senior HP specialists, two Radiological Control foremen, and six Radiological Control technicians (on a rotating basis)).

The Radiological Control group has identified their additional staffing requirements due to dual-unit operation and has received approval and authorization to fill approximately fifty percent of these identified opening .2 Selection, Training, and Qualification of Personnel Based on the licensee's plans fo additional Radiological Control personnel, on the physical differences between the two units, and on new instrumentation / equipment planned for at Unit 2 and not used at Unit 1 (ex. digital radiation monitoring system (DRMS)), the following items will be addressed in future inspections:

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Selection criteria of new or promoted Radiological Control personnel versus the requirements of the technical

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specifications (TSs).

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Training and qualification of Radiological Control personnel in procedures unique to Unit The licensee stated that a Unit 1/ Unit 2-system-differences training program (three-day duration) has been developed and was scheduled to be started within a few week .

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4.3 External Occupational Exposure Control and Personnel Dosimetry The following items were discussed with the licensee:

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Access control to radiation areas in Unit 2;

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Identification of locked high radiation areas (LHRAs) and means of control; and

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Need for additional personnel dosimeter At present, the licensee has a HP access control point located on the 774' 6" elevation of the waste handling building. The licensee plans to use this as the main access control point to the main radiologi-cally controlled area (RCA). Another HP access control point to a secondary RCA in the safeguards building is also planned since this building cannot be accessed from the main RCA. During the inspec-tion, several Radiological Control personnel were observed physically inspecting areas identified as potential LHRAs in the ALARA Design Review. These Radiological Control personnel were discussing the most effective locations for the installation of lockable gates. The licensee stated that 4000 additional TLDs (vs. 8000 presently for Unit 1) and 1300 additional SRDs (vs. 2500 presently for Unit 1) had been ordere Based on the previous discussion, the following items will be addres-sed in future inspections:

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Access control and procedures for radiation areas;

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Installation of physical controls for LHRAs; and

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Receipt, QA testing, and calibration of additional dosimetry device .4 Internal Exposure Control and Assessment The licensee stated that the need for additional equipment had been evaluated. Equipment, identified for ordering, included thirty recirculating SCBAs, one respirator-fit-test head, and three portable supplied-breathing-air systems. This equipment is to be of the same type already used at Unit Also, the licensee is considering the purchase of additional whole-body counters (WBCs).

The following items will be addressed in future inspections:

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Receipt of additional respiratory protection equipment;

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Receipt of new WBCs and calibration procedures for same; and

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Ventilation system test procedures and results (direction of air flow in plant from areas of low potential airborne radioactivity to areas with higher potentia .5 Control of Radioactive Materials and Contamination, Surveys, and Monitoring The following items were discussed with licensee personnel:

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Area radiation monitoring system (ARMS);

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Routine radiation surveys; and

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Instrumentation need .

The licensee stated that the DRMS had been identified as a critical item in their preparations for Unit 2 operation and that a separate working group had been established to bring this system on-line. A tour of the plant showed that many of the monitors were in place with protective coverings (sheet metal or plastic). The inspector observed a Radiological Control technician and I&C technician calibrating an area radiation monitor (ARM) (2 RMP-DAU-205). The technicians stated that several ARMS had been calibrated at this point in time using local readout The DRMS consoles in the control room and at the main HP access control point were not yet operational. None of the airborne or process radiation monitors have yet been calibrate The inspector observed maps for routine radiation surveys being developed. Documentation of the licensee's evaluation of portable instrumentation needs was reviewed. Several portable instruments of types different from those in use at Unit I are being considered for purchase. The licensee is also considering the purchase of automated frisking equipmen The following items will be addressed in future inspections:

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Calibration procedures and records for CRMS;

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Routine radiation survey procedure;

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Adequacy of the numbers of portable survey meters, counters, air samplers, friskers, and portal monitors; and

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Calibration procedures and records for new instruments or equipment different from that at Unit '

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4.6 Facilities and Equipment The following items were discussed with Radiological Control personnel:

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Issue points for dosimetry, RWPs, protective clothing, survey meters, and respirators;

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HP counting facilities;

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HP instrument calibration area;

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Personnel decontamination facilities;

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Equipment decontamination facilities;

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Clothing change rooms;

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Storage of contaminated equipment;

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HP storage areas; and

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HP office spac Through tours and discussions with Radiological Control personnel, the following was determined:

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Single site issue points for dosimetry and RWPs are being considered; issue of protective clothing, survey meters, and respirators for Unit 2 is to take place at or in the immediate vicinity of the HP access control point in.the waste handling buildin A location for a HP counting facility in the vicinity of the HP access control point is not yet finalized; for gamma spectro-scopy of air samples, the radiochemistry lab, in the vicinity of the HP access control point, is to be utilized; this is similar to the present arrangement at Unit HP instrument calibration area at Unit 1 is to be used for both unit There are two personnel decontamination facilities in the vicin-ity of the HP access control point in the waste handling build-in The equipment (hand tools, small parts, etc.) decontamination area at Unit 1 is to be used for both unit \

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The locations for clothing change rooms, storage of contaminated equipment, and HP-supplies / equipment / instrumentation storage space have not yet been finalize The licensee indicated that HP office space will be available in the South Offices & Shop Services Building which is attached to the Unit 2 turbine buildin .7 Maintaining Occupational Exposures ALARA The licensee contracted with the A/E (Architect / Engineer) to have a detailed ALARA Design Review (ADR) performed for Unit 2. The inspector reviewed this documen Plant design features were systematically reviewed by the A/E by dividing each building / complex evaluated (reactor containment, auxiliary building, condensate polishing building, waste handling building, and fuel and decontamination buildings) into subcompartments or cubicles with consideration given to radiation zone designations, shielding facilities, source locations, personnel access areas, and ventilation patterns. Approximately one-hundred-forty subcompartments or cubicles were identified, and each was evaluated using a detailed ALARA checklist. The A/E categorized the results of the ADR into three classifications, as follows: operating restrictions, pre-fuel load modifications, and modifications recommended following commercial operation. The operating-restrictions classification applied to areas identified for which design modifications to the plant would not be feasible or would not be cost effective in reducing operational radiation exposures. Therefore, in these cases, the A/E defined specific operating restrictions to minimize opera-tional radiation exposure The licensee stated that the Radiological Control and engineering groups reviewed the A/E's ADR and that operations, Radiological Control, and engineering personnel performed a physical walkdown of the areas of concern identified by the A/E. The licensee subsequently notified the A/E of the results of their review and identified authorized pre-fuel-load modifications. In addition, the licensee authorized the A/E to update the ALARA design review for design changes from the 1981-1982 time frame to August, 198 As mentioned previously, there are ten Radiological Control persons presently assigned to Unit 2. In addition to physical walkdowns by these personnel, a radiation engineering specialist has been involved in evaluating LHRAs. While a formal systematic Radiological Control /ALARA field inspection and review prior to start-up using formal guidance and criteria has not been developed, the licensee stated that field inspections would be conducted prior to Radiological Control acceptance of turnover package *

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The followirg items will be reviewed during future inspections:

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ADRs of modifications from 1981-1982 time frame to August 1984;

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Assignment of. responsibility for and implementation of field inspection of pre-fuel load modifications;

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Assignment of responsibility for and implementation of incorpor-ation of operating restrictions into appropriate procedures; and

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Field inspection prior to turnover / start-up to evaluate field-originated changes to equipment (for example, radiation monitor locations and air sampling line origins and reinsertions).

5.0 Fuel Receipt (BV-2)

The licensee's program for the receipt, control and handling of new fuel was reviewed against criteria contained in:

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10 CFR 19.12, lastructions to Workers;

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10 CFR 20, Standards for Protection Against Radiation; and

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Special Nuclear Material License (SNM) No.1954, dated April 9,198 The licensee's performance relative to the above requirements was deter-mined by:

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Discussions with cognizant personnel;

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Observation of new fuel handling evolutions;

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Inspection of new fuel storage areas;

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Review of the following licensee procedures:

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CMP, 2-75-57M " Site Receipt and Handling of New Fuel Assemblies";

RPl.8, " Receipt of Fuel";

RP3.9, " Monitoring Vehicles";

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Review of Radiation Work Permits (RWP), numbers 15001 and 15003, entitled: " Receipt and Storage of Unit 2 New Fuel Assemblies";

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Review of the survey results for seven new fuel shipments to Beaver Valley Unit 2; and

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Review of training records for mechanical department personnel handling new fue *

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Within the scope of this review, no violations were noted. The licensee has implemented an effective program for the receipt, handling and control of new fuel assemblie Inspector review of Radiation Work Permits and survey records associated with receipt and handling of the fuel assemblies did, however, identify a significant number of administrative errors, including the following:

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Contamination surveys, both incoming and outgoing, for new fuel ship-ment number five, incorrectly indicated the shipment was contaminate A Health Physics technician providing continuous coverage for new fuel handling failed to sign-in on the RW Additional weaknesses on RCM 8.1 Form, Section 3, were noted as follows:

Forms, which had been. reviewed by management personnel, were incomplet = Forms were not being reviewed in a timely manner. Some of the sheets had gone for up to a month without being reviewed. They are normally reviewed on a daily basi *

Dosimeter totals for individual personnel, as well as for the page, were frequently omitte The extent of these administrative errors indicators a lack of management attention to detail and subsequently reduces the overall quality of health physics records. The inspector discussed these items with the licensee who took immediate corrective actio .0 Exit Interview The inspectors met with the personnel denoted in Section 1.0 at the conclusion of the inspection on October 24, 1986. The scope and findings of the inspection were discussed at that time.