IR 05000334/1987004

Occupational Radiation Protection Insp Repts 50-334/87-04 & 50-412/87-09 on 870210-13.No Violations Noted.Major Areas Inspected:Status of Previously Identified Items,Organization & Mgt Controls,Surveys,Alara & Internal Exposure Control

ML20207S753
Person / Time
Site:	Beaver Valley
Issue date:	03/13/1987
From:	Loesch R, Mcfadden J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207S740	List: IR 05000334/1987004 ML20207S739
References
50-334-87-04, 50-334-87-4, 50-412-87-09, 50-412-87-9, NUDOCS 8703200242
Download: ML20207S753 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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50-334/87-04 Report No /87-09 50-334 Docket Nos. _50-412 DPR-66 --

C License No CPPR-105 Priority --

Category B Licensee: Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Power Station, Units 1 and 2 Inspection At: Shippingport, Pennsylvania Inspection Conducted: February 10-13, 1987 l

Inspectors: A M 8 dY p.McFadden,SeniorRadiationSpecialist d(te /

• l' M, R. Loesch, Radiation Specialist lb ?

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Approved by: # C/

M. Shanbaky 7 C51ef, Faciktties Radiation date 3//5/f/7 _

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Protection Section Inspection Summary: Combined Inspection on February 10-13, 1987 (Inspection Report Nos. 50-334/87-04 and 50-412/87-09 Areas Inspected: Unannounced routine occupational radiation protection inspection including: status of previously-identified items; organization and management controls; external exposure and personnel dosimetry,* internal exposure control and assessment,* control of radioactive materials and contam-ination; surveys; monitoring; ALARA at Unit 1; preoperational activities at Unit 2. Two regionally-based inspectors were onsi'.e for this inspectio Results: No violations were identifie NO32$$N f5b

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DETAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewe .1 Licensee Personnel

• A. Bevan, Health Physics Specialist D. Blair, Director, Radiological Health Services

• Canan, Sr. Health Physics Specialist E. Cohen, Sr. Health Physics Specialist R. Freund, Rad Con Foreman

• D. Girdwood, Director, Radiological Operations

• J. Godleski, Sr. Test Engineer, SVG-BV-2 M. Helms, Health Physics Specialist

"J. Kosmal, Manager, Radiological Control S. Koty, Rad Con Foreman

• F. Lipchick, Sr. Licensing Supervisor

• T. Noonan, Superintendent, SVG-BV-2

• J. Sieber, Vice President, Nuclear

• Somerville, Sr. Health Physics Specialist

• R. Vento, Director, Radiological Engineering

• Weitz, Sr. Health Physics Specialist J. Wilbur, Rad Con Foreman K. Winter, Sr. Health Physics Specialist

• T. Zog1mann, Sr. Project Engineer, Licensing - BV-2

• Attended the exit meeting on February 13, 1987.

Additional licensee personnel were contacted or interviewed during this inspectio .2 NRC Personnel Attending the Exit Interview A. Asars, Resident Inspector, BV-2 J. Beall, Senior Resident Inspector, BV-2 W. Troskoski, Senior Resident Inspector, BV-1 2.0 Purpose The purpose of this inspection was to review the licensee's occupational radiation protection program with respect to the following elements:

Status of previously identified items (BV-1)

Organization and management controls (BV-1 and BV-2)

Training and qualification of personnel (BV-2)

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External occupational exposure control and personal dosimetry (BV-1 and BV-2)

Internal exposure control and assessment (BV-1 and BV-2)

Control of radioactive materials and contamination, surveys, and monitoring (BV-1 and BV-2)

Facilities and equipment (BV-2)

Maintaining occupational exposures ALARA (BV-1 and BV-2)

3.0 Status of Previously-Identified Items (BV-1)

3.1 (Closed) Follow-up Item (50-334/84-17-02):

During NRC Inspection No. 84-17, the licensee agreed to conduct a review of their contracted whole-body-counting service for compliance with Regulatory Guide 8.26 (ANSI N343).

During this current inspection, a work practice document for the contracted whole-body-counting service was available and was reviewed by the inspector. This document described the equipment, operation, calibration, and reporting of results for the Low Level Radiation Monitoring Facility operated by the University of Pittsburgh. This document indicates the following:

the facility maintains QA documentation (but lacks formalized QA procedures);

system performance is verified prior to each count;

lower limits of detection for the "65 centimeter arc geometry" are within Regulatory Guide 8.26 (ANSI N343) recommendations; and

Calibrations are traceable to the National Bureau of Standard Based on these findings, this item is considered close .2 (0 pen) Follow-up Item (50-334/86-10-01):

During NRC Inspection No. 86-10, the inspector noted several inade-quacies in the air sampling program. Subsequently, the licensee committed to take corrective actions in those specific area During this current inspection, the 'nspector noted the following:

procedure RP 7.3, " Air Samplint Field Evaluation and Sample Assessments," has been revised necessary;

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the revised air sample log now allows better correlation between gross counting results and gamma spectroscopic results; and

all charcoal air sample cartridges are now routinely analyzed utilizing the CESCO geometry and are flipped midway through the coun The licensee stated that the air-sampling portion of the contractor radiological protection training would be upgraded prior to the upcoming outage in November 1987 and that a radiological controls supervisor would be assigned to oversee the air sampling program during outages. These latter areas will be reviewed in a subsequent inspectio .0 Organization and Management Controls (BV-1 and BV-2)

The licensee's organization and management controls for the radiological protection function were reviewed against criteria contained in:

10 CFR 50, Appendix B, QA Criteria for Nuclear Power Plants;

Licensee Technical Specification 6.0, Administrative Controls (BV-1);

Licensee Final Safety Analysis Report (BV-2), Section 12, Radiation Protection;

Licensee Final Safety Analysis Report (BV-2), Section 13, Conduct of Operations; and

Regulatory Guide 8.8, Information Relevant to Ensuring that Occu-pational Radiation Exposures at Nuclear Power Stations Will be As Low As Reasonably Achievabl The licensee's organization and management controls for the radiological protection function were evaluated against these criteria by the following:

discussions with licensee radiological protection personnel;

review of applicable licensee documentation; and

review of staffing level Within the scope of this review, no violations were identifie .1 Unit 1 Plant management is kept informed of the status of the radiological protection program by being on distribution for various applicable reports. The following reports, for which plant management is on distribution, were reviewed by the inspector:

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status report on the 1966 Radiological-Control-related objectives;

Radiological Control L4partment Objectives for 1987 through 1991;

Radiological Control Trend Monitoring Report - December 1986;

Fourth Quarter 1986 r posure x Assessment;

Personnel Exposure History Report - January 1987; and

Preliminary 1987 Person-Rem Budge The inspector also reviewed a memorandum issued by the acting Unit 1 plant manager on January 30, 1987. This memorandum was in response to audit finding It stated that the implementation of the radio-logical protection program was everyone's responsibility and, in addition, it required that each line supervisor on distribution to monitor frisking and radiological work practices at least once per week for three months ard that this monitoring and any related cor-rective action be documented and forwarded to the plant manager's office. This instance indicates that plant management is responsive to issues identified in the radiological protection information reported to the The Radiological Control Department has instituted a " Rad Con Daily Surveillance Report" form. A radiological control foreman gathers the required information, completes the form, and distributes the form on a daily basis. This is a mechanism to ensure that radio-logical control supervision are made aware on a daily basis of the following:

deficiencies observed in frisking practice;

audit status of radiological work permits (RWPs) and radio-logical access control permits (RACPs);

! personnel skin / clothing contaminations; i personnel failing to log off RWPs/RACPs;

abnormal air sample results;

personnel exceeding administrative dosimeter limits; abnormal radiological conditions;

abnormal radiation monitoring system readings; i

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abnormal levels detected during laundry monitoring; and

lost keys (radiation barriers).

The development and use of this mechanism indicates an increased effort by radiological control supervision to perform their review and oversight functio .2 Unit 2 A licensee representative stated that interdisciplinary working Group N of the Operational Readiness Review Team (0RRT) has continued to meet onca every two weeks. The radiological control group is represented in this working group. The inspector verified that the licensee is tracking progress on the list of radiological protection-related open items (items based on differences between the two units and on changes due to dual-unit operation). In addition, the licensee has instituted a Digital Radiation Monitoring System (DRMS)

interdisciplinary task force due to this system's high priorit This group meets once a month and has developed a separate open items checklist for tracking progress on the DRMS. There are also plans to form an ALARA walkdown team in the near futur This six person team is to include three radiological control department members and one person each from the engineering, operations, and maintenance department At the time of NRC Inspection No. 86-34, the Radiological Control Department had identified their additional staffing reouirements to support dual-unit operation and had received approval and authori-zation to fill approximately fifty percent of these identified openings. As of this current inspection, only approximately one-third of the current approved and authorized additional positions have been fille .0 Training and Qualification of Personnel (BV-2)

The licensee stated that supervisory radiological control personnel would complete a Unit 1/ Unit 2-system-differences training program (three-day duration). The content of this previously-mentioned training program is to be incorporated into a separate module of the existing radiological control department's continuing education program. The radiological control technicians are to be trained in the system differences through this module in the continuing education program cond eted by the Training Department. Implementation of this training will be reviewed in a future inspectio .0 External Occupational Exposure Control and Personnel Dosimetry (BV-1 and BV-2)

The licensee's program for external occupational exposure control and personnel dosimetry was reviewed against criteria contained in:

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10 CFR 20, Standards for Protection Against Radiation;

Licensee Technical Specification 6.0, Administrative Controls;

L1:ensee Final Safety Analysis Report (BV-2), Section 12, Radiation Protection; and

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation).

The licensee's performance relative to these criteria was determined by:

discussions with licensee radiological protection personnel;

review of applicable licensee documentation;

tours of BV-l's radiologically controlled area and of BV-2's proposed radiologically controlled area; and

observation of radiological work practice Within the scope of thi: review, no violations were identifie .1 Unit 1 The following licensee documentation, procedures, and records were reviewed:

fourth quarter 1986 exposure assessment consisting of tables for:

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RWP exposure by work category

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RACP exposure by work group

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TLD exposure by work group

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1986 person-rem budget sunary;

listing of cumulative individual whole body exposures for 1986;

personnel exposure history report for January 1987;

Radiological Control Manual, Chapters 1 and 2, Standards and Requirements and Radiation Worker Practices, respectively; '

Radiological Control Manual Procedures including:

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RP 2.1 - Area Entry Requirements

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RP 2.2 - Radiological Work Monitoring

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RP 5.1 - Expossre Alitboriza' tion and Contrb 8 m

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RP8.1-RadiologicaYWorkPermit - '

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RP 8.4 - Radological Access Control Permit; and "

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selected Form NRC-4s and -5 ; T During this current inspection, the licensee reported that a large fraction of TLDs had changes in $ heir element correction factorst (ECFs). Thesechanc,esweredetectedafterperforminganannual,EFF verification test on a portion of their TLD Preliminary evalua*

tions indicate th'et personnel who had been assigned these badgesh, would not have esceeded any regulatory dose limits even with the'

most conservative corrections made based on the changes in'these ?,

ECFs. The licensee's final evaluation nf this problem will be reviewed in a future inspectio During NRC Inspect. ion No. 78-22, the licensee's responseto IE Bul-letin No. 78-08, Radiation Levels from Fuel Element Transfer Tuber dated June 12, 1978, was reviewed and the item was closed. The bulletin required the licensee to review the shielding of, access i to, and posting of fuel transfer tube C During this current inspection, follow-up on this matter was I conducted. The licensee's " Transfer Tube and. Area Radiation Survey Data" record for surveys performed on June 7,1986, with associated ,

area maps was reviewed by the inspector. ' The survey rewits indi-cated that two high radiation areas existed inside containment and one outside containment at the following locations: A - containment transfer tube shield (elevation 718'6") (0.1 to 1.0 R/hr), B - leak monitoring room (elevation 722') (2 R/hr), and C - containment (elevation 738') (10 to 20 R/hr). Licensee personnel stated the following: that, at location A, the bottom of the fuel transfer tube shielding is above head-level and that the dose rate readings were taken in contact with the shielding; that access to location B is restricted by a locked radiation barrier; and that the readings at location C were taken with an extendable probe survey instrument in contact with the transfer tube shielding, and the readings obtained at the closest point accessible by personnel were less than fifteen mR/hr. In addition, the licensee stated that, during refuel-ing operations, the only personnel allowed in containment are the refueling crew and radiological control technicians. Physical access, access controls, and posting requirements for the three areas identi-fied will be reviewed in a future inspection.

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The licensee has further defined the layout of a HP access control point (774'6" elevation of the waste handling building) to the main s radiologically controlled area (RCA). This layout includes a RWP/

^ RACP signoff area and an instrument issue locatio t,

Q% The inspector reviewed the following two licensee internal letters:

(1) " Unit 2 RBC High Radiation Area Barriers," dated October 20,

\ 1986, and (2) " Radiological Barriers Outside the RBC," dated g

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October 3, 1986. These letters were based on the Radiological Con-

] 'crol Group's investigation of the need for additional radiological D ' ' p' barriers at Unit 2. The first letter describes twenty-five areas already scheduled to be barricaded and recommends six additional areas to be barricaded within the RBC. The second letter identifies

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forty-one locations outside the RBC where barriers are recommende The provisions implemented for barricading potential locked high h radiation areas (LHRAs) will be reviewed in a future inspectio Thirteen hundred additional self-reading dosimeters (SRDs) have been received. The additional thermoluminescent dosimeters (TLDs), which were ordered, have not yet arrive .0 Internal Exposure Control and Assessment (BV-1 and BV-2)

The licensee's program for internal exposure control and assessment was reviewed agair.st criteria contained in:

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10 CFR 20.103, Exposure of Individuals to Concentrations of Rcdio-active Materials in Air in Restricted Areas

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Regulatory Guide 8.26, " Applications of Bioassay for Fission and Activation Products" ,

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ANSI N343, " Internal Dosimetry for Mixed Fission and Activation Products"

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Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection"

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10 CFR 20.401, Records of Surveys, Padiation Monitoring, and Disposal

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Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations and Assumptions for a Bioassay Program" The licensee's performance relative to these criteria was determined by:

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interviewing selected personnel

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review of Daily Surveillance Reports and individual exposure reports

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review of whole body counting facilities

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review of revised internal procedures Within the scope'of this review, no violations were identifie .1 Unit 1 The licensee has recently ordered two state-of-the-art, high through-put whole body counters (WBCs) - one NaI and one dual germanium uni This equipment will be trailer mounted for support of both plants, greatly enhancing the licensee's in-vivo bioassay capabilitie Within the scope of this review, the following program improvement item was identified. The licensee has outlined in Appendix 7, Part

'I.D, of their Radiological Control Manual, those circumstances under which additional indirect bioassays are required. Since no in-house

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capability exists for these measurements other than tritium, the services of an outside laboratory will be required. The licensee has not identified and audited a specific vendor nor developed procedures for the collection and handling of the indirect bioassay sample The licensee agreed to review this aspect of their bioassay program,

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and this item will be addressed during a subsequent inspectio .2 Unit 2 As stated previously, two WBCs have been ordered and will be used in support of both plant Ventilation system test procedures and results (direction of air flow in plant from areas of Sn, potential airborne radioactivity to areas with higher potential) ile,+ yet to be addresse Preoperational tests are scheduled to begin in March 1987 and will be reviewed in a future inspectio .0 Control of Radioactive Materials and Contamination, Surveys, and Monitoring (BV-? and BV-2)

The licensee'. program for control of radioactive materials and contam-ination, surveys, and monitoring was reviewed against criteria contained in:

10 CFR 20, Standards for Protection Against Radiation;

Licensee Technical Specification 6.0, Administrative Controls;

Licensee Final Safety Analysis Report (BV-2), Section 12, Radiation Protection; and Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation). .- ._ ,

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The licensee's performance relative to these criteria was determined by:

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discussions with licensee radiological protection personnel;

review of applicable licensee documentation;

teurs of BV-l's radiologically controlled area and of BV-2's proposed radiologically controlled area; and

observation of radiological work practice Within the scope of this review, no violations were identifie .1 Unit 1 The following licensee documentation and procedures were reviewed:

selected calibration records for portable survey instruments;

selected dose evaluations for skin contamination incidents;

Radiological Control Manual, Appendix 4, Routine Survey Program;

Radiological Control Manual Procedures including:

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RP 9.1 - Contaminated Area Control

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RP 9.4 - Anti-Contamination Clothing /Use During this inspection, the following matter was reviewed. The licensee had recently returned a Model 848-8 Area Monitor Field Calibrator to Victoreen for recertification. The new calibration certificate, dated November 8, 1986, was not in agreement with the previous July 10, 1974, calibration. A confirmatio.: by the vendor verified the new calibration. The licensee then investigated the impact on previous area monitor calibrations. All GM detectors were biased conservatively by 25-85%. An ion chamber unit (only one is in use) was non-conservatively biased by as much as 33%. The inspec-tor noted that the only Technical Specification Area Monitor, RM-207 (Fuel Pool Area), was a GM unit. This GM unit had been tagged 0. along with the single ion chamber unit, RM-201 (Containment Hi-range), by the licensee upon discovery of the discrepancy. The licensee stated that all monitors will be recalibrate Within the scope of this review, the following program improvement item was identified. The licensee has outlined in Appendix 4 of their Radiological Control Manual the routine survey program for radiation and contamination levels. This document states the pur-pose of these surveys, gives instructions, and specifies areas to be surveyed, map numbers, and survey frequencies, but does not address routine (for trending) airborne radioactivity surveys. The a

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licensee has a general procedure on air sampling and has specific procedures for the operation and calibration of various types of continuous air monitors. The inspector verified that a satisfactory routine air sampling program was being implemented using' continuous air monitors and that records were being kept in a form readily amenable to detecting. trends. However, the lack of specific proce-duralized guidance for the routine air sampling program provides less assurance that this program will continue to be implemented uniformly and consistently than.if it were as proceduralized as the routine radi-

, ation and contamination survey progra The licensee agreed to review this aspect of their routine survey program, and this item will be addressed during a future inspectio The licensee stated that eight new automated friskers had been ordered (four for Unit I and four for Unit 2).

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8.2 Unit 2-The licensee is currently testing the detectors of the DRMS at their

field locations. Preoperational tests and calibrations for the

system are scheduled for March 1987. This area will be reviewed in l a future inspectio None of the additional portable turvey instrumentation ordered has

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been received yet.

. The.Itcensee reported that two new gamma. spectroscopy units had been

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ordered (one for chemistry and one for radiological control).- The -

ordering of four automated friskers for Unit 2 was mentioned

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A security access facility, to be common to both plants, has been constructed. There are four new portal monitors in place in this facility. Applicable procedures and calibrations for these monitors will be reviewed in a future inspectio .0 Facilities and Equipment (BV-2)

Since the last NRC occupational radiation protection inspection, the licensee has further defined items in this area as follows:

a single site issue point for dosimetry is contemplated adjacent to the newly constructed common security access facility;

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locations for a HP counting facility and for additional HP storage  :

space have been allocated (HP counting facility will have gamma spectroscopic capability); and

• locations for clothing change rooms have been identifie ,

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10.0 Maintaining Occupational Exposures ALARA (BV-1 and BV-2)

The licensee's program for maintaining occupational exposures ALARA was reviewed against criteria contained in:

10 CFR 20.1, Purpose;

Licensee Technical Specification 6.0, Administrative Controls (BV-1);

Licensee Final Safety Analysis Report (BV-2), Section 12, Radiation Protection;

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation); and

Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will be As Low As Reasonably Achievabl The licensee's performance relative to these criteria was determined by:

discussions with licensee radiological protection personnel

review of the following licensee documentation:

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Fourth Quarter 1986 Exposure Assessment

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Preliminary 1987 Person-Rem Budget

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minutes of the Nuclear Group ALARA Review Committee (NGARC)

Meetings Within the scope of this review, no violations were identifie .1 Unit 1 Since approximately 1985, the licensee has set annual person-rem goals. In addition, to an annual goal, the licensee also has set a goal of achieving less than 450 person rem (three year running average).

For 1986, the actual person-rem total was 627 versus the goal of 570 person-rem. At the end of 1986, the actual three year running average was 398 versus the goal of 450 person-rem. The licensee stated that the following unplanned outage work, resulting in almost 100 additional person-rem, was responsible for the fact that their 1986 person-rem goal was not achieved:

one hundred percent eddy-current testing on all three steam generators (S/Gs) instead of just one;

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tube expansion work on one S/G; and

work on a loop isolation valve (MOV-591).

Based on this relatively high actual-annual person-rem total recorded for 1986 (627), on the licensee's preliminary budget of 429 person-rem for 1987 (mid-November outage including additional 10 year ISI work), and on the possibility of this mid-November outage extending into 1988, the licensee facen a formidable task in continuing the downward trend in their three year running average for actual person-rem. The licensee's averages for Unit I have been as follows:

Average Annual 3-Yr. Period Person-Rem

- 1982 thru 1984 607

- 1983 thru 1985 428

- 1984 thru 1986 398 The NGARC consists of members from twelve site organizational units and meets quarterly. The inspector noted that attendance at the 1986 meetings seemed low. The licensee stated that, although quorums were always present, sparse attendance had been noted, documented, and was being addressed. Licensee documentation showed that, for eight meetings starting in 1984 and extending well into 1986, only six of the twelve units represented had a 75 percent or greater attendance record. This concern will be reviewed in a future inspectio .2 Unit 2 As noted previously in Section 4.2 of this report, the licensee intends to form an ALARA walkdown team. Guidance and criteria used by this team and the results of its field inspections will be reviewed in a future inspectio .0 Exit Interview The inspectors met with the personnel denoted in Section 1.1 at the conclusion of the inspection on February 13, 1987. The scope and findings of the inspection were discussed at that time.