IR 05000334/1989003

Radiological Controls Insp Repts 50-334/89-03 & 50-412/89-03 on 890130-0203.Major Areas Inspected:Licensee Action on Previous NRC Findings & Planning Preparation for Upcoming Refueling Outage.Licensee Identified Violation Reviewed

ML20235Y935
Person / Time
Site:	Beaver Valley
Issue date:	02/23/1989
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235Y925	List: IR 05000334/1989003 ML20235Y922
References
50-334-89-03, 50-412-89-03, NUDOCS 8903140690
Download: ML20235Y935 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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.l Report No /89-03 50-412/89-03 Docket No I 50-412 License No DPR-66 Priority -

Category C RPF 73 Licensee: Duquesne Light Company One Oxford Center 301 Grant Street PTtTsburgh, Pennsylvania 15279 Facility Name: Beaver Valley Power Station, Unit I and 2 Inspection At: Shippingport, Pennsylvania Inspection Conducted: January 30 - February 3, 1989 I

Inspector: kl M 2 13l'Sl '

R. L. Nimitz, Se'nior Radiation Specialis date Approved by:

-pr/ . SL [W M. Shanbaky, Chief, Fac(lities Radiation ME.3!N date Protection Section Inspection Summary: Inspection conducted on January 30 - February 3, 1989 ( Combined Inspection Report No. 50-334/89-03; 50-412/89-03 )  :

Areas Inspected: Routine, announced Radiological Controls Inspection of the following: licensee action on previous NRC findings; planning and preparation for the upcoming refueling outage at Unit I and Unit 2; audits, assessments and corrective action system; ALARA, radiological controls practices and housekeep-in Results: One licensee identified violation was reviewed with respect to 10 CFR Part 2 criteria for non-issuance of a Notice of Violation. Licensee actions met all criteri Several areas for improvement were identifie G 8903140690 890301 PDR ADOCK 05000334 g PDC l

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I DETAILS 1.0 Individuals Contacted 1.1 Duquesne Light Company J. D. Sieber, Vice President, Nuclear Group W. S. Lacey, General Manager, Nuclear Operations K. D. Grada J.A.Kosmal, Manager,NuclearSafetyManager, Radiological Controls .

M 1 C.E.Ewingle,anager,QADirector, C. Hunke QA Operations V. T. Linnenbom, Corporate Nuclear Chemist R. Vento, Director,' Radiological Engineering D. Kirkwood, Director, Radiological Operations, Unit 1 E. D. Cohen, Director, Radiological Operations, Unit 2 M. Helms, ALARA Coordinator F. J. Lipchick, Senior Licensing Engineer B. F. Sepelak, Licensing Engineer 1.2 NRC J. Beall, Senior Resident Inspector, Beaver Valley Station The above individuals attended the exit meeting on February 3,198 The inspector also contacted other licensee personnel during the course of this inspectio .0 Purpose and Scope of Inspection This inspection was a routine, announced Radiological Controls Inspection.'

The following areas were reviewed:

- licensee action on previous NRC findings;

- planning and preparation for the upcoming outages at Unit I and Unit 2;

- ALARA;

- audits, assessments and corrective action system;

- radiological controls practices and

- housekeepin .0 Licensee Action on Previous Findings (Closed Inspector Follow-up Item (50-334/85-15-01 . Licensee to review adequacy) of the organization used to implement the) respiratory protection program. Licensee to also review the policy allowing personnel to wear a respirator for a specific work activity even though a respirator is not require '

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3 j The licensee enhanced the definition of responsibilities and training, as appropriate, for the various groups involved in implementing the respiratory protection program. The licensee concluded that the organization appears to be functioning adequately with few problems attributed to the number of groups involved in implementing the progra Inspector discussions with the radiation protection supervisor responsible for coordinating the respiratory protection program did indicate that personnel continue to rotate frequently into and out of the groups inspection and issuance of responsible respirators. for Therepair, maintenance,d inspector indicate the frequent rotation of personnel

! has the potential, due to lack of continuity, to result in some program implementation concerns. Licensee personnel indicated this would be reviewed and appropriate action will be take The licensee indicated he intended to honor personnel requests for respirators, on a case by case basis, and allow respirators to be worn during work activities where a respirator was not required. Licensee personnel indicated unnecessary use of respirators was not a problem. The licensee's program was revised to require issuance of respirators to only those individuals who are properly trained and fitte The inspector informed licensee personnel that it was the licensee's prerogative to allow use of respirators by personnel where the . radiological conditions did not warrant the use of respirators. However, the inspector informed licensee personnel that such use could result in additional external radiation exposure to personnel due to extended work time needed to complete a task while wearing a respirator versus when not wearing a i respirator. Licensee personnel indicated this aspect would be reviewed, l The above items are closed. The effectiveness of the respiratory protection program will continue to be reviewed during future inspection .2 Closed ) Inspector Follow-up Item (50-334/88-03-05; 50-412/88-02-02 L(icensee to revise alpha airborne radioactivity sample counting procedu)res to provide for ease in identifying natural alpha emitters such as rado The licensee revised applicable procedures to include steps for recounting of samples to identify natural alpha emitters. This item is close ' ( Closed ) Unresolved Item (50-334/ 88-18-01 NRC to review the circumstances associated with an individual w) earing respiratory protective equipment when his quantitative fit test had expired. Inspector review i indicated the practice was previously permitted by procedures provided allowance was not made for the use of the equipment. The licensee ;

subsequently revised procedures to prohibit use of respiratory protective equipment unless the individual has an up to date fit test. This item is close .4 ( Closed ) Unresolved Item (50-334/88-09-04; 50-412/88-05-02) NRC to review the circumstances associated with an apparent high rate of problems I experienced by personnel using Chemox breathing apparatus.

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Inspector review indicated a 0.86% 15 out of 1739 Chemox ..

issuances was ex Chemox iss)uances)perienced'in and a 2.5% pro was experienced by personnel in 198 problem 1988. Inspector rate revie (blem of the events indicated the principle difficulty encountered was alignment-of the Chemox canister in the. breathing device. Personnel receive training-on canister loading prior to use of the device. This problem was considered inherent in use of the device. The licensee established a respirator problem report to track resolution of identified concerns and i reinstructed personnel in use of the device if warranted. No apparent i health concerns associated with use.of the device was identified. Th ,

. alignment problem principally results in excessive use of the Chemox 1 canisters. The licensee is in the process of phasing out the Chemox

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equipment. This item is close .5 ( Ope Inspector Follow-up Item (50-334/88-03-06; 50-412/88-02-03 Licensee) to establish and implement a Hot Particle Exposure Control )

Program. The licensee established a Hot Particle Exposure Control Progra Appropriate procedures were revised to incorporate exposure control methods. However, inspector review indicated the licensee's program did not incorporate defined.and appropriate survey methods to be used by personnel when that exhibited searching high general for areaand controlling dose rates (hot particles in environments.g., steam

.. Such procedures are to use optimization methods to minimize areas)ial

)otent exposure to hot particle and personnel whole body exposur _icensee personnel stated procedures in this area will be enhanced prior to the unit outages. Licensee enhancements in this area will be reviewed during a subsequent inspectio .6 ( Closed ) Unresolved Item (50-334/88-03-03 NRC to review circumstances-and licensee actions associated with an offs)cale dosimeter inciden During steam generator work activities on January 22, 1988, a worker exceeded his allowable 800 millirem exposure administrative limit and his 1000 millirem pocket dosimeter went-offscale. NRC findings identified during review of the circumstances surrounding this event are discussed in NRC Combined Inspection Report 50-334/88-03; 50-412/88-02.. The inspector's review of the licensee's investigation of this matter indicated the incident represented a licensee self identified violation of Technical Specification 6.11 which requires that radiation protection procedures be '

implemente i The licensee's Radiation Protection Manual, Part II, states in section E.4.C, that " If an individual's authorized exposure (based on dosimeter is insufficient to permit the individual to participate in radiation wor measurements)k without potentially exceeding that the authorizat individual is restricted from radiation areas until a new author granted." Contrary to this requirement, a radiation protection supervisor authorized an individual to make a second half jump into a steam generator even though the individual's remaining ex)osure (based on dosimeter  ;

measurements) was insufficient to permit lim to complete the jump and a new authorization was not obtained. As a result the individual's dosimeter went offscale and the individual exceeded his authorized dose limi +

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The inspector reviewed this matter relative to 10 CFR Part 2, Appendix 1C Section G, Exercise of Discretion andconcluded.thatthelicenseemettbe

.five criteria for non-issuance of,a Notice of Violation. The licensee's corrective actions appear adequate to prevent a recurrence. This unresolved item is therefore converted to a licensee identified violation and closed for administrative-purpose .0 Planning and Preparation for the Upcoming Outage The inspector reviewed the licensee's planning and > reparation in the area of radiological controls for the upcoming outage. Evaluation of licensee performance in this area was based on discussions with personnel and review of documentation. The following areas were reviewed and discussed with licensee personnel:

- work scope;

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organization and augmentation of the staff _to support outage activities;

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assignment of. responsibilities and oversight of outage work activities;

- training; i

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equipment and supplies (e.g., shielding and protective clothing);

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ALARA planning and preparation; and

- licensee actions to preclude recurrence of radiation protection problems, identified during the previous outag Within the scope of this review, no apparent violations were identifie The licensee purchased additional supplies to support the outag Person-loading and organizational charts were under developmen Identified outage work was being pre-reviewed from an ALARA stand poin Within the scope of this review, the following areas for improvement were

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identified:

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Although the licensee obtained additional personnel to perform ALARA on-going job reviews during the outage, only one individual is performing the majority of the pre-job ALARA reviews for outage wor additional Considering personnel to the licensee assist is planning in preplanning for'two should outages, be considere

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Although the Unit 2 outage is about one and one-half months away.the licensee does not have any completed work packages with accompanying ALARA reviews and radiation work permits. Licensee radiation protection personnel indicated no requests for radiation work permits were received, consequently completion of appropriate radiation work permit forms has not begun. The forms provide a basis for the radiological controls and ALARA measures to be implemente ;

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l Licensee personnel indicated aggressive planning via interdepartmental meetings was performed and that no work will be performed without completion of procedure required review .0 ALARA  !

The inspector reviewed selected aspects of the licensee's ALARA Progra Emphasis was placed on licensee planning and goal settin outages at Unit I and Unit 2 and source term reduction.The g for the-upcoming review was with respect to criteria contained in the following:

- Site Administrative Procedure Chapter 22, Nuclear Group ALARA Review Committee

- Site Administrative Procedure Chapter 23, Occupational Radiation Exposure Reduction

- Radcon Procedure 8.1, Radiological Work Permit

- Radcon Procedure 8.4, Radiological Work Permit (Access Control)

- Radcon Procedure 8.5, ALARA Review

- Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Exposure at Nuclear Power Stations Will Be As Low As Is ,

Reasonably Achievable

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Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation As Low As is Reasonably Achievable

- NUREG/CR-3254, Licensee Programs for Maintaining Occupational Exposure to Radiation As Low As Is Reasonably Achievable

- NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power Stations; Study on High-Dose Jobs, Radwaste Handling and ALARA Incentive Within the scope of this review no violations were identified. Inspector discussions with licensee personnel indicates extensive efforts are underway to reduce radiation levels of the primary system The following positive observations were noted:

- The licensee performed a comprehensive review of the sources of Cobalt - 60 in the Beaver Valley Station. The evaluation used information available from the Electric Power Research Institute and serves as a basis for the licensee's Transient Cobalt Control Program which is under developmen l l

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The licensee placed Unit:1 on coordinated lithium / boron chemistry in

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1982. Unit 2 was placed on this same. chemistry:at start-up. The'

clicensee has initiated efforts to operate the units with a higher .

primary water pH. The licensee believes operation at~the the; higher pH will reduce primary system radiation levels through reduction .in crud -

depositio The licensee has initiated' extensive reviews to support a full chemical decontamination of the primary system of- Unit 1. The effort will include decontamination of the reactor vesse The licensee is attempting to maximize removal;of crud and minimize-primar system corrosion through tight primary water chemistry contro s.- Currently the ' licensee does not recycle any water collected-

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The licensee has ordered replacement fuel for Unit I with low l cobalt. content grid straps and fuel debris screen i

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The licensee plans the following work in the Primary Containment to l- reduce long term exposure:

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removal.of unnecessary large and small bore snubbers to reduce exposure sustained during surveillance

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removal;and replacement of resistance temperature detector loops installation of hardpiping to support testing of Loop Stop-

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An estimated 2-3 person months was used during ALARA walkdowns I at Unit 2 to identify areas for potential dose reductio Items fo improvement are addresse The licensee has augmented the ALARA organization with seven additional-individuals to assist in ALARA reviews during the outag ,

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The licensee established a separate outage planning group. The group, among other matters, ensures that necessary support activities are being considered for the main work activit The licensee will construct steam generator work platforms for the Unit 1 steam generators. This will eliminate exposure custained during scaffolding erection to support steam generator work activitie . - _ _ _ _ -

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6.0 Audits, Assessments and Corrective Action System The inspector reviewed selected licensee audits and assessments of the Radiation Protection Program. Also reviewed was the licensee's corrective l action system. The review was with respect to criteria contained in l

Technical Specification 6.5.2.8, Audits and applicable licensee procedure The following documents were reviewed:

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Radiological Controls Audits for the past 18 months

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Audit BV-C-87-16, Calibration and Documentation

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Audit BV-1-87-27, Monitoring and Control, dated June 30, 1987

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Audit BV-C-88-22, Monitoring and Control, dated July 14, 1988

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Audit BV-C-88-42, Calibration and Documentation, dated January 10, 1989

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Audit BV-C-88-09, Radwaste Handling, dated, April 8, 1988

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Audit BV-C-88-13, Training and Qualification, dated June 2, 1988

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Audit BV-C-88-49, Technical Specifications, dated December 27, 1988

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Miscellaneous surveillance Within the scope of this review, no violations were identified. Audits were considered to be thorough relative to verification of procedure compliance. The following positive observations were noted:

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Open items including NRC open items are reviewed periodically by a .

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subcommittee of the Operations Review Committee (ORC .

- The Radiological Controls Group established an open i) tem tracking system. All internal and external action items assigned to radiological controls are tracke The radiological controls group is developing a mechanism to track and sort findings to improve ease of reporting. A root cause j analysis program is being use The licensee performed an indepth review of the most recent Systematic Assessment of Licensee Performance (SALP) Report and implemented actions to address areas for improvement identified therei The following areas for improvement were noted:

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Utilize technical specialists when performing audits of activitie Review of the last five radiation protection audits indicated an individual with some limited radiation protection expertise was used as a audit team member only onc ._

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Improve audit quality to evaluate performance relative to standard -

industry practices and regulatory requirements. As discussed above, audits were compliance. primarily oriented to verification of verbatim procedure !

7.0 Plant Tour Observations The inspector toured the radiological controlled areas of the plant and l reviewed the following matters:

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>osting, barricading and access control, as appropriate, to radiation 11gh radiation areas;

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control of radioactive and contaminated material;

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personnel adherence to radiation protection procedures and good radiological control practices; and

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use of personnel contamination control device The review was'with respect to criteria contained in applicable licensee procedures and 10 CFR 20, Standards for Protection Against Radiatio Within the scope of the above review, no violations were identifie Posting, barricading and labeling of areas and material was commendabl The following areas for improvement were identified:

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The physical arrangement of the Main Radiation Protection Check Point in Unit 2 allows personnel to bypass installed whole body frisker Consequently personnel who have used the friskers and are preparing to exit the radiological controlled area may interface with personnel who have not used the friskers. This could create the potential for cross contamination. The licensee was reviewing this matter and indicated that during an outage personnel would be stationed at the friskers to ensure their use. The inspector noted personnel are required to perform a hand and foot contamination survey prior to use of the device Personnel enter and use the whole body friskers while wearing hard hats although personnel may not wear them at the work location in the radiological controlled area. Consequently the hard hat may shield some low level contamination on the head of personnel. The licensee initiated a review of this matter, i

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Inspector review found personnel using sample counting equipment '

while attempting to hold the sample counting drawer closed with a i lead brick. Also some counting equipment that could generate a high l voltage was being operated with the counting instrument covers removed. The licensee initiated a review of this matte ;

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A drinking fountain was being used by personnel in the radiological controlled area of Unit This was considered a poor practice. The licensee initiated a review of this matte The inspector observed personnel processing paper work at the Unit I radiation work permit office pass the paper work back and forth across the radiological control boundary with out frisking it. The licensee initiated an immediate review of this matte The licensee had setup some frisker stations at Unit 2 outdoors outside the radiological controlled area (RCA . Consequently personnel had to exit the RCA, traverse a shor)t distance in the non-RCA, then use the frisker to check for personnel radioactive contamination. This was considered a poor practice with the potential to contaminate small areas of the facility pavement. The licensee initiated a review of the status of previous work requests which were generated to allow placement of the stations inside the RC Inspector observation of on-going radiological work activities and implementation of. radiation work permits indicated that radiation protection technicians are permitted to make in-field changes of the permits based on changing radiological conditions. The inspector indicated this was a questionable practice in that radiation protection supervisors were not afforded the opportunity to review the adequacy of the changes prior to their implementation, particularly for radiologically significant work activities. The licensee's Manager, Radiation Protection concurred in this observation and indicate the practice would be reviewe .0 Housekeeping The inspector toured the station periodically during the inspection.

l housekeeping was reviewed during the tours. The following was noted:

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The licensee placed decontaminating andsignificant effort painting the Unitin 1cleaning, facility. The inspector noted a substantial improvement in the facilities appearance as l compared to previous visits. Licensee efforts in this area were noteworthy. Station contaminated areas were noted to be less than 2%

of the radiological controlled area (excluding containment).

The following areas for improvement were noted:

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The Unit 2 facility radiological controlled area exhibited a dusty and dirty appearance. The inspector noted protective clothing such as cotton glove liners stuffed above instrument racks, apparent dust cloths wedged between small bore piping, and apparent old drawings stuck behind I-beams.

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The inspector noted some examples of graffiti at both Unit I and Unit

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2. The Unit 1 example was written on a freshly painted surfac The ins ector identified some discarded' candy wrappers in the radiolo ical ~ controlled areas ( RCA ) at Unit I and Unit 2 indicatin potenti 1 ingestion of food in the RCA, a violation of licensee work rule Licensee personnel indicated the above matters would be reviewe .0 Exit Meeting The inspector meet with licensee representatives denoted in section 1 of-this report on February 3, 1989. The inspector summarized the purpose, scope and findings of the inspection. No written material was provided to the license _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _