IR 05000334/1989006
| ML20247D434 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/12/1989 |
| From: | Nimintz R, Pasicak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247D424 | List: |
| References | |
| 50-334-89-06, 50-334-89-6, 50-412-89-06, 50-412-89-6, IEB-78-08, IEB-78-8, NUDOCS 8905250415 | |
| Download: ML20247D434 (7) | |
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l U.S. NUCLEAR REGULATORY CN'" SSION
REGION I
h Report Nos.
50-334/89-06 50-4]E/89-06 Docket Nos.
50-334 50-412
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Category C
License Nos.-
DPR-66 Priority
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NPF 73
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c Licensee:
Duquesne Light Company One Oxford Center 301 Grant Street Pittsburgh, Pennsylvania 15279 Facility Name:
Beaver Valley Power Station, Unit 1 and 2 Inspection At:
Shippingport, Pennsylvania Inspection Conducted:
April 10-14, 1989 Inspector:
R. i.. h3 d SltohCr R. L. Nimitz, Senior Radultion Specialist date f1).
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Approved by:
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W. Pasciak, Criief, f acilities Radiation date Protection Section Inspection Summary:
Inspection conducted on April 10-14, 1989 ( Combined Inspection Report No. 50-334/89-06; 50-412/89-06 )
Areas Inspected:
Routine, unannounced Radiological Controls Inspection during the Unit 2 refueling outage. Areas reviewed included : organization and staffing, training and qualifications, procedures, internal and external exposure controls, licensee action on previous NRC findings; audits, assessments and corrective action system, ALARA and housekeeping.
Results: No violations were identified. Weaknesses were identified in the coordination and control of steam generator work activities, industrial safety and housekeeping.
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DETAILS 1.0 Individuals Contacted 1.1 Duquesne Light Company
- W. S. Lacey, General Manager, Nuclear Operations J.A.Kosmal, Manager,NuclearSafetyManager, Radiological Controls
- K. D. Grada
- D. C. Hunkele, Director, QA Operations R. Vento, Director, Radiological Engineering
- D. Kirkwood, Director, Radiological Operations, Unit 1
- E.D. Cohen [ARACoordinatorDirector, Radiological Operations, Unit 2 M. Helms, A
- F. J. Lipchick, Senior Licensing Engineer
- B. F. Sepelak, Licensing Engineer
- W. F. Wirth, Director, Effluent Controls and Environment
- D. Blair, Director, Radiological Health Services 1.2 NRC
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- S. Pindale,enior Resident Inspector, Beaver Valley StationResident Inspector, Be
- J. Beall S
- The above individuals attended the exit meeting on February 3,1989.
l The inspector also contacted other licensee personnel during the course of this inspection.
2.0 Purpose and Scope of Inspection This inspection was a routine, unannounced Radiological Controls Inspection. The following areas were reviewed:
- licensee action on previous NRC findings;
- radiological controls during the Unit 2 outage ;
- routine radiological controls at Unit 1
- ALARA;
- audits, assessments and corrective action system;
- housekeeping.
3.0 Licensee Action on Previous Findings (Closed) Violation Licerisee did not follow radiological controls procedures (50-334/88-18-02).
3.1 relative to control of air samples. The inspector reviewed this matter relative to the licensee's July 18, 1988 letter to NRC. The licensee adequately implemented the corrective actions discussed in the letter. This item is closed.
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, Closed) Inspector Follow-up Item (50-334/88-03-06; 50-412/88-02-03)t (
3.2 ticensee to implement a program to control personnel exposures to ho nrticles.. The licensee implemented revisions to procedure 2.10 to address at particle controls. Inspector review indicated the licensee's program incorporated defined and appropriate survey methods to be used by aersonnel when searching for and controlling hot p(e.g.cles in environments tlat, steam gener arti exhibited high general area dose rates areas)..The procedures used optimization methods to minimize potential exposure to hot particles and to minimize personnel whole body exposure.
The procedure provides guidance for review, evaluation and control of work locations exhibiting hot particles.
This item is closed.
3.3 (Closed) Unresolved Item (50-334/88-03-04) Licensee to evaluate current practices used for collection of airborne radioactivity air samples for steam generator work. The licensee evaluated the current collection practices and found them to be adequate. This item is closed.
4.0 Organization, Staffing, Training and Qualifications training and The inspector reviewed the organization, staffing,d radiological controls qualification of personnel comprising the augmente organization established to support outage work activities.
Evaluation of licensee performance in this area was based on discussions with personnel and review of documentation. The review was with respect to criteria contained in applicable license and procedure requirements. The following areas were reviewed and discussed with licensee personnel:
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organization and augmentation of the staff to support outage activities; assignment of responsibilities and oversight of outage work
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activities;-
training;
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communications;
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licensee actions to preclude' recurrence of radiation protection
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problems identified during the previous outage.
no violations were identified.
Within the scope of this inspection;s performance in the above areas was Observations indicated the licensee generally adequate. The licensee established a qualification requirement sheet for qualifying radiological controls foremen and technicians hired as contractors. Management attention to ensuring qualified personnel were hired to support the outage was apparent. The following matters were discussed with licensee personnel:
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Communications and coordination of steam generator work needs improvement. A work group was observed performina work activities in a steam generator cubicle while personnel were ex$ ting the steam generator platform areas. This resulted in personnel exiting the highly contaminated areas of the steam generator platform and coming in close contact with personnel performing routine work. This is contrary to licensee general practices. The licensee immediately initiated action to counsel' individuals relative to the identified Concern.
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Although a formal organization chart depicting the augmented radiological controls organization was established and distributed, the responsibilities and authorities of the augmented radiological controls staff was not formally described. Draft responsibilities and authorities were developed but not distributed.
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During inspector tours of the Unit 2 reactor containment at about 4:00 PM on April 11, 1989, the inspector observed and overheard a senior radiological controls technician apparently informing work groups that an NRC inspector was present in the reactor containment building. An October 1988 rule change to 10 CFR 50, specifically 10 CFR 50.70(b)(4), prohibited communicating the presence of NRC inspectors onsite. This is to allow NRC 3ersonnel to observe on-going activities without any apparent clange in job or task performance based on personnel knowledge of NRC inspector presence. The licensee immediately initiated a review of this matter and informed all radiological controls personnel that such notification is not acceptable.
5.0 Audits, Assessments and Corrective Action System The inspector reviewed selected licensee audits and assessments of the Raciation Protection Program. Also reviewed was the licensee's corrective action system. The review was with respect to criteria contained in applicable Technical Specifications and licensee procedures.
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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The licensee's radiological controls group performs a number of surveillance to verify proper program implementation. The findings are reviewed on a generic basis to evaluate potential root causes of identified concerns.
The following areas for improvement were noted:
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Some surveillance reports identified poor worker practices and concerns that potentially resulted in unnecessary radiation exposure.
For example, a surveillance report dated April 4,1989 identified removal of the wrong snubbers in Unit 2 containment resulting in potential unnecessary radiation exposure to workers.
However, copies of the reports were not provided to the radiological controls group for their review. The licensee initiated a review of this matte _ __
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.i 6.0 External and Internal Exposure Controls The inspector toured the radiological controlled areas of the plant and reviewed the following matters:
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posting,- barricading and access control, as appropriate, to Radiation, High Radiation, and Airborne Radioactivity Areas; i
High Radiation Area access point key control;
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control of radioactive and contaminated material;
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personnel adherence to radiation protection procedures, radiation
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work permits and good radiological control practices; use of personnel contamination control devices;
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use of dosimetry devices; use of engineering controls and respiratory protective equipment;
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records and reports of personnel exposure; and adequacy of radiological surveys to support pre-planning of work and
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on-going work.
The review was with respect to criteria contained in applicable licensee-procedures and 10 CFR 20, Standards for Protection Against Radiation.-
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The inshector also reviewed the licensee's evaluations and radiologicalto su i
control review was' wit 1 respect to criteria contained in the following:
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IE Bulletin No. 78-08, Radiation Elements from Fuel Element Transfer l;
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Tubes, dated June 12, 1978; Final Safety Analysis Report Question 471.12, Control of Access' to
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Spent Fuel Transfer Area.
Evaluation of licensee performance in the areas was based on review of documentation and on-going work.
Within the scope of the above review, no violations were identified.
Licensee performance in the above areas was adequate.
The licensee samales and analyzes breathing air quality for
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workers who use areathing air supplied respirators. Inspector review
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of sample data for samples collected to support work on No. 21 Steam
Generator indicated the samples were collected upstream of the breathing air manifold with respect to the actual breathing air lines hooked into. The licensee stated that this practice was done to minimize personnel whole body exposure. The inspector questioned the
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adequacy of this practice. The licensee initiated a review of this i
matter.
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7.0 ALARA The inspector reviewed selected aspects of the licensee's ALARA Program.
The review was with respect to criteria contained in the following:
Regulatory Guide 8.8, Information Relevant to Ensuring that
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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
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NUREG/CR-3254, Licensee Programs for Maintaining Occupational Exposure to Radiation As low As Is Reasonably Achievable
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NUREG/CR-4?C4, Occupational Dose Reduction and ALARA at Nuclear Power Stations; Study on High-Dose Jobs, Raiwaste Handling and ALARA Incentives.
Within the scope of this review no violations were identified. The following area for potential improvement was identified:
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The licensee borated the primary system of Unit 2 toward the end of March 1989 in preparation for refueling the Unit 2 reactor. An apparent unexpected crud burst occurred which resulted in subsequent transport of crud throughout the Unit 2 primary system. This resulted in general area exposure rates near )rimary components increasing by as much as a factor of five. T11s has resulted in an apparent potential for exceeding exposure goals for outage work.
At the time of the inspection the licensee was unable to 3rovide details regarding exact cause for the apparent high crud aurst or the a) parent reasons as to why the clean-up systems were unable to remove tie crud prior to transport throughout the system.
The licensee indicated this matter would be reviewed.
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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 work.
The licensee indicated this matter would be reviewed.
8.0 Plant Tour Observations The inspector toured the radiological controlled areas of the plant. The following matters were brought to the licensee's attention:
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The ins ector identified some discarded candy wrappers in the radiolo ical controlled areas ( RCA ) at Unit 1 and Unit 2 indicating potenti 1 ingestion of food in the RCA, a violation of licensee work rules.
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Numerous pieces of discarded protective clothing and other materials, were identified inside the Unit 2 primary containment.
The inspector identified several individuals working in the overhead
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in Unit 2 containment. The individuals were not wearing safety belts.
The licensee initiated an immediate review of the above matters.
9.0 Exit Meeting The inspector meet with licensee representatives denoted in section 1 of this report on April 14, 1989. The inspector summarized the purpose, scope and findings of the inspection. No written material was provided to the licensee.
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