IR 05000334/1990019

Insp Repts 50-334/90-19 & 50-412/90-19 on 900917-21.No Violations Noted.Major Areas Inspected:Status of Previously Identified Items,Organization & Training,Internal & External Exposure Controls & ALARA

ML20059N467
Person / Time
Site:	Beaver Valley
Issue date:	10/01/1990
From:	Mann D, Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059N466	List: IR 05000334/1990019 ML20059N465
References
50-334-90-19, 50-412-90-19, NUDOCS 9010160015
Download: ML20059N467 (7)

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O.S. NUCLEAR REGULATORY COMISSION REGION I  !

q Report No /90-19 )

50-412/90-19  !

Docket No , I License No DPR-66 RPF73 Category C c

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Licensee: Duauesne Li<aht Company ~ l One Oxford center i'

301 Grant street Pittsburgh. Pennsylvania 15279 ,

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Facility Name: Beaver Valley Power Station. Unit's ,1 and 2- -l Inspection At: Shippinoport, Pennsylvania

. Inspection Conducted: September 17 - 21, 1990 Inspector: b6/ d/

P. O'Connell, Radiation Specialist-1.27-fo date '

b /) M Abri/fo . .$

D. Mann, Radiation Specialist dtte

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t Approved b : L'

hW.~Pasciak,-chief #///#

Facilities Radiation 'date j ProtectionSectIon >

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Ins >ection Summary: Inspection conducted on Se>tember 17 - 21,'1990.-NRC Com)1ned Inspection Report Nos. 50-334/90-19; 5)-412/90-1 Areas Inspected: Routine,. unannounced inspection of the implementation of the l Radiation Protection Program during the Unit 2 refueling outage. Areas reviewed 1 include:.

Internal and Status of Previously External ExposureIdentified-Items, Controls, _and AL ARA... Organization and Training, Results: Within the scope of this review one non cited violation was 1 identified 1

9010160015 901001 )

PDR ADOCK 05000334 '

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. l DETAILS 1.0 Individuals Contacted 1.1 Licensee Personnel

• J. Beltiore Senior Quality Assurance Specialist

, *D. Blair, Director, Radiological Health Services

• D. Canan, Senior Health Physics Specialist  ;

• E. Cohen, Director...Radiolo ical Operations (BV2) '

R. Freund Senior Health Ph sice Specialist  !

• D. Girdwoo;d, Director,. Radi logical Operations (BVI)

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• M. Helms

.*J. Kosmai, Senior Manager, Health HealthPhysics PhyticsSpecialist <

• F. Lipchick, Senior Licensing Supervisor '

R. Pucci q

• D. Roman, Health Physics Specialist

, Supervisor,-Quality Assurance - Maintenance  ;

• D. Sperry, General Manager Nuclear Operations' Services I

• N. Tonet, Manager, Nuclear, Safety

• R. Vento, Director Radiological Engineering i D. Weitz, Senior 'lealth Physics Specialist i 1.2 NRC Personnel

• J. Beall Senior Resident ~ Inspector

• B. Ruland

• P. Wilson,, ResidentChief, RPS Inspector, Beaver 4B,ValleyRegion I , Beaver Valley l l

• Denotes those individuals who attended the Exit Meeting on September 21,  !

1990. . .

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2.0 Purpose  !

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The inspection was a routine unannounced inspection of the implementation of the Radiation Protection krogram during the Unit 2 refueling outag Areas reviewed include: Status of Previously Identified Items Or and Training, Internal and External Exposure; Controls, and AlkRA.ganization .

3.0 Status of Previously Identified Items- 2 (Closed Violation 50-334/89-21-01 Examples of licensee personne1' failing to follo)w radiation (protection proce)dures. These examples included failures.;

ALARA Review forms and failures to'docu) ment non routine wearino ofto update R personnel monitoring devices.: The inspector' verified that~ the Ticensee had I completed the corrective actions as specified in their response letter )

' dated February 15, 1990. The corrective actions included incorporating a- i procedure compliance video tape into the contractor training program...This '

item is close l

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3.2 (Closed) 50-334/89-21-02 Failure to conduct adequate surveys for secondary side steam generator S had completed the corr (e/G? work. The inspector verified that the licenseect9ve ac dated February 15 1990. The corrective actions included: requiring all secondary side S/d foreign object search and retrieval work to be completed through a two inch opening, unless specific Health Physics authorization is

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obtained, develo ing.and implementing a work package and procedure for 1 secondar side 5 G maintenance and inspection work and assigning '

s radiolo cal con oversig[at ofroisignificantquality. assessors to provide btter su outage work. This item is closed. per 1 J

4.0' Organization and Training 1 ector reviewed the staffin levels of both permanent and j The'inskor contrac Health Physics (HP) Tec!nicians. The licensee augmented the HP '

staff with approximately 180 contractors, including 98 Senior HP l 1 technicians and 19 HP Foremen.-During several tours of the facility and 4 i

including S/G tube observing theins pulling and resistance-temperature radiological = job coverage detector for(RTD ~

several work act removal work the  :

cover the ac{ivities.pector observed adequate staffing of During a morning meeting the inspector noted that HPHP Technic .

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Supervision was actively involved in the schecu, ling process for outage wor activitie ,

The licensee also augmented their supervisory oversight. staffing for the >

outage. Six licensee supervisors have been detailed as radiological controls quality assessors for the duration of the outage. An assessor.is scheduled to cover each shift to provide supervisory oversight of- )

radiologically significant activities. The inspector reviewed several of the 'Radcon Quality Assessor Job Review Checklists" and noted-that the -

quality assessors were doing an effective job of ensuring that individuals were in compliance with postings radiation work permits- and t I

procedures. The licensee stated that the use of radiologic al (RWPs),trols con quality assessors will continue during the next refueling outag The inspector noted that the licensee had in place a well staffed ALARA group. ALARA contractors had been brought onsite prior to the start of the-outage with sufficient time to complete the ALARA reviews. The staffing level of the ALARA group resulted in an improvement in ALARA planning. . ,

The inspector reviewed training lesson plans for contractor ' Senior and  !

Junior HP Technicians. The licensee had a well structured program for: -

determining the site specific training needed for contractor HP  !

who had not:previously worked at Technicians. Contractor are given four HPweeks Technicians,ite of s specific training which includes-  ;

the facility,iews procedure rev and examinations and job performance measures. Contractor- '

HP Technicians who had worked at the facility during the previous-18 months are given a two week site specific training course which details recent ~

procedural and programmatic change ,

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L The inspector reviewed selected resumes of contractor HP Technicians and

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verified that-the individuals had sufficient experience to qualify.as Senior HP Technicians in accordance with the licensee's Technical

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Specification .0 Internal and External Exposure Controls I

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ob coverage for several work-The activit inskector es, including observed S/G the maintenance radiologicalan repair work and RTD modification work. The HP Technicians aL1 HP Foremen covering the activities were ,

i knowledgeable of the radiological conditions of.the work and were j i satisfactorily implementing the licensee's radiological controls - ,

procedures. During a previous ins it was noted that the: licensee's- ,

! RWP procedure required the HP Tec1nicians >ection, to spend a significant amount of~ '

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time com)leting paperwork, rather than overseeing the work being conducte it was noted~that the lironson h:d streamlined i During their RWP t11s inspection,

)rocedure to eliminate srme of the duplicate documentation. .It

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appeared t1at HP Technicians now had more time available to oversee work, e rather than complete paperwor l The licensee is in the rocess of of making.significant i rovements in l their radiation protect on pro ram, lhe licensee demonstr ed:their newl '

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stem wil developed be capable computerized RWP sys of generating RWPs em. It is199 by January anticipated:that Long term plans-the sy#or the l system include dose tracking and access contic1. Eq ipment improvements included six. additional. personnel contaminatis mon tors, which were installed during the ins >ection period. The licence also ordered over 100- *

alarming dosimeters whic) should upgrade the licenste's exposure tracking  ;

and monitoring capabilitie ,

In response to a previous NRC concern the licer.see has purchased three l sourcecheckdevices.Thesourcecheckdeviceswillbeusedtoconductthe j daily source checks of portable radiath,r surveying instruments. Currently .J l

the licensee is conducting the daily ' source checks using an enclosed  :

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calibration device. This process is very time consuming.'Using the new  :

I source check devices, it will be easier to conduct daily source checks on the instrument scales used to conduct surveys in High Radiation Area The inspector conducted several. tours of the f0cility and verified that areas generally were properly posted, barricaded or locked as required. The ,

inspector did note that the posted dress out-requirements for access to the ,l containment specified one set of rubber wl'en in practice <two sets ~

were required. The' licensee immediately glovescorrecfedtheposting.Duringthe-first part of the inspection period, the< inspector noted several examples of workers improperly conducting personnel contam'. nation surveys with hand  !

held friskers upon exiting containment. Durina the-inspection period, the licensee installed six additional personnel contamination monitors at'the-exit point from the containment. While the new monitors eliminated the need'

for individuals to use hand held friskers in this area, worker. frisking practices in-other areas needs improvement. Housekeeping throughout the facility was goo ,

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! On September 20, 1990 the inspector noted that the door to-the Unit 2 source room, where radioactive calibration check sources are stored, was i left unattended and unlocked. The sources in the room were stored inside an l open safe. The licensee initiated a survey of the area and found the .

maximum dose rate on the exterior of the safe to be 11 arenVhr and that the  !

room was properly posted. The licensee also conducted an inventory 'of the  ;

sources and could account for all the source j i

The inspector noted that Radeon Procedure 142, " Radioactive Standards )

specifies, in Section 2.4, that all- i Handling

" radioactiveandsource Routine standardsAccountability" are to be stored in locked storage cabinets, J casks, safes, or other approved storage facility." i The failure to lock the source room as required by the procedure was identified as a violation of Technical Specification 6.11 which, requires, in part that procedures for personnel radiation protection be adhered to for all, operations involving personnel radiation exposure.; ~

Prior to the exit meeting, the licensee provided the inspector with:a list'

of corrective actions to ensure that the. radioactive sources be kept locked when unattended. The corrective actions included repairing the door loc The door lock was sticking which made it difficult to close. The licensee also stated that they would place a sign on.the door reminding the HP -

Technicians that the door was required to be locked and that they would inform all the HP Technicians of the incident. The inspector, determined that, due to the minor safety significance and the prompt. corrective >

actions taken by the licensee, this violation met the criteria, specified ,

in 10 CFR 2 Appendix C, V. G., for a non-cited violatio :

(50-412/9019-01) {

The inspector reviewed thegiven personnel ex!osure records oflimits selected f individuals who had been administ ative exposure of greater >

than 1.25 rems per calendar quarter. The inspector verified that the

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liconsee had complete exposure records,. Form NRC-4, for the individuals, '

prior to giving administrative exposure limits greater than 1.25 rems pe .

calendar quarte The inspector reviewed the licensee's program for surveying individuals who ,

alarm either personnel contamination monitors when exiting from the .

radiation controlled areas of the plant or the portal monitors when exiting the plant through the, security building. The licensee has a well defined  :

program for distinguishing be; ween contamination alarms resulting from ~

naturally occurring radon particulate daughters or licensed radioactive material. In addition the licensee provided the inspector with the results of the 1989 and 1990 radon monitoring program, which monitored. areas with'

potential for high levels of radon gas. The results determined that the radon levels in all areas monitored were below the U. S. Environmental Protection Agency's 4 pC1/1 guidelin :

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l 5.1 Contamination of the Fuel Handling Building l

The inspector reviewed the circumstances surrounding a September 15 .1990 l

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containment purge exhaust isolation which resulted in the contamination of .

several cavity reactor elevations of the Fuel15, on September Handling 1990 Buildingthe containme(FHB).nt purge isolation While flooding the ! ,

dampers automatically closed due to a high activity alare on the exhaust i air monitor. The inspector determined that although the licensee did not l evacuate the containment thelicenseetookadequateradiolo  !

protective measures for the individuals inside containment, gical j

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The containment isolation resulted in a positive pressure differential between the containment atmosphere and the ambient atmosphere of the FH '

At the time of the containment isolation the. transfer tube, which connects (

with the. transfer canal = i the reactor located cavity inside located the FHB wasinside open containment,for as required cavity flood up. The . C resulting pressure difference cau,:s ed the water level- to rise above conduit-. 0 penetrations in the transfer canal and onto the floors and floor grating of the FHB. This resulted in the contamination of. severa1' elevations of the FHB. The licensee was still evaluating corrective actions to preclude similar incidents from happening in the future. This item will be reviewed -

during a-future inspectio !

6.0 ALARA l The inspector reviewed the ALARA staffing and >rocedure, Radeon Procedure 8.5, and discussed the pre-outage and outage A. ARA programs with the ALARA-supervisor, foremen, and technician '

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There are only two licensee employees assigned to the ALARA'section for the-outage. However the inspector noted that with the complement of contractor personnel,thedLARAsectionappearedtobewellstaffed. Also,-.four of:  ;

the contractor personnel- were present onsite for several weeks p(three rior to foremen the startand oneoutag of the technician)These fou contractors have repeatedly participated in licensee outages. This provided a knowledgeable staff to perform ALARA reviews for the outag The inspector noted that there was extensive ALARA review of scheduled work  ;

prior to the outage. The ALARA section produced ten weekly Pre-Outage ALARA Progress Reports. These reports categorized the exposure estimate by department and work task. It also provided both preliminary and revised total man-rem estimates-(MRE). The inspector viewed this as a significant ,

strength in the ALARA progra One of the highest MREs for this outage is the RTD Bypass Elimination-project. The inspector reviewed the document entitled "ALARA Exposure ,

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Reduction Techniques Report and ALARA Design Review for DCP 1469.'RTD Bypass Elimination at BVPS2". The report documented the consideration i

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and evaluation of many ALARA exposure reduction techniques. It contained a i a reevaluation of the  :

description techniques, and of arecommendations similar project atforUnit applica1, tion of each technique at Unit {

, 2. The inspector viewed this work as comprehensive and a strength in the ,

ALARA program, i The inspector also reviewed the ALARA section daily report. This report  !

includes: a table of the outage exposure per day; a graph depictin the . -  :

daily and cumulative daily ex>osure for September includina month 1 targets  :

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for September October Novem>er, and December; and a listIno of a 1 activeRWPswIththeir,currentexposure.The:inspectorfeltthatthi ;

provided good exposure. information to plant managers and personne l

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The 1990 yearly exposure goals for both Unit 1 J<75 ren) and Unit 2 (<350" i rem) appeared both reasonable and justifiable. The 1990 yearly exposure ..

at the time of the i targetforbothUnit1(50 inspection appeared attainabl rem).andUnit2-(300res)fatargetexposureis; The determination o *

considered,to be a good licensee initiativ j .

7.0 Exit Meeting  ;

The inspector met with licensee representatives denoted in Section 1.of  !

this report on September 21, 1990. The inspector summarized the purpose, i scope and findings of the inspectio .

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