IR 05000346/1993007
| ML20035G259 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/20/1993 |
| From: | Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20035G256 | List: |
| References | |
| 50-346-93-07, 50-346-93-7, NUDOCS 9304270054 | |
| Download: ML20035G259 (8) | |
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i U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report No. 50-346/93007(DRSS)
License No. NPF-3 j
Docket No. 50-346 l
Licensee: Toledo Edison Company Edison Plaza
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300 Madison Avenue
Toledo, OH 43652
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i Facility Name: Davis-Besse Nuclear Power Station
Inspection At: Davis-Besse Site, Oak Harbor, Ohio
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Inspection Conducted: March 22-26, 1993
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' C Inspector:
R. A. Paul Date/
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Approved By:
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M. C. Schumacher, Chief Date i
Radiological Controls Section 1
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Inspection Summary
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Inspection on March 22-26. 1993 (Recort No. 50-346/93007(DRSS))
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Areas Insoected:
Routine announced inspection of the licensee's radiation i
protection program after the station implemented revised 10 CFR Part 20 during
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i a refueling outage (RF08) including organization and management controls (IP l
83750), ALARA (IP 83750), audits and appraisals (IP B3750), licensee actions
on previous inspection findings, and an LER concerning high radiation area j
controls.
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Results: The licensee's radiological controls program continue to be well l
l conducted. The organizational structure, management. controls, and staffing levels for the program appeared good. ALARA performance was good given the j
size and scope of the outage. A weakness concerning degraded radiological i
controls in the containment during decontamination efforts was identified.
One non-cited violation was issued for an unlocked high radiation area door.
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FDR ADOCK 05000346 G
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DETAILS
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1.
Persons Contacted
- B. Andrews, Associate Auditor, Quality Verification
- L. Bonker, Supervisor, Rcdiological Health
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R. Greenwood, Senior Health Physicist C
- B. Hudson, General Supervisor, Radiological Support
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- D. Hainam, Manager, Engineering G. Honma, Compliance Supervisor, Nuclear Licensing
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- J. Moyers, Manager, Quality Verification
- N. Peterson, Engineer, Licensing
- J. Polyak, Manager, Radiological Controls i
- A. Rabe, Supervisor, QA
- J. Rogers, Manager, Maintenance
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- R. Schrauder, Manager, Nuclear Licensing J. Storz, Plant Manager
- M. Turkal, Engineer, Licensing
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- S. Stasek, Senior NRC Resident Inspector
- K. Walton, NRC Resident Inspector
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The inspector also contacted other licensee and contractor employees.
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- Denotes those present at the onsite exit meeting on March 26, 1993.
2.
General
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This inspection was conducted to review the radiological sontrols and the implementation of the revised 10 CFR Part 20 requirements during a refueling and maintenance outage. Tours of the containment, auxiliary and radwaste building were made to review radiological and contamination controls and worker performance. Auxiliary and containment building access controls were sufficient and it appeared there were adequate
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radiation protection personnel available to provide health physics
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coverage. To reduce total effective dose, many jobs were performed allowing personal intakes. Housekeeping in the containment was generally not good; gloves, tools, face shields, and other personal equipment were observed laying outside step-off-pads and-laydown areas.
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3.
Licensee Action on Previous Inspection Findinas (IP 92701)
(00en) Inspection Follow-Up Item (IFI 50-346/92009-01):
Evaluation of
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containment neutron flux. A licensee contractor performed measurements
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in containment at power of neutron spectral distributions and dose
equivalent rates to provide data useful for dose assessment and
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shielding evaluations.
Dose equivalent rates were determined using l
survey meters, TLDs, and a tissue equivalent proportional counter l
(TEPC); neutron energy distributions were determined using helium-3 i
spectrometers. The average neutron energy at full power (22 to 34 kev)
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was significantly lower than the range (500 to 1000 kev) appropriate to l
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the currently used quality factor of eleven. Also both the survey
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meters and TLDs showed a significant over-response when compared with the TEPC. As a result, the licensee reduced the quality factor used for neutron dose assessment and modified the exposures recorded for individuals who made containment entries at power during 1992. The licensee also requested its dosimetry vendor to use the new quality factor to correct neutron TLD readings and applied survey meter
correction factors. Ilowever, the quality factor selected (2.5) appears too low for the average neutron energies determined. This was discussed with licensee representatives who stated they would review the matter
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and make appropriate changes. This item remains open pending further review at a future inspection.
(0 pen) Deviation from a licensee Commitment (DEV 50-346/92001-03:
Failure to install the SER prescribed detector on the effluent monitoring system in the low-Level Radwaste Storage Facility (LLRNSF),
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and failure to calibrate the installed monitor. The licensee intends to replace the current detector with the prescribed beta scintillator and develop procedures for the calibration of the whole radiation monitoring i
system in 'ii. LLRWSF after the completion of RF08. -In addition, e
i personnel i. ;1ved in the calibration and maintenance of the system will be trained. This matter will be reviewed at a future inspection.
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(0 pen) Inspection Follow-Vo Item (IFT 346/91003-03) and (346/92009-04):
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Final deposition of contaminated soil from a pipe break and a spill of
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reactor coolant water onto the ground. NRR is reviewing this matter and intends to provide guidance in the near future. This item remains open pending the implementation of this guidance.
(Closed) Part 21 report concernino desian deficiency in Eberline model
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AMS-3A Beta Particle Air Monitor. The design deficiency concerned a vacuum relief valve, which if opened under certain conditions, could result in sample flow bypassing the detector while the rotometer indicated flow.
The licensee measured the flow rates on their AMS-3s using a mass flow meter, and found they were within 10% of the
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expected readings.
In addition, they ordered repair kits that Eberline
developed to correct the problem by moving the relief valve to a
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position downstream of the flowmeter. Modification will be completed
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after the current refueling outage and the resident inspector will verify their installation.
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4.
Chances (IP 83750)
The health physics staff has remained stable. Tt.e most significant
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change was the appointment of a new General Supervisor-Radiation Operations and the termination of the Radiological Assessor; no other significant changes were made to the overall administration of the radiation protection program. With the exception of the General i
Supervisor-Radiation Protection, the radiation protection staff appear
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well qualified in accordance with the ANSI N18.1 - 1971 qualification criteria. Although management concluded that the newly appointed
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General Supervisor-Radiation Operation met the qualifications for
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supervisors not licensed by the AEC, NRC evaluation of his experience
indicated a weakness due to his limited commercial nuclear power i
radiation protection experience. This matter was discussed with the
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radiation protection manager who stated that he and other qualified i
members of his staff would continue to provide assistance and oversight until the expected experience level is reached. This matter was l
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discussed at the exit meeting and will be reviewed during a future
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inspection.
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The licensee has continued to encourage and the health physics staff to i
participate in the in-house training program for National Registry of Radiation Protection Technology (NRRPT) certification.
Currently there
are fourteen radiation protection technicians (RPTs) and several staff i
expected to be trained and certified in 1993. Overall, health physics
is sufficiently staffed with experienced ai.d technically qualified
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personnel.
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No violations or deviations were identified.
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5.
Trainina and Oualification (IP 83750)
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The inspector observed members of the staff and contractor radiation protection technicians (RPTs) performing their duties during outage i
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i conditions. Based on these observations, review of training outlines,
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j and discussions with station and contract workers about the quality of
radiation protection training, it appears adequate to prepare
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individuals for_ work during outage conditions.
The adequacy of the
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program was challenged during this outage because of the large number of J
i first time workers and the implementation of the revised 10 CFR Part 20 t
requirements.
Training has been provided to plant and contractor staff
on the revised Part 20 and it appears comprehensive in scope and t
content.
Station procedures and policies affected by the revision have
i been developed and in most cases been implemented.
j No violations or deviations were identified.
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Audits and Acoraisals (IP 83750)
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The inspector reviewed several Quality Assurance Surveillance Reports
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covering audits of the radiation protection program, personal i
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i contaminations, ALARA review and planning, and implementation of ALARA for RF08 under the revised 10 CFR Part 20.
Except for comments on
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weaknesses related to documenting and tracking of personal contamination j
events, the audits indicated good performance overall.
The inspector also reviewed selected aspects of the licensee's implementation of revised 10 CFR 20 and found no significant problems.
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An independent review of revised 10 CFR 20 implementation by a QA
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Department contractor was in progress at the time of this inspection.
The preliminary indications of this review were that the station had developed a good program.
This will be reviewed further in a subsequent
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inspection.
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No violations or deviations were identified.
7.
Licensee Event Report (LER-93-001) Unlocked Hiah Radiation Area Door
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On February 19, 1993, the licensee discovered that the door to the emergency airlock vestibule (door 360), which provides the locked barrier to the high radiation area (HRA) inside containment, was unlocked.
It had been unlocked for about two days after completion of
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technical specification (TS) required surveillance of the containment emergency air lock (CEAL). The plant was in Mode 1 at 73 percent power.
This is a violation of T/S 6.12.2 which requires locked access doors to
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areas where any individual could receive in excess of 1000 mrem in one hour.
Steps were taken to properly control the area.
Followup investigation determined that the door had been closed but not locked after the CEAL
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surveillance but identified no unexpected personnel exposures or unauthorized entries while the door was unlocked.
The investigation also verified that a control room alarm sounded when the CEAL outer door was opened and that approximately eighty security tours during the two days had verified the door as closed. The primary cause of the event was that the individuals who closed the door wrongly assumed that it locked automatically and did not know that a key was needed to lock the
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deadbol t.
After they closed the door they verified it would not open before they left the area; however, it was later established the door
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did not operate freely and required an inordinate amount of force to Open.
Licensee corrective action included training of personnel regarding the specific operation of the lock (deadbolt) on the door, instructions to visually verify the deadbolt is engaged, and installed a sign near the door which instructs individuals to use the key to secure the door lock.
The unlocked door is an example of a violation of TS 6.12 requirements; however, a notice of violation will not be issued for this isolated
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Severity Level IV violation because the criteria specified in Section VII.B of the " General Statement of Policy and Procedures for NRC l
Enforcement Actions," (Enforcement Policy, 10 CFR Part 2, Appendix C)
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were satisfied.
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One non-cited violation was identified.
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8.
External Exposure Control (IP 83750)
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The inspector reviewed a sample of outage radiation work permits (RWPs)
for adequacy and observed work under selected ones to observe their
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implementation. Worker adherence to and understanding of RWP i
requirements was satisfectory.
There was no refueling outage in 1992 and total station exposure was about 20 person-rem. Most of the dose came from containment entries at
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power for containment leakage identification and containment air cooler
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cleaning.
No violations or deviations were identified.
9.
Control of Radioactive Materials and Contamination (IP 83750)
j The contaminated area of the station increased from the preoutage level of about five percent.
In 1992, there were about 45 personal i
contamination events (PCEs). During the first two weeks of the outage the licensee experienced a higher than expected number of PCEs owing mainly to poor work practices by inexperienced workers exacerbated by higher than normal containment contamination levels. The inspector
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noted that after the licensee increased worker and supervisor awareness of the problem, the rate of PCEs decreased to an expected level. Many
PCEs also resulted from licensee approval of reduced protective clothing use in contaminated areas. These measures were taken to improve industrial safety and reduce overall radiation exposure, consistent with i
No problems were noted with these measures and improvements were
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made in response to weaknesses identified in the tracking and trending
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of the PCEs early in the outage.
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No violations or deviations were identified.
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Internal Exoosure Control (IP 83750_1 During this outage the licensee took steps to reduce the total effective dose equivalent (TEDE) by reduced use of respirators.
To evaluate the
potential internal dose they used previous air sample data, and lapel
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air sample data obtained during the current outage. The inspector reviewed the licensee's air sample and analysis program and compared i
assigned derived air concentration hours (DAC-hrs) with in vivo bioassay results for several workers. The program appeared sufficient to
evaluate potential internal dose.
It included guidance on choice of
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instrumentation, sampling location, the environment to be measured, and working conditions. Doses based on air samples tended to be somewhat
lower than doses based on whole body counts but compared well generally.
The licensee expects to continue these comparisons.
One specific job reviewed was the steam cleaning (decontamination) of a steam generator in the east "D" ring.
Based on the pre-job evaluation the work was performed without the use of respirators and the personal intakes of the workers involved with the job were consistent with the evaluation. While the job was in progress, outage management permitted opening of tne containment equipment which resulted in airborne radioactivity from the steam cleaning to contaminate nearby portions of the auxiliary building and minor intakes and contamination of personnel working close by in containment. Radiation protection stopped the job until it was reevaluated and subsequently wrote a condition report.
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poor practice of allowing the opening of the equipment hatch door during i
the decontamination work was discussed with licensee representatives and
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at the exit interview. The inspector was informed that this practice would be evaluated during future work of this nature.
j No violations or deviations were identified l
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As low As Reasonably Achievable (ALARA) (IP 83750)
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There have been no major changes in the overall station ALARA management
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program since the previous inspection. The inspector reviewed ALARA l
program performance and initiatives implemented during RF08.
Some of
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the larger dose contributing work during RF08 (projected to be about
250 person-rem) was control rod drive maintenance, letdown cooler
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replacement, and steam generator activities including sleeving of about 420 tubes, and some emergent work including the steam generator head
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vent repair work.
i ALARA measures used to reduce personal exposure include a new reactor
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head shield, use of dose saving equipment, additional shielding, and i
chemical cleanup of the reactor coolant system at shutdown by lithium
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removal and boration. Addition of hydrogen peroxide and control of
reactor coolant temperature were used to increase solubilization of crud and removal by demineralizers. This initiative was credited with removing about 1100 curies of cobalt-58 but the net effect in dose saving had not yet been determined.
It appeared lessons learned and historical job information, pre-job meetings, and ALARA briefings, were used for planning and implementation of engineering controls and were generally effective for this outage.
As noted in Section 10, the licensee also began a program to reduce, where practicable, the use of respirators and protective clothing in order to allow work in external fields to be done more efficiently and
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quickly and with reduced overall dose (person-rem).
This initiative appeared to have been well planned and was progressing well.
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Exit Interview
The scope and finding of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on March 26, 1993, and discussions were held with licensee representatives concerning neutron spectral analysis on March 31, 1993.
One non-cited i
violation was identified during this inspection. No documents were l
identified as proprietary by the licensee. The following matters were specifically discussed by the inspector.
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Actions taken as a result of the neutron spectral evaluation
(Section 3)
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LER on unlocked high radiation area door (Section 7)
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Implementation of revised Part 20 (Sections 3 and 6)
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The qualification of the General Supervisor-Radiation Protection
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The opening of the containment equipment hatch during
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decontamination work (Section 10)
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