IR 05000346/1998007

Insp Rept 50-346/98-07 on 980427-30.No Violations Noted. Major Areas Inspected:Alara Planning & Controls for Eleventh Refueling Outage & Review of Radiation Worker Practices & Recent Events Including Resin Breakthrough

ML20248B189
Person / Time
Site:	Davis Besse
Issue date:	05/26/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248B126	List: IR 05000346/1998007 ML20248B122 ML20248B162
References
50-346-98-07, 50-346-98-7, NUDOCS 9806010210
Download: ML20248B189 (16)

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U.S. NUCLEAR REGULATORY COMMISSION-REGIONlli Docket No: 50-346 License No: NPF-3 Report No:. 50-346/98007(DRS)

Licensee: Centerior Service Company Facility: Davis-Besse Nuclear Power Station Location: 5503 N. State Route 2 Oak Harbor, OH 43449

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Dates: April 27-30,1998

.j inspectors: Ronald A. Paul, Senior Radiation Specialist Nirodh Shah, Radiation Specialist

' Approved by: Gary Shear, Chief, Plant Support Branch 2 Division of Reactor Safety i

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9906010210 990526 PDR- ADOCK 05000346 e PDR ._

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f EXECUTIVE SUMMARY Davis-Besse Nuclear Power Station NRC Inspection Report 50-346/98007

! This was a routine inspection of the as-low-as-is-reasonably-achievable (ALARA) planning and l-

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controls for the 11th refueling outage (RFO11), and a review of radiation worker (radworker)

practices and several recent events including a resin breakthrough from a purification domineralizer, an unescorted entry into a locked high radiation area (LHRA), unanticipated dose rates encountered in the annulus during incore detector pulls, and several contamination events occurring during the removal of steam generator insulation. The licensee's documentation of records required by 10 CFR 50.75(g) were also reviewed.

, . Overall the ALARA planning and controls for RFO11 were good, but some examples of inaccurate or incomplete ALARA planning documentation were identified (Section R1.1).

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. The licensee took appropriate actions to control exposure after workers encountered unexpected, transient, high dose rates in the annulus area during incore detector.

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movement. However, the failure to recognize this condition given known industry history

~ and to establish appropriate controls was an example of a violation of 10 CFR 20.1501(a)(2) (Section R1.2).

• Poor documentation of the ALARA planning for the respiratory protection controls and the failure to evaluate those ALARA controls implemented during the removal of steam generator mirror insulation, constituted another example of a violation of 10 CFR 20.1501(a)(2) (Section R1.3).

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The radiation protection department response to the breakthrough of resin from a purification domineralizer was good. The radiation protection staff effectively evaluated the changed radiological conditions following the resin breakthrough, and controlled access to affected areas without incident (Section R1.4).

. The calibration and maintenance program for area radiation monitors was well implemented. One weakness was identified in that monitor performance data was not I reviewed by the licensee, which may prevent early identification of problems (Section i R2.1).

. The licensee's maintenance of records important for the safe decommissioning of the !

facility, as required by 10 CFR 50.75(g), wa's good (Section R2.2). l l

. One Non-Cited violation was identified for the failure to provide a continuous radiation l

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protection escort prior to allowing an operator to enter an LHRA. The inspectors noted that the corrective actions for this violation were good and designed to prevent recurrence (Section R4.1). ,

. The inspectors observed good radiation protection technician work coverage, control of high radiation areas (HRAs) and LHRAs, and verified that workers were knowledgeable ;

of RP requirements. However, some problems were identified with the licensee's control of contaminated areas and with the control of hoses used in containment 1 (Section R4.2).  !

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Report Details IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Implementation of the 11th Refueling Outaae (RFO11) insoection Scone (IP 83750) -

The inspectors reviewed the as-low-as-is-reasonably-achievable (ALARA) planning and controls for RF011. The inspection consisted of interviews with station personnel, observations of work in progress, attendance at various outage tumover and planning meetings, and a review of station documents.

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Specific procedures reviewed during this inspection were: DB-HP-1901 (revision (re )), " Radiation Work Permits;" DB-HP-1800 (rev. 4), "ALARA Review;" and DB-HP-1901 (rev.1), "ALARA Design Review." Observations and Findings Overall, outage dose was well controlled and ALARA plans were properly documented and implemented. As of April 30,1998, about 83 rem was accrued with slightly over 50% of the outage work completed. The accrued dose was significantly below the to date goal of 121 rem due primarily to less than expected emergent work. For example, unlike previous outages, there were no control rod drives that needed rebuilding and only one snubber failed inspection. This resulted in only about two rem of emergent dose (from steam generator work) compared to an anticipated total of 12 rem. Also -

lower than expected dose rates were encountered during steam generator tube sheet work, resulting from good reactor water chemistry controls since the previous refueling outag Those. outage activities having the greatest dose impact (and their status as of April 30, 1998) were:

• Reactor head dis / reassembly (including O-ring replacement): 13 rem (60%

complete);

a Steam Generator inspection and Testing: 20 rem (90% complete);

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. D-Ring area (including Reactor Coolant Pump (RCP) work) activities: 29 rem (70% complete); and

. Balance of Plant work: 15 rem (50% complete)

Together these activities accounted for about 70% of the outage goal of 168.5 rem. The inspectors observed each of the above activities and noted good use of ALARA controls such as shielding, identified low dose rate areas, teledosimetry and remote camera RP staff activities such as job coverage, challenging workers regarding RP requirements, and controlling containment access were also observed to be good. For

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each of the above jobs, the inspectors verified that the associated radiation work permits (RWPs) were consistent with the respective ALARA plans and were well understood by workers.

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The inspectors confirmed that preplanning for RFO11 was good and included the development of detailed plans for placement and utilization of shielding, scaffolding, video cameras and teledosimetry; incorporated lessons-leamed from RFO10; and included contingency plans for jobs having the highest potential for adverse radiological consequences. Additionally, the inspectors verified that the station ALARA committee had reviewed these efforts and, in particular, the significant RFO11 activities listed abov During attendance at several outage planning meetings, the inspectors observed that the RP staff was appropriately and actively involved in outage job planning and scheduling. Specifically, the inspectors noted that other work groups kept the RP staff appraised of upcoming activities and that the RP staff placed holds on work until radiological controls could be establishe However, there were several examples where the ALARA planning documentation did not meet RP management expectations. Specifically:

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The respiratory protection evaluation for RAP No.1998-5505 (rev. 0) was based on historical results and stated that a revised evaluation (using actual radiological conditions) would be performed prior to the start of the activit However, there was no record of a second evaluation having been performe .

The personal contamination evaluation for RAP No.1998-5401 (rev. 0)

recommended that double PCs be wom during work, but did not specify the basis (i.e., historical results or dose / risk calculation).

. The electronic dosimetry (ED) dose / dose rate alarm setpoint evaluation for RAP No.1998-5301 (rev. 0) stated that the highest and average whole body dose rates were 1040 and 50 millirem / hour, based on plant history, respectivel However, the RAP stated actual dose rates were as high as 8 rem / hour at the manway/ handholds and general area dose rates were between 75-100 millirem / hour. There was no documented evaluation conceming the dose rate discrepancy that the calculated setpoints were consistent with the actual radiological condition Although there were documentation problems, the inspectors verified that the implemented ALARA controls were appropriate. While station procedures were not specific regarding the required ALARA information, RP management expected that information critical for ALARA planning and radiologicaljob histories be documente Failure to meet this expectation was considered a weakness in the ALARA progra The inspectors also noted a lack of documented " Work in Progress Evaluations" for RFO11 work. Station procedure DB-HP-01901 required that RPTs perform evaluations

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to ensure that radiological conditions were within the scope of the RAP (step 6.6.1) and that they be documented on the ALARA review sheet (step 6.6.3). Additional items such as worker efficiency, proper tooling or items delaying work were also expected (but

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not required) to be recorded on these sheets. The inspectors verified that the RPTs were evaluating and recording the required information in the RP logbook, but could not find any associated ALARA review sheet entries. For example, problems with scaffolding / shielding and higher than expected worker man-hours during the early stages of D-ring area work were documented in the logbook, but not in ALARA review sheets. Station RP staff stated that these sheets were typically filled out after the outage based on the recollection of the RP group. However, the inspectors were concerned that this practice may result in some information being forgotten and not documented. The licensee agreed with the inspectors assessment and planned to review the practic Conclusions Overall, the ALARA planning and controls for RFO11 were good, but some examples of inaccurate or incomplete ALARA planning documentation were identified R1.2 Unanticipated Dose Rates Durina Passaae of incore Detectors insoection Scooe The inspectors reviewed the circumstances surrounding an event where workers encountered unexpected, transient, high dose rates in the annulus between the containment vessel and the wall of the shield building during the pulling of incore detector probes. The inspection consisted of interviews with station personnel and a review of documents, Observations and Findinas

During the backshift on April 21,1998, two workers setting up scaffolding in the annulus area received dose rate alarms on their EDs. The workers immediately evacuated the area and contacted the RP group. When a subsequent RP survey failed to identify the cause of the alarm, the workers were allowed to retum but with continuous RPT coverage. After a second dose rate alarm occurred, the RPT measured dose rates ,

between 10-20 rem /hr slong the containment vessel surface. The workers immediately i evacuated the area and the RP group initiated an investigation. The highest dose and l dose rates recorded by the workers EDs were 7 millirem and 532 millirern/ hour, j respectivel '

The investigation identified that the high dose rates were due to the intermittent passage ;

of four activated incore probes. The probes were being pulled from the shielded incore instrumentation tunnel into the water filled incore tank for cutup and disposal. The traversing path between the two shielded locations was adjacent to the annulus work area and was essentially unshielded. Given the transfer length and speed, the licensee determined that the transient, high dose rates would exist for about a 15 second perio .

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Although this was the first recorded occurrence, the licensee believes that it was likely that this condition existed during past outage ,

The annulus area is normally considered a radiation area during the outage and required only minimum RP controls (i.e., EDs, thermolumiscent dosimetry and RAP) to enter. Because the annulus area is also adjacent to the fuel transfer canal, it is controlled as a locked high radiation area (LHRA) during fuel transfer. However, fuel transfer was not occurring during this event, therefore annulus access was not -

restricte Due to the prompt actions by the workers and RP personnel, coupled by the use of EDs and the short duration of the dose rates, the inspectors concluded that a substantial potential for an overexposure was unlikely. It was also unlikely that the probe could become stuck during the transfer, given the short transfer path configuration and the lack of a similar historical occurrence. Additionally, the EDs worn by the workers were set to alarm if the dose and/or dose rate had exceeded 25 millirem and 75 millirem / hour, respectively. The possibility of ED failure was also remote, as each ED was electronically tested prior to us The inspectors also discussed with the licensee, the possibility of this type of event

. occurring before the use of EDs. The licensee believed that prior to 1993-1994 (when EDs were implemented at the station) personnel were not allowed to enter the annulus area. However, RP management was still evaluating this issu Although this type of event had not been observed before at the licensee's facility, there were several, well documented industry events where high, transient dose rates had occurred during incore detector movement. For example, NRC Information Notice 88-63 and associated supplements, document several events involving transient, high dose rates in reactor cavity areas during movement of incore detectors. A similar type of event involving high dose rates in the reactor cavity, had occurred at the licensee's facility during the 1980 The licensee was unable to determine if the annulus had been surveyed in the past during incore detector movement. Discussions with station personnel indicated that a survey might have been performed during the early operating history, but there were no documented results of such a surve Given the industry history, the previous event at the facility and the lack of prior survey results, the inspectors concluded that the licensee had not recognized the potential for ,

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high, transient dose rates in the annulus during incore detector transfer and had not instituted appropriate controls. The failure to evaluate the radiological conditions in the annulus region during incore detector movement was considered a violation of 10 CFR 20.1501(a)(2) which required that licensee's perform such surveys as are necessary to evaluate the potential radiological hazards that may be present. As defined in 10 CFR 20.1003, a survey means an evaluation of the radiological conditions and potential hazards incident to the use of radioactive material or other sources of radiation l (Violation (VIO) 50-346/98007-01a).

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The licensee continued to evaluate this incident and develop corrective actions at the time of this inspection. These actions will be reviewed during a subsequent inspectio Conclusions The licensee took appropriate actions to control exposure after workers encountered unexpected, transient, high dose rates in the annulus area during incore detector movement. However, the failure to recognize this condition given known industry history and to establish appropriate controls was an example of a violation of 10 CFR-20.1501(a)(2).

R1.3 ' High Levels of Contermination During insulation Removal Inspection Scope The inspectors reviewed the ALARA controls and planning for the removal of insulation from the east steam generator (SG) following several minor personal intakes of radiological material. The inspection consisted of interviews with personnel, a walkdown of the work area and a review of applicable documents, Observations and Findinas On April 23,1998, an insulation crew (nine workers) was removing mirror insulation from -

the east SG when they encountered high levels of radioactive contamination ranging from 50 to 500 millirad / hour (smearable), in the form of loose, dusty rust. The workers each wore a full set of protective clothing (PCs; i.e., coveralls, booties, gloves, hood)

. and dust masks, used lapel air samplers to measure breathing zone air concentration and were under continuous coverage by a contract RPT After exiting containment, the workers were discovered to have contamination (primarily in the facial area) ranging from 1000-30,000 corrected counts / minute. Subsequent whole body counting, identified that six workers had small intakes equating to a calculated Committed Effective Dose Equivalent less than 1 millire In 1994, the licensee received a violation for the failure to property evaluate appropriate

- radiological controls for similar insulation removal work. This violation was described in NRC Inspection Report No. 94010, which described several weaknesses in the job ALARA controls and planning, such as the failure to evaluate the use of engineering controls. The inspectors verified that the corrective actions from the 1994 event had been incorporated into the 1998 work and had been discussed with the worker Although the licensee was still evaluating the root cause of the recent event, the inspectors' review identified several problems with the ALARA planning and the communications between work groups. The ALARA respiratory evaluation for this job

. recommended that the initial insulation removal be done in respirators, based on past history and the results of a risk evaluation calculation. However, this calculation was not

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documented and the inspectors could not determine if it had been properly performed and ifits conclusion was valid.

! ' Prior to the job start, RP supervision had relaxed the respiratory protection requirements and required only the use of full PCs, faceshields and dust masks. However, the dust masks were not considered protective devices and were to be worn at worker discretio )

The faceshields were considered the minimum protection against a significant intake or j facial contamination. The decision to relax the requirements was based on heat stress !

concems and an informal (i.e., undocumented) reevaluation of the risk based on actual j radiological conditions. The lack of documentation for this revaluation did not meet RP i management expectations as discussed in Section R During their review, the inspectors noted that no engineering controls were used during i this job.- Licensee ALARA planners stated that the close confines of the work area and the proximity of structural components prevented the effective use of these control The RWP required that workers wear full PCs and other clothing as specified by RP personnel. it also required that the insulation and underlying surface be kept wet, to the extent possible, to minimize the spread of airbome contamination. These controls were discussed at a prejob briefing, which stressed that faceshields were to be worn during -

the jo The contract RPT, who had attended the briefing, believed that he had discretion regarding the PC requirements and the RP controls (i.e., wetting). During the job, the RPT relaxed the requirement for faceshields to alleviate worker discomfort concems and had decided against wetting the SG surface for fear of worker slippage. However, these 'j

' changes were not communicated to RP supervision, resulting in the work being l performed outside the existing ALARA analysis. The RPT was experienced with this j type of work and had encountered similar loose, rusty contamination before, but not of .

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the magnitude identified at the licensee's facility.-'

' The inspectors concluded that the poor documentation of the ALARA planning for the respiratory protection controls and the failure to evaluate those ALARA controls implemented during the job, which differed from those discussed in the prejob briefing or as stated in the RWP, constituted an overall failure to adequately evaluate the potential'

radiological hazards and was another example of a violation of 10 CFR 20.1501(a)(2)

(see section R1.2). (VIO 50-346/98007-01b).  !

i Conclusions Poor documentation of the ALARA planning for the respiratory protection controls and the failure to evaluate those ALARA controls implemented during the removal of steam i generator mirror insulation, constituted another example of a violation of 10 CFR j 20.1501(a)(2).

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R1.4 Resin Breakthrough from Purification Demineralized l

The inspectors reviewed the licen ee's response following the breakthrough of resin l from a purification demineralized. The inspection consisted of plant walkdowns of affected areas, interviews with personnel and a review of RP logbooks and radiological survey result During an April 10,1998, plant shutdown for RFO11, the TS-3 Purification Demineralized apparently experienced damage to its intemals resulting in resin intrusion into the downstream #1 and #2 makeup filters and a loss of letdown flow. Subsequent compensatory, operator actions to restore this flow resulted in the resin being further transferred into downstream piping. Overall, the resin transfer caused an increase in area dose rates in several of the affected area The RP group promptly responded to the event by performing systematic radiological surveys of affected areas and instituting appropriate radiological controls. The inspectors review conclude 1 that the RP response was good and identified no adverse radiological consequences (such as personnel contaminations, etc) from this even The operational aspects of this event will be reviewed by the NRC resident inspectors and documented in their repor R2 Status of RP&C Facilities and Equipment i

R Review of Area Radiation Monitors Insoection Scooe The inspectors reviewed the operation and calibration methodology for the area radiation monitors (ARMS). The inspection included a walk down of some of the ARMS, the calibration facility and equipment, observation of radioactive source condition and a review of procedures, detector operability history, alarm setpoint calculations and calibration and test result Observations and Findings The ARM calibration and maintenance program was well implemented and the monitors were observed to be operable, in good condition and as described in the Final Safety Analysis Report. Calibration and maintenance of the ARMS were performed by the ,

Instrument and Control (l&C) group; however, the RP group maintained control over the radioactive sources used to calibrate the instruments. These sources were traceable to the National Institute of Standards and Technolog The inspectors noted that the RP group does not oversee the implementation of the l&C responsibilities for the ARMS, but does review the associated procedures. The calibration, maintenance, and test methodology was technically sound for those ARMS

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- reviewed during the inspection and the associated alarm setpoints were in accordance with the station Radiation Monitor Set Point Manual. In June 1996, the licensee discovered that some of the standard source devices were not functioning properly, and that there were no requirements for l&C source calibration

frequencies as recommended by American National Standards Institute (ANSI) n N323 " Radiation Protection Instrumentation Test and Calibration." Subsequently, the malfunctioning source devices were repaired and a procedure was developed to require triennial source decertification under the oversight of the RP group. The inspectors observed that these source devices were operable and identified no problems with the associated decertification and repair dat However, the inspectors noted that instrument performance was not trended by the

~ licensee. Specifically, while a performance history sheet was maintained for each ARM, i

there was no formal requirement for either the l&C, system engineering or RP groups to track, trend and review this data, in particular, when "as found" or "as left" tolerance limits were exceeded on subsequent occasions. The inspectors considered this a program deficiency, as not performing this review may prevent early identification of instrument problems. This was discussed with the licensee who planned to review this matte Conclusions The calibration and maintenance program for ARMS was well implemented. One deficiency was identified in that monitor performance data was not reviewed by the licensee, which may prevent early identification of problem . R2.2 ' Documentation of Past Radiological Events The inspectors reviewed the licensee's documentation of spills or unusual occurrences involving the spread of contamination in or around the facility and corresponding events important to the safe and effective decommissioning of the facility, as required by 10 CFR Part 50.75(g).

The licensee's Regulatory Affairs staff maintained a file describing the various deposits of contaminated soil within the controlled areas of the station. The file appeared l complete and as of May 30,1997, a total of 4 events were documented. The  ;

documented areas included the station settling pond, soil contaminated by a spill of l radioactive liquid caused by a corroded / broken pipe, soil contaminated by a spill of radioactive liquid caused by poorly attended leaky valve, and soil contaminated outside the auxiliary building due to a leakage from auxiliary vents and drain The inspectors' review concluded that the licensee was correctly implementing the requirements of 10 CFR 50.75(g).

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R4' Staff Knowledge and Performance in RP&C R4.1 Unescorted Entry into Locked Hiah Radiation Areas (LHRA)

1 Insoection Scone The inspectors reviewed an event where a plant operator was allowed to enter an LHRA without having a continuous RPT escort as required by station procedure no. DB-HP-1109 (rev. 4), "High Radiation Area Access Control." This event was documented in Potential Condition Adverse to Quality Reports (PCAQR) Nos.1998-0734 (dated April 23,1998) and 1998-0738 (dated April 24,1998).

The inspection consisted of plant walkdowns, interviews with station personnel and a review of applicable documentatio Observations and Findinas On April 22,1998, a contract RPT allowed an operator to perform routine rounds in the

1. 2 Emergency Core Cooling System (ECCS) room, an LHRA, unescorted. The #2 i ECCS room, normally a radiation area, was one of the areas affected by the resin event I discussed in section R1.4. This event resulted in a portion of overhead piping (about 20

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feet above the Decay Heat Pump) having dose rates of 3-0 rem / hour at 30 centimeter Access to this area required an individual to step off an adjacent catwalk, onto a nearby tank and cross over onto the affected piping. The contract RPT was responsible for controlling this area until appropriate controls (i.e., locked door) could be establishe The operator was aware of the elevated dose rates and performed his rounds without l

adverse consequence. However, neither he nor the contract RPT recognized that a -

continuous escort was required while inside the LHRA. The event was identified when a station RPT, who retumed to establish the proper controls, questioned the contract RP The contract RPT was subsequently released and the operator was counseled by the RP staf Step 6.2.7 of station procedure no. DB-HP-1109 requires that entries into HRAs greater than 1000 millirem / hour be under the direct surveillance of RP personnel. Based on discussions with RP management, direct surveillance can only be accomplished with a continuous RP escort. Licensee Technical Specification 6.8.1(a) requires that procedures recommended in Appendix A to NRC Regulatory Guide 1.33 (dated November 1972) be implemented. Appendix A, section 7(e)(1) of the subject Regulatory Guide recommends a procedure for access control to radiation areas. The failure to follow the requirements of the above station procedure was considered a violation. However, this non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with SecUon Vll.B.1 of the NRQ Enforcement Poliev (NCV 50-346/97008-02).

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• Conclusions One Non-Cited violation was identified for the failure to provide a continuous radiation protection escort prior to allowing an operator to enter an LHRA. The inspectors noted that the corrective actions for this violation were good and designed to prevent recurrenc R4.2 Plant Walkdowns and Observations of Work Insoection Scone The inspectors performed walkdowns of the Radiological Restricted Area including the turbine building and containment, and observed radworker performance and activities in progres Observations and Findinos-During the walkdowns the inspectors noted good work coverage by RPTs and

. appropriate posting and control of HRAs and LHRAs. While in containment, the inspectors interviewed several workers regarding work site radiological conditions and RWP requirements; no problems were identified. The inspectors also verified that workers were knowledgeable of the proper use of RP established engineering controls for controlling airbome contamination and those requirements for accessing HRA and LHRAs (see section R4.1).

Overall, radworker practices were considered good, but some problems were observed with the control of contaminated areas. Specifically, during several walkdowns of the turbine building and containment, the inspectors observed numerous examples where contamination area boundaries were not properly controlled. For example, the inspectors observed items stored in proximity in the boundaries challenging their effectiveness or actually crossing the boundarL' Of greater concem, was an apparent prevalent attitude among workers that maintaining proper control of these areas was primarily the responsibility of the RP group and not the work crews. Also, during

. interviews with an inspector, a station RPT attributed these problems to a lack of timely walkdowns by the RPT and not the need to reinforce station expectations to the responsible work cre Another concem raised by the inspectors was with the control of hoses in containmen Specifically, during a containment walkdown, an inspector observed that there did not appear to be adequate controls to prevent hoses used in contamir,ated systems from being used in less contaminated or " clean" systems, thereby increasing the potential for cross-contamination. A subsequent licensee review confirmrsd the inspector's observations and identified that this potential had existed for some time, but that fortunately, no cross-contamination events had occurre . _ _ _ _ . __-_ - _ - _ - - -

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Licensee management planned to evaluate the inspectors' concerns regarding contamination area control and the control of hoses used in containment, and to develop the appropriate corrective action Conclusions i

The inspectors observed good RPT work coverage, control of HRAs and LHRAs, and verified that workers were knowledgeable of RP requirements. However, some problems were identified with the licensee's control of contaminated areas and with the control of hoses used in containmen V. Management Meetings X1 Exit Meeting Summary On April 27,1998, the inspectors presented the inspection results to licensee managemen The license acknowledged the findings presented and identified no proprietary informatio _ _ _

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PARTIAL LIST OF PERSONS CONTACTED

- Licensee M. Beier, Manager, Quality Assurance B. Coad, Superintendent RP R. Greenwood, RP Supervisor J. Lash, Plant Manager D. Lickwood, Reguiatory Affairs Supervisor J. Lons, Maintenance Engineering Supervisor R. Scott, Manager, RP and Chemistry G. Wolf, Regulatory Affairs L. Worley, Director, Nuclear ALsurance NBC S. Campbell, Senior Resident inspector LIST OF INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED 50-346/98007-01a VIO Failure to survey annulus area during movement of incore detectors (section R1.2)

50-346/98007-01b VIO Failure to evaluate potential radiological hazards prior to removing steam generator insulation (section R1.3)

50-346/98007-02 NC/ Failure to escort operator performing rounds in Locked High Radiation Area (section R4.1)

LIST OF ITEMS REVIEWED OR CLOSED NOTE: NO ITEMS WERE REVIEWED OR CLOSED THIS INSPECTION

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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable ARM Area Radiation Monitor ECCS Emergency Core Cooling System .

ED Electronic Dosimeter i l

HRA High Radiation Area l&C Instrument and Control ]

l LHRA Locked High Radiation Area NCV Non-Cited Violation ,

PC Protective Clothing PCAQR Potential Condition Adverse to Quality Report RFO Refuelirig Outage RP&C Radiation Protection and Chemistry RPT Radiation Protection Technician RWP Radiation Work Permit SG Steam Generator TS Technical Specification VIO Violation i

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PARTIAL LIST OF DOCUMENTS REVIEWED Radiation Work Permit Nos:

19985502, rev. 0 - Insulation removal and replacement in the east D-ring 19985102, rev. O Remove / replace reactor head ventilation duct and assoc. work 19985103, rev. O Remove / Reinstall reactor head vent line and assoc. work 19985108, rev. O Remove / replace reactor head insulation .

19985116, rev. O Reactor head / vessel inservice Inspection Exams 19985115, rev. O Remove reactor head o-rings and assoc. work 19985113, rev. O Perform Control Rod Drive video inspection and close-out inspection 19985301-5304, rev. 0 East steam generator work (includes eddy current testing)

19985401-5405, rev. O West steam generate work (includes eddy current testing)

19985602, rev. O Insulation removal ar,1/eplacement in the west o-ring 19985020, rev. O Insulation work outside the D-rings and refueling canal 19985505,5605, rev. 0 All work activities associated with Reactor Coolant Pumps 2-1 and 2-2 l

Potential Condition Adverse to Quality Reoort Nos:

1998-0553 (dated 5/1/98) > T 5-3 Purification Demineralized Damage to Internals )

1998-0639 (dated 4/17/98) Shielding of Spent Fuel Pool filter i 1998-0529 (dated 4/13/98) Manual reactor trip due to increasing letdown pressure j 1998-0703 (dated 4/22/98) Momentary high dose rates in reactor annulus  !

Other Documents (as listed)

Intracompany Memorandum from R. Greenwood, Health Physics Supervisor (dated 4/30/98),

" Preliminary Assessment of Transient High Dose Rates in the Annulus" Intracompany Memorandum from S. Slosnerick, Senior Engineer-Nuclear (dated 8/27/98),

" Tenth Refueling Outage Shutdown Chemistry Report" Intracompa y Memorandum from S. Slosnerick, Senior Engineer-Nuclear (dated 12/3/97),

" Radiation Surveys to Support Shutdown Chemistry Control"

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Eleventh Refueling Outage Preplanning Guide (Selected Sections)

' ALARA Committee meeting minutes for 5/28/97,8/28/97 and 12/15/97

' Davis Besse Maintenance Instruction Nos. 3407 and 3408, " Containment High Range Monitor Calibration," and 3416, " Fuel Handling Radiation Monitor Calibration."

Licensee area contamination records for 10 CFR 50.75(g).

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