IR 05000412/1987023

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Insp Rept 50-412/87-23 on 870413-17.No Violations Noted. Major Areas Inspected:Status of Previously Identified Items, Organization & Mgt Controls,Training & Qualifications of Personnel & External Exposure Control
ML20214Q048
Person / Time
Site: Beaver Valley
Issue date: 05/21/1987
From: Mcfadden J, Shanbaky M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214Q035 List:
References
50-412-87-23, IEB-78-08, IEB-78-8, IEC-77-14, IEC-79-18, IEC-79-21, IEC-80-14, NUDOCS 8706040218
Download: ML20214Q048 (10)
v • d • e


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N Docket N License No. CPPR-105 Priority -

Category B Licensee: Duquesne Light Company Post Office Box 4 Shippi_ngport, n Pennsylvania 15077 Facility Name: Beaver Valley Power Station, Unit 2 Inspection At: Shippi,ngport, Pennsylvania Inspection Conducted: April 13 - 1L 1987

Inspector: d( ht etwwA- .

T. McFadden, 3enior adiation Specialist SlLllH date

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Approved by: 4 /Z H. Shanbaky I ef,gFaciliti

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Radiation Protection Section Inspection Summar -Ins pection on April 13-17,'987(Inspection _ Report NE $0741278 N23)y:

Areas Inspected: Unannounced occupational radiation protection inspection l during preoperational activities including: status of previously-identified i

items, organization and management controls, training and qualifications of personnel, orternal exposure control, internal exposure control, control of radioactive materials and contamination, surveys and monitoring, and ALARA,

! One regionally-based inspector was onsite for this inspectio Results: No violations were identified. The licensee will be utilizing an existing and experienced radiological controls program and staff, existing and

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tested procedures, and instrumentation and equipment from unit 1 at unit Radiological controls personnel have been assigned at unit 2, have become familiar with the facility, and have initiated procedures unique to unit The Itcensee's schedule for completion of radiation monitoring and ventilation system testing required by technical specifications appears to be adequat Based on these f acts, there appear to be no major impediments for core load in l

the occupational radiation protection are ngp PDR ADOCK 05000412 G PDR

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DETAILS 1.0 Persons Contacted j During the course of this inspection, the following personnel were

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contacted or interviewe !

1.1 Licensee Personnel I

j R. Bernier - Supervisor, Preop Ventilation Testing Group 1 (Stune and Webster Engineering Corporatinn (SWEC))

! *P. Bienick - Assistant Superintendent, Engineering (SWEC-Site Engineering Group (SEG)) ,

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D. Blair - Director, Radiological Health Services '

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(Duquesne Light Company (DLC))

W. Canan - Sr. HP Specialist (DLC)

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  • D. Claridge - Compliance Engineer (DLC)

i E. Cohen - Sr. HP Specialist (DLC)

R. Freund - Rad. Con Foreman (DLC)

, *3. Girdwood - Director Radiological Operations (DLC)

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I *J. Godleski - Sr. Test Engineer (DLC - Startup Group (SUG))

C. Haney - Director, Technical Craf t Training (DLC)

J. Harding - Engineer (DLC-SEG)

D. Hosmer - Operations and Maintenance Instructor (DLC) i

  • J. Johns - Supervisor, QA Surveillance (DLC)  ;

J. Kosmal - Manager, Radiological Control (DLC) i G. Maksin - Radiation Safety Supervisor (DLC) '

S. Moore - Sr. Test Engineer (SWEC)

D. Powers - Ventilation Balancing and Flitration Specialist (SWEC)

-l *L. Rabenau - Lead Compliance Engineer (DLC)

  • R. Vento - Director, Radiological Engineering (DLC)
*K. Winter - Sr. HP Specialist (DLC)
  • R. Wittschen - Licensing Engineer (SWEC)
  • J. Wolfe - Coordinator, QC Commitments (ECI)

i 1.2 NRC Personnel Attending the Exit Interview

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J. Beall - Sr. Resident Inspector

  • L. Prividy - Resident Inspector

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Additional licensee personnel were contacted during this inspection.

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! l 2.0 Purpose l

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The purpose of this inspection was to review the licensee's occupational

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radiation protection program with respect to the following elements:

, Status of previously-identified items

Organization and management controls

Training and qualification of personnel I l

External occupational exposure control and personal dosimetry

Internal exposure control a.1d assessment

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Control of radioactive materials and contamination, surveys, and f

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i Maintaining occupational exposures ALARA 3.0 Status of Previously-Identified __ Items 3.1 (Closed);_ Unresolved Item 86-37-01:

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This item concerned a potential violation of 10 CFR 34.23 which requires positive control over radiographic exposure devices to

] prevent tampering or removal by unauthorized personne q Based on the previous inspection findings (NRC Inspection No. 86-37)

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and on a discussion with a licensee representative during the present '

l inspection, it appears that a radiographic oxposure device was nearly 1 left physically unsecured and not under the direct surveillance of an authorized individual on three separate occasions. Discussion with a  :

licensee representative demonstrated that the licensee was aware of t

! the requirements of 10 CFR 34.23. In addition the inspector reviewed *

i the recent annual training records for the two radiographers involved l l in the potential violation. The inspector verified that both y

I individuals had received annual radiation safety retraining in  !

j February 1986. The training materials provided as part of this j

retraining included a copy of the pertinent section of the NRC l j inspection report which identified this item, i

Based on these findings, this item is resolved and closed.

j 4.0 Organization _an_d Nana_gement__ Controls

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l The Itcensee's organization and management controls for the radiological i j protection function were reviewed against criteria contained in i

j Licensee Draft Technical Specification 6.0, Administrative Controls l

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Licensee Final Safety Analysis Report

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f Regulatory Guide 8.8, Information Relevant to Ensuring that ,

l Occupational Radiation Exposures at Nuclear Power Stations will be  !

As Low As Reasonably Achievable

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l The licensee stated that the following two teams have continued to meet l regularly: the Operational Readiness Review Team (ORRT) and the Digital l

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. Radiation Monitoring System (DRMS) Interdisciplinary Task Force.

, Checklists are used by the licensee for tracking progress against l milestones on preoperational radiation protection program action item Updated checklists for procedure changes and additions, facility modifi-cations, and new equipment and instrumentation were reviewed by the

, inspector. These checklists and discussions with licensee representatives indicated that preoperational activities in preparation for core load are i

almost complet They also demonstrate steady progress is being made on '

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radiation protection action items for initial criticality, startup, and i commercial operation.

. In the area of staffing, some additional progress has been made. The j vacancy for Director of Radiological Operations for Unit 2 is to be l filled within the next several weeks. Several of the approximately ten  !

vacancies for radiation protection technical personnel are slated to be l

! manned in early May 1987. Approximately eighty percent of the additional i

! radiation protection technician positions have been filled. If the i remaining vacancies are not filled by core load and if the licensee j judges that the current manpower resources have to be supplemented j immediately, contracted personnel may be used, i The licensee has continued to .nake the necessary changes and upgrades to

! the Radiological Control Manual. In keeping with the site color-coding i' system, this manual will end up containing predominantly pink procedures (common to both units) with some white (unit 1) and some blue (unit 2)

i procedure The procedures unique to unit 1 or unit 2 address topics j such as sampling of specific waste systems, radiation monitoring systems, and emergency operating procedures. The licensee's checklist indicated

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{ completed or were near completion.

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Within the scope of this review, no violations were identified.

J 5.0 Training _andQuayficationof_ Personnel

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j The licensee's program for training and qualification of personnel was l reviewed against criteria contained in:

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Licensen Draft Technical Specification 6.0, Administrative Controls t

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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant j Personnel"

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The licensee's performance relative to these criteria was determined by:

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discussions with licensee personnel

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review of licensee documentation

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The licensee has identified the following additional training topics which have been addressed or need to be addressed in the near future:

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dose projection methodology (unit 2)

i waste discharge permit procedures (unit 2)

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description of the DRMS (unit 2)

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shift radiological controls technician (SRCT) training (unit 2)

! including: systems different from unit 1 (1 day), description of new radioactive material counting systems (1 day), and SRCT's l responsibilities (0.5 day)

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description of new radiological controls instrumentation and equipment

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radiological controls technician training course (for individuals t

with minimal past training and experience); approximately six j individuals to start this one year program in June 1987

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radiological controls technician training course (for individuals

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with past training and/or experience); approximately six previously

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trained individuals to take this site specific program

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contracted training on maintenace and repair of the DRMS for instrumentation and control personnel (7 days)

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The licensee stated that nearly all the RCTs had completed their rotation through a unit 2 familiarization work assignment and the training for familiarization with the DRMS. The licensee reported that the SRCT training program had been started. The licensee also stated that the seven-day ORMS maintenance and repair training had already been conducted on three separate occassions. The implementation and documentation of

{ these training programs will be reviewed in future inspections.

! Also to be reviewed in future inspections are the following:

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selection criteria for new or promoted radiological controls j personnel versus the requirements of the final technical j specifications (TSs)

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training and qualification in new and/or revised procedures

generated by new instrumentation, equipment, and facilities J

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Within the scope of this review, no violations were identifie .0 External Occupational Exposure Control and Personal Dosimetry The licensee's program for external occupational exposure control and personal dosimetry was reviewed against criteria contained in:

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10 CFR 20, Standards for Protection Against Radiation

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Licensee's Draft Technical Specifications

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Licensee's Final Safety Analysis Report The licensee's performance relative to these criteria was determined by:

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discussions with licensee personnel

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review of licensee documentation

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observations made during tours of unit 2 facilities Since the last inspection, the licensee has further modified the main HP access control point located on the 774' 6" elevation of the waste handling building. These modifications were to facilitiate the issuance of RWPs and portable instruments from this area. The licensee has defined the radiologically-controlled area (RCA) to be serviced by this main control point. Dosimetry issue is to take place at a common issue point starting in late May 1987. Eleven hundred of the thirteen hundred self reading dosimeters (SRDs) received as additional equipment required by unit 2 operation have been receipt inspected, tested, and calibrated according to the license The licensee stated that the four thousand additional thermoluminescent dosimeters (TLDs) have arrived onsite and that receipt inspection is in progress. The licensee also stated that the six additional locked-radiation-barrier doors for inside containment and the thirty-six doors outside containment, recommended by the site radiological controls organization, have been accepted by site managemen These barriers are in addition to the twenty-five locked radiation barrier doors recommended by SWEC for inside containment. The licensee stated that most of the barriers for inside containment were in the final stages of installation and this was confirmed by the inspecto The following items will be reviewed in future inspections:

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access control to a secondary RCA in the safeguards building

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implementation of a common dosimetry issue point

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receipt inspection, testing, and calibration of new SRDs and TLDs

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final installation of locked - radiation-barrier doors

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licensee's evaluation of I&E Bulletin No. 78-08, " Radiation Levels from Fuel Element Transfer Tubes," June 12, 1978 Within the scope of this review, no violations were identifie .0 Internal Exposure Control and Assessment The licensee's program for internal occupational exposure control and assessment was reviewed against criteria contained in:

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10 CFR 20, Standards for Protection Against Radiation

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Licensee's Draft Technical Specifications

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Licensee's Final Safety Analysis Report The licensee's performance relative to these criteria was determined by:

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discussions with licensee and contracted personnel

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review of licensee documentation

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observations made during tours of unit 2 facilities Since the last inspection, the additional recirculating self-contained breathing apparatus (approximately 27 units) have been received on sit The licensee is currently evaluating the feasibility of installing an automated respirator decon/ sanitizing / drying unit. None of the ventilation systems servicing the RCA, control room, or secondary alarm station have received final testing as yet. Licensee representatives

indicated that the ventilation systems required to be operational at core load were on schedule.

,. The following items will be reviewed in future inspections:

receipt of two trailer-mounted whole-body counters scheduled for

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early June 1987; calibration procedures and calibrations of same

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provisions for respirator decon/ sanitizing / drying / testing

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provision. for respirator issue point

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receipt of three portable supplied-breathing-air systems

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numerical adequacy of HEPA-filtered exhaust units

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ventilation system test procedures and results (filter testing and direction of air flow in plant from areas of lower potential airborne radioactivity to areas with higher potential)

Within the scope of this review, no violations were identifie .

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8.0 Control of Radioactive Materials and Contamination, Surveys, and Monitoring The licensee's program for control of radioactive materials and contamination, surveys, and monitoring was reviewed against criteria contained in:

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10 CFR 20, Standards for Protection Against Radiation

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Licensee's Draft Technical Specifications

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Licensee's Final Safety Analysis Report The licensee's performance relative to these criteria was determined by:

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discussions with licensee and contracted personnel

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review of licensee documentation

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observations made during tours of unit 2 facilities Additional instruments and equipment have arrived on site since the last inspection, including two gamma spectrometers (one for the HP counting facility), eight automated friskers (three are in place by the main HP control point), and a large portion of the additional portable instrumentation. Licensee checklists for the status of DRMS and for procedures for the DRMS indicated that the radiation monitors required for core load would be calibrated and operational at that tim The following items will be reviewed in future inspections:

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calibration procedures and results for the DRMS and its monitors I

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numerical adequacy of portable survey meters, counters, air samplers, and friskers; and calibration procedures and results for new types of the same

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completion of the HP counting facility

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calibration procedures and records for the new automated friskers and gamma spectrometers

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calibration procedures and records for the new portal monitors

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completion and stocking of facilities for clothing change and for donning and doffing of anti-contamination garments l i

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licensee's evaluation of the following IE Circulars- l l

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Circular No. 77-14, " Separation of Contaminated Water Systems from Uncontaminated Plant Systems"

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Circular No. 79-18, " Audibility Problems Encountered on l Evacuation of Personnel from High-Noise Areas"

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Circular No. 79-21, " Prevention of Unplanned Releases of Radioactivity"

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Circular No. 80-14, " Radioactive Contamination of Plant Demineralized Water System and Resultant Internal Contamination of Personnel" Within the scope of this review, no violations were identified. '

9.0 Maintaining Occupational Exposures ALARA The licensee's program for maintaining occupational exposures ALARA was reviewed against criteria contained in:

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10 CFR 201, Purpose

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Licensee's Draft Technical Specifications

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Licensee's Final Safety Analysis Report The licensee's performance relative to these criteria was determined by:

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discussions with licensee and contracted personnel

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review of licensee documentation

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observations made during tours of unit 2 facilities l

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Since the last inspection, an ALARA walkdown of the facility was

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conducte The walkdown team consisted of two representatives from l radiological controls and one each from operations, maintenance, and l engineering. The walkdown was perforced utilizing an ALARA checklis ;

The focus of this walkdown was to identify any additional ALARA improve- l ments possible besides the items already documented by SWEC and site  ;

personnel. In addition, the licensee stated that SWEC had completed their i ALARA design review (ADR) of design changes made in the 1982 to 1984 timefram The following items will be reviewed in future' inspections:

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verification of the implementation of pre-fuel load modifications and of operating restrictions recommended by SWEC and accepted by DLC

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documentation of SWEC's ADR of design changes (1982 - 1984)

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documentation of DLC's ADR results

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provisions for photographing plant areas, cubicles, and systems which will eventually become high dose work locations so that these photographs can be used in future job preparation and plannin Within the scope of this review, no violations were identifie . Exit Interview The inspector met with the personnel denoted in section 1.0 near the completion of the inspection on April 16, 1987. The scope and findings of the inspection were discussed at that time. No additional significant findings were identified by the completion of the inspection on April 17, 198 !

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