ML19327B500
| ML19327B500 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/13/1989 |
| From: | Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19327B499 | List: |
| References | |
| 50-334-89-21, 50-412-89-20, NUDOCS 8910310316 | |
| Download: ML19327B500 (10) | |
See also: IR 05000334/1989021
Text
y
. ,
.
% _
-
-
.
. . .
,
-
.
,rg.
[
s
,-
,
i
'
L
U.S. NUCLEAR REGULATORY COMMISSION
b
REGION I
{
.
Report Nos.
50-334/89-21
'
{
50-412/89-20
h
Docket Nos.
50-334
50-412.
- .
Category
C
I'-
License Nos.
Priority
-
NPF 73
_
' Licensee:
Duquesne Light Company
4
One Oxford Center
301 Grant Street
Pittsburgh, Pennsylvania 15279
Facility Name:
Beaver Valley Power Station, Unit 1 and 2
Inspection At:'
Shippingport, Pennsylvania
' Inspection. Conducted:'
September 25 - October 10, 1989
Inspector: kZ [M/
/v-/f' I f
'
,
P. O'Connell, Radiation Specialist
date
Approved by:
_
et-, a
f a- /7- 8 f
-
W. Pasclak, Chief Facilities Radiation
date
ProtectionSection
Inspection Summary:
Inspect' ion conducted on September 25 - October 10, 1989
'( Combined Inspection Report. No. 50-334/89-21;
1
- l
50-412/89-20 )
)
L
Areas Inspected:
Routine, unannounced inspection of the implementation of the
!
licensee's Radiological Protection Program during the current outage. Areas
,
, reviewed include Organization and Management, Audits and Appraisals, External
l
,
Exposure Control, and Internal Exposure Control.
l
Results: Within the scope of this review two apparent violations and one
.
unresolved item were identified. The apparent violations involved multiple
'
examples of personnel failing to follow radiation protection procedures and a
s
failure to perform an adequate survey. These two apparent violations resulted in
L
a> substantial potential for an exposure in excess of 10 CFP. Part 20 limits. One
item remains unresolved pending licensee final dose evaluation.
p
-
,
8910310316 891026
..
ADOCK 05000334
h'
O
-
.
$
.
F
'
I
.
.
q
"
..
r
r
D_ETAILS
'l.0 Licensee Personnel Contacted
D. Hunkele, Director, QA Operations
- D. Girdwood, Director,diological ControlsRadiological Operations, Unit 1
- J. Kosmal, Manager, Ra
General Manager,ing EngineerNuclear Operations Services
- W.LaceyIck
,
- F. Lipch
Senior Licens
- T. Noonan, deneral Mana er, Nuclear Operations
-
- B. Sepelak, Licensing E gineer
S. Vassello, Director,
icensing
'
- W. Wirth, Industrial Safety
- Denotes those individuals who attended the exit meeting on September 29,
1989.
The inspector also contacted other licensee personnel during the course
'
of this inspection.
2.0 Purpose and Scope of Inspection
,
This inspection was a routine unannounced inspection of the licensee's
implementation of their Radiological Controls Program durin
Unit I refueling outago. The following areas were reviewed:g the current
+
,
Management and Organization,
Audits and Appraisals {rol,
-
,
External Exposure Con
Internal Exposure Control.
3.0 Management and Organization
The inspector reviewed the crganization chart for the Radiological Control
Department. All professional level positions indicated on the organization
Control Department is authorized to have 56 RCTs and)y
chart were staffed. The inspector noted that currentl
vacancies for Radiological Control Technicians (RCTs . The Radiological
currently the licensee
has 37 qualified RCTs. The licensee stated that the number of vacancies is
partially due to the licensee's overtime pay policy for different
.
departments. The licensee also stated that, typically, unexperienced
individuals are hired to fill RCT positions and it takes three years for
these individuals to become fully qualified. Currently the licensee is
employing 13 contractors on a long term basis, to compensate for the
deficit in the number of, licensee RCTs.
,
The inspector reviewed the licensee's staffing levels of contractor RCTs
and Radiological Control Foremen RCF for the Unit I refueling outage. At
the time of the inspection the lic(ense)e had 111 Senior RCTs on-site which
was 12 short of the licensee's outage goal,18 RCF, and 28 Junior RETs.
.
- -..
. . .
-
. . .
.
.
---
-. .
-
.
1
[
l
i
.
.
l m.
,
,
3
-
L
During inspector observation of various work activities in Unit I it
-
appeared that the staffing levels of contractor RCTs were adequate to
i
provide job coverage for outage work activities.
During tours inside containment and observation of work activities inside
containment the inspector noted that the majority of the work inside
containment was conducted under the supervision of contractor RCF. The
inspector reviewed the licensee's outage staffing organization and noted
,
that contractor RCF were directly responsible for in-field radiological
,
control of all steam generator work, nightshift refueling activities, ISI
work, work in the PAB and Auxiliary buildings, and balance of containment
,
work. If a contractor RCF had a problem or a question licensee
Radiol 0 ical Control Supervision was available as Daily Afternoon and
NightshYft Coordinators, however these coordinators did,not routinely
'
provide in-field management oversight of work activities. Based on
6.0 , it appeared that management oversight of work activitie(See Section
ins ector observation of work activities and problems noted
s is an area
whi h needs improvement.
4.0 Audits and Appraisals
The licensee's Quality Assurance Unit conducts three QA audits of the
Radiological Control Program each year. The audits are in the areas of
calibration and documentation, radwaste handling and transportation, and
monitoring and control.
.
A previous NRC inspection identified a weakness in these audits in that the
audits were not being performed by individuals with a background in
'
radiological control principles and practices. In response to this concern,
the licensee is )lanning on having a health physics contractor company
-
conduct the cali) ration and documentation audit which is scheduled far
,
hovember 1989. This audit will include topics such as posting of controlled
I
areas, calibration of survey instrumentation, control of radioactive
L
sources, respiratory protection, and performance and documentation of
l
radiological surveys.
During the inspection the monitoring and control portion of the CA audit
was being conducted. The inspector noted that a licensee Senior fealth
,
Physics Specialist from the Radiological Engineering Department was part of
"
the audit team. These audits will be reviewed during a future inspection.
The inspector reviewed several Radiological Control Supervision
Surveillance Reports. These surveillance re> orts are internal audits of the
Radiological Control and Safety Programs. Tie surveillance reports
'.
L
consisted of observations of on-going work activities in the controlled
l
areas of the plant and overall plant conditions. The majority of
I
surveillance reports reviewed were completed by the Director of
L
Radiological Operations after he conducted routine tours of the plant.
L
Corrective actions a.ppeared to be appropriate for the surveillance report
j
findings.
l
l
l
,
,
I
l'
.. -
.
.- .
--
.
-
t.
I
'
.
,
i
l
L
t
4
1
J
The inspector noted the following weaknesses in the licensee's audit
1
the
program. Audits were not performed of contractor firms to ensure (fo)r
,
accuracy of NRC Form 4's, and (2) appropriate medical evaluations
-
respirator qualification.
These weaknesses are discussed in Sections 5.0 and 6.0 of this report.
5.0 Internal Exposure Control
!
The inspector reviewed the licensee's program for controlling personnel
internal exposures relative to criteria contained in 10 CFR Part 20,
Standards for Protection Against Radiation, and applicable licensee
'
'
procedures.
The following strengths in the licensee's program were noted.
-
'
The inspector reviewed the licensee's Whole Body Counting Data Positive
Results Log and noted that the number of individuals with positive whole
body counts was very low. The inspector also noted that no individual had
.
l
significant intakes of radioactive material.
'
The inspector reviewed the licensee's Maximum Permissible Concentration
(MPC) Hour Assessments for calendar years 1987 through 1989. The licensee
records and tracks exposures based on air sample results which indicate
,
airborne radioactivity concentrations greater than 25 percent of MPC. There
were no instances of individuals exceeding regulatory limits (520
MPC-hours / quarter) or control limits (40 MPC-hours /7 consecutive days). The
inspector noted that the MPC-hour exposures assigned to individuals were-
low and these results were consistent with the whole body count results.
'
The inspector toured the whole body counting facility and reviewed the
quality control charts for the whole body counter in use. Quality control
checks are performed every four hours while the counter is in operation and
l
supervision is notified if a quality control value falls outside the
'
l
licensee's control parameters. The control charts were frequently reviewed
'
by supervision.
'
.
The inspector reviewed respirator issue logs and determined that the
l
licensee's control of the issuance of respirators was adequate. The
l
individual issuing respirators uses a list of respirator qualified
personnel to determine whether or not to issue a respirator to an
>
'
!
individual. The inspector verified that only qualified individuals were
issued respirators.
l
The inspector noted the following areas for improveuent.
h
,
o
i
.-. -
.
.
-
..
-.
..
.
.
i
,
[p3 -
-
F
'
I
o
,
h
'
'
' The inspector reviewed the licensee's Respirator Fit Test Log and
Respirator Issue Log to determine if individuals had the required traininE
and evaluation by a physician prior to wearing a res)irator. The licensee s
Medical Services Section sends a list of personnel w1o are medically
'
restricted from wearing respirators to the Radiological Health Services
!
Department. The' inspector compared this list with the Respirator Fit Test
!
Log and noted that an individual had been fit-tested for three types of
'
respirators approximately three months after a physician pieced him on the
i
medical restricted list. The licensee reviewed this finding and determined
that this occurred when a contractor, using a new type of fit-testing
fit-tested licensee personnel. The contractor's fit-testing
equipment,had been approved for use by the Onsite Safety Committee (OSC
,
The contractor's procedure was inadequate in that it did not require the).
'
procedure
'
contractor to verify that an individual was not on the medical restricted
list prior to fit-testing the individual. Subsequently, the licensee
purchased new fit-testing equipment and implemented their own fit-testing
procedures which require verification of no medical restrictions prior to
fit-testing. The inspector verified that the individual had not been issued
a respirator after being placed on the niedical restricted list and that
l
l:
this was an isolated occurrence. This is an example where additional
l
licensee attention needs to be placed on review of contractor activities
'
and procedures.
,
The inspector reviewed the manner in which the licensee ensures that
!
contractor personnel using respirators have had an annual medical
'
evaluation. The licensee requires contractors to submit a statement
certify 1 g that the contractor's employees have current physicals and are
-
I
l
medicall > fit to wear respirators. The licensee does not require this
certific tion to be completed by a licensed physician. Licensee management
i
I
oversight of this area was considered poor in that the licensee has never
audited contractors to ensure that appropriate medical evaluations are
l
being completed. The licensee stated that they would review this matter.
,
The inspector examined several HEPA units which were being used to minimize
airborne radioactivity concentrations inside containment. The inspector
'
l
noted that the magnahelix gauge on one unit did not appear to be
functioning properly (i.e. less than zero inches of water . On a different
!
L
HEPA unit the magnahelix gauge was reading greater than 3 4 of the scale.
'
The RCT and RCF providing job coverage for these areas in ide containment
of the HEPA unit is performed.ges are not checked when a performance check
stated that the magnahelix gau
The RCF stated that the HEPA unit
perforr1ance check consisted of a dose rate verification, however the RCF
had been given no guidance as to what dose rates on the HEPA would require
action by the RCF. Further training and guidance needs to be given the RCFs
and RCTs regarding the verification of the operability of HEPA units.
6.0 External Exposure Control
The inspector reviewed the licensee's program for controlling personnel
external exposures relative to criteria contained in 10 CFR Part 20,
Standards for Protection Against Radiation, and applicable licensee
procedures.
-
_
_
. .
._
.
e
,
i
'
,
+
r
'
.
6
.
, k
1,
'
'
The licensee provided the inspector with a copy of their National Voluntary
L&boratory Accreditation Program LNVLAP) accreditation renewal, which is
effective until October 1
1990, ihe licensee's dosimetry processing is
accreditedforANSI-N13.llcategoriesIthroughVII
inclusive. The
~
inspectornotedthatthelicenseewasassigningwholebodydosesbasedon
,'
the dose delivered to the lenses of the eyes through a tissue equivalent
absorber having a density of 300 mg/cm^2.
'
The inspector reviewed the licensee's exposure records for individuals
working on the steam generators in order to evaluate if the licensee had
determined the individuals' accumulated occupational whole body doses prior
to permitting the individuals to receive occupational whole body doses
greater than 1.25 rems / quarter. The inspector noted that the licensee did
not have the actual. records of contractor employees' occupational
exposures. Contractor companies provide the -licensee with a completed list
'
(containing the same information as Form NRC-4 of their employees'
occupational doses, but do not provide the lice)nsee with the actual
'
-
records. The licensee stated that they do not audit contractors to ensure
l
that the licensee is given accurate information. The inspector stated that
L
this is another example of the licensee's lack of oversight of contractor
activities.
While reviewing several Unit I outage work activities inside containment,
the inspector identified several examples where individuals were'not
adhering to the licensee's Radeon procedure 8.1 " Radiological Work Permit"
(RWP). Examples include:
A.
Procedure 8.1 requires, in part, in Section 3.3.2.14, that a
Preliminary ALARA Review (RCM Form 8.1 Section 16) shall be initiated
'
and completed by the work party supervisor when the ALARA initiation
values exceed 200 mrem per worker or 1000 person-mrem for the work
party. The inspector identified several RWP work packages;Chemicalincluding
RWP 16266 "RTD Modification", dated 9-5-89 and RWP 16272
-
Decon of A, B C Steam Generators" dated 9-6-89, where the ALARA
initiationvalues,wereexceededand,thePreliminaryALARAReviews
l
L
were not conducted as required.
B.
Procedure 8.1 requires, in part, in Section 2.6 that all RWPs shall
'
be updated to reflect changes or requirements. ihe inspector
[
RWPs were not updated as required. For example,ges were made but the
identified several RWP work packages where chan
l
Modification" dated 9-5-89 was not updated to reflect that workers
were no longer, wearing arm and hand monitors. RWP 16272 " Chemical
L
was not
Decontamination of A, B, C, Steam Generators", dated 9-6 89, face
1.
updated to reflect that workers were no longer wearing full
l-
particulate respirators,
l
l
1
.
.-
.
- .
. -
.
.
.
,
. _ _
i
q.;
l
<ov-
[
'
7
!
'
C.
Procedure 8.1 requires, in part, in Section 3.3.2.11
that Special
Whole-Body / Extremity Monitoring Data (RCM Form 8.1, $ection 13) shall
.
be initiated and completed as required to provide documentation of
non-routine wearing of whole-body exposure monitoring devices. The
inspector identified that on 9 28-89, under RWP 16297 "FOSAR",
'
,
whole-body exposure monitoring devices were repositioned from the
chest area to the arms of workers without RCM Form 8.1, Section 13
being completed as required.
These examples are an apparent violation of Technical Specification 6.11
which requires,d to for all operations involving personnel radiationin part, that procedu
shall be adhere
exposure (50-334/89-21-01).
I
In many instances, based on discussions with several RCTs and RCF it
appearedthattheRCTsandRCFprovidingjobcoverageofworkactivities
inside containment were not aware of the requirements of the controlling
RWP.
,
i.
The inspector noted two other examples indicating that management oversight
of contractors needs improvement,
t
(1)
Most of the licensee's RWPs contain a provision stating "The
cognizant RCF will implement additional radiological controls based
a
on RCM Form 8.1 Section 12, work steps, prework survey and :lob
support surveys". The inspector discussed the meaning of thls
statement with several individuals. Licensee supervision interpreted
.
'
this statement to mean that the cognizant RCF may add radiological
controls to a work activity but not downgrade the controls. Many
1:
contractor RCF stated that they interpreted this statement to mean
that they had the authority to downgrade radiological controls and
that they had done so in the past.
L
(2)
The inspector questioned a discrepancy between posted frisking
i
instructions for personnel coming out of containment. Two signs were
'
posted, one stated that a whole body frisk was required for all
personnel and the other sign stated that a whole body frisk was
required only for personnel exiting a " Zone C" area. The RCT in the
area and a licensee supervisor were of different opinions as to which
i
sign was correct.
6.1
FOSAR Incident
.
The inspector reviewed the circumstances regarding an apparent
administrative overexposure to a contractor working in the Unit I B-2 steam
generator handhole. At approximately 12:30 p.m. on September 28, 1989 an
RCT provided job coverage for five individuals performing Foreign Object
on the B steam generator. Three of these
Search and Retrieval (FOSAR)hed into the steam generator to manipulate
individuals alternately reac
L. '
equipment. The licensee had set an administrative extremity dose limit of
4.0 rem for each of the individuals. The RCT calculated stay times, which
is the amount of time an individual could have his arm in the handhole
without exceeding the authorized dose, based on a September 13, 1989
survey.
1
.
.
.,
_ . - _ , - . .
- - . . . - . ,
.
.-.
.
. -
- -
.
- - -
-
r,
'
1
'.
'e
.
>
.
..
,
>
1
8
That survey. indicated the following exposure rates in the B-2 handhole:
1200
hr at the entrance to the handhole
,
l
3000 m hr at a position 2 inches inside the handhole
12000
hr at a position 6 inches inside the handhole
20000 m hr at a position 20 inches inside the handhole
The RCT evaluated a stay time of 22 minutes based on an average exposure
rate of 10000 mR/hr inside the handhole. The RCT stood at a distance and
timed individual entries. For approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> the workers
alternately reached into the handhole area without checking or having the
RCT periodically check the readings on the workers' self reading pocket
i
dosimeters which were located on the workers' hands and upper arms. At
+
approximately 2:00 p.m., based only on a stay time calculation, the RCT
estimated that two of the individuals were close to reaching their
,
< administrative dose limit. The RCT instructed the workers to stop work and
read their pocket dosimeters. The workers stated that the job was close to
i
being com)leted and that it would only take an additional 1 to 2 minutes to
finish. T1e RCT allowed the work to continue without reading the workers'
L
pocket dosimeters.
The licensee's Radcon Procedure 4.5 " Pocket Dosimeters-Controlling"d
'
requires
in part, in Section 3.3.1, that " dosimeters are to be rea
frequently when working in radiation areas". This is another example of an
apparent violation of Technical Specification 6.11 which requires,d to forin part,
that procedures for personnel- radiation protection shall be adhere
!
i
all operations involving personnel radiation exposure (50-334/89-21-01).
l.
Approximately 20 minutes after the RCT initially told the workers to stop
'
work and check their pocket dosimeters the work was completed. At that time
the RCT read the workers' pccket dosimeters and noted that one individual's
l
extremity pocket dosimeter was off-scale (over 5000 mR). The licensee
~
,
l
subsequently processed this individual's thermoluminescent dosimeter (TLD)
'
-
and determined that this individual received an extremity dose of 10.5 rem.
The licensee's immediate corrective actions included terminating all F0SAR
work,resurveyingtheareainvolved,holdingacritigueregardingthis
issue, and issuing a memo to RCF emphasizing the RCT s stop work authority.
The FOSAR work was conducted under the control of RWP 16297 "F0SAR" which
required continuous radiological monitoring. The licensee's Radeon
Procedure 8.1
Radiological Work Permit", defines continuous monitorin
in Table 3.8.l."1, to mean that " continuous surveillance and awareness of,
L
L
I.
the radiological conditions of the area and the exposure status of the work
'
crew is required".
The RCT providing continuous radiological monitoring for the F0SAR work on
September 28, 1989, did not adequately monitor the exposure status of the
,
L
work crew. This resulted in a worker receiving an extremity exposure of
greater than twice the administrative dose limit. This is another example
of an apparent violation of Technical Specification 6.11 which requires, in
i
part, that procedures for personnel radiation protection shall be adhered
I
o for all operations involving personnel radiation exposure
(50-334/89-21-01).
L
1
l
.-.
.
.
. - -
.
_
.
_
.
,
v
3
,
,
[
.. '
j
-
, -
j
h
i'
,
9
On September 29, 1989 the licensee surveyed the handhole and determined
-
that the expnsure rate at the entrance to the handhole was 2000 mR/hr and
6000 mR/hr two inches inside the handhole. These exposure rates are
approximately twice those indicated on the September 13, 1989 survey. The
exposure rates six~ inches and twenty inches inside-the handhole were the
same as indicated on the September 13, 1989 survey.
On September ~29, 1989 the licensee also constructed a mock-up arm extremity.
to evaluate the radiation fields inside the handhole and what gradients of
exposure would exist for a fully inserted arm. The results of this survey
showed that, with an individual's arm fully inserted, an individual's hand
.(where the extremity /hr. The individua)l'would be in a radiation field of
.
dosimetry is worn
approximately 6600 mR
s arm, above the elbow, at the
'
same time would be in a radiation field of approximately.5650 mR/hr. It did
not a) pear that the licensee was adequately untrolling personnel exposure
for t1is activity based on an administrative limit'of 4 rem to the
extremity because an individual could receive an occupational whole
body dose in excess of regulatory limits (3 rem / calendar quarter) without
exceeding the licensee's administrative control limit.
The inspector stated that it appeared that the licensee did not perform an
adequate evaluation of the radiation hazards prior to initiating the F0SAR
work on September 28, 1989. The licensee's evaluation was inadequate in the
following areas:
'
,
The licensee based stay time calculations on a survey which did not
accurately reflect the radiation levels in the work area. A
subsequent survey showed exposure rates in some areas approximately
twice those indicated on the survey.
The licensee established personnel exposure controls based on an
administrative dose limit of 4.0 rem to the extremities. The licensee
did not establish personnel exposure based on a whole body dose to a
'
worker fully inserting his arm into the handhole.
This is an apparent violation of 10 CFR 20.201(b) which re utres that "each
licensee shall make or cause to be made such surveys as (1 may be
necessary for the licensee to comply with the regulations n this part, and
l-
(2) are reasonable under the circumstances to evaluate the extent of
radiation hazards that may be present" (50-334/89-21-02).
L
The RCT stated that, based on his timing of the workers, the individual
L
whose pocket dosimeter was off scale had his arm inside the handhole for 26
l
minutes. Discussions with the workers and the RCT indicated that the RCT
l
may have incorrectly identified the workers and assigned incorrect stay
'
times for the workers who had their arm inside the handhole. The three
workers were dressed in full sets of protective clothing and had their
,
,
l
backs to the RCT throughout the job evolution and the RCT would have had
'
difficulty distinguishing between the workers.
'
'
l
l-
p
.
-_._.
-
. . . .
. - - .
-
-
. - - -
(m,
.
.
,
i
i
/,
)
- *
.f
.
1
i
'
10
I
.
the three workers had their arms
1
by his calculation,inutes respectively. However, one
The RCT stated that
inside the handhole,for 26, 21
and 18 m
of the workers, the foreman slatedthatheonlyreachedinsidethe
j
handhole for a total time of approximately 7 to 8 minutes.
]
L
Subsequently the licensee reconstructed the work activities and estimated '
l
that the worker whose dosimetry was off scale had his arm inside the
i
,
(
handhole for approximately 46 minutes.
The RCT stated that he repositioned the workers' whole body TLDs to their
I
positioned to record-the highest dose to the whole body, i.y was not
.
upper arms prior to starting the job. However, the dosimetre. it was
positioned above the elbow and may have moved further up the worker's arm.
The licensee is evaluating the individual's whole body occupational dose to
,
l-
' determine if the regulatory limit of 3 rems / calendar quarter was exceeded,
j
This matter is unresolved pending licensee evaluation (50-334/89-21-03).
,
l
The failure of-the licensee to conduct an adequate evaluation of the
!
radiation hazards combined with allowing the workers to exceed calculated
.'
stay times without evaluating their accumulated exposures by reading their
pocket dosimeters, and incorrectly evaluating the period of time each
1
individual was ex)osed, limits.resulted in a substantial potential for an exposure
'
'
l
in excess of 10 C:R 20
l
NRC Inspection Report 50-334/88-03 identified a similar lack of control
- '
l
during significant radiological- operations which resulted in an
administrative overexposure. That inspection noted that a RCF allowed a
worker to re-enter a steam generator with accumulated dose close to the
administrative limit. The worker subsequently exceeded his administrative
dose limit. The licensee revised their procedures for radiological control
i
of primary side steam generator work but did not incorporate those controls
for the secondary side steam generator work.
,
7.0 Exit Meeting
The inspector met with licensee representatives denoted in Section 1 of
i-
this report on September 29, 1989. The inspector summarized the purpose,
scope and findings of the inspection.
.
>
1
M
-
- . - - . .--- .
-
--
- - .
- ---.