ML20006E710
| ML20006E710 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/15/1990 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9002260253 | |
| Download: ML20006E710 (8) | |
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' JOHN D. blEDER (I12) 393-5256
' Vice PresstJent
- Noctear Group f E-February 15, 1990-f 1
. U.
S.
Nuclear. Regulatory Commission
~
' Attn:
Document. Control' Desk ni Washington,.DC-20555.-
Reference:
Beaver 7 alley Power Station, Unit No. 1 and No. 2 V
BV-1: Docket-No.f50-334, License-No..DPR-66 BV-2-Docket No. 50-412, License No.LNPF Combined Inspection Report 50-334/89-21 and 50-412/89-20'
- Gentlemen:
'In response to.NRC correspondence dated' January 18, 1990 and in accordance! with110 CFR 2.201, the attached reply addresses the^ Notice 4
of Violation included'with the referenced inspection-report.
I 1:1E there are.any- ' questions = concerning this response, please contact my. office.-
y Very truly yours, h
J. D. Sieber Vice President:
Nuclear Group-j Attachment 1,
- cc:'
Mr. J.
Beall,'Sr. Resident Inspector Mr.'W.
T.' Russell, NRC Region I Administrator j
Mr.
P.' Tam, fur. Project Manager
~
'Mr. R. Saunders (VEPCO)
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9002260253 900215 4
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DUQUESNE LIGHT COMPANY Nuclear Group Beaver Valley Power Station Units 1 & 2 Reolv to Notice of Violation Combined Inspection Report 50-334/89-21 and 50-412/89-20 Letter dated January 18, 1990
-VIOLATION I (Severity Level III, Supplement IV)
Descrintion of Violation (50-334/89-21-02) 10 CFR 20.201(b) requires, in part, that each licensee make or cause to be made such surveys. as may be necessary to comply with the regulations of 10 CFR Part-20.
10 CFR 20.201(a) defines a survey, in-
- part, as an evaluation of the radiation hazards incident to the production,
- use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of-conditions.
When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation present.
10 CFR 20.101 requires that no licensee possess, use,oor transfer licensed material in such a manner as to cause any individual in a
restricted area to receive in a calendar quarter from radioactive material and other sources of radiation a total occupational dose in excess of the limits set forth therein.
Technical Specification 6.11 (Radiation Safety Program) requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20 and shall be adhered to for all operations involving personnel radiation exposure.
Radioactive Work Permit (RWP) 16297, "FOSAR," prepared for Foreign Object Search-and Retrieval (FOSAR) maintenance activities, required continuous radiological monitoring.
Radcon Procedure 8.1 (Radiological Work Permit),
Table 3.8.1.1, defines
" continuous monitoring"- to mean
" continuous surveillance and awareness of the radiological-conditions of the area and the exposure status of the work crew is required."
Contrary to the
- above, on September 28,
- 1989, during FOSAR maintenance activities on the B-2 steam generator (a restricted area),
adequate surveys were not performed to evaluate the radiation hazards present to assure compliance with 10 CFR 20.101 and RWP 16297, as evidenced by the following examples:
1.
For a
period of approximately 1.5
- hours, a
contractor
-Radiological' Control Technician (RCT)
(employed by General Technical Services) responsible for providing continuous radiological monitoring of the FOSAR activity did not check the
-work-crew's self-reading dosimeters to determine their dose accumulation or to determine if the rate of dose accumulation was consistent with the radiological conditions upon which the work crew's stay time was calculated;
J~
,[t -
Nstica to R: ply'of Violation
' Combined Inspection Report 50-334/89-21 and 50-412/89-20
]
'Le.tter dated January 18, 1990 l
Page 2
.yIOLATION I (Continued) 2.
The-RCE did not positively identify and monitor the individual workers in such-a manner so as to ensure that he was able to assign correct stay times for the individual workers while their u
arms were in the B-2 steam generator.handhole; and l
3.
The RCT permitted the work crew members to exceed their
)
calculated stay times established under.the controlling Radiation Work Permit (No.
16297) without reading their pocket dosimeters j
to determine if they had reached their assigned dose limits.
Admission or Denial of Alleaed Violation Duquesne Light Company (DLCo) admits the violation occurred as stated.
Reasons for the Violation The violation occurred as a
result of poor. judgement by the contractor-Radiation Technician in that the direct reading dosimeters were-not read and recorded at a
frequency that related to the exposure rate; "Stop Work" authority was not exercised by. the contractor Radiation Technician; the work-crew did not respond to the request made by. the contractor Radiation Technician. to have the-direct-reading-dosimeters read; and the worker performing the specified task was not positively identified.
Corrective Actions Taken
.Upon discovery of this event, the following actions were taken:
[
Work was immediately stopped and the FOSAR crew was removed from the radiologically controlled area.
i
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All' FOSAR work was terminated on September 29, 1989 at 0800 l
hours.
A fact-finding critique was held September 29, 1989 at 0815 hours0.00943 days <br />0.226 hours <br />0.00135 weeks <br />3.101075e-4 months <br />.
4 A
special outage management meeting was held on September 29, 1989 at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> by the General Manager, Nuclear Operations to discuss and emphasize the importance of supporting and obeying l
all requests made by radiological control personnel.
A radiation survey was performed in the secondary-side of the steam generator in the area directly above the tube sheet where the worker's hand had been located.
L l
N3tici to R3 ply of Violation
- ;ofCombin@d-Inspection Report 50-334/89-21 and 50-412/89-20
.i
- Letter dated January 18, 1990 Page 3 J
A radiation survey was performed in the secondary-side of-the steam generator-in the area immediately inside the 6
inch.
handhole where the worker's upper arm would have been located if the worker's arm had been fully inserted into the steam generator.
s Additional verification radiation surveys were performed in the secondary-side of the steam generator to verify the stability of-the. radiation exposure rates used by the contractor Radiation Technician _for stay-time calculations.
The results from. a TLD
" tree" survey were used to establish' radiation / dose gradients inside the secondary-side steam generator handhole.
Following our review of the circumstances surrounding this event, the J.
following actions were taken:
L A.
secondary-side steam generator-mockup was utilized to develop i
additional radiation survey techniques.
Radiation Work Permit procedure (RCM Chapter 3,
RP.8.1) was L
revised to. incorporate an additional form specifically for tracking. extremity exposures for secondary-side steam generator l
handhole and other similar work.
.The
- Director, Radiological Operations issued a
letter:to all Radiological Control outage management emphasizing "Stop-Work" authority.
Disciplinary action was taken for the contractor Radiation L
Technician involved.
1 All remaining FOSAR work tasks were' completed without further Lincident.
-Action Taken to Prevent Recurrence In order to avoid similar events in the future, we plan to:
l~,
Develop and implement a maint9 nance and inspection control. Work package for secondary-side steam generator work tasks.
+
Require that all FOSAR work tasks be performed through a 2-inch opening to limit access, _unless specific Health Physics and management authorization to work through a
6-inch opening is obtained.
Assign radiological control
" quality assessor (s)"
to provide supervisory-oversight of significant outage work tasks.
L
.r Notic3 to R: ply of Violation l
' ' ~
Combined Inspection Report 50-334/89-21 and 50-412/89-20 LLetter~ dated January 18, 1990 Page 4 Details of this violation will be reviewed with contractor Radiation i
Technicians and have been included in the DLCo Radiological Operations Personnel Continuing Training Program.
Date When Full Comoliance Will Be Achieved The corrective actions that have already been taken ensure that full compliance is-achieved at-the present time.
The additional programmatic corrective actions to prevent recurrence will be implemented by September 1, 1990.
VIOLATION II (Severity Level IV, Supplement IV) t Descriotion of Violation (50-334/89-21-01)
[
Technical Specification 6.11 (Radiation Safety Program) requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20 and shall be adhered to for all operations involving personnel radiation exposure.
1.
Radeon Procedure 8.1 (Radiological Work Permit) Section 3.3.2.11 states that Special Whole-Body / Extremity Monitoring Data (RCM Form 8.1,
~Section 13) shall be initiated and completed as required. to' provide documentation of non-routine wearing of whole-body exposure-monitoring devices.
This record documents the relocation of normal personnel whole body monitoring devices.
l L.
and/or the wearing of multiple whole body devices at different body locations.-
t Contrary to.the
- above, on September-28, 1989, Special Whole Body / Extremity Monitoring Data (RCM Form 8.1, Section 13) was not jn:tiated and completed to provide documentation of non-routine wearing of whcle body exposure monitoring devices.. Specifically, under RWP No.
16297 (FOSAR), whole body monitoring devices were repositioned from the chest area to the arms of the workers and RCM Form 8.1, Section 13-was not initiated and-completed as required.
2.
Radcon. Procedure 8.1, Section 3.3.2.14 states that a Preliminary l
ALARA Review (RCM Form 8.1, Section 16) shall be initiated and completed by the work party supervisor when-the ALARA initiation
(
values listed on RCM Form 8.1, Section 12 are exceeded.
RCM 8.1, J
Section 12 states that ALARA Review is required if the man-rem
)
estimate exceeds 200 mrem per worker or 1000 mrem for the work L
party.
l-l'
1 Notic3 to R ply of-Violation l Combined Inspection Report 50-334/89-21 and 50-412/89-20
' Letter dated January 18,_1990 1
.Page 5 iL VIOLATION II (Continued)
Contrary to the
1989 and RWP 16272 (Chemical Decontamination of A,
B, and C
Steam Generators). dated September' 6,
1989, contained ALARA initiation values that: exceed 200 mrem per worker or 1000 mrem for the work-party, and the Preliminary ALARA Reviews were not initiated and completed by the work party supervisor as required.
3.
Radcon Procedure 8.1, Section 2.6 states, in part, that all RWPs shall be updated to reflect changes or requirements.
Contrary to the. above, on September 26, 1989, RWP work packages were changed and the RWP's were not updated to reflect the changes, as evidenced by the following examples:
.j a.
RWP 16266 (RTD Modification) dated September'5, 1989, was not updated to reflect that workers were no longer wearing arm and hand monitors; and b.
RWP 16272 (Chemical Decontamination of A,
B, C
Steam Generators) dated September 6,
- 1989, was not updated to, reflect.that workers were no longer wearing full face particulate respirators.
Admission or Denial of Alleaed ViolatiSD 1)
Duquesne Light Company admits that RCM Form 8.1, Section 13 was not initiated as required under RWP 16297.
2)
Duquesne' Light Company admits that an RCM Form.8.1 Section 16 was not-initiated or completed by the work party supervisor for.RWP 16266 and RWP 16272.
- However, the intent of the'RCM Form 8.1, Section 16 is to insure that the work party supervisor is involved in the ALARA review of the work evolution.
There is also an RCM Form 8.5, which is used to document a more formal l
ALARA review.
For these two RWPs, the RCM Form 8.5 was completed L
prior to the start of the work and the work group supervision was involved in completing an ALARA review.
Therefore, DLC believes-g I
that the completed RCM Form 8.5 met the intent of the RCM Form 8.1, Section 16, 3)
Duquesne Light Company admits that RWP 16266 and RWP 16272 were L
not updated to reflect changing requirements.
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.p NOtic3 to Rhply of Violation Combined Inspection Report 50-334/89-21 and 50-412/89-20
- Le,tterl dated January 18, 1990
'Page 6.
Reasons for the Violation 1)
Poor judgement. was exercised by the Radiation Technician, in
- that, he overheard a
conversation in which another Radiation Technician.was being briefed on the-discontinuing of RCM Form 8.1 Section 13 for another work task.
He assumed that this.
' discussion was also applicable to his job and discontinued the use of this form.
L 2)
RCM Form 8.1 Section 16 was originally part of the RWP work request. on RCM Form 8.1 Section 12.
The Section 12 had been revised to incorporate a hot particle zone decision chart and the back of the original section 12 was made Section 16.
As the Section 16 had been moved to a new part of the procedure, the reduced ~ visibility ' lead to it being inadvertently omitted from the work supervisor review package.
3)
RWP personnel had been instructed to-make the necessary changes to~
RWP 16266 and RWP 16272 by the
- Director, Radiological Operations.
Due to perceived priorities of these changes, the requested revisions were not performed in a timely manner, ggrrective Actions Taken 1).
Failure to complete the required RCM Form 8.1 Section 13 was discussed with the Radiation Technician -and he subsequently i
completed the' forms as required.
2)
RWP personnel were instructed to ensure that the RCM Form 8.1, Section is is properly completed as-required by procedure.
-Subsequently,- RCM-Forms 8.1, Section 16 are being completed as
' required.
3). The referenced RWPs were updated to reflect the changes.
Agtfon Taken to Prevent Recurrence 1)~ The ~ failure to' complete the required forms as-noted in the I
I inspection report will be reviewed with contractor Radiation-L Technicians.
Details of this violation were included in the DLCo Radiological Operations Personnel Continuing Training Program.
-l 2)
Upon discovery of this discrepancy, the RCM Form 8.1, Section 12 f.
tracking log was revised and will continue to be utilized to initiate the completion of the RCM Form 8.1, Section 16 as required.
3)
Computerizing RWP generation is currently under evaluation and it is anticipated that this would facilitate timely rewrites and/or updates.
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Notice t3 Reply Cf ViC1CtiCn Combined Inspection Report 50-334/89-21 and 50-412/89-20 t
4',
@ tter dated January 18, 1990 Page 7 t
Date When Pull Como11ance Will Be Achieved The corrective actions that have already'been taken ensure that full compliance is achieved at the present time.
The additional programmatic corrective actions will be implemented by September 1, 1990.
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