IR 05000334/1985021
| ML20138G374 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/18/1985 |
| From: | Mcfadden J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20138G310 | List: |
| References | |
| 50-334-85-21, NUDOCS 8510250465 | |
| Download: ML20138G374 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No. 50-334/85-21 i
Docket No.
50-334 i
License No. OPR-66 Priority Category C
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Licensee: Duquesne Light Company P. O. Box 4
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Shippingport, PA 15077 a
i Facility Name: Beaver Valley Power Station, Unit 1
Inspection At: Shippingport, Pennsylvania ll Inspection Conducted: September 23-27, 1985 Inspector: hN)ckd#&
/0-f FS T l
VJ. McFadden, Radiation Specialist date g __ Iy,' Chie'f, P'
/e//f/Ff" Approved by:
M. Shanba
' da(e (
l Radiological Protection Section i
Inspection Summary:
Inspection on September 23-27, 1985
(Report No. 50-334/85-21 Areas Inspected: Routine unannounced inspection of the radiation safety
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program including: organization and management controls, training, instrument calibration and maintenance, posting, labelling and control of areas, and I
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quality assurance audits.
The inspection involved 34 inspector-hours onsite I
by one regionally based inspector.
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Results: No violations were identified.
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DETAILS l
1.0 Persons Contacted i
During the course of this routine inspection, the following personnel were
contacted or interviewed, i
1.1 Licensee Personnel
i A. J. Bevan Dosimetry Foreman
- W. D. Canan Senior HP Specialist
- R. J. Freund RadCon Foreman
- D. O. Girdwood Director, Radiological Operations J. A. Kosmal Radiological Control Manager
- F. J. Lipchick Senior Compliance Engineer i
- D. J. Roman QA Supervisor-Maintenance
- B. F. Sepelak NSU Engineer j
J. D. Sieber Senior General Manager
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K. J. Winter Senior HP Specialist
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- R. J. Zamule O&M Instructor
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Attended the exit interview on September 27, 1985.
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i Additional licensee employees were contacted or interviewed during this
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inspection.
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1.2 NRC Personnel Attending the Exit Meeting i
i W. Troskoski Senior Resident Inspector l
2.0 Purpose
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The purpose of this routine inspection was to review the licensee's j
radiation protection program with respect to the following elements:
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Organization and Management Controls
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Training
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Instrument Calibration and Maintenance
Posting, Labelling and Control of Areas
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Quality Assurance Audits
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j 3.0 Organization and Management Controls
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The licensee's organization and management control of the radiological
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l controls function was reviewed against criteria contained in:
10 CFR 50.34(b)(6), " Contents of applications; technical information" i
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Licensee Technical Specification 6.0, " Administrative Controls"
l Licensee Radiological Controls Manual, Appendix-1, "RadCon
l Administrative Guide" l
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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant
Personnel" Regulatory Guide 1.8, " Personnel Selection and Training"
The licensee's performance relative to these criteria was reviewed during discussions with the Director of Radiological Operations and a Radiolog-ical Control Foreman.
The licensee's management organization is currently undergoing a restructuring and retitling; this activity has affected changes in the radiological controls function where personnel and titles have changed; the ftrmer title, Radiological Operations Coordinator, has now become Radiological Control Manager; this individual, the equivalent of the Radiation Protection Manager, still reports administratively and functionally as before, but the titles and number of organization levels below this individual have changed; the need for clear descriptions of the functions and responsibilities for each job title had been discussed during a previous inspection.
Within the scope of this review, no violations were identified.
4.0 Training The licensee's training program for general employees, radiation workers, and radiological control technicians was reviewed against criteria contained in:
10 CFR 19.12, " Instructions to workers"
Licensee Technical Specifications 6.3 and 6.4, " Facility Staff
Qualifications" and " Training", respectively Licensee Radiological Controls Manual, Appendix I, Part VI,
" Qualifications and Training" Licensee Training Administrative Manual, Vol. 2, Sec. 3.0,
" Radiological Controls Training Programs" ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant
Personnel" Regulatory Guide 1.8, " Personnel Selection and Training"
The licensee's performance relative to these criteria was reviewed by examination of the training manual for scope and frequency of training, training materials, and the practical training area and by examination of training attendance records for selected individuals.
The inspector also interviewed the Director of Technical and Crafts Training and several trainers and observed the start of a retraining session for general em-ployee/ radiation workers. This session consisted of an approximately fifteen-minute introductory lecture followed by an hour and one half of self-study of training materials to be followed by an examination and practical training.
The licensee stated that this retraining approach using self-study had been requested by repeat annual trainees instead of an iteration of the initial training which consists of lectures, tapes, i
and slides and lasts two and a half days for new employees.
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i An INPO examination is used to test radiation workers.
In the case of
retraining, a score of 80 percent is required or the individual must I
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attend a version of the initial radiation worker course, i
l These are three training programs available for radiation technicians.
For personnel with no practical training and experience in nuclear power
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plant radiation protection practices, the Radiation Technician Training i
Program consists of approximately one year of a combination of formal l
classroom and practical training.
For personnel with a minimum of two
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years of working experience in radillogical protection of which one year
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i was at an operating nuclear power plant, the Radiation Technician
Site-Specific Training Program consists of a nominal 8-week course j
i consisting of classroom instruction, practical training, and self-study.
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For radiological operations personnel, there is a continuing training
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program which consists of formal classroom training, practical and l
l performance training, and individual self-study.
j Selective examination of training records for radiation technicians
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indicated that the year-long Radiation Technician Training Program had l
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been conducted several times over the last few years and that the
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j radiation technicians whose records were examined had received an average of 43 contact hours each of continuing training for 1985.
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Records were also reviewed to determine if the radiation technicians met the minimum qualifications of ANSI N18.1-1971.
The radiation control organization tracks the accumulation of hours of working experience for
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its radiation technicians and when they become qualified per ANSI l
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N18.1-1971 as evidenced by documented memos. A letter dated
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i August 12, 1985 from the radiological control manager to the radiological j
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control foreman describes the licensee policy for guidance and supervision
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j of the work activity of radiation technicians who are not yet qualified l
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per ANSI N18.1-1971; this letter stated that only two of the fifty
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presently employed radiation technicians were not fully qualified.
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l The licensee's training representative was not aware of accelerated access l
j training for NRC inspectors. Due to this situation, the licensee stated
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that there will be further documentation on the policy for accelerated
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I access training. The training organization will provide the radiological i
j controls unit a list of radiological control procedural items which are
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not addressed or not fully addressed in the " Station Orientation for Tem-
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parary Employees". The radiological controls organization will provide to i
the NRC resident inspector a description of the accelerated access train-
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I ing which will consist of a station orientation by security (approximately I
one half-hour) and a radiological controls orientation by RadCon personnel j
(approximately one half-hour).
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5 The licensee strength in radiation technician training was demonstrated by the development and effective implementation of their Radiation Technician Training and Continuing Training Programs. Within the scope of this re-view, no violations were identified.
5.0 Instrument Calibration and Maintenance The licensee's program for calibration and maintenance of portable survey meters and air sampling instrumentation was reviewed against criteria contained in:
10 CFR 50, Appendix B, Criteria XII, " Control of Measuring and Test
Equipment" Licensee Technical Specifications 3/4.7.9 and 6.10.1.h, " Sealed
Source Contamination" and " Record Retention", respectively.
Licensee Radiological Controls Manual, Chapter 3, Procedure 4.6,
" Pocket Dosimeters - Testing and Calibration" Licensee Radiological Controls Manual, Chapter 4, "RadCon Instrument
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Procedures" ANSI N323-1978, " Radiation Protection Instrumentation Test and
Calibration ANSI N322-1977, " Inspection and Test Specifications for Direct and
Indirect Reading Quartz Fiber Pocket Dosimeters" The licensee's performance relative to these criteria was reviewed by selective examination of calibration records and calibration procedures.
The licensee performs a daily inventory in the process of completing the
" Survey Instrument Daily Check" form.
Several instances were noted where this form was not completed on a daily basis, but " Daily Work Assignments" checklists indicated that the daily inventories had been performed. When an instrument is calibrated, the licensee's recordkeeping system requires that " Instrument Status Log Sheet", "Out of Service", and " Instrument Calibration" log books be updated. The following type of recordkeeping inconsistencies were noted: CP-TP-10K (SN10806) was calibrated by an outside vendor on May 2, 1984, but there was no entry in the instrument status log; recent calibration records for PNR-4 (SN3380) were not in the calibration record book; the status log sheets for seven PMC-4 portal monitors which were in service were up to date, but calibration records for only two of these monitors were found in the calibration record book.
All radiation survey instruments and portable air samplers which were examined had current calibration stickers affixed.
Electronic calibration and maintenance of radiation survey instruments are performed by MCRs (meter control repairman in the Instrument Shop) in accordance with
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manufacturer's manuals. Calibration of portable air samplers is also
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performed by MCRs in accordance with specific procedures, such as " Field Calibration Procedure, CP-2082, Battery Operated Air Sampler, Model H-80982, Calibration", which procedure required the use of a Kurz Model
525-9/505-9 air flow rate measuring device calibrated by an outside contractor.
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The ion chamber survey meter cited previously (CP-TP-10K) is used for the measurement of high dose rate gamma radiation, primarily in emergency situations.
RadCon Instrument Procedure 3.16 requires that this instrument be calibrated semiannually and after repair.
The procedure states that the instrument is normally calibrated by a vendor and that a check of the calibration will be performed after the instrument is returned to verify proper calibration.
The instrument status log sheet i
for this instrument had a note reading " yearly cal" and the following entries: calibration by outside contractor /in service (8/4/84), in service / relocated (8/15/84), out of service / calibration due (11/26/84),
calibration (2/5/85), in service / relocated to ROC /EPP (3/7/85), and in service /same location (6/17/85).
The above date of August 4,1984, refers to the date that the instrument was put back in service after being returned by an outside contractor who calibrated the instrument on May 2, 1984.
The calibration on February 5, 1985, was performed by RadCon personnel according to licensee's procedure for " check of calibration" by
. outside contractor and used a radiation intensity of 450 R/hr (approximate) to check the 10,000 R/hr scale and one approximately r
midpoint-of-scale intensity for each of the three lower scales.
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licensee stated that approximately a year ago the decision was made to i
place this instrument on a yearly cycle for calibration by an outside contractor due to the large time losses in transit to and from the calibration facility but that the procedure had not yet been changed to
j reflect the new recalibration procedure.
The licensee also stated that
this instrument had not been used since May 2, 1984. As of September 26, 1985, an approved permanent change to Procedure 3.16 stated that the CP-TP-10K is calibrated annually and after repair.
Discussions were held with RadCon foremen and technicians concerning survey meter and air sampler calibration and maintenance and the control and calibration of pencil dosimeters.
The licensee stated that the in-consistencies and record keeping inadequacies will be examined and cor-rected. The inspector observed the calibration of a portable radiation i
survey meter by a RadCon technician.
Compliance with the requirement for sealed source leak testing was reviewed.
Licensee records indicated that all discrete sources are inventoried every three months and leak tested every six months.
l The licensee stated that some computerized recordkeeping programs to
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assist in tracking due dates for instrument calibrations, leak tests, etc.
were under development.
Within the scope of this review, no violations were identified.
I 6.0 Posting, Labelling and Control of Areas The licensee's program for posting, labelling, and control of areas for radiation safety was reviewed against criteria contained in:
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10 CFR 20.203, " Caution signs, labels, signals and controls"
Licensee Technical Specifications 6.11 and 6.12, " Radiation
Protection Program" and "High Radiation Area," respectively.
Licensee Radiologic &l Controls Manual Chapter 3, Procedure 8.3,
" Containment Radiation Barrier Key Control-Shutdown and Major Maintenance" The licensee's performance relative to these criteria was reviewed by examination of key accountability records in the control roon., by interviews with the shift supervisor, the director of radiological operations, and a RadCon foreman, and by observaticns made and radiation level measurements taken during plant tours thru the service, auxiliary, fuel and decon buildings and the protected areas.
The applicable RadCon procedure and Technical Specification 6.12 required that keys for locked high radiation areas be maintained under the administrative control of the shift supervisor on duty and/or a facility health physics supervisor. At the time of the inspection, high radiation areas (greater than 1000 mrem /hr) were locked and the keys were located in a combination-lock key cabinet within the shift supervisor's office. A key sign-out log and a key inventory are used every shif t to maintain administrative control.
The shift supervisor stated that keys are only issued to radiation technicians or to operators who are meter qualified and in accordance with Technical Specification 6.12.
During normal reactor operation keys are only available in the control room. During an outage another key set is issued to the RadCon Supervisor who has to set up a key accountability system. RadCon Procedure 8.3 addresses radiation barrier key control and the key accountability system within the RadCon organization.
Within the scope of this review, no violations were identified.
7.0 Quality Assurance Audits The licensee's recent audits were reviewed against criteria contained in:
10 CFR 50, Appendix B, Criterton XVIII, " Audits"
Licensee Technical Specification 6.5, " Review and Audit"
Regulatory Guide 1.33, " Quality Assurance Program Requirements
(Operation)"
Regulatory Guide 1.146, " Qualification of Quality Assurance Program
Audit Personnel for Nuclear Power Plants" ANSI /ANS-3.2-1982, " Administrative Controls and Quality Assurance for
the Operational Phase of Nuclear Power Plants" ANSI /ASME N45.2.23-1978, " Qualification of Quality Assuranc.e Program
Audit Personnel for Nuclear Power Plants"
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The licensee's performance relative to these criteria was reviewed by examination of the first two audits of the three QA unit audits, conducted during 1985, of the Radiological Controls Department and by examination of the qualifications of the lead auditors for the audits reviewed.
QA Audit BV-1-85-08 covered the radioactive solid waste management program including preparation for shipment.
This audit was conducted from June 3 to July 1,1985, and the report was issued July 15, 1985. A satisfactory response to the identified deficiency involving the issuance of radiation survey meters was dated August 6, 1985. QA Audit BV-1-85-30 covered control over pocket dosimeters, personnel radiation badges, body counting, and radiation clearance and work permits. This audit was conducted on August 2 and 19-23, 1985, and the report was issued September 19, 1985.
One finding was identified during the audit and involved deficiencies concerning control and retention of radiological control records.
The QA organization and the training organization are working on the development of a radioactive solid waste management course for auditors to replace similar courses available through outside contractors. The licensee stated that an in-house plant-specific course would be more beneficial to the quality of audits.
Within the scope of this review, no violations were observed.
8.0 Exit Interview The inspector met with the personnel denoted in section 1.1 at the con-clusion of the inspection on September 27, 1985.
The scope and findings of the inspection were discussed at that time. At no time during this inspection was written material provided to the licensee by the NRC in-spector.
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