ML20150B540

Insp Repts 50-334/88-03 & 50-412/88-02 on 880125-29. Violation Noted.Major Areas Inspected:Licensee Implementation of Radiological Controls Program During Unit 1 Outage,Diving Operations,Posting & Labeling & ALARA

ML20150B540
Person / Time
Site:	Beaver Valley
Issue date:	03/02/1988
From:	Markley M, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20150B520	List: ML20150B518 ML20150B525 ML20150B540
References
50-334-88-03, 50-334-88-3, 50-412-88-02, 50-412-88-2, NUDOCS 8803170043
Download: ML20150B540 (16)

See also: IR 05000334/1988003

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I l

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Report Nos. 50-334/88 03 i

50-412/88 02 i

Docket Nos. 50-334 -

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50-412

License Nos. DPR-66 Category C

NPF-64

Licensee: Duquesne Light Company

P.D. Box 4

Shippingport, Pennsylvania 15077

Facility Name: Beaver Valley Power Station, Units 1 and 2

Inspection At: Shippingport, Pennsylvania  !

Inspection Conducted: January 25 - 29, 1988

Inspectors: d. [LIru

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6 Mz!iTV

A. Weadock,~ Radiation Spectalist, Date

Facilities Radiation Protection Section

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_ 3-2 -95

=M. Markley, RadiatiqF 5pecialist Date

Facilities Radiation Protection Section i

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Approved by:

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_ M. Shanbaky, Thief, Facil ,tfes -

e

Radiation Protection Section

Inspection Summary _: Inspection on Januar 25 - 29, 1988 (Combined Inspection

Report Nos. 50-374/88-03 and 50-412/88-02 .

Areas Inspected: Routine, unannounced inspection of the licensee's

implementation of the Radiological Controlt. Program during the Unit 1 outage.

Areas inspected included diving operations, posting and labeling, external and

internal exposure controls, personnel training and qualifications, and ALARA.

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g3170043800304

g ADOCK 05000334  !

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Results: Within the scope of this inspection, one apparent violation, concerning

a failure to follow the Radiological Work Permit procedure, was identified

(section

worker 5.0 . station administrative limitsAn unresolved item, concerning the exposure of a maintenance

above)

l is discussed in section 6.0.

l Weaknesses were identified in posting and labeling, external exposure controls,

and ALARA. ,,

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DETAILS

1.0 Persons Contacted

1.1 Licensee Personnel

• J. Belfiore Senior Quality Assurance (QA) Specialist

• D. Blair Director, Radiological Health Services

• W. Canan Senior Health Physics (HP) Specialist

+J. Crockett Senior Manager, Nuclear Operations

• +D. Girdwood Director, Radiological Operations

M. Helms HP Specialist

• D. Hunkele Director, QA Operations-

• +J. Kosmal Manager, Radiological Controls

• +F. Lipchick Senior Licensing Supervisor

• +D. Roman Supervisor QA Maintenance ,

• B. Sepelak Engineer

• +J. Sieber Vice President, Nuclear

• R. Vento Director, Radiological Engineering

• D. Shaw Licensing Engineer

1.2 NRC Personnel Attending +he Exit Interview

• J. Beall Senior Resident Inspector

• Attended the Exit Meeting held on January 29, 1988.

+ Participated in a telephone conference call with Mr. A. Weadock of RI on

February 10, 1988. l

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Other licensee personnel were also contacted during the course of this  ;

inspection. ,

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2.0 Purpose

The purpose of this routine, unannounced inspection was to review the l

implementation of the licensee's Radiological Controls Program during the Unit 1

outage. The following areas were included in this review:

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- status of previously identified items, j

- diving activities associated with the thermal shield bolt removal operation,

- posting and labeling,

- external exposure controls, 1

- internal exposure controls,

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- training and qualifications,

- ALARA,

- status of the licensee's program to identify and control hot particles.

3.0 Status of Previously Identified Items

Follow-up Item (334/86-10-01): Licensee to correct weaknestes in

3.1 (Closed)

the air samp ling program. This area was reviewed in NRC Inspection Report No.

334/87-04, at which time the majority of improvements committed to by the

licensee were reviewed and satisfactorily closed out. Two licensee connitments

were left open for tracking: 1) licensee to ex

techniques provided to contractor technicians, and pand2 the training

licensee in air-sampling

to assign an

individual to oversee air-sempling during the upcomin)g outage.

In response to the first item, the licensee has developed Job Performance

Measure

tecnnicians(JPM)ho

w will be assigned job coverage responsibilities.#3A, Air-Sampling, to be

This JPM

includes specific on-the-job training

evaluation of technician performance. qualification sheets which requireThe inspector revie

the sheets and determined they address the deficiencies in NRC Inspection Report

No. 334/86-10.

In response to the second item, the inspector determined through discussion with

licensee personnel that two air sample coordinators were designated for the 6R

outage. These coordinators set air sample counting priorities, reviewed air

sample count logs, and tracked air sample results for different plant areas.

The licensee stated that assignment of these two individuals provided additional

measures of control and that this practice would probably be continued during

future outages. This item is closed.

3.2 (Closed Follow-up Item (334/85-28-02 Review licensee's 1986 audit of

qualificatio)ns of the radiation protection): staff. Inspector review of QA audits

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indicated that radiation protection staff qualifications had been reviewed

relative to criteria contained in Technical Specification 6.5.2.8.

Specifically, audits BV-1-8642 and BV-1-8713 addressed these criteria. The

licensee also issued a QA program guidance letter requiring evaluation of

recently promoted and newly hired personnel.

4.0 Diving Activities Associated with the Thermal Shield Bolt Removal

On January 26, 1988 the licensee utilized a diver to extract and replace a

sheared bolt from the reactor thermal shield. The dive was conducted in the

refueling cavity, with the thermal shield suspended in the cavity water above

the reactor vessel. The inspector reviewed the licensee's implementation of

radiological controls for the dive by the following methods:

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- discussion with cognizant personnel,

- attendance at the pre-dive briefing,

- review of the following materials:

o procedure RP 8.8, "Controlled Area Diving Operations,"

o Radiation Work Permit (RWP) 15797, "Replacement of Thermal Shield Support

Block Bolt DCP 878" and associated surveys and ALARA review,

- observation of dive activities.

The bolt extraction / replacement was conducted with the diver located on a fixed

underwater platform, utilizing long handled tools. This minimized the

possibility for the diver to inadvertently swim into an unsurveyed area.

Adequate surveys were conducted prior to the dive to identify area dose rates.

Continuous dose rate measurements were made during the dive to confirm pre-dive

surveys. Maximum exposure for the diver was approximately 110 millirem whole

body (based on initial pocket dosimeter readings).

During the course of the above review several areas for improvement were

identified, including the following:

o Procedure RP 8.8 did not include a requirement to insure diver air was

appropriately sampled and certified to meet breathing air requirements prior to

use. The inspector queried the licensee prior to the dive and determined the

licensee had failed to make this determination. The diver's air supply

(com)ressor and emergency bottle

to tie dive and found to be accep) table.was Thesubsequently tested

licensee stated by the licensee

a requirement to prior

certify diver air prior to any dives would be added to the controlling

procedure.

o Procedure RP 8.8 failed to include a specific requirement to insure bioassay

(urine samples arc obtained from the diver. The licensee's administrative

procedu)res already require baseline and termination urine samples for all

workers, so it was not felt necessary to add this requirement to the dive

procedure. The inspector noted however, that in situations where dive

activitiesmightextendovermultipledaysmorefrequentsampleswouldbe

desirable to identify if problems are developing during the operation, rather

than waiting until the dive crew leaves the site. The licensee stated procedure

RP 8.8 would be revised to require more frequent bioassay sampling during

extended dive operations,

o Direct visual observation of the diver's body position can be critical during

Licensee radiological

dives,ls

contro (RC) coverage during the dive of Januaryparticularly when dose

26, 1988 included two rates are highly v

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technicians, an RC foreman and the ALARA coordinator. Despite this coverage,

the inspector noted that for brief periods during the dive constant visual

surveillance of the diver by the RC staff was not maintained. It was also not

apparent that one individual had been assigned specific responsibility for

observing the diver. The inspector did note, however, that the licensee

maintained constant surveillance of the remote readout for the survey probe

attached to the diver.

Once brought to the attention of tha licensee, constant surveillance of the

diver was maintained for the duration of the dive The licensee also indicated

procedure RP 8.8 would be revised to require assignment of a "dedicated"

individual to maintain visual surveillance over divers,

o Pending the above improvements, procedure RP 8.8 was noted to be generally

suitable for controlling the fixed platform dive operation that was completed on

January 26, 1988. The inspector noted, however that the radiological controls

included in RP 8.8 are not comprehensive enough,to adequately control all diving

operations and in particular spent fuel pool diving operations. Potential

upgrades include requirements for verifying fuel bundle and miscellaneous source

positions prior to dives, shiftly RC supervisory sign-off for the integrity of

installed barriers, guidance on conducting fuel pool surveys, etc. The licensee

indicated procedure RP 8.8 had been revised exclusively to cover the January 26,

1988 dive and that this procedure would be critically reviewed and revised prior

to its use in any other diving situations. The licensee stated that a

cautionary statement would be added to the current procedure RP 8.8 requiring

it's revision prior to use in fuel pool dive situations.

The inspector had no further questions in this area. Licensee planned upgrades

to RP 8.8

responsible diver

(diverobserver,

air certification, bioassay

cautionary frequency,

note requiring designation of

revisions

pool dives) will be reviewed during a subsequent inspection (334/88-03-01; prior to fuel

412/88-02-01).

5.0 Posting and Labeling

The licensee's program for the survey, posting, and control of radioactive

materials and radiological areas was reviewed against the following criteria:

- 10 CFR 20, "Standards for Protection Against Radiation,"

l - Technical Specification 6.12, "liigh Radiation Area,"

- procedure RP 2.4 (Chapter 3), "Area Posting."

Licensee performance in this area was evaluated by discussion with cognizant

personnel and tours of the Unit 1 Containment and Auxiliary Building.

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The inspector did note that general radiological housekeeping and radiological

posting practices were poor compared to other utilities. The following examples

of poor posting and housekeeping were noted during tours of the Primary

Auxiliary Building (PAB) and Containment:

- Radiological signs were hung on barriers so loose that signs were effectively

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posted at ankle height or actually rested on the floor.

- Radiological signs were obscured by stacked 55-gallon barrels.

- A contaminated area on the 722'6" elevation of the PAB was inadequately posted

with only yellow and magenta tape on the floor; no signs or barrier rope were

used to post the area.

- A large number of yellow bags containing tools, etc. were noted to be

unattended in Containment. Although these bags were pre-marked with the

radiation caution symbol, they were often unsealed and did not feature any

dose rate or survey information.

- Signs were noted to be downgraded from "High Radiation Area" to "Radiation

Area" in an inconsistent fashion. The inspector noted the word "High" was

scratched out by marker in some instances and covered with tape in others.

These inconsistencies raise doubtr as to whether these posting changes were

made by appropriate personnel.

- The licensee also posts areas as "Radiation Zone" one through five (i.e., Zone

1 area, Zone 2 area) based on area dose rates. The inspector noted two

instances where High Radiation Areas were downgraded to Radiation Areas

without a corresponding change in the area Zone posting.

The licensee has been conducting a Radiological Surveillance Program in the

controlled areas in which a RC foreman audits the controlled area and corrects

identified deficiencies. The inspector reviewed selected Surveillance Reports

and noted they detailed similar findings as those described above. The

inspector stated that, based on the above concerns the licensee's Radiological

Surveillance program appeared ineffective in identifying and minimizing

radiological deficiencies.

The licensee stated that radiological posting and housekeeping conditions had

declined with the onset of the outage, due to the need to shift HP supervisory

attention to more urgent matters. The licensee indicated that additional

measures, such as designating specific RC supervisors as responsible for the

radiological conditions in assigned plant areas, would be evaluated.

On January 26, 1988, the inspector noted an RC technician inside the Unit I

containment wearing an incomplete set of anti-contamination (anti-C) clothing.

Specifically, it was noted that the technician was not wearing anti-C coveralls

or hood. The inspector followed the technician to the containment access and

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questioned him at the undressing area. The technician stated he had been

covering the diving operation inside containment. Upon exiting and removal of

his full set of anti-Cs, the technician had the diver's ID badge in his

possession. The RC technician stated he had then donned one pair of shoecovers

and gloves in addition to his personal clothing and had re-entered containment

to return the badge.

The inspector noted the subject RC technician had been identified as being

contaminated upon his second exit from the containment. Tha RC technician

stated he felt this was due to his earlier job coverage of the diving operation,

rather than his second entrance to containment in partial anti-Cs.

Subsequent inspector review identified the technician had entered on

Radiological Work Permit (RWP) No. 15630, "Radcon Functions and Job Sugport for

Specific RWP." This RWP states that anti-C clothing requirements are per

specific RWP." The inspector then reviewed applicable specific RWP No.15797,

"Replacement of Thermal Shield Support Block Bolt OCP 878." Minimum anti-C

clothing requirements specified on this RWP included cloth hood, coveralls, and

two pairs each of shoecovers and gloves. The inspector noted that in addition

to the RWP requirements the Unit 1 containment was posted as a contaminated

area.

section 6.11, Radiation Protection Program,

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requires, inSpecification (TS) dures for personnel radiation protection shall be

part, that proce

approved, maintained and adhered to. Procedure RP 8.1, Radiological Work

Permit, states in section 3.2.1.8 that an individual's signature of the RWP

signifies his understanding and acceptance of the conditions and controls of the

RWP.

Failure to dress in accordance with the minimum RWP clothing requirements

constitutes an a parent violation of the RWP procedure and hence TS section 6.11

(50-334/88-03-02 . The licensee's immediate corrective actions included

counselling of t e involved technician.

6.0 External Exposure Controls

The inspector reviewed the effectiveness of the licensee's program for

controlling and reducing personnel exposure by discussion with cognizant

personnel and review of the following documentation and procedures:

- procedure RP 8.1, "Radiological Work Permit,"

- procedure RP 8.3, "Radiation Barrier Key Control,"

- procedure RP 8.5, "ALARA Review,"

- various Radiological Work Permits (RWPs) associated with ongoing work

activities, including steam generator (S/G) maintenance,

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- selected S/G surveysI log entries and worker written statements included as

part of the licensee s investigation for an exposure in excess of

administrative limits,

- selected worker exposure histories.

Within the scope of the above review, the inspector noted that an exposure

significantly in excess of station administrative limits occurred in association

with S/G maintenance activities. On January 22, 1988, a worker authorized to

receive a maximum of 800 millirem actually received an exposure of 1290 millirem

while performing two half-body entries into the S/G and providing platform

support. This resulted in a total quarterly exposure for the worker of 2306

millirem, which is below the federal limit (3000 millirem / quarter with complete

exposure history).

The inspector

associated reviewed

with various

the incident. Theworker statements,d

inspector note that statements by thelog entries, and

subject worker and by the RC technicians covering the work differed greatly

concerning the level of control over the work. The worker's statements

indicated radiological coverage was poor; however, the RC technician's

statements indicated work was adequately controlled until the worker's last

half-entry to the S/G. Prior to this last entry the technician's statements

and log entries indicate the worker's pocket doslmeter was read and indicated an

exposure of 650 millirem. Following a 16 second half-entry to the S/G, the

worker's pocket dosimeter was read and found to be offscale (0 to 1000 mrem

dosimeter range).

The ins based on S/G dose rates (680 millirem / minute) and the

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worker'pector noted thatsprevious650milliremexposure

the worker's 16 second entry by itself

wouldhavecontributedenoughadditionalexposureforhimtoexceedthe800

millirem administrative limit. Allowance of this second 16 second half-entry

indicates a lapse of controls during significant radiological operations.

Subsequent to the conclusion of the inspection, the licensee indicated that

further investigation identified that an RC foreman had been in communication

with the worker and the technicians at the time and had authorized the second ,

hal f-entry. The licensee indicated, however that an RC foreman was not

authorized to modify station administrative )imits.

The licensee had not completed their formal investigation of the above incident

at the conclusion of this inspection. The adequacy of the RC coverage

associated with this administrative overexposure, including the decision making

process of the RC technicians and foremen, remains unresolved pending review of

the licensee's final report and corrective actions (50-334/88-03-03). The

licensee indicated that in an effort to improve control in this area a RP

procedure will be developed identifying radiological controls to be implemented

during S/G primary and secondary side inspection. The licensee indicated this

procedure would be in place prior to the next outage. Adequacy of this

procedure will be reviewed in conjunction with the above unresolved item.

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Several additional areas for licensee improvement were not'd and include the

following:

o Communications among the RC staff concerning radiological deficiencies should

be improved. On January 26, 1988, an individual with an administrative limit cf

490 millirem exited the S/G platform area with a pocket dosimeter reading of 550

millirem. The inspector questioned the Director of Radiological Operations on '

January 28, 1988 corcerning details of the apparent second administrative

overexposure and noted that he was not aware of the incident. Subsequent

investigation by the licensee determined the worker's pocket dosimeter

overresponded and the actual TLD value was within the 490 limit.

The licensee indicated all RC foremen were subsequently briefed to ensure all

information concerning radiological deficiencies gets passed from the field to

the appropriate management.

o The licensee's practice of posting surveys at the controlled area access for

worker review suffered in effectiveness due to problems of posted survey

timeliness and availability. The inspector reviewed the posted surveys at the

access to the controlled area on January 28, 1988 and noted the following

deficiencies:

despite ongoing diving operations, the most recent survey of the

containment refueling floor was dated January 21, 1988,

- survey maps depicting general walkway radiation and contamination levels for

the entire elevation were only present for two of the four containment

elevations,  ;

- despite ongoing maintenance in the area, no survey was posted on the board

showing radiological conditions on the B S/G platform. l

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The inspector also noted that, although platform surveys were available, no

surveys showing dose rates inside the S/G channelheads were available at the B '

and C S/G control point desk. The ins

verified they were knowledgeable of S/pector questioned

G channelhead the area

stay-time dose technicians

rates. and

V)on identification, the above survey concerns were corrected by the licensee.

T1e inspector determined current surveys for the above areas were available but

had not been posted at the controlled area access.

7.0 Internal Exposure Controls ,

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The licensee's program for cvaluating and controlling personnel exposure to  ;

airborne radioactive materials was evaluated by discussion with cognizant '

personnel and review of the following documentation:

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- procedure RP 7.3, "Air Sampling, Field Evaluation and Sample

Assessment of Radioactive Particulates, lodines and Noble Gases,"

- procedure RP 10.14, "Portacount Quantitative Respirator Fit Test System

Operation,"

memo dated December 11, 1987, to J. Hale from L. Cunningham, Radiation

Protection Branch, NRR,

4 - respirator fit-test results for selected radiation workers,

4 - air sample counting logs and analysis results for selected air samples taken

during the current outage.

Within the scope of the above review, no violations were identified. The

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following specific areas for improvement were identified,

o The inspector determined the licensee's practice is to collect an air sample

at the steam

itself, prior generator

to initial (S/G)ker

wor entry to the S/G.manway access

The inspector area, rather than in th

questioned

whether such a sample would be representative of the air in the channelheads.

The licensee stated that, considering the protection factor of the air-supplied

hoods worn by S/G entry personnel, such a sample was sure to ba adeguately

conservative. The licensee did indicate, however, that an air sample would be

taken in the S

opening of the/G channelhead

S/Gs during the as well

next as at The

outage. the manway

two sam access at the initial

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compared to evaluate adequacy of their current practice.ples Thiswill

willthen be

be reviewed

during a subsequent inspection (50-334/88-03-04).

o The inspector noted that procedure RP 7.3 does not include followup guidance

ste)s that should be followed for air samples when alpha activity is present. '

Altlough instruction (hold and recount in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to establish half-life) is l

posted on the counting room wall the inspector noted this instruction is not

included in the procedure. ThelicenseeindicatedprocedureRP7.3wouldbe

revised to include this instruction. This will be reviewed during a subsequent

inspection (50-334/88-03-05; 50-412/88-02-02).

The licensee is currently using the Portacount respirator fit-tester

manufacturedbyTSIIncarporated,asthedeviceforperformingquantItative

respirator fit-testing. This device differs from currently accepted fit-testing

devices in that it uses ambient air as the challenge aerosol in evaluating

acceptability of respirator fit. The inspector verified that the licensee

evaluated the suitability of this device prior to it's use, and that they used

vendor information and input from recognized experts in the respiratory

protection field to develop their Portacount operation procedure. The inspector

also verified that formal training was given to Portacount users prior to the ,

use of this device. Although the licensee performed no onsite testing of the i

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Portacount, they had reviewed and provided the inspector a copy of a paper

describing the results of an evaluation of this device performed by the U.S.

Army. Based on review of the paper and the scope of the above review, the

inspector had no further questions in this area.

8.0 Training and Qualifications

Licensee management controls in the area of personnel selection and training

was reviewed by the following methods:

- review of selected contractor technician resumes and training records,

- review of selected Quality Assurance (QA) audits,

- discussion with cognizant licensee personnel.

Review of contractor technician resumes found all personnel qualifications

examined to meet or exceed n.inimum qualifications of ANSI N18.1-1971. The scope

of the licensee's contractor technician training program was noted to be

extensive and includes required reading sign-offs, procedure based quizzes, and

on the job practical HP sign-off requirements for performance of surveys,

instrument use, and documentation.

The inspector reviewed licensee audits of plant staff qualifications and

training to close out NRC follow-up item No. 50-334/85-28-02 (see section 3.2).

The licensee was noted to have performed an extensive audit of staff

qualifications in 1986 (BV-1-8642). The 1987 audit in this area (BV-1-8713) was

less extensive in that fewer individuals were evaluated. In response to

inspector concerns, the licensee has established program guidelines to ensure

continued evaluation of staff training and qualifications including newly hired

and recently promoted personnel. The inspector had no further questions in this

area.

9.0 ALARA

The licensee's implementation of an ALARA program to support the Unit 1 outage

was reviewed by the following methods:

- discussion with cognizant personnel,

- tour of radiologically controlled areas,

- review of station annual and outage ALARA goals,

- review of selected Nuclear Group ALARA Review Committee (NGARC) 1987 meeting

minutes,

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- review of selected RWPs and associated ALARA reviews,

- review of relevant station ALARA procedures. ,

Within the scope of the above review, no violations were identified. The

licensee's annual exposure for 1987 totaled 209 person-rem, with 198 person-rem

for Unit 1 and 11.7 person-rem for Unit 2. This exposure was within the 1987

exposure goal (436 person-rem) and resulted from an approximate one month delay

of the outage.

At the time of the inspection the licensee had exceeded their original outage

goal of 390 person-rem (actual exposure was 406 person-rem) with only 40% of the -

steam generator (S/G

equipment was used,)S/G exposure was significant and totaled approximatelwork 53 comple

person-rem at the time of the inspection. The licensee indicated that in tial

outage planning budgeted for analysis and maintenance to the A S/G only. During

the outage, the work scope was expanded to include all three S/Gs.

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The revised 1988 annual exposure goal of 445-465 person-rem includes 50

person-rem for Unit 2. However, at the time of the inspection, actual exposure

for 1988 was 301 person-rem. Considering the 1988 exposure to date and the

expanded outage scope, it is unlikely that the licensee will meet the current

year's exposure goals.

The following areas for improvement in ALARA were noted during this review and

discussed with the licensee.

o The level of ALARA staffing was identified as a weakness. One individual, the

ALARA Coordinator, is assigned the responsibility for evaluating work packages

and performing ALARA reviews and inplant ALARA functions for the two unit site.

Four individuals provide technical support and trending; however, they do not

perform ALARA briefings, reviews or inplant ALARA implementation.

Consequer? ',y, the ALAM program Is limited by the time the ALARA Coordinator has

available to address major work evolutions. Licensee management acknowledged

this concern and stated that additional ALARA support will be provided,

o Inspector review of RWPs indicated lapses in licensee implementation of ALARA

reviews. Specifically, an ALARA review was not performed for RWP 15775, titled

"Cut and Weld Feedwater Nozzles, A,B,and C Generators." Procedurally, ALARA

reviews are required to be performed when a cumulative exposure greater than one

Rem to the work party is expected. At the time of the inspection the total

exposure for RWP 15775 was 4.590 person-rem. The ALARA Coordinator indicated an

ALARA review had not been performed for this job since the original work scope

did not flag a review. No ALARA review was subsequently performed when the

original work scope was expanded.

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The inspector stated the concern that the licensee is dismissing procedural

guidance designed to maintain occupational exposures ALARA. The licensee

indicated additional attention would be paid to this area in the future.

o Unproductive activities in the radiologically controlled area were observed.

During the January 26 diving operation,the inspector noted an excessive number

of workers gathered on the scaffolding around the steam generators to observe

the diving evolution. The licensee directed these workers to resume their duties

only after prompting by the NRC.

o Inspector observation of radiologically"controlled areas identified a lack of

posted low exposure "ALARA Waiting Areas. These signs are becoming standard in

the industry and are used to identify low-dose waiting areas to workers who must

wait for short periods in the radiological area. Licensee management

acknowledged this weakness, stated such signs have been used in the past and

indicatedthelackofthesesignsduringthecurrentoutagewasanoverslght

which would be corrected.

o On January 25, 1988, during a Unit I reactor building tour the inspectors

noted a shielded barrel stored in the 767 ft. elevation pressurizer cubicle.

Insulation workers were noted to be working on a scaffold within

five feet of the bar(RWP rel. A15684)diation

ra survey, posted on the door to the cubicle,

identified the barrel as reading 10 R/hr and contributing to general area dose

rates. The inspector noted, however, that the primary contributor to area dose

rates was the pressurizer itself. Both the HP Operations Supervisor and the

ALARA Coordinator were unaware of the barrel or it's contents. Subsequent

investigation identified the barrel contained spent filters and had been placed

in the cubicle on January 16, 1988, pending disposition as waste. The inspector

noted this to represent a weakness in the licensee's ability to identify sources

of exposure that may affect the licensee's ALARA program,

o Prior to the current outage the licensee evaluated and decided not to perform

a chemical decontamination of the S/G channel heads due to the limited scope of

planned S/G work. S/G inspection results, however, necessitated additional

inspection on all three steam generators. Inspector review of licensee

radiological surveys indicated S/G tubesheet dose rates up to 67 R/hr. These

exposure rates are high as compared to other PWRs. The inspector noted that

although expanded S/G work is not uncommon for plants with increased

reactor-years of operation, the licensee's outage planning did not include a

contingency to address the dose rates or possible needs for chemical

decontamination due to an expanded scope of work.

The licensee acknowledged the inspector's concern for the high dose ratas seen

in the S/Gs and indicated that for the next cutage an ALARA evaluation would

be undertaken to identify if a chemical decontamination would be cost-effective.

The licensee indicated that S/G crud samples were taken during the current

outage and provided to a vendor for analysis in preparation for this

eventuality.

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o Review of Nuclear Group ALARA Review Committee (NGARC) meeting minutes

indicated an attendance problem. Specifically, the October 12, 1987 meeting had -

i to be rescheduled for lack of a quorum.

,

The inspector communicated the above concerns to the licensee and stated that

these areas would continue to be reviewed during subsequent inspections.

10.0 Radioactive (Hot) Partic'le Program

The licensee's program for control of radioactive, or hot particle,

contamination was reviewed during this inspection. Evaluation of licensee

performance was based on:

- discussion with licensee personnel,

- review of licensee internal memo generated in response to NRC Information l

Notice (IN) 86-23,

- review of selected RWP surveys,

- review of selected personnel contamination reports,

- review of Hot Particle Control Training leston plan.

The inspector determined the licensee is aware of recent information concerning

hot particles and has specifically trained RC personnel in this area. Control

measures that have been taken by the licensee include the acquisition and use of

whole body friskers at the controlled area exits, the performance of masslin

wipe surveys to identify hot particle areas and monitoring for the presence of

contaminationonincominglaunderedprotectIveclothing. The licensee has a

computer program (DISCDOSE) which is used to evaluate skin doses resulting from

hot particle and other contamination events. Altnough adequacy of the dose

assessment computer program was not reviewed during the inspection, the

inspector identified skin doses arising from hot particle contaminations are I

reported per NRC guidance (one square centimeter of skin at a depth of 7

milligrams /squarecentimeter). The licensee's lesson plan for hot particle i

training was noted to be extensive.

l

The inspector noted the above actions are informal and the licensee has not

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described the scope or content of their hot particle program in an approved I

procedure. The licensee indicated this was intended and they were currently

evaluating the best method to formalize the program, i.e. in an independent

procedure or as part of the RWP procedure. The scope and extent of the

licensee's formalized hot particle program will be reviewed during a subsequent

inspection (50-334/88 03-06;50-412/88-02-03),

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12.0 Exit Mee g

The inspector met with the licensee's representatives (denoted in Section 1.0)

at the conc' ion of the inspection on January 29, 1988. The inspector

summarized .4 purpose and scope of the inspection and findings as described in

this report. A telephone conference call was held on February 10, 1988 with the

personnel identified in Section 1.0 to further discuss the findings of the

inspection.

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