ML20150B540
| 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: |
| 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
Report Nos.
50-334/88 03
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50-412/88 02
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Docket Nos.
50-334
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50-412
License Nos. DPR-66
Category
C
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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Mz!iTV
A. Weadock,~ Radiation Spectalist,
Date
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Facilities Radiation Protection Section
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3-2 -95
=M. Markley, RadiatiqF 5pecialist
Date
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Facilities Radiation Protection Section
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Approved by:
_ M. Shanbaky, Thief, Facil ,tfes
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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.
g3170043800304
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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
worker above) station administrative limitsAn unresolved item, concerning the exposure of a maintenance
(section 5.0 .
is discussed in section 6.0.
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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
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- 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.
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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
implementation of the licensee's Radiological Controls Program during the Unit 1
outage. The following areas were included in this review:
- status of previously identified items,
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- diving activities associated with the thermal shield bolt removal operation,
- posting and labeling,
- external exposure controls,
- 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) ling program. This area was reviewed in NRC Inspection Report No.
the air samp
334/87-04, at which time the majority of improvements committed to by the
licensee were reviewed and satisfactorily closed out.
Two licensee connitments
techniques provided to contractor technicians, pand the training in air-sampling
were left open for tracking:
1) licensee to ex
individual to oversee air-sempling during the upcomin)g outage.
and 2 licensee to assign an
In response to the first item, the licensee has developed Job Performance
Measure (JPM)ho will be assigned job coverage responsibilities.#3A, Air-Sampling, to be
tecnnicians w
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.
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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 subsequently tested by the licensee prior
The licensee stated a requirement to
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
procedu)res already require baseline and termination urine samples for all
(urine samples arc obtained from the diver.
The licensee's administrative
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
dives,ls (RC) coverage during the dive of Januaryparticularly when dose rates are highly v
Licensee radiological
contro
26, 1988 included two
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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
responsible (diver air certification, bioassay frequency, designation of
to RP 8.8
diver observer, cautionary note requiring revisions
pool dives) will be reviewed during a subsequent inspection (334/ prior to fuel
88-03-01;
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,"
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- 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
posted at ankle height or actually rested on the floor.
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- 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.
Technical Specification (TS) dures for personnel radiation protection shall be
section 6.11, Radiation Protection Program,
requires, in part, that proce
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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 surveys log entries and worker written statements included as
part of the licensee s investigation for an exposure in excess of
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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 reviewed various worker statements,d that statements by thelog entries, and
associated with the incident. The inspector note
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
worker'pector noted thatsprevious650milliremexposure
the worker's 16 second entry by itself
wouldhavecontributedenoughadditionalexposureforhimtoexceedthe800
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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
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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
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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.
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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
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verified they were knowledgeable of S/pector questioned the area technicians and
and C S/G control point desk.
The ins
G channelhead stay-time dose rates.
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
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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,
- respirator fit-test results for selected radiation workers,
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- air sample counting logs and analysis results for selected air samples taken
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during the current outage.
Within the scope of the above review, no violations were identified.
The
following specific areas for improvement were identified,
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o The inspector determined the licensee's practice is to collect an air sample
at the steam generator (S/G)ker entry to the S/G.manway access area, rather than in th
itself, prior to initial wor
The inspector 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
opening of the/G channelhead as well as at the manway access at the initial
taken in the S
compared to evaluate adequacy of their current practice.ples will then be
S/Gs during the next outage. The two sam
This will be reviewed
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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.
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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
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
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use of this device. Although the licensee performed no onsite testing of the
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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.
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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
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equipment was used,)S/G exposure was significant and totaled approximatelwork comple
steam generator (S/G
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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.
The revised 1988 annual exposure goal of 445-465 person-rem includes 50
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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 15684)diation survey, posted on the door to the cubicle,
rel. A ra
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
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to be rescheduled for lack of a quorum.
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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
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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
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reported per NRC guidance (one square centimeter of skin at a depth of 7
milligrams /squarecentimeter). The licensee's lesson plan for hot particle
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training was noted to be extensive.
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The inspector noted the above actions are informal and the licensee has not
described the scope or content of their hot particle program in an approved
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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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