ML20198L416
| ML20198L416 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/09/1998 |
| From: | Legrand R DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-334-97-08, 50-334-97-8, 50-412-97-08, 50-412-97-8, NUDOCS 9801160024 | |
| Download: ML20198L416 (7) | |
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e va ley Power Station Sheppegport. PA 16077-0004 e
AONALD L LeGRAND (412) 393-7622 Drvision Vee President -
Jgggg,g'gggg Fax (412) 393-4905 Nuclear Operatsons and Plant Marager L-98-003 U. S. Nuclear Regulatory Commission Attention: Docurnent Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit No. I and No. 2 HV-1 Docket No. 50-334, License No. DPR-66 HV-2 Docket No. 50-412, License No. NPF-73 Integrated Inspection Report 50 334/97-08 and 50-412/97-08 Reply to Notice of Violation in response to NRC correspondence dated November 26,1997, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the subject inspection report.
An extension of the due date of C,: response until January 9,1998, was requested of the NRC staff on December 24 1997.
Duquesne Light has perfonned a detailed review of the circumstances surrounding alleged Violation B.
Based on the details provided in the attached response to this violation, Duquesne Light respectfully requests that this violation be withdrawn.
If there are any questions concerning this response, please contact Mr. J. Arias at (412)393 5203.
Sincerely, m\\
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Ronald L. LeGrand Attachment
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Mr. D. S. Brinkman, Sr. Project Manager Mr. p. W. Eselgroth, Chief, Reactor Projects Branch No. 7, Region 1 Mr. D. M. Kern, Sr. Resident inspector Mr.11. J. Miller, NRC Region 1 AdminisGator DELIVERING G 0 A l'1i V p
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DUQUESNE LIGHT COMPANY Nuclear Power Division Beaver Valley Power Station, Unit Nos. I and 2 Reply to Notice of Violation Integrated Inspection Report 50-334/97-08 and 50-412/97-08 Letter Dated November 26,1997
,V.JOLATION A (Severity Level IV, Supplement IV)
Description of Violation (50-334/97-08-04)
Unit 1 Technical Specification (TS) 6.8.1.a requires that, " Written procedures shall be established, implemented, and maintained covering...the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978,"
which includes radiation protection procedures. This requirement is partially implemented by the site Health Physics Manual, which requires in Chapter 1, Part II, Section E.2.g, that individuals shall comply with the provisions of their radiological work permit (RWP) and any supplementary posted material for work in the radiologically controlled area (RCA). All licensee RWPs require the user to review tne radiological conditions of their work area by reviewing the posted area survey maps.
Contrary to the above, workers were found during the period of October 6-8,1997, in the radiologically controlled areas (primary auxiliary and containment buildings), who had not reviewed their survey maps prior to entry and were unaware of the radiological conditions in their work and travel areas in the RCA.
Reason for the Violation The primary cause of the violation is that management did not develop and communicate adequate standards to ensure compliance. A review of site procedures determined that there was a lack of specific guidance to be provided to workers regarding requirements for knowledge of radiological conditions in low dose rate travel areas. A secondaiy cause was that workers were complacent or had a lack of concern about their dose and the dose rates in low dose rate areas. This is partit.!!y attributed to the lack of adequate standards.
= Reply to Noticeof Violation NRC Integrated Inspection 50-334/97-08 and 50-412/97-08 '
I Page 2 1
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Corrective Actions Tehen and the Results Achieved l
x The following were immediate corrective actions, some of which are interim and will be discontinued when other corrective actions are completed that will provide a similar level.
- of compliance. These actions ensured workers were aware of the radiological conditions, in their work and travel areas.
Developed and issued a Standard of the Week for two consecutive weeks that included the expectation that workers are responsible to be knowledgeable of the radiological conditions of their work and travel areas.
Instituted interim direct verbal worker briefings at strategic Radiologically Controlled Area (RCA) entry points. These briefings informed workers _of the radiological conditions in their work and travel areas and included the location of any applicable
- ALARA low dose waiting areas.
. Communicated details of the deficiency and the revised interim controls to station managera and requested they achieve compliance from all individuals under their cognizance.
Added a supplement to radiation worker training that included management expectations that workers are responsible to be knowledgcable of the radiological conditions in their work and travel p6s, The following corrective actions were taken in addition to the immediate corrective actions listed above:
Revised the responsibility for Health Physics updating of posted survey maps to ensure more timely and efficient updating.
Upgraded and simplified the posted survey maps at the entrances to RCAs to make
- a them easier for the worker to read and understand.
Issued a letter to Health Physics personnel describing the corrective actions taken and
~ those planned to be taken to address the deficiency.-
i Issued a letter from the Plant Manager to station radiation workers reinforcing management expectations of worker responsibilities with regard to their knowledge of radiological conditions in their work and travel areas.
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Reply to Notice of Vi:lation j
-NRC Integrated Inspection 50-334/97-08 and 50-412/97-08 Page 3-t Corrective Actions to Prevent Further Violati.01 9
The following additional corrective actions will be implemented:
Incorporate additional management expectations for worker knowledge of radiological conditions in their work and travel areas into radiation worker training. This will be completed by January 31,1998.-
- - Revise Health Physics Manual (HPM) procedures to describe the methods to be.
followed to ensure timely posting and updating of survey maps. The HPM will also be revised to describe the requirements for the workers to familiarize themselves with-the radiological conditions in their work and travel areas. These will be completed by-Februaiy 28,1998.-
Provide werkers retuning for the next refueling outage (2R07), that are not required to receive radiation worker requalification training, infonnation about management -
4 expectations regarding worker knowledge of radiological conditions in their work and i
travel areas. Thi3 will be completed by the start date for 2R07.
Conduct an effectiveness review of the corrective actions throughout the first half of 1998, inclusive of 2R07 completion. This will be completed by June 30,1998.
Date When Full Compliance Was Achieved With the institution of the direct verbal worker briefings at strategic RCA ently points, full compliance was achieved.
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' Reply to Notice cf Vi:lation
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NRC Integrated Inspection 50-334/97-08 and 50-412/97-08 Page 4 s
VIOLATION B (Severity Level IV,' Supplement IV)
Description of Violation (50-334/97-08-05)
Unit 1 Technical Specification (TS) 6.8.1.a requircs thr' " Written procedures be established, implemented and maintained covering.;.the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, Februany 1978,"
- which includes proc beres for radiation monitoring system (RMS) operation.
Contrary to the above, the licensee failed to establish adequate RMS calibration
_ instructions in regard to determining RMS operating l@h voltage. Specifically, operating
' high voltage was not established o;. a plateau for RM-llJM-215A (Unit 1 Containment Particulate) and RM-ILW-104 (Unit 1 Liquid Waste Efnaent). This was contrary to 8
vendor manual "Victorcen Installstion, Operation, and Ma ntenance, Instruction Manual Beta Scintillation Detectors Models 843-20,843-20A, and 243-20B" and "Victorcen Instructional Manual Gamma Scintillation Detector Model 843-30" respectively; and was contrary to RMS calibration standards and industry guidance documents.
Discussion of the Allened Violation
= Duquesne Light Company (DLC) has evaluated the alleged violation and the related discussion in NRC Inspection Report 50-334/97-08 & 50-412/97-08 and does not concur with the violation. The method used for calibration of the Victoreen (vendor) Radiation Monitoring System (RMS) follows vendor recommendations for performing periodic electronic and radiation calibrations of the monitors, and utilizes approved site specific Maintenance Curveillance Procedures and Health Physics Manual procedures. These procedures use a calibration method described in the vendor's system manual which was provided with the purchase of the Beaver Valley Power Station (BVPS) Unit 1 Radiation Monitoring System'(RMS). The site calibration procedures have incorporated vendor
' improvement. in the method for maintaining source geometry during calibration of the units since the inidal issue of vendor's system manual. OLC has obtained written
- confirmation from the vendor that use of the calibration methed provided with the system
- manual including the use of the standard geometry fixtare is correct.
(With regard to the specific vendor manuals cited in the violation (Victorcen Ir-tallation,
- Operation, and Maintenance, Instruction Manual Beta Scintillation Detectors iets 843-20, 843-20A, and 843-20B and Victoreen Instructional Manual Gamma i dilation Detector Model 843-30), DLC has obtained written confirmation from the vendor that the u
manuals are intended for general use, where detector is typically used for detection of a 4
- single isotope.x This is not the case for a process radiation monitor, where the detection
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m ReplyisNotice cf Violation ;
NRC Integrated Inspection 50-334/97-08 and 50-412/97-08 =
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and measurement ofisotopes with characteristic decay energies from 80 Kev to 3 Mev are required. This is the detection range for the BVPS Unit 1 RMS.
The violsilon refers to "RMS calibration standards,".which apparently refers to the inspection report reference to ANSIN42.18. DLC has reviewed this document and Tconcludes that this standard neithe: directs nor implies that the operating high voltage be set on a plateau.- Specifically, DLC has co.icluded that ANSI N42.18, Section 5.4.7.5,
" Power Requirements" under Standards of Performance, is intended to address the effects o
on instrument accuracy ofline voltage and frequency variations; not operating highj
' i voltage variations. Also, this section appears to be directly related to a previous ~section in the standard under Specification of Performance,5.3.2.4.2, Power Variations, which.
addresses line voltage.
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The violation ~ also refers to " industry guidance documents," which apparently refers to
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the discussion of EPRI TR-102644 in the inspection report. DLC performed a search of applicable regulations and NRC guidance documerits and could not locate any NRC endorsement of tl s document. Likewise, DLC has not endorsed this document in its RMS calibration procedures.
In addition, an independent third party ' evaluation of the ali ed violation was performed N
at the request of DLC. This evaluation asseswd the calibration methodology used at BVPS and concluded that the specific count rate method of calibration is acceptable and that setting the voltage on a plateau for scintillation detectors using photomultiplier tubes is unnecessary.
In conclusion, RMS calibrations are performed in accordance with vendor recommendations and technical documentation, and applicable regulations using approved site specific procedures. Based on the above discussion, DLC respectfully requests that the violation be withdrawn.
Discussion of Radiation Monitor System Calibration Method DLC performed a detailed review of the methods used for calibrating the BVPS radiation monitoring systems in an effort to ensure that the current practice used at BVPS is correct. The following discussion summarizes this review is being provided as additional information.
(The process and effluent RMS is calibrated to measure the concentration of radioactive
. isotopes over a wide energy range (80 Kev to 3 Mev). Calibration methods developed and recommended by the vendor and used at BVPS standardizes the response of the RMS scintillation detectors in a manner that provides traceability to the original detection geometry primary isotopic calibration. The method used, as described by the vendor, is
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- called the " Specific Count Rate Method" (SCRM). The vendor acknowledges that there 5
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- NRC 1ntegrated Inspection 50-334/97-08 and 50-412/97-08 j
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are two additional methods that can bs employed to establish a photomidtiplier tube
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. (PMT) operating point for scintillation detectors, " Detector Plateau Method" and ~
" Specific Pulse neight Method." However, the vendor did not and does not recommend 3
the use of either of these methods for the calibration of the BVPS Unit 1 RMS.
!The SCRM recommended by the vendor requires setting thi low discriminator to a staridardized value. The detector is then placed in a specific geometty'and exposed to a reference transfer source traceable to the primary calibration. The PMT high voltage is
, then varied until a specific count rate is produced from the detector; Additional sources-r
, of di.fferent energies are then u ed to verify the energy response linearity and the source
' strength _ linearity of the detector. This method is similar to the " Detector Plateau -
Method," but with the added feature of using a specific count rate to select the operating 3
high voltage and eliminating the ambiguity associated wifn selecting an operating high voltage from a plateau. The primary beriefit of using the SCRM is that all detectors in the
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.same geometry will have the same gain, or sensitivity and "as-found" and."as-left" l
- analysis may bel performed as part of the calibration, to demonstrate the detector was 1
operating properly since the last calibration.
j The primary disadvantages of using the " Detector Plateau Method" for determining the PMT operating high voltage is that the sensitivity of each detector will be different and u
the same detector may have a different sensitivity after each calibration. This would result in recalculating detectcr sensitivity afler each calibration which could directly affect monitor alarm setpoints and inputs to release calculations. Setting the operating I
high voltage on a plateau would minimize count rate enang s due to voltage drift or PMT i
gain changes above or below the selected operating high voltm 'Iowever, for a non-monenergetic application (gross activity detection), such as the.esired in a nuclear power plant, selection of an operating high voltage based on a plateau would not ensure the low energy response of the system.
i 1 As noted in the inspection report, a small change in operating high voltage could result n.
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' a significant change in output count rate. However, in consultation with the vendor, any H
! such changes would be readily apparent in the nominal monitor readings. Also, as noted b
in the inspection report, performance of the BVPS Unit 1 RMS with respect to high voltage based on "as-found" and "as-left" data indicate that the high voltage power
. supplies ~are highly stable and that typically there is little if any high voltage drift.
In' summary, during factory primary calibrations, the vendor did not and does not attempt to find a plateau and does not select PMTs to obtain specific response characteristics.
Because of the variables involved in calibrating scintillation detectors to operate over a i
- wide energy range, selection of an operating high voltage using the " Specific Count Rate
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- Method" pennits not utilizing generation and u.;e of plateau data.
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