ML20151N835

Responds to NRC Re Violations Noted in Insp Rept 50-334/85-22.Corrective Actions:Employee Status Rept Revised to Identify Terminated Individuals,Directive Prepared for Uniform Reporting Method & Sump Secured to Prevent Release

ML20151N835
Person / Time
Site:	Beaver Valley
Issue date:	12/16/1985
From:	Sieber J DUQUESNE LIGHT CO.
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8601030153
Download: ML20151N835 (6)

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'Af Telephone (412) 393-6000 Nuclear Group Nppingport, PA 15077-0004 U.

S. Nuclear Regulatory Commission Office of Inspection & Enforcement Attn:

Mr. Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects Region 1 631 Park Avenue King of Prussia, PA 19406

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 85-22 Gentlemen:

In response to your letter of November 14,

1985, and in accordance with 10CFR2.201, the attached reply addresses the Notice of Violation wnich was included with the referenced report.

We share your concern regarding the recurring failures t., issue contractor personnel termination exposure reports.

In o.': der to prevent recurrence, a

review of past problems was conducted.

While each previous failure to issue termination exposure reports lad its own peculiarities and was handled as separate events, the review of past problems resulted in identifying a more uniform method which could be applied to the large cross-section of craft

workers, consultants and Company employees.

A new Nuclear Group Directive will be implemented to provide the controls considered necessary to establish a

more uniform method of reporting Radiation Workers who are terminating employment at Beaver Valley.

The violation concerning the Unit 1/2 shared system boundary isolation valve was reviewed to address the interface of those systems shared by both Unit 1 and Unit 2, while Unit 2 is still under construction.

These planned cross-connnects were reviewed to ensure that all potential leak paths to Unit 2 are properly isolated until such time as the lines are required for testing or operation.

The actions taken are further described in our reply.

If you have any questions concerning this

response, please contact my office.

Very truly yours, lii'RDPciUf4!!a*

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Sieber G

Senior Manager Nuclear Group f

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B$cvsrValleyPowerStation,UnitNo. 1

. Docket No. 50-334, Licensa No. DPR-66 fnspection' Report 85-22 Page 2 cc:

Mr. W. M. Troskoski, Resident Inspector U.

S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261

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DUQUESNE LIGHT COMPANY Beaver Valley Power Station, Unit No. 1 Reply to Notice of Violation Inspection 85-22 Letter dated November 14, 1985 VIOLATON A (Severity Level V; Supplement 1)

Description of Violation (85-22-04) 10 CFR 20.408, Reports of Personnel Monitoring on Termination of

Work, requires the licensee to report an individual's exposure to radiation and radioactive-material incurred during the period of employment or work assignment in the licensee's facility within 30 days after the exposure has been determined or within 90 days after the date of termination, whichever is earlier.

Contrary to the

above, the termination exposure reports for two contractor radiation workers who terminated employment at Beaver Valley Power

Station, Unit 1

on May 5 and May 30, 1985, were not issued until the omission was discovered on September 30, 1985.

In

addition, we are concerned that Violation A

is the second violation to occur in the past 12 months involving failures to issue contractor personnel termination exposure reports.

Corrective Steps Taken and Results Achieved A

site employee status report has been revised to identify individuals who have terminated.

This report is forwarded, by

Security, to dosimetry laboratory personnel on a

routine basis enabling timely processing of-personnel termination records.

This action has enabled required Radworker termination reports to be completed in a timely manner.

Corrective Steps Taken to Avoid Further Violations A

review of this and the previously identified occurrances (NRC Inspection reports 84-15 and 84-33) was conducted.

The corrective action which was taken on February 6, 1985 addressed construction worker termination reporting problems which gave rise to that violation.

The recent violation originated from miscommunication to the dosimetry laboratory regarding contractor (1

consultant and 1

security guard) personnel termination, which until presently, was communicated in a

different manner than for construction worker terminations.

',Rtply to Notico of Violation

. Insp:ction 85-22 Letter dated November 14, 15 15 Page 2 VIOLATION A, (Continued)

A Nuclear Group Directive has been prepared that will establish a uniform method of reporting Radiation Workers who are terminating employment at the Beaver Valley Power Station.

The directive provides a

format for documenting Radworker terminations to enable timely reporting of terminated Radiation Worker dose.

Additionally, the termination requirements will be included as part of initial Radiation Worker and General Employee Refresher Training.

Date When Full Compliance Will be Achieved All corrective actions should be completed and implemented by January 15, 1986.

VIOLATION B (Severity Level IV; Supplement I)

Description of Violation (84-22-01)

The BVPS Operations Quality Assurance

Program, Section A.2.2.5, Instructions, Procedures and

Drawings, and ANSI N18.7-1972, Administrative Control for Nuclear Power

Plants, require the establishment and implementation of equipment control procedures to avoid unauthorized operation of equipment.

These procedures shall include control measures such as locking or tagging to secure and identify equipment in a controlled status.

Operating Manual Chapter 1.48 specifies the methods for placing equipment on clearance, including the use of tags and locks.

Operating Manual-Table 48.6,' Safety Related Systems and Procedures, identifies the Boron Recovery System as being under this Jurisdiction.

Contrary to the above, the accidental and unauthorized operation of an unlocked and untagged Unit 1/2 boron recovery system boundary isolation

valve, 3R-79, which was on clearance, resulted in the unmonitored release of several hundred gallons of radioactive liquid from the boric acid hold tank on October 31, 1985.

Corrective Steps Taken and Results Achieved 1.

Upon. notification by Unit 2 that water was discharging from the open end of an uncompleted Unit 1/ Unit 2 cross-connect pipe, Operations and Maintenance personnel were immediately dispatched to find the leak pathway and isolate it.

The sump receiving the water was secured to assure no effluent release pathway existed to offsite areas.

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Reply,to Notice of Violation

,- Inspection 85-22 Letter dated November 14, 1985

'Page 3 VIOLATION B, (Continued) 2.

A Radiation Technician was immediately dispatched to begin sampling operations.

RadCon immediately commenced a

survey program of onsite/offsite waterways.

Liquid release calculations were performed by RadCon based on a sample taken from the open ended pipe.

The appropriate notifications were made including a written Special Report (NDlSS1:2617), dated November 29, 1985.

3.

RadCon setup survey teams to frisk all individuals who may have Deen in the area of the spill.

Two craft workers had slightly contaminated clothing (i.e.

one shoe on the first and shoes and pant cuffs on the second).

No skin contamination was detected.

4.

Construction personnel were evacuated from the building and security guards were posted to control access to the area.

RadCon performed a

comprehensive survey of surrounding areas.

This was performed to assure the adequate posting and control of affected areas.

5.

The NSOF shut the Boric Acid Hold Tank [BR-TK-7] inlet and outlet valves to stop ene leak.

The particular Unit 1 isolation valve llBR-79]

to Unit 2 was later chain locked in the closed position along with parallel valve

[lBR-83].

(Clamping devices will be placed on these ball valves to replace the chain locks.)

The open ends of these two pipes were welded closed on November 25, 1985.

6.

The Unit 2

sump contained a total of 1300 gallons of [BR-TK-7]

effluent.

This was pumped back to Unit 1 for processing via an approved Temporary Operating procedure.

7.

Radiological decontamination crews worked around the clock until Unit 2

unrestricted access could be allowed.

All work was performed under the direction of the Unit 1 Radiological Control Manual.

Corrective Steps Taken to Avoid Further Violations 1.

The clearance was reposted on all Unit 1 isolation valves and drain valves on cross-connect lines to Unit 2 using more durable plastic laminated danger tags.

All Unit 1

isolations of potentially contaminated effluent to Unit 2,

except the isolations which are ball valves, have been chain locked in the closed position.

These ball valves will be maintained closed with specially designed clamping devices.

The clamping devices will be installed by January 31, 1986.

Seply to Notice of Violation Inspection 85-22 Letter dated Ncvember 14, 1985 Page 4 VIOLATION B, (Continued) 2.

An additional dam was installed at the east end of the south trench to prevent any water in the trench from leaking into Unit 2.

The top cover of this trench has been sealed into place.

Signs have been posted on the trench cover and on the Unit 2

end of the trench to warn personnel to leave the barriers in place.

3.

Operations reviewed all Unit 1

operating flow schematics and Unit 1/

Unit 2

interconnection drawings for identification of potentially radioactive piping interconnections.

From this

review, 16 interconnecting lines were identified and in-field visual checks were performed to identify actual ties and their degree of isolation.

Of 16 interconnecting

lines, 7

were visually identified as capped and the remaining 9

do not penetrate the original installed Unit 1/ Unit 2 trench barrier.

Due to their location in the Unit 1 trench, they are presently inaccessible by normal means.

All valves in their piping scheme have been verified closed and tagged.

These valves will have locking devices installed when fabrication of the devices is complete.

As mentioned

above, a

second barrier has been installed in the trench.

4.

The Construction Department has implemented a new lesson plan for the training of construction personnel.

This is directed at eliminating inadvertent contact with equipment that may be active in a system to avoid situations such as this event.

Date When Full Compliance Will be Achieved We are in full compliance at this time.

Further actions to assure proper isolation of these interconnections, the installation of clamping devices, will be completed by January 31, 1986.