ML20050A984
| ML20050A984 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/05/1982 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20050A974 | List: |
| References | |
| NUDOCS 8204020471 | |
| Download: ML20050A984 (18) | |
Text
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"%t5 NI2) 4N 435 $sath Avenue F5ttsbutgh. Pa.
is219 March 5, 1982 Mr. R. C. Ilaynes, Regional Administrator United States Nuclear Regulatory Commission 1
Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Health Physics Appraisal Inspection 81-05 Gentlemen:
This letter forwards our response to llealth Physics Appraisal Inspection 81-05 for your information.
Due to the large number of individual items which we have identified to be corrected, we are unable to submit a schedule for accomplishing each of these items at this time.
The schedule for performing the required changes is under active review and we will submit a schedule for completion of each of these items within 45 days of the date of this letter.
/
If you have any questions regarding this response, do not hesitate to contact me.
Very trul yours, J
J.
arey Vice President, Nuclear Attachment cc:
Mr. D. A. Beckman, Resident Inspector United States Nuclear Regulatory Commission Beaver Valley Power Station, Unit No. 1 Shippingport, PA 15077 United States Nuclear Regulatory Commission c/o Document Management Branch Washington, D. C.
20555 8204020471 820329 PDR ADOCK 05000334 0
DUQUESNC LICill COMPANY Beaver Valley Power Station Unit No. 1 Reply to llealth Physics Appraisal Inspection Report No. 81-05 Letter dated December 23, 1981 A.
Organization, Responsibilities, and Staffing Finding A.I. Management should make further efforts to become less reliant on contractor health physics personnel and actively recruit technical, supervisory and technician personnel in order to sustain a permanent facility staft.
(Section 1.4.1)
Response
Forty-one Duquesne Light Co. (DLC) employees are currently enrolled in the Company Radiation Technician Training Program.
The training will continue until these individuals become qualified to replace contractor Radiation Technic ians.
A time period of one to three years will be required to phase in the DLC Radiation Technicians to replace the contractor technicians.
The current enrollement of forty-one DLC personnel and five currently qualified DLC Radiation Technicians should provide an adequate staf f for routine operations.
It is anticipated that technic'.an turnover should be completed by December 31, 1984.
Radiological Control technical and supervisory personnel are currently being recruited. The recruiting will continue until all designated supervisory and technical positions are filled.
Each designated position that is filled will require approximately six months of parallel work with a contracted individual to enabic an acceptable turnover.
It is anticipated that ninety-five percent of the designated supervisory and technical positions will be filled by December 31, 1982.
Finding A.2. Job / position descriptions currently in existence should be upgraded to reflect actual duties and responsibilities assigned for the Radiological Control Group staf f members. Also, RADCON procedures describing specific functional responsibilities should be compared to proposed or existing job descriptions and revised as necessary for consistency.
(Section 1.3.1)
1 Beaver Valley Power Station, Unit No. 1 Reply to Health Physics Appraisal Inspection No. 81-05 Page 2
Response
Job descriptions currently in use by Duquesne Light Company are the method by which the Company evaluates jobs for the purpose of our wage and hour practice. The methodology which we use to prepare, evaluate and enforce rules and regulations related to job descriptions has a long-standing history within the Company and is closely connected to the Union agreement. Except as necessary to revise job descriptions for the purposes of improving their use in administering the Corporate labor policy, we do not plan to make any modifications to the job descriptions for any other purpose. The job descriptions in use in the Operations Radiation Control Section are generic in nature and are not intended to describe in detail the duties of the various functional subgroups within the organization.
In addition, a reorganization has taken place which has redefined some jobs and has resulted in the creation of, or rewriting of, several job descriptions.
Our review of existing job descriptions sheets no incon-sistencies between actual functional duties and the descriptions used to describe generic requirements.
While we find no regulatory requirement to modify our job descriptions in accordance with your finding, we believe that there may be value in further delineating the duties, responsibilities and qualifications of individuals who perform duties in functional areas within the Radcon I
organization.
We plan to write Functional Task Descriptionc which will list the specific duties, responsibilities and required qualifications for the major functional areas within the Operations Radiettion Control organization. Those Functional Task Descriptions will become a part of of the Radiation Control Manual. We expect to complete the preparation of Functional Task Descriptions by December 31, 1982.
Finding A.3. The Quality Assurance Department should re-evaluate their audit procedures / plans and assure that audits are being accomplished in such a manner as to identify programmatic problems.
(Section 1.5.1)
!!e sponse The Operations Quality Assurance Program is written to conform to the Applicable requirements of Appendix B to 10 CFR 50 and Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operations)".
Packaging of Radioactive Material for Transportation in accordance with 10 CFR 71 is identified in Appendix B to the Operations Quality Assurance Program as being covered by the Program.
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Beaver Valley F ver Station, Unit No. I j
Reply to !!ealth t'hvsics Appraisal Inspection No. 81 - 0.*'
page 3 l
Yearly audits are conducted by the Quality Assurance Department to assure station compliance with 10 CFR 71 for packaging and shipment of radioactive ma t e r ia l. The last such audit was performed by trained and qualified auditors in Ma rch 1981 (BV-1-81-07).
The arean reviewed during the audit and found to be satisfactory were:
labeling, storage and monitoring of radioactive waste packages, shipment vehicle monitoring and inspection, waste packaging seals and closures, shipment records and worksheets and DOT requirements and specifications for radioactive waste shipments.
Ano the r audit of this area is scheduled for March, 1982.
H.
Personnel Selection, Qualification and Training Program Finding B.I. Job / position descriptions were not established for all positions j
within the dodiological Controls Department.
(Section 2.3) a
Response
i Job descriptions which contain inconsistencies as stated in the details of Section 2.3 of the llealth Physics Appraisal report will be modified 4
by July 1, L982.
Functional Task Descriptions will be prepared for all major functional positions in accordance with the response to Finding A.2 above.
Finding B.2. Not all job / position descriptions contain selection and qualifica-tion criteria actually used in the hiring and promotion process such as, education, training and experience related to health physics.
(Section 2.3)
Response
Proposed job / position descriptions and existing job / position descriptions 4
are currently being written or revised to include selection an6 qualifi-cation criteria.
Inclusion of the job / position selection and qualification criteria should be completed by December 31, 1982.
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Beaver Valley Power Station, Unit No. 1 Reply to Health Physics Appraisal Inspection No. 81-05 Page 4 C.
Exposure Control Program Finding C.I. (Item 1) The Respiratory Protection Program was found to be inadequate in that:
An individual qualified in accordance with the requirements of NUREG-0041, is not assigned the responsibility for the overall Respiratory Protection Program.
(Section 3.2.5.2)
Response
An individual has been assigned the responsibility for the overall Respiratory Protection Program.
This program is currently under the direction of a health physicist.
Finding C.I. (Item 2) The Respiratory Protection Program was found to be inadequate in that: The air sampling program is unacceptable.
(Sections 3.2.5.2 and 3.3.3)
Response
The Radcon manual is being revised to incorporate the changes to the air sampling program as recommended under Section 3.2.5.2 and 3.3.3.
Specific actions which have been taken include:
1.
A test of r, representative population of HP-210 detector probe assemblics has been conducted for defining the methods of determining and analyzing the mean and range of response to calibration sources.
This information will be directly applicable to calibration and QC testing of new and inservice MS-3 scaler /HP-210 probe combinations.
2.
Tests have been conducted on the stabilized assay meters using NBS traceable mixed radiciodine equivalent iodine collection cartridges which were purchased specifically to assist in calibrating the SAM-2/RD-22 units.
Additional methods of electronic alignment have been defined. A draf t revision to RP 5.13 has been written to incorporate specific guidance for calibration of this instrument.
3.
The use of Whatman-41 filter paper has been discontinued and a filter paper which provides greater than 99% collection efficiency for 0.3 m particles has been initiated. The range of flow rates for which this efficiency is applicable covers the specified flow rates within current air sampling procedures.
Beaver Valley Power Station, Unit No. 1 Reply to Health Physics Appraisal Inspection No. 81-05 Page 5 4.
A review of RP-7.5 was performed and it has been verified that the use of an area correction factor of 3 ijt correct.
Specific actions which will be taken include:
1.
The revision of air sampling procedures to specify the use of the appropriate filter media, proper method of marking the filter for direction, indicating the corresponding collection efficiencies at various flow rates (as deemed necessary), and ensuring limitations on flow rates for various filter media are clearly specified in the procedure will be performed.
2.
The revision of the SG-3 procedure RIP 5.6 and SAM-2/RD-22 procedure RP 5.13 will be performed.
3.
The air sampling procedure referring to waiting four hours between collection and counting of particulate samples will be revised to accommodate the comparison of short-lived radionuclide activity to the 10 CFR 20, Appendix B. Table I, Column I listing.
4.
The analytical methods for tritium analyses which require a 24-hour waiting period will be re-evaluated and, if feasible or necessary, a procedure will be developed to allow a more rapid analysis.
Finding C.1. (Item 3) The Respiratory Protection Program was found to be inadequate in that:
Fitting and training for filter equipped respiratory pro-tection is not consistent with the overall program.
(Section 3.2.5.2)
Response
Since the appointment of a respiratory protection program supervisor in April, 1981, part of the long range goal for respiratory protection is to revise, upgrade and clearly define respiratory protection equipment, its applications and associated support (maintenance, training, QC) in a separate respiratory protection procedure manual.
Within this framework, plans are set forth to revise the training of personnel for wcaring of the resr*ratory equipment.
The auditor indicated that training for all but the air purifying respirator meet the NUREG-0041, Section 8.4 criteria and that the fitting of the respirator should be evaluated by a quantitative fit test method as stated in NUREG-0041, Section 8.5.2.2.
Beaver Valley' Power Station, Unit No. 1 Reply to Health Physice Appraisal Inspection No. 81-05 Page 6 It is the opinion of the respiratory protection program supervisor that the quantitative fit test program is the method of choice when deciding upon the quality of facepiece fit.
This fitting process also serves as a method of " challenging" the individual in a work type environment as approximately 6 exercises must be performed over a period of approxi-mately 10-15 minutes for such a test.
In addition, the workee who is identified as having dif ficulty obtaining an adequate seal is given special attention and instruction at the fit test booth in donning and adjusting the facepiece to obtain the desired quality seal.
Steps which have been taken:
1.
The quantitative fit test booth has been and is currently operated in an effort to document the facepiece seal quality on a significant percentage of the total station population for the full-face air purifying respirator. The respiratory protection program currently does not restrict an individual f rom respirator use if no such test has been made; however, when poor facepiece seals are identified during a quantitative fit test, an effort is made to evaluate the quality of the fit in another equivalent category respirator device used at BVPS.
RP-10.8 has been revised to reflect this practice.
Steps which will be taken:
1.
A goal of the respiratory protection program is to use the results of the quantitative fit testing program for the controlled issue of respiratory protection equipment to qualified individuals.
Steps taken toward this goal include the request for a computer program listing format which will itemize the devices, measured protection factor, test date and nuclear physical date for trained respirator waarers.
The impleuentation philosophy will be detailed in a revision of Appendix 6 of the RCM and the Maintenance Manual, Section Y.
Finding C.1. (Item 4) The Respiratory Protection Program was found to be inadequate in that:
Annual medical examinations are not performed as required by NUREG 0041.
(Section 3.2.5.2)
Response
Our medical department has reviewed this requirement and is of the opinion that our current physical examination policy regarding employees assigned to nuclear power stations is adequate to meet the intent of NUREG 0041.
Currently, this policy consists of:
a) physical examinations upon initial employment or work assignment and at least triennially thereafter
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,e ye Beaver Valley Power Station, Unit No. 1 Reply to llealth Physics Appraisal Inspection No. 81-05 Page 7 b) medical statements required for employees returning to work following absence due to a Non-Occupational Illness or Injury (NOI&I) c)
review of n;edical records to determine the physical status of employees who were absent due to NOI&I d) more frequent examinations for employees who appear to have recurring medical problems e) annual eye examinations for the qualification of inspection personnel Finding C.1. (Item 5) The Respiratory Protection Program was found to be inadequate in that:
The inspection, testing and repair of air supplied respiratory protection equipment is unacceptable based on documentation and training.
a
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(Section 3.2.5.2)
Response
Steps which have been taken:
1.
Appropriate training has been conducted by Mine Safety Appliances Co. for four individuals to qualify as certified MSA-401 air mask repairmen.
Two of these individuals are hbintenance Instrument foremen.
2.
A review and change has been made of Operations Surveillance Test procedure 1.33.19 (revision 34) regarding the periodic inspection and testing of MSA-401 air mask respirators.
3.
All maintenance of the air purification equipment is currently being performed as detailed by the respiratory protection program supervisor.
Specific draf t maintenance procedures for air purification equipment have been written.
4.
Calibration and operating procedures have been written and OSC approved for the carbon monoxide airline monitors which are integral parts of the air purifying filter assemblies.
(CP-173 revision 0)
Steps which will be taken:
1.
In recognition that " mechanical experience alone is not enough when health and safety is involved," maintenance training programs for all respiratory protection equipment will be developed through the cooperative efforts of the training department supervisor and the respiratory protection program supervisor.
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Beaver Valley Power Station, Unit No. 1 il Reply to Health Physics Appraisal Inspection No. 81-05 Page 8 i
F Finding C.2. The Quality Ar,surance program for internal exposure control does not contain provisions for an independent evaluation of the onsite (licensee's) lung / thyroid counter and the offsite (vendor) lung / thyroid t
counter.
(Section 3.2.6)
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Response
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l Steps which have been taken:
I 1.
A manufacturer of a state-of-the-art human phantom with separate i
compartments for upper torso, lungs, G1 tract and thyroid and j
k solid NBS traceable sources has been located for the purposes of QC testing and calibration of the lung / thyroid counter activities.
Steps which will be taken:
)
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1.
The administration of the QC test program will be arranged such that the vendor evaluation will be a blind study.
l 2.
A QC program will be developed to provide cross-correlation of data l
between Presbyterian-University Hospital (vendor lung / thyroid in-vivo j
gamma analysis services) and the BVPS lung / thyroid counter using the human phantom.
A* ne sources are NBS traceable, the information 5
will provide a method of leveloping a periodic QC evaluation of both l
counting facilities.
D.
Surveillance Program 4
Finding Y
D.1. The licensee procedures were cumbersome, did not adequately define the J
basis for surveillance activities, lacked sufficient detail, and many were outdated. Specific subjects requiring improvement include:
l instrument selection and use; survey frequencies; instrument calibra-
[
tion; air sampler calibration; the methods for performing checks t
I and calibration of Radeon and Chemistry Counting equipment; and, use of protective clothing.
(Section 3.3.2) t t
Response
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The Radeon Manual is being revised continually to reflect regulatory f
k changes and updated methods of performing work functions at BVPS. Two individuals have been assigned the task of making necessary revisions to the manual. As new equipment is purchased, i.e., instruments and radio-active standards, procedures will be revised to state current Radeon
[
practices.
Procedures referring to obsolete equipment have been deleted I
from the manual.
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Beaver Valey Power Station, Unit No. 1 Reply to llealth Physics Appraisal Inspection No. 81-05 Page 9 It is anticipated that procedure problem areas, addressed in Section 3.3.2 of the Appraisal report should be resolved by December 31, 1982.
Finding D.2. Problems appeared to exist between wording of procedures and the Quality Assurance Group's interpretation.
(Section 3.3.2)
Response
As previously noted, Radcon procedures are under continual review and revision.
Every ef fort is made to clearly state the actions required within the body of the precedure.
Problems may have existed in the past between the wording of the procedures and the Quality Assurance Groups interpretation, however, there have not been any problems in this area during the past two years.
It is recognized by Quality Assurance that absolute literal interpretation is not always appropriate. When there is a question on the intent of a procedure, the Radiological Control supervision is consulted.
As long as their inter-pretation does not violate the requirements it is accepted by Quality Assurance.
Finding D.3. The RWP program was inadequate and was not being followed.
(Section 3.3.2)
Response
All sections of the Radeon Manual, referred to in Section 3.3.2 of the Appraisal Report, have been revised for uniformity stating the requirements for Radiological Work Permits (RWP's).
In addition RP 8.1 has been rewritten deleting references to Blanket RWP's and Extended RWP's.
Beaver Valley currently uses only two types of Permits - Radiological Work Permits and Radiological Access Control Permits (RACP's).
Radcon supervision has to approve all RWP's and RACF's prior to issue. All individuals working under RWP's or enter'.ng controlled areas under RACP's have to sign the appropriate section of the Permit (s) indicating that they understand and accept the conditions and controls of the Permit.
Radeon Procedure 8.1, Radiological Work Permit, was placed into effect on May 2, 1981.
Finding D.4. The frequency for performing radiological surveys requires re-evaluation.
(Section 3.3.2)
Beaver Valley Power Station, Unit No. 1 Reply to IIcalth Physics Appraisal Inspection No. 81-05 Page 10
Response
The specific comments made in the audit report in this section give reference to Appendix 4 and Chapter 1 of the Radiation Control Manual. Currently, the general approach to these required surveys and their epecified types and frequency of survey measurements is a separate effort from the job support function surveys.
There is usually no credit given to the required surveillance prograa for a survey taken in the same location for a work task.
It is, therefore, possible that although current survey information is available for a given location, a review by the auditor of ' required' survey data may appear to indicate surveys are only obtained at the specified frequency in Appendix 4 or Chapter 1.
It may also appear to indicate that other areas, such as exit points from Controlled Areas, are not surveyed because such a location may not be listed on the ' required' survey schedule, when in fact, survey data is obtained for other reasons.
Steps which have been taken:
1.
A continuous ef fort has been given over several months to upgrade the quality and accurately represent plant equipment locations on all Radeon survey maps.
The use of the improved maps has been implemented.
2.
Recently, in-plant and on-site gridded maps have been developed and will be used to re-evaluate and define important ' required' surveillance areas.
Steps which will be taken:
1.
The minimum surveillance fraquency and types of measurements specified in Appendix 4 and Chapter 1 of the Radiation Control Manual will be re-evaluated.
2.
If feasible at this time, a method will be devised and implemented to take credit for job support surveys to meet the minimum required surveillance program specifications.
Finding D.5. Management emphasis on the need for all personnel to adhere to procedures is required.
(Section 3.3.2) e I
Beaver Valley Power Station, Unit No. 1 Reply to llealth Physics Appraisal Inspection No. 81-05 Page 11
Response
Steps which have been taken:
1.
Radcon supervision has appointed an individual who is assigned to follow-up training and documentation for the F1dcon group concerning new and revisions to existing procedures.
This individcal is also responsible for checking off Radiation Technician trainees on practical applications of Radcon procedures.
2.
Qualification criteria have been developed for evaluating contractor Radiation Technicians performance on BVPS Radeon procedures which are applicable to the assigned job tasks.
3.
The emphasis of Radcon and Training group efforts in establishing procedural training indicates that management expects personnel to adhere to practices within written procedures.
4.
A Radeon Supervision / Technical / Administrative Surveillance Report system has been developed and implemented to provide an internal supervisory audit system for Radcon operations.
This audit system documents the observation of work practtees, area posting and/or records for compliance with current Radcon Ibnual procedures; and reports remarks, corrective actions and/or recommendations to Radcon supe rvision.
Finding D.6. The mechanism for and records of the repair of Radcon instruments requires improvement.
(Section 3.3.3)
Response
Steps have been taken to send out of service Radcon survey instruments to qualified vendors for repair services.
This practice has reduced the percentage backlog of instruments requiring repair, adjustment and calibra-tion.
A new instrument repair shop, in addition to the present instrument shop, has been constructed and will be put into full use by March 15, 1982.
This shop will be devoted completely to the repair and inspection of radiation tunitoring instrumentation only.
This new instrument shop will contain an equipment history card file.
The problem (s) & repair (s) made to each instrument, brought in for maintenance, will be entered onto its corresponding history card.
In this way an historical record will be maintained and made available so that trending or possible generic problems encountered can be analyzed.
Beaver Valley Power Station, Unit No. 1 Reply to Health Physics Appraisal Inspection tio. 81-05 Page 12 Finding D.7. The airborne radioactive material sampling program is inadequate.
(Section 3.3.3)
Response
Steps which have been taken:
1.
Maintenance group air sampling instrument calibration procedures have been written to upgrade the method of calibration. New calibration test equipment, traceable to NBS, has been purchased and received and will be used on Radeon air sampling equipment in future calibrations.
2.
Draft revisions of all Radcon air sampling instrument procedures now specify a calibration frequency. The procedures specify the need for air flow calibration specific to the type of collection media, filter holder and other equipment used to connect the sample collection head to the air mover.
Steps which will be taken:
Refer to the response to finding C l.(Item 2) for additional information concerning the changes in the air sampling program and actions scheduled to be taken.
Finding D.8. The counting equipment calibration and use programs were not in accordance with the recommendations contained in ANSI-N323 and ANSI-N42.14.
(Section 3.3.3)
Response
Steps which have been taker 1.
Refer to the response provided to finding C.l. (Item 2) in which specific counting equipment calibration tests have been addressed.
Steps ahich will be taken:
1.
As indicated in response to finding C.1. (Item 2) counting equipment procedures will be revised to include more specific calibration guidance and a frequency of re-calibration will be specified.
2.
We will review our Chemistry Manual with regards to the recommendations contained in ANSI N42.14 and make changes where we identify deficiencies as compared to the intent of the Standard.
Beaver Valley Power Station, Unit No. 1 Reply to llealth Physics Appraisal Inspection No. 81-05 Page 13 I
Finding D.9. The quality control programs for Chemistry counting equipment and smear counting instrumentation were deficient. (Section 3.3.3)
Response
We have consistently demonstrated accurate calibration of GeLi detectors in any geometry when the NRC has checked them.
We are of the opinion that our current method of quality control for Chemistry counting equip-ment is effective.
4 Refer to the response to findings C.I.
(Item 2) and D.8. for changes to be made on quality control for smear counting instrumentation.
Finding D.10. The calibration program for portable survey instruments is not in accordance with the recommendations contained in ANSI-N323. (Section 3.3.3)
Response
Steps which have been taken:
1.
Numerous portable survey instrument procedures have been revised.
These revisions include:
a.
. calibration at sufficient number of points on each scale (ANSI-N323 section 4.2.2) for all instruments b.
improved instructions for making required adjustments c.
acceptance criteria changes and/or additions for calibration and daily source checks d.
recording of "as found" and "as lef t" data c.
detector orientation requirements during calibration for compatibility with procedures instructing the user for the normal orientation for surveys f.
specifying the calibration jig to be used, and 1
g.
use of a low activity calibration source and geometry for low l
range scale calibration of instruments.
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i Beaver Valley Power Station, Unit No. 1 Reply to llealth Physics Appraisal I
Inspection No. 81-05 Pa ge 14 2.
The Victoreen R-Chamber procedure RIP 1.3 has been revised and the chambers have been calibrated with radiation energies comparable to those used for calibrating the survey instruments.
Steps which will be taken:
1.
An evaluation of the calibrator radiation beam uniformity is to be performed.
2.
All portable survey instruments procedures will be revised to indicate the additional calibration requirements listed above.
Finding D.11. Additional justification is needed to support the calibration factor used with portable neutron survey equipment.
(Section 3.3.3)
Response
The manufacturer of the PNR-4 neutron rem counter who obtained neutron spectra measurements in the Containment Building has been contacted to provide verification of an appropriate calibration factor.
Upon receipt of required documentation from the manufacturer, the service agreement requirement for calibration will be changed if necessary.
E.
Radioactive Waste lhnagement Program Finding E.1. Formal documented job / position descriptions should be developed for the managerial and oversight responsibilities in the areas of solid, liquid and gaseous radwaste sytems.
(Section 4.2)
Response
The Environmental Technical Specifications (ETS) are currently being reviewed and changes being negotiated between the station, Franklin Research Institute and the NRC.
It is expected that the programs implemented to comply with the ETS will provide the necessary managerial oversight in the areas of solid, liquid and gaseous waste system.
4 Beaver Valley Power Station, Unit No. 1 Reply to Health Physics Appraisal Inspection No. 81-05 Page 15 As detailed in the report, a full time daylight supervisor monitors the operation of the solid waste system and radioactive gas / liquid inventories are tracked on a daily basis to insure that system input is within the design of the station processing capability. We do not believe that there is suf ficient need to assign additional personnel in the areas of liquid /
gas rad waste and that these responsibilities are being ef fectively managed by shift personnel. The ultimate goal of the programs, "to limit releases to as low as reasonable achievable" values has been effectively carried out and demonstrated over the yerc.
Incorporation of the ETS into all operating plants is anticipated by the NRC to be completed during the current fiscal year. Therefore, any additional job description or managerial oversight required to meet these regulations will be implemented at that time.
Finding E.2. A permanent, liquid radwaste processing capability (such as the temporary demineralizer) should be installed to provide continuously available back-up processing capability to the present liquid rad-waste system (evaporator and polishing demineralizer).
The system should be designed taking into consideration the ALARA practices of Regulatory Guide 8.8 and the design guidance of Regulatory Guide 1.143. (Section 4.3.1)
Response
A Design Change Package (reference DCP 471) has been initiated to modify the existing backup processing capability.
It is not possible at this time to give a credible schedule to complete this modification, nor do l
we find it necessary since the installed system will continue to provide the necessary backup processing capability until such time that the modifications are completed.
1 Finding E.3. A high level alarm for the steam generator drain tanks should be installed in the control room.
(Section 4.3.1)
Response
The inspection report incorrectly indentified the absence of high level alarms on these drain tanks and an overflow to the outside area. Two high level alarms and a high-high level alarm are provided (reference annunciators A2-36, 37, 45) in the contro; room and two stages of overflow are provided on the drains tanks. The tanks overflow to each other and a common 3-inch overflow is routed to the Decon Building.
Beaver Valley Power Station, Unit No. 1 Reply to Health Physics Appraisal Inspection No. 81-05 Page 16 The high-high overflow referenced in the report is actually a tank vent that takes in outside air for sweep gas purposes.
The two stages for design overflow and communication would prevent water from entering this vent.
F.
Facilities and Equipment Findings 1.
The health physics counting room requires additional space and shielding. (Section 6.1.1) 2.
The chemistry counting room requires added space to facilitate the use of existing equipment and for the adequate storage and processing of samples.
(Section 6.1.2) 3.
A dedicated area with adequate space and shielding is required for portable instrument calibration.
(Section 6.1.1) 4.
The storage of anti-contamination clothing and contaminated equipment requires a dedicated area with increased capacity.
(Section 6.1.1)
Response
We are currently pursuing the construction of an Emergency Response Center and Training Facility.
It is expected that these buildings will provide addi tional onsite capability once personnel are relocated to those facilities.
It should be understood that during the period of the audit, all available space was severly overtaxed due to the fact that the Unit was recovering from a major outage and there were many additional personnel onsite for that purpose. We are limited in the expansion of existing facilities by seismic considerations, physical and structural constraints, and 10 CFR 73 require-ments; therefore, we do not anticipate any new significant construction within the protected areas beyond that already identified at this time.
We can only provide additional capacity in cases where safety or potential non-conservatism being introduced into counting equipment are issues. We have not identified significant issues within sections 6.1.1 and 6.1.2 and conclude that our available space, although it is limited, is adequate to safely perform functions within the scope of existing regulations.
We are however, continuing our efforts in restricting storage of contaminated equipment in any non-radiologically controlled areas and organizing equip-ment within existing areas to provide additional storage capacity. We expect that the problems associated with the storage of contaminated equip-ment will be resolved with the install tion of a new solid waste storage area which is presently in the desigt stage of development.
In addition, we have assigned additional counting personnel full time during outage periods to reduce the backlog of samples.
This will limit the need for additional storage space for samples
h.
Beaver Valley Power Station, Unit No. 1 Reply to Health Physics Appraisal Inspection No. 81-05 i
Page 17 The problem with inadequate air flow through the chemistry lab exhaust hood has been resolved. Air flow monitoring has been provided on the lab exhaust hood.
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