IR 05000146/1996001

Insp Rept 50-146/96-01 on 961119-21.No Violations Noted. Major Areas Inspected:Control & Monitoring of Asbestos, Control of Workplace Industrial Hazards & Conduct of Industrial Safety Program

ML20133P952
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	01/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133P942	List: IR 05000146/1996001 ML20133P938
References
50-146-96-01, 50-146-96-1, NUDOCS 9701270165
Download: ML20133P952 (8)

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i U.S. NUCLEAR REGULATORY COMMISSION '

REGION I

Docket No: 50-146 License No: DPR-4 '!

l Report No: 96-01  ;

Licensees: GPU Nuclear Corporation and '

Saxton Nuclear Experimental Corporation Facility: ' Saxton Nuclear Experimental Facility Location: Saxton, Pennsylvania 16678 -

l Dates: November 19-21,1996

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Inspector: Thomas F. Dragoun, Project Scientist Approved by: John R. White, Chief, Radiation Safety Branch Division of Reactor Safety

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• 9701270165 970121 PDR ADOCK 05000146

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EXECUTIVE SUMMARY Saxton Nuclear Experimental Facility NRC Inspection Report No. 50-146/96-01 '

Addition of temporary trailer facilities and new building construction to support decommissioning was well planned. Safety practices and supervisory oversight of the small work force was good. The licensee's process of performing safety reviews as required by 10 CFR 50.59 is inconsistently implemented.

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Reoort Details Summarv of Plant Status Construction of the new decommissioning support building is near completion. Grading and placing of crushed stone for access roads to the new building was underwa Asbestos removal in the reactor containment continue DI Industrial Safety l Insoection Scoce The inspector reviewed the fcilowing areas:

• Control and monitoring of asbestos:  !

• Control of workplace industrial hazards; and, l

• Conduct of the industrial safety progra i Observations and Findinas The inspector interviewed the TMI-based industrial hygienist / safety specialist, who was on site for a weekly visit, regarding the industrial hygiene and worker safety programs. The inspector noted that a industrial hygiene made frequent periodic visits (biweekly) to evaluate asbestos monitoring activities and sampling data to assure that the asbestos enclosures maintained proper integrity, and to verify the acceptability of worker breathing zone j Respirators and protective clothing for the asbestos removal are required. The protective equipment and clothing appeared appropriate and was properly use Use of confinements to control the spread of airborne asbestos in reactor containment was good. The packaging and handling of radioactively contaminated asbestos was performed in accordance with the regulatory requiremerit Lighting and ventilation in work areas inside containment was good. Scaffolding, walking, and working surfaces were in good condition. Openings were guarde GFCI protected electrical distribution panels were installed in the work areas to provide temporary power. Fire prevention measures were appropriate. The licensee has adopted the requirements of the Three Mile Island safety manual for use at the site, C_onclusions Control of industrial hazards and toxic material was effective and well planned

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07 Quality Assurance in Operations 07.1 Review and Audit and Desian Chanae Functions Inspection Scoce The inspector reviewed:

• the licensee's practice and planned use of Readiness Review Committees;

• the licensee's process of conducting 10 CFR 50.59 reviews; and, e selected engineering changes in the facility that were made in accordance with the requirements of 10 CFR 50.5 Observations and Findinas The Manager, Decontamination and Decommissioning Engineering (DD&E) described the process for the conduct of 10 CFR 50.59 reviews and provided documentation of completed reviews. Since the Engineering department is expected to coordinate and plan changes in tF ility, as necessary to support decommissioning activities, the licensee expects tt ..gn an engineering staff to the site to conduct evaluations as required ,10 CFR 50.5 In review of this area, the inspector noted that the quality of the reviews completed so far were inconsistent. While some reviews clearly identified the change, documented the safety evaluation that was performed to support the change, described the licensing basis that applied, and the basis for the determination that no unreviewed safety question existed, other reviews failed to be supported by the same quality of effort and documentation. The inspector noted that the licensee's process was unclear and lacked specific guidance. The inspector described the NRC expectation for the quality of 10 CFR 50.59 evaluations, and noted that it was imperative that the licensee improve the process for performing 50.59 evaluations prior to executing significant decommissioning activities. In response, the licensee committed to improve the process by establishing, implementing and maintaining an effective procedure designed to assure consistency in acceptability, approach, and quality. The Manager, DD&E, stated that a policy and procedure would be developed that was modelled on the TMl process and incorporate industry group experiences and recommendations for decommissioning. This will be completed b' fore the start of decommissioning at the Saxton Site. This matter will be reviewed in a future inspection (Inspector Followup Item 50-146/96-01-01).

As a matter of policy and common practice, the licensee's upper management establishes Readiness Review Committees to provide a multi-disciplinary review of major projects. The inspector reviewed records of activities and findings of various committees that were establie:,ed by the licensee, and noted that the efforts appeared to be effective in the independent evaluation of safety performance of activities. While there is r o formal requirement for these types of review, the Vice President SNEC (Saxton N Jclear Experimental Corporation) stated his intention to use Readiness Review Conimittees (RRC) for evaluation and assessment of major

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3-evolutions, such as removal of the reactor pressure vessel. Accordingly, RRC hold points will be incorporated'into the project schedules in order to accommodate RRC review activities. The inspector noted that the practice appeared to be a good initiative in independently verifying and validating the effectiveness of processes, procedures, and work practices.

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. Conclusions j While some efforts relative to performing safety evaluations in accordance with 10 CFR 50.59 were acceptable, the inconsistent quality of effort and supporting

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documentation gave evidence that the licensee's program is not sufficiently developed to support significant decommissioning activitie : R1 Radiological Protection:

R1.1 Imolementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71

L Insoection Scooe (Temoorary Instruction 2515/133)

The inspector reviewed the following areas:

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e Qualifications of the supervisor overseeing radioactive wesa shipments;

-e Training certifications of personnel involved in radioactiv - : aste shipping i activities;

!- Shipping procedures; and, e.

e implementation of SI units and revised A1/A2 values as required be the revised Department of Transportation regulations.

n Qhagrvations and Findina '

l Interviews with the radioactive waste handling supervisor and review of applicable

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records indicated that he had extensive experience and was highly qualified. The

computer program "RADMAN," used to classify shipments and prepare shipping j; documents, was determined to contain revised A1/A2 values, waste stream data e based on site characterization studies, and the uniform manifest format required b'y the burial site.

The inspector reviewed the licensee preparations, documentation, and plans for a shipment of contaminated dirt and asbestos, scheduled to occur in about two

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. weeks. The planning and preparation wat well done and in accord with regulatory

- requirement Conclusions

, Revised DOT and NRC transportation regulations were properly implemented.

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- R1.2 Radiation Protection Proaram Insoection Scoos

. 1 The inspector reviewed:

• . Use of Radiation Work Permits, o Protective clothing use, o Personnel dosimetry and exposure records, e Routine area and personnel exit surveys,.

e ALARA implementation, o Pre-job Briefings, and e HP Technician Job Coverage Observations and Findinas Radiation' area warning signs, postings, and banicades inside the containment were effective in identifying radiological hazards, controlling personnel access, and conveying information. HP technicians provided full time job coverage. Exit surveys for skin and clothing contamination were effectively accomplished by use of a sensitive, computerized, whole body scanne The inspector noted that the Radiation Work Permits were based on initisi job radiation conditions and did not appear to be frequently updated. in followup in this i area, the inspector determined that only the Group Radiological Control Supervisor (GRCS)is authorized to change a RWP; that comprehensive worker pre-job briefings 1 are conducted by the GRCS using a standardized checklist that references important l safety aspects of the job. The briefings typically include photographs of the jobsite, a detailed description of current radiological conditions, a discussion of the radiation protection requirements, and the ALARA methods and measures expected to the implemented. The GRCS stated that the practices and policies established by the radiation protection program were designed to accommodate the needs and requirements of a small work-force that may not have any extensive experience in working in radiologically controlled area Conclusions l l

. The radiation protection program.was established, implemented, and maintained to meet the regulatory requirements in 10 CFR 2 Exit Interview (Inspection Procedure 30703)

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, The inspector presented the inspection results to members of licensee management at the

conclusion of the inspection on November 21,1996. The licensee acknowledged the findings presented.'

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PARTIAL LIST OF PERSONS CONTACTED Licensee Perry Caramel, Site Supervisor l William Heysek, Licensing Department  ;

Joe Kuehn,Jr., Vice President SNEC l Arthur Paynter, Radiation Safety Officer  !

Rick Miller, industrial Hygienist i Sylvia Morris, Public Affairs

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Louis Shamanek, Assistant Site Supervisor  !

Lawrence Simon, Radwaste Shipping Supervisor ,

- Galen Tomlinson, GRCS j

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Sexton Citizens Task Force ,

Charlie Barker, Task Force Member  ;

Roger Granlund, independent Assessor (Penn. State RSO) ]

l Commonwealth of Pennsvivania ,

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Kenneth Singh, Bureau of Radiation Protection

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INSPECTION PROCEDURES USED IP 30703: ENTRANCE AND EXIT INTERVIEWS l Tl 2515/133: Implementation of Revised 49 CFR Parts 100-179 and 10 CFR  !

Part 71 1 l

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ITEMS OPENED, CLOSED, AND DISCUSSED i

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Opened 50 146/96-01-01 IFl Revise policy for conduct of 50.59 safety reviews i

Closed

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' LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable i CFR Code of Federal Regulations DD&E Decontamination and Decommissioning Engineering ;

DOT Department of Transportation l GFCI Ground fault circuit interrupter )

GPU General Public Utilities Corporation GRCS Group Radiological Controls Supervisor I-H Industrial hygiene IP inspection procedure I NRC Nuclear Regulatory Commission l RWP Radiation Work Permit Si international System ,

TMl Three Mile Island power station  !

TS Technical Specifications i

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