IR 05000277/1980018
| ML20004C701 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/02/1981 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20004C697 | List: |
| References | |
| NUDOCS 8106040534 | |
| Download: ML20004C701 (7) | |
Text
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KING OF PRUSSIA, PENNSYLVANIA 19406 Docket Nos. 50-277 50-278 0 2 APR 1981 Philadelphia Electric Company ATTN: Mr. S. L. Daltroff Vice President Electric Production 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen:
Subject: Health Physics Appraisal The NRC has identified a need for licensees to strengthen the hcalth physics programs at nuclear power plants and has undertaken a significant effort to assure that action is taken in this regard. As a first step in this effort, the Office of Inspection and Enforcement is conducting special team appraisals of the health physics programs, including the health physics aspects of radio-active waste management and onsite emergency preparedness, at all operating power reactor sites.
The objectives of these appraisals are to evaluate the overall adequacy and effectiveness of the total health physics program at each site and to identify areas of weakness that need to be strengthened. We will use the findings from these appraisals as a basis not only for requesting individual licensee action to correct deficiencies and effect improvements but also for effecting improvements in
"'C requirements and guidance.
This effort was identified to you in a letter dated January 22, 1980, from Mr. Victor Stello, Jr., Director, NRC Office of Inspection and Enforcement.
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During the period of June 16-27, 1980 and July 7-11, 1980, the NRC conducted the special appraisal of the health physics program at the Peach Botton Atomic Power Station, Units 2 and 3.
Areas examined during this appraisal are described in the enclosed reports (50-277/80-18 and 50-278/80-10). Within these areas, the appraisal team reviewed selected procedures and representatives records, observed work practices, and interviewed personnel.
It is requested that you carefully review the findings of this report for consideration in effecting improvements to your health physics program.
The findings of the appraisal at Peach Bottom indicate that although your overall health physics program is adequate for present operations, several significant weaknesses exist.
These include the following:
(1) Failure to establish an ALARA program.
(2) An inordinate reliance placed on contractor health physics personnel.
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Philadelphia Electric Company
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~(3) A lack of. technical proficiency among the health physics staff.
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(4) Failure to establish an adequate quality assurance / quality control program for both the internal and external dosimetry programs.
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(5)$ Lack of job / position descriptions and defined authorities and responsibil-ities, for the health physics program.
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(6) Weaknesses in the Emergency Planning Program regarding organization, training, notification, and implementing procedures.
- These findings are discussed in more detail in Appendix A, "Significant Appraisal
findings." We recognize that an explicit regulatory requirement pertaining to-each signifi %nt weakness identified in Appendix A may not currently exist.
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However, to determine whether adequate protection will be provided for the
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health and safety of workers and the pubitc, you are requested to submit a written statement within twenty (20) days of your receipt of this letter, des-cribing your corrective action for each significant weakness identified in
. Appendix A including:
(1) steps which have been taken; (2) steps which will be taken; and (3) a schedule for completion of sction.
This request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
During this appraisal, it was also found that certain of your activities did not appear to have been conducted in full compliance with NRC requirements as set forth in the Notice of Violation enclosed herewith as Appendix B.
The items of noncompliance in Appendix B have been categorized into the levels of severity as described in our Criteria for Enforcement Action dated December 13, 1974.
Section 2.201 of part 2, Title 10, Code of Federal Regulations, requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply including:
(1)
corrective steps which have been taken by you and the results achieved; (2)
l corrective steps which will be taken to avoid further items of noncompliance;
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and (3) the date when full compliance will be achieved.
You should be aware that the next step in the NRC effort to strengthen health physics programs at nuclear power plants will be the imposition of a require-ment by the Office of Nuclear Reactor Regulation (NRR) that each licensee develop, submit to the NRC for approval, and implement a Radiation Protection Plan. Each licensee will be expected to include in the Radiation protection
Plan sufficient measures to provide lasting corrective action for significant
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weaknessess identified during the special appraisal of the current health physics program. Guidance for the development of this plan will incorporate pertinent findings from the special appraisals and will be issued for public comment in early 1961.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.
If this material contains any information that you believe to be proprietary, it is necessary that you
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Philadelphia Electric Company
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make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by
.the Commission as listed in Subparagraph (b)(4) of Section 2.790.
The infor-mation sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you'in this regard within the specified period, this letter and the enclosures'will be placed in the public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
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Boyce H. Grier Director Enclosures:
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Appendix A, Significant Appraisal Findings 2.
Appendix B, Notice of Violation 3.
Office of Inspection and Enforcement
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Inspection Report Nos. 50-277/80-18 50-278/80-10 cc (w/encis):
W. T. Ullrich, Station Superintendent Troy B. Conner, Jr., Esquire (Without Report)
Eugene J. Bradley, Esquire (Without Report)
Raymond L. Hovis, Esquire (Without. Report)
Michael J. Scibinico, II, Assistant Attorney General (Without Report)
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APPENDIX A-SIGNIFICANT APPRAISAL FINDINGS
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Philadelphia Electric Company Docket Nos. 50-277
. Peach Bottom Atomic Power Station 50-278 Based on the results of the NRC Health Physics Appraisal conducted June 16-27, 1980, and July 7-11, 1980, it appears that several significant weaknesses
>3xist in your health physics program as indicated below.
Details regarding these weaknesses are found in the referenced sections of the appraisal report.
A.
Radiation Protection Organization (See Section 1 of the report)
1.
Job / Position descriptions had not been' developed for all positions within the Radiation Protection and Radwaste Departments.
2.
Administrative procedures had not been developed which defined the authorities and responsibilities of the Radiation Protection Department.
3.
An %Minate reliance was placed on contractor health physics personnel.
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B.
Personnel Selection, Qualification, and Training (See Section 2 of the. Report)
1.
A formal training / qualification program had not been established for individuals responsible for technical areas such as TLD systems, external dosimetry, internal dosimetry, and respiratory protection.
2.
Formal job descriptions and selection criteria had not been established for licensee and contractor personnel.
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3.
Requirements had not been established for an annual general employee retraining program.
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4.
A training program had not been established for the health physics professional staff.
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Some individuals in supervisory positions lacked practical experience in the areas they were assigned to supervise.
C.
Exposure Control (See Sections 3.1 of the report)
1.
External Exposure Control a.
Adequate QA/QC programs had not'been established for the offsite TLD vendor and the. licensee's in-house dosimetry program.
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Appandix A
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Tne differences between the offsite vendor and thr. licensee's in-house TLD. results had not been resolved.
2.
Internal Exposure Control (See Section 3.2 of the report)
a.
An adequate whole body counter QA/QC program had not-been astablished.
b.
Formal procedures had not been established for collection, handling, shipping, and processing excreta bioassay samples.
c.
~ Formal procedures had not been established that detailed the action to be taken if an individual received a significant
internal deposition of radioactive material.
D.
Surveys and Access Cont' il (See Section 3.3 of the report)
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Comprehensive in plant continuous air monitoring and breathing zone sampling programs had not been established.
E.
Radwaste Management (See Section 4 of the report)
Full range calibration had not been performed on the effluent monitors.
F.
ALARA Program (See Section 6 of the report)
A formal ALARA program had not been established.
G.
Internal Audit (See Section 7 of the report)
An audit had not been performed on the offsite vendor providing calibration services for portable survey meters and TLD quality control irradiations.
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H.
Administration of Emergency Planning (See Section 10 of the report)
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Proper management controls and implementing procedures were missing in the following areas:
1.
Station chemistry personnel were not included in the emergency organization to perform chemistry activities under emergency conditions.
2.
The organizational assignment of responsibility for maintaining continuity of.the radiation protection program during emergencies was not specified.
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There were procedural discrepancies in relation to leadership of the Security and Re-entry Teams.
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App;ndix A
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Emergency plan fraining (S'ee Section 11 of the report)
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performance objectives and a means to verify objectives for each emergency job function of the onsite, offsite and heal services support organizations.
2.
Provisions had not been developed for assigning qualified instructors 3.
and not adequate to substantiate that training wa
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accordance with the training procedure.
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Implementing procedures Notifications (See Section 13.4.1 of the report)
1.
"Immediate Action Steps" of each implementing instr n.
2.
Action levels for notification of the site emergen groups and local, state and federal agencies were not specified 3.
Pre planned messages and announcements for initial notifications
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were not developed.
4.
The licensee has a built-in 20 minute delay in the notification managers prior to the initiation of notifications to PF NRC.
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requiring notification of the station superintendent.Th K.
Implementing Procedures Assessment Action (See Section 13.4.2 of the report)
1.
There were no procedures describing the methods and equi used to perform emergency in plant radiological surveys.pment to be 2.
Action levels and protective action guides which will be used by assessment personnel as a basis for considering or initiating
, emergency measures to terminate, or mitigate the in the Emergency Plan Implementing Procedures.
3.
The licensee had not developed a method for initially projecting exposures or exposure rates to the thyroids of offsite individuals 4.
There were ra provisions for immediate notificat
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an actual or potential exposure to the whole body or thyroid in e
excess of protective action guides.
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Appendix A
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There were no provisions for trend analysis of assessment data.
6.
Procedures related to personnel monitoring and decontamination were not-developed which specify contamination levels that require decon-tamination or' reference decontamination procedures for various levels and types of contamination including skin contamination with radiciodine..
7.
Personnel contamination action levels were not specified which required further assessment including designation of the element of-the emergency organization responsible for performing the follow-up assessment.
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8.
The means for providing collected personnel contamination / monitoring data and information to the individual or organizational element responsible for_the radiation protection program during emergencies was not specified.
9.
The radiation protection program for use during emergencies did not address the following areas:
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a.
Personnel dosimetry (availability, use and processing);
b.
Exposure records; c.
Positive access controls; d.
Instructions to emergency workers (licensee as well as contractor or other persons / agencies augmenting the onsite emergency
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organization) regarding radiological conditions; e.
Dose assessment of exposed / contaminated persons; f.
Provisions for preventing re-exposure of individuals or ilmiting further exposure; g.
Special controls to be implemented for emergency conditions; and
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Plans for expanding the respiratory protection program in the event of an accident, e.g., expanded supply of respirators, provisions for expanded decontamination facilities and provisions for promptly refilling air bottles, etc.
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10.
Procedures were not developed which describe the concept of the operations for repair or corrective action activities to include specification of the individuals to whom the team will report, the steps to essure that the team is composed of individuals with_ proper skills, and that individuals are properly briefed as to the radiological conditions, stay times, etc. prior to the conduct of any repair or corrective action operation.
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