IR 05000277/1985028
| ML20135G433 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/09/1985 |
| From: | Bicehouse H, Dragoun T, Kottan J, Pasciak W, Zibulsky H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20135G432 | List: |
| References | |
| 50-277-85-28, 50-278-85-26, NUDOCS 8509190072 | |
| Download: ML20135G433 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No /85-28 50-278/85-26
Docket Nos. 50-277 50-278 License No DPR-44 Priority -
Category C DPR-56 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
- Facility Name
- Peach Bottom Atomic Power Station Inspection At: Delta, PA
Inspection Conducted: July 22 - 26, 1985 Inspectors: N.(,N .; -
H. J. 31cehouse Radiation Specialist 4ff!ff date
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/h/N l J. Kottsn, l'atioratory Specialist / /date
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T. F. ' Dragoun,
. tuk Ea adiation Specialist w date
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- ll Ylh/$h ertil.}ibulsk,Sfeguard9 Chemist / / ate i Approved by:
W.V fu e r b(b0
)a'scyk, Chief
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9[ i BWR R Iiological Protection Section fd'te ,
l Inspection Summary: Inspection on July 22-26, 1985 (Combined Inspection Report Nos. 50-277/85-28; 50-278/85-26) '
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Areas Inspected: Special, announced team inspection of the licensee's radia-tion protection and chemistry programs including: previously identified items, organization, selection, qualification and training, procedures, radiation protection program, radiological and chemical confirmatory measurements and audits, appraisals and management oversight. The inspection involved 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> onsite by 4 regionally-based inspectors.
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Results: No violations were noted within the areas reviewed. Several apparent weaknesses in the licensee's radiation protection and chemistry programs were brought to the licensee's attention.
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DETAILS 1.0 Persons Contacted During the course of this special inspection, the following personnel were
, contacted or interviewed:
1.1 Licensee Personnel Mr. D. Ahmuty, Administrative Assistant - Training Mr. G. Barley, Assistant Plant Chemist 1 Mr. R. Bullmer, Superintendent Corporate Nuclear Training Section Mr. P. Dunn, Training Instructor
- Mr. R. Fleischmann, Manager, Peach Bottom Atomic Power Station Mr. N. Gazda, Health Physicist - ALARA
- Mr. A. Hilsmeir, Senior Health Physicist Mr. T. King, Technical Assistant
- Mr. W. Knapp, Director, Corporate Radiation Protection Section
, Mr. G. McCarty, Health Physicist - Support
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Mr. D. Mowery, Chemist
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Mr. S. Nelson, Health Physicist - Applied
, Mr. A. Odell, Chemical Engineer
- Mr. D. Oltmans, Senior Chemist Mr. F. Polaski, Outage Plar ning Engineer g
- Mr. M. Ryan ,
- Mr. G. Stenclik, Chemistry Instructor
- Mr. J. Valinski, Senior Technical Assistant - Chemistry
- Mr. J. Wilson, Site Quality Assurance Supervisor
- *Mr. J. Winzenreid, Superintendent, Plant Services
- Other licensee personnel were also contacted or interviewed during this inspection.
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1.2 NRC Personnel
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- Dr. R. Bellamy, Chief, Emergency Preparedness and Radiological Protection Branch, Region I
- Mr. T. Johnson, Senior Resident Inspector
- Mr. J. Williams, Resident Inspector
- Attended the exit interview on July 26, 1985.
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2.0 Purpose The purpose of this special inspection was to review the licensee's radia-
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tion protection and chemistry programs to:
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determine the status of previously identified items in radiation protection and chemistry;
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determine whether the licensee is organized, staffed and motivated to effectively control radiation, radioactive material and plant chemi stry;
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determine whether the licensee ensures that plant employees and t contractors are adequately trained and qualified; I
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determine the adequacy of the licensee's occupational radiation protection program during the Unit 3 Refueling Outage; and
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evaluate the licensee's analytical capability to make consistently accurate radioactivity and chemical measurements during normal operations.
4 3.0 Previously Identified Items I 3.1 (Closed) Inspector Follow-up Item (50-277/83-36-01) Obtain a check source which will produce a response on each scale used. Licensee's 1 procedures for issuance, source response checking and use of radia-tion survey meters were reviewed and discussed with members of the d
- Health Physics staff. The licensee has an adequate program for
- checking instrument response prior to use. This item is closed, i
i 3.2 (Closed) Inspector Follow-up Item (50-77/84-12-01) Review efforts to i maintain Recirc. and RHR Piping replacement exposures below estimated i
exposures. Radiation exposure controls during piping replacement were reviewed during several inspections of the licensee's radiation protection program. This item is close .3 (Closed) Inspector Follow-up Item (50-277/84-12-03) Licensee to ;
incorporate HP & QC responsibilities into Interface Procedure Manual.
- Health Physics (HP) and Quality Assurance (QA) responsibilities during Unit 2 piping replacement were adequately addressed in other licensee documents. This item is closed.
3.4 (Closed) Inspector Follow-up Item (50-277/84-12-04) Review scope of RWPs for pipe replacement. Radiation Work Permits (RWPs) were
- reviewed during Inspection Nos. 50-277/84-18 and 50-277/85-11.
- Problems were noted in RWP specificity during those inspections, j This item is closed.
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3.5 (Closed) Violation (50-277/84-18-01) Failure to provide training in procedures related to pipe replacement to Health Physics technicians.
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Actions described in the licensee's letter (dated August 31,1984)
were reviewed. Training and instruction of technicians in these i
cited procedures was completed and the licensee's Health Physics technician training procedure was reviewed. This item is close .
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i j 3.6 (Closed) Unresolved Item (50-277/84-18-02) Licensee to change (
i Procedure HP0/CO-68 to require source check for audible alarming !
dosimeters and initiate checks. Procedure HOP /CO-68, (" Field Use of '
Alarming Digital Dosimeters") was reviewed. Records of source checks
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of audible alarming dosimeters were also reviewed. This item is close .7 (Closed) Violation (50-277/84-18-03) Failure to provide specific radiological exposure controls on RWPs associated with pipe replacement. Actions described in the licensee's letter (dated August- 31, 1984) were reviewed. Selected RWPs associated with pipe replacement during August and September 1984 were also reviewed. The licensee completed actions as described in the licensee's response to the violation. This item is close .8 (Closed) Inspector Followup Item (50-277/84-22-03) Review actions taken to ensure that anticontamination clothing met contamination limits in Procedure HP0/CO-100. The licensee's program for examining protective clothing for contamination prior to use was reviewed and deemed adequate. The licensee's quality control program for reviewing the performance of the contract laundry was also reviewe This item is close .9 (Closed) Inspector Follow-up Item (50-277/84-25-01) Provide formal training in external dosimetry to the individual responsible for operation of the dosimetry program. The Technical Assistant current-ly assigned responsibility for the dosimetry program has received documented training in external dosimetry. This item is close .10 (Closed) Inspector Follow-up Item (50-277/84-25-02) Provide means to determine and document the competency of personnel who work in dosimetry. The licensee has initiated a practical factors review program for dosimetry personnel. Review of records and discussions with licensee personnel indicated that the program has been initiated and is continuing. This item is close .11 (0 pen) Inspector Follow-up Item (50-277/84-25-03) Modify RWP proce-dure to incorporate criteria for the assignment of extremity and other supplementary dosimetry. In a memorandum (dated September 27, 1984), the licensee provided guidance on the issuance of extremity dosimetry to the Health Physics staff. However, similar guidance for supplementary dosimetry had not been provided. This item remains ope .12 (0 pen) Inspector Follow-up Item (50-277/84-25-04) Modify lost dosimetry procedure (HP0/CO-138) to ensure that a dose estimate is made prior to the replacement of any lost dosimeter and to specify who can make the dose estimate. Licensee's Procedure HP0/C0-138, (" Management of Exposure Related to Lost or Found Personnel Dosimetry Badges") had not been revised. This item remains ope .13 (Closed) Violation (50-277/84-25-05) Failure to track dosimeter loss rate by work group as required by Procedure HP0/CO-13E, Action as des-cribed in the licensee's letter (dated December 4,1984) were reviewed and determined to be adequate. This item is closed.
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3.14 (Closed) Inspector Follow-up Item (50-277/84-25-06) Develop procedure
, to screen daily Harshaw TLD data to detect possible beta doses. The licensee has modified the computer program used to determine doses to list beta doses 100 millirem greater than the gamma dose measure This program was initiated July 15, 1985. This item is close .15 (Closed) Inspector Follow-up Item (50-277/84-25-07) Modify acceptance criteria in Procedure HP0/CO-32 to reflect criteria contained in ANSI N13.11 for dosimetry processors. Procedure HP0/CO-32 and ancillary procedures were reviewed. Criteria contained in ANSI N13.11 had been included. This item is close .16 (Closed) Violation (50-277/84-25-08) Failure to apply correction factors to Harshaw TLD data as required by HP0/CO-32. Actions as described in the licensee's letter (dated December 4,1984) were reviewed and determined to be adequate. This item is close .17 (0 pen) Inspector Follow-up Item (50-277/84-25-09) Establish procedure to monitor daily Harshaw TLD reader calibration data to reflect trends which might indicate degraded or unstable performance. Proce-dure to monitor daily Harshaw TLD reader calibration data was not established. This item remains ope .18 (Closed) Inspector Follow-up Item (50-277/84-25-10) Perform quarterly test of beta response of Eberline dostmeter using HP0/C0-32 Implementation of Procedure HP0/CO-32A (" Exposing TLDs for Check Purposes With A Beta Source") was reviewed and determined to be adequate. This item is close .19 (Closed) Inspector Follow-up Item (50-277/84-25-11) Evaluate results i of dosimetry performance test. The results of the dosimetry per-formance test were evaluated and summarized in Combined Inspection 7 Report Nos. 50-277/85-19; 50-278/85-15. This item is close .
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3.20 (Closed) Inspector Follow-up Items (50-277/84-29-01; 50-277/84-29-02)
Review completion of corrective actions in licensee's Discrepancy l'
Reports Nos.84-111 and 84-112. The licensee completed corrective actions for the licensee - identified violations described in the :
Discrepancy Report These items are close .21 (Closed) Inspector Follow-up Item (50-277/84-29-03) Review RWPs for [
requirement for Health Physics escort below the 135-foot elevation of '
the Unit 2 Drywell af ter August 14, 1984. Selected Radiation Work l Permits from August 14, 1984 through October 15, 1984 were reviewed, i The licensee had required a Health Physics escort for work in those !
- areas. This item is close i j 3.22 (Closed) Inspector Follow-up Item (50-277/84-42-01; 50-278/84-34-01) I l' Review licensee's actions regarding INPO finding related to t retraining of Chemistry Technicians. The licensee has implemented a
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continuing training program for all chemistry personnel, including i supervision. This item is close l
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3.23 (Closed) Violation (50-277/84-42-02) Violation of 10 CFR 20.311(d)(3); failure to provide a QC program to assure compliance with 10 CFR 61.56(a)(5). Actions described in the licensee's letter (dated February 28, 1985) were reviewe The licensee had completed actions as described in the response to the violation. This item is close .24 (0 pen) Inspector Follow-up Item (50-277/85-06-01; 50-278/85-06-01)
< Implementation of a laboratory measurement control program. The licensee has yet to complete implementation of the program in all area This item remains open and additional details are provided in Section .25 (0 pen) Inspector Followup Item (50-277/85-09-01) Liquid Scintillation Counter (LSC) QC program. The licensee has taken the old LSC out of service and is about to purchase a new LSC. Until the new LSC is purchased and put into operation, a vendor laboratory is being used for tritium analyses. This item remains open until a QC program for the new LSC is establishe .26 (0 pen) Inspector Follow-up Item (50-277/85-09-02; 50-278/85-09-02)
, Gamma Spectroscopy system resolution. The licensee has made adjust-ments to the gamma spectroscopy system to eliminate noise. The licensee also plans to make pulse pileup corrections, but this has yet to be don In the interim, the licensee has imposed an administrative dead time limit of 10% for routine sample analysi Until the pulse pile up corrections are made, this item will remain l ope i
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3.27 (0 pen) Inspector Follow-up Item (50-277/85-09-03; 50-278/85-09-03)
j Tritium measurement disagreemen The split of a recent effluent i sample was also in disagreement. Another sample has been split. This
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item remains open and is further discussed in Section .28 (0 pen) Inspector Follow-up Item (50-277/85-09-04; 50-278/85-09-04)
Chemistry software documentation and verification. The licensee has 1 yet to take action in this area. This item will remain open until
- chemistry sof tware is documented and verifie .29 (Closed) Violations (50-277/85-11-01) Failure to provide specific
{ radiological exposure controls; (50-277/85-11-02) Failure to evaluate radiation hazards; (50-277/85-11-03) Failure to make suitable measurements of airborne radioactivity; (50-277/85-11-04) Failure to establish dose rates and inform workers when using audible-alarming
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dosimeters in high radiation areas; (50-277/85-11-06) Failure to supply and require the use of extremity and supplemental monitoring equipment; (50-277/85-11-07) Failure to require respiratory
protective equipment; and (50-277/85-11-09) Failure to ensure workers were aware of radiological status of work area. These findings related to two incidences of personnel contamination which shared a
- common root cause. The licensee's corrective actions addressed the
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management process to ensure that each work group clearly understood the scope of the work planned, radiation protection personnel had adequately evaluated the radiological conditions and adequate radiological hazards controls were in place to safely complete the work. Licensee actions as described in Appendix A to the letter (dated June 7, 1985) responding to the violations were reviewed. The management work control process being employed for the Unit 3 refueling outage (in progress during the inspection) was also reviewed. The licensee appeared to have instituted sufficient
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management controls to ensure that radiation protection personnel responsible for radiological hazard control of work activities were aware of the daily planned work activities, the scope of those activities and the radiological controls needed to complete the activitie These items are close l 3.30 (Closed) Unresolved Item (50-277/85-11-05) Determine the adequacy l of controlling external exposure to high beta fields with audible alarming dosimeters. The licensee provided a technical evaluation of the use of audible alarming dosimeters in the work situation associated with the 81A Valve and adjacent piping of the Residual
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Heat Removal (RHR) Syste The licensee's analysis and technical <
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evaluation showed that the licensee's actions regarding the radio-logical conditions associated with the work were adequate for the 1 beta hazard involved. This item is close ,
l 4.0 Organization Radiation protection and chemistry at the Peach Bottom Atomic Power Station are the responsibility of the licensee's Electric Production Department (EPD) with support and technical assistance from the licensee's corporate staff. Within the EPD, recent reorganizations have separated
. the radiation protection and chemistry functions. The radiation protec-
{ tion operation reports to the Senior Health Physicist. The Senior Health
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Physicist reports through the Superintendent, Plant Services to the Station Manager. The chemistry operation reports to the Senior Chemis The Senior Chemist reports through the Superintendent, Operations to the Station Manage .1 Radiation Protection The radiation protection organization, (i.e. Health Physics Section)
was reviewed against criteria and recommendations provided in:
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Technical Specification 6.2, " Organization"; I t
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NUREG-0761, " Radiation Protection Plans for Nuclear Power i Reactor Licensees" (March 1981);
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NUREG-0731, " Guidelines for Utility Management Structure and
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Regulatory Guide 8.8, "Information Relevant to Ensuring that ,
Occupational Radiation Exposures at Nuclear Power Stations will '
be as low as is reasonably achievable", (Revision 3, June 1978).
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- The licensee's performance relative to these criteria and recommenda-
- tions was determined by interviews of the Senior Health Physicist and j members of the staff, examination of reporting relationships, position j
descriptions and other records and observation of the working rela- '
j tionship evidenced by the Unit 3 Refueling Outage.
l l Within the scope of this review, the following weaknesses in the [
] licensee's reorganized radiation protection structure were identified and brought to the licensee's attention:
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Section C.I.b(3) of Regulatory Guide 8.8 recommends that the
] Radiation Protection Manager (RPM) have direct recourse to
) responsible management personnel in order to resolve questions
! related to the conduct of the radiation protection progra ! Section II.A.1 of NUREG-0737 recommends that radiation l j^ protection be assured independence from operating pressures and have clear lines of authority to the Plant Manager. Two main goals for the organizational structure are to give assurance i that the radiation protection group is independent from opera-
! tions and operational pressures and the RPM has direct access to the Plant Manager in all radiation protection matter ,
Since the Senior Health Physicist (Station RPM) reported through
! the Superintendent, Plant Services, the inspector questioned the j RPM to determine if direct recourse to the Station Manager in l
radiation protection matters was available in the reorganized
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management structure. The Senior Health Physicist indicated f l that he would bring radiation protection questions to the Super- i
! intendent, Plant Service .
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At the exit interview on July 26, 1985, the licensee's represen-I tative provided assurance that the RPM has direct access to the Plant Manager in all radiation protection matters. This area will be reviewed in subsequent inspections. 50-277/85-28-01; j 50-278/85-26-01
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Position Guides outline the functions, qualifications, general :
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responsibilities, specific duties, relationships to other plant l
- personnel and measurements for job performance for the licensee.
j Several position guides were reviewed to determine if they re- ,
flected the function, responsibilities, reporting relationships ;
j and specific duties in the reorganized radiation protection !
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group. The inspector noted that:
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- (1) a position guide for the Health Physicist - ALARA was not l
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! (2) position guides did not reflect the altered duties of the f
} Health Physicist-Support; and
! (3) position guides did not generally address the new reporting relationship for the Senior Health Physicist.
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! At the exit interview on July 26, 1985, the licensee's represen- ,
tative indicated that revised and new position guides were being t
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developed to reflect the functions, responsibilities, reporting j relationships and specific duties of the various positions. The '
i New and Revised Position Guides will be reviewed in a subsequent I inspectio /85-28-02; 50-278/85-26-02
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] 4.2 Chemistry i
I The chemistry organization was reviewed relative to recommendations -
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I provided in NUREG-0737.Section II.A.1 of NUREG-0731 states that one .
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i characteristic that forms the basis for a plant organization is that
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" distinct functional areas are separately supervised and/or managed."
l Figure 1 of NUREG-0737 shows radiation protection separate from j chemistr i The inspector noted that the reorganization had separated the radia-f tion protection and chemistry functions. The separation is con-j sidered a potential strength since it:
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allows the RPM to devote sufficient attention to radiation
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i protection and not be distracted from this responsibility by responsibility for chemistry;
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provides full-time management of and technical input to the i chemistry program by the Senior Chemist; and I --
recognizes the close ties between chemical analysis and plant j operational needs in controlling overall plant coolant l
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5.0 Selection, qualification And Training ;
i The licensee's program for selection, training and qualification of i personnel assigned to the Health Physics and Chemistry areas was reviewed .
l against criteria and commitments provided in the following: ;
Technical Specification 6.3, " Facility Staff Qualificction";
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Technical Specification 6.4, " Training";
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ANSI N18.1-1971, " Selection And Training Of Nuclear Power Plant Personnel;
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Technical Specification 6.8, " Procedures";
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Licensee's Procedure HP0/CO-80, "Non-PEC0 Health Physics Technician Entry Procedure", Revision 4 (August 7, 1984); and
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Licensee's letter from S. L. Daltroff to T. T. Martin, NRC dated January 29, 1982 in response to Combined Inspection Report No /80-18; 50-278/80-1 The major elements of the licensee's program were reviewed including;
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the basis used for the selection of personnel to be trained;
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the schedules, lesson plans and performance of the training;
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the determination of the individual's competence in the training given; and i --
the methods used to inform personnel of changes in procedures and licensee's requirements.
- 5.1 Health Physics Professional Training Health Physics Section professional staff members' training was re-viewed to assess the licensee's performance in maintaining and en-hancing staf f proficiency and knowledge in radiation protection area The inspector noted that seminars, workshops and courses were pro-vided to professional staff members. In 1982, the Corporate Nuclear Training Section implemented a program which provided a training matrix defining topics to be covered for corporate physicists and technical assistants and station health physics engineers, physicists
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and technical assistants. The licensee's performance in implementing this program was reviewed by examination of training records and in-1 terviews and discussions with selected health physics professional staff member Within the scope of this review, the following weakness was noted:
Although the licensee planned a complete program cycle covering 60 topics over a 3 year period (i.e. 1982-1985), approximately 1/2 of the program was incomplete at the time of the inspection. In 1984, a total of 3 training sessions were conducted. When this was brought to the licensee's attention, the licensee acknowledged that the training program had not received sufficient attention during 1984 due to of the piping replacement activities. At the exit interview on July 26, 1985, the licensee stated that the need for the profes-sional training program was recognized and efforts were underway to
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provide the training as originally planned. Professional training
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will be reviewed during a subsequent inspection. 50-277/85-28-03; 50-278/85-26-03 5.2 Senior Health Physics Technician Training A 5 day Senior Health Physics Technician Preparatory training program provided by the licensee in May of 1985 was reviewed. The lesson plan for the training was reviewed and discussed with the training instructor and the scope of the training was discussed with health physics staff members. The inspector noted that the training program provided training specifically addressing the Senior Technician's duties and responsibilitie The development and implementation of this program is considered a potential strength to the overall health physics training progra .3 Health Physics Technician Training The licensee has developed and is implementing a health physics technician training and qualification program which has received accreditation by the Institute for Nuclear Power Operations (INP0).
This program was reviewed during previous inspection .4 Contractor Health Physics Technician Training The adequacy and effectiveness of the licensees program for selection, training and qualification of contractor HP technicians was reviewed against criteria contained in:
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10 CFR 19.12, " Instruction to workers;"
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Technical Specification 6.4 " Training;"
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ANSI N18.1-1971 " Selection and Training of Nuclear Power Plant Personnel;"
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Technical Specifications 6.8, " Procedures";
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Station procedure A-50 " Training Procedure," and
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Station procedure HP0/CO-80 "Non-PECO Health Physics l Technician Entry Procedure."
Performance relative to these criteria was determined by:
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interviews with various training department personnel;
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review of qualification manuals and lesson plans; and l
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review of personnel experience resumes and training records, l
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r Within the scope of this review, no violations were identifie The inspector noted that the supervisor who screens contract HP technician candidates has incorporated the recommendations provided in INP0 Good Practice 82-001-0EN-06 " Selection of Contract Radiological Protection Technicians". This approach results in the selection of the most qualified technicia However, this policy has not been documented to ensure its continued use as the responsibility for screening is re-assigned to other supervisor The contract technician training lesson plan as approved by licensee
supervision is a list of subjects without much detail. The course material is presented in a four-day session by a contract instructo Discussions with the instructor indicated that course content is enhanced by a detailed review of priority procedures, practice problems in calculations required in the plant, supplementary reading, interpretation of multi-channel analyzer data, review of NRC regulations and provisions for refresher training. The inspector advised the licensee that these program improvements should be included in the lesson plan. This matter will be reviewed in a future inspection. (50-277/85-28-04; 50-278/85-26-04)
5.5 Chemistry Training During this inspection the licensee's chemistry retraining program was reviewe The licensee's training program in this area was re-viewed during a previous inspection (Combined Inspection Report No /85-06; 50-278/85-06). A continuing training program was im-plemented by the Peach Bottom Nuclear Training Section during 198 This program consists of five cycles, each approximately 5 days in length, that cover such topics as BWR Power Plant Systems, BWR Chemistry, Emergency Preparedness, and Technical Writing. The cycles are further divided into subtopics such as laboratory quality control, analytical techniques, and cnalytical accuracy under the BWR Chemistry cycle. The inspector reviewed the class attendance lists as well as the formalized lesson plans for Cycle I, BWR Power Plant Systems. Approximately 90% of the eligible personnel attended the Cycle I training, including chemistry supervisio The inspector noted that only one contractor technician attended Cycle I of the continuing training program. The licensee stated that any contractor technicians which would remain on site long term would attend the training. The inspector also noted that Nuclear Training Section personnel had attended a laboratory QC training course given by an independent laboratory. The inspector discussed with the licensee, the value of training personnel as well as chemistry department personnel attending this type of training. No violations were identified in this area.
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l 6.0 Procedures Selected licensee procedures were reviewed against criteria provided in:
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Technical Specification 6.5, " Review and Audit";
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Technical Specification 6.8, " Procedures"; ;
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Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation);" and i
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ANSI N18.7-1972, " Administrative Controls For Nuclear Power Plants." ,
6.1 Administrative Procedures
[ Under the licensee's Procedure A-86, (" Administrative Procedure For -
1 Corrective Action"), radiological discrepancies are investigated, '
< documented, reported, tracked, closed and trended. In view of the i events described in Inspection Report No. 50-277/85-11, implemen-1 tation of Procedure A-86 was reviewed. Four radiological discrep- l l ancies reported under Procedure A-86 were reviewed and discussed with !
! the licensee to assess the licensee's self identification and j correction progra :
} Under the licensee's Procedure A-84, (" Control of High Radiation Area {
Keys"), access to high radiation areas within the plant is '
I controlled. Implementation of Procedure A-84 was reviewed to assess ,
q the licensee's control ;
t j Within the scope of this assessment, the licensee appeared to be !
j implementing these administrative procedures adequatel .2 Radiation Protection Procedures
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Selected Health Physics and Chemistry Operating (HP0/CO) Procedures ;
were reviewed against the criteria above, 10 CFR 20. Technical Spect- !
fication 6.11, (" Radiation Protection Program"), and Technical Spect- !
3 fication 6.13, ("High Radiation Area"). HPC/C0 Procedures covering (
j surveys, radiation work permits, respiratory protection, personnel l
! dosimetry, personnel bioassay, control point operation and posting ,
j radiologically controlled areas were reviewed and discussed with the !
licensee's health physics staff. Special operating instructions i
- i associated with the Unit 3 Refueling Outage were also reviewed.
! Emphasis was place on Procedure HP0/CO-4, (" Radiation Work Permits")
j in view of the findings in Inspection Report Nos. 50-277/84-18 and
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50-278/85-11.
j Within the scope of this review, no violations or weaknesses were 1 noted, i
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l 6.3 Analytical Procedures Evaluation
- During the inspection, standard chemical solutions were submitted by the inspector to the licensee for analysi The standard solutions were prepared by the Brookhaven National Laboratory (BNL) for NRC i s
Region I, and were analyzed by the licensee using normal methods and !
equipment. The analysis of standards is used to verify the licensee's capability to monitor chemical parameters in various plant i systems with respect to Technical Specifications and other regulatory requirements. In addition, the analysis of standards is used to evaluate the licensee's analytical procedures with respect to accuracy and precisio The results of the standard measurements comparison indicated that with the exception of two measurements, all of the results were in agreement under the criteria used for comparing results. (See i
Attachment 1) The two disagreements are not considered significan the results of the comparisons are listed in Table The inspector identified a problem with the specific ion electrode analysis for chloride (backup procedure). The licensee's results using this procedure on the NRC standards were significantly low. The licensee polished the electrodes, reran the NRC standards and achieved acceptable results (not included in Table 1).
No violations were identifie .0 Radiation Protection Program The implementation of the licensee's radiation protection program during the Unit 3 Refueling Outage was reviewed to determine if:
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planning and preparation for the outage were adequate;
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the radiation work permit system and other administrative controls were adequate; i
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surveys, monitoring activities and exposure controls supported the radiation work permits and other controls; and
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corrective actions taken by the licensee as a result of Inspection No. 50-277/85-11 in communications and controls were being utilize .1 Planning And Preparation The licensee's planning and preparations for the Unit 3 Refueling ,
Outage were reviewed against guidance provided in Regulatory Guide 8.8, "Information Relevant To Ensuring That Occupational Radiation Exposures At Nuclear Power Stations Will Be As Low As Is Reasonably Achievable" and NUREG-0761, " Rad a 1' tion Protection Plans For Nuclear Power Reactor Licensee's". The licensee's performance relative to <
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l l this guidance was assessed by discussions with Health Physics and l Outage Planning personnel and review of instructions to health physics technicians and staff members, i
Within the scope of this assessment, the inspector noted that guide-lines for outage included:
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Health Physics lead personnel for each outage plant division;
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improved communication of work scope and location by the Maintenance Request Forms (MRF) and daily work lists;
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increased surveillance and work review responsibilities for Health Physics Technical Assistants and professional staff;
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defined outage responsibilities for incident evaluations by the ALARA coordinator; and
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weekly management meetings to discuss outage activities and '
l information exchange for the senior health physics staf .
7.2 Radiation Work permit System The licensee's radiation work permit (RWP) system for the control of radiation work and the protection of workers was reviewed against criteria contained in:
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Technical Specification 6.11, " Radiation Protection Program";
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Health Physics / Chemistry Operating Procedure HP0/CO-4,
" Radiation Work Permits", Revision 23 (5/20/85);
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20 CFR 20,201, 20.202 and 20.206;
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Technical Specification 6.8, " Procedures";
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Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)";
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Administrative Procedure ( A)-26, " Procedure For Corrective Maintenance"; and l
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HP0/C0 - 101, " Control Point Operating Procedure", Revision 0 (7/20/82).
The licensee's implementation of this program was reviewed by:
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interviews of Technical Assistants (TA) responsible for each work division, health physics supervision, Senior Health Physics Technicians and Control Point Technicians; l
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_ _ . . _ . _ _ _ _ , _ _ , _ _ _ - - . _ _ _ _
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examination of the Health Physics Section Instruction, " Guide-lines For The Conduct Of The Unit 3 HP/ALARA Program" (7/11/85);
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review of outage schedules, daily work schedules and the imple-I mentation of the Health Physics Section Instruction;
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review of selected RWPs and supporting records; and
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tours of the work areas and observation of work in progres Within the scope of this review, no violations were noted. The following licensee strengths and improvements were noted:
- The refueling outage work for Unit 3 has been divided into four major i work zones
- Dry Well, E21ance of Plant, Fuel Floor, and Reactor Systems. The work in each zone is controlled by a HP-TA and an
- engineer who obtain direction from the Outage Coordinator. A daily
planning meeting results in an official work schedule that provides j the only authorized work in each are <
The work is identified and fully described using a computerized file called Maintenance Request Form (MRF)/ Computerized History and ,
_
Maintenance Program System (CHAMPS). The MRF/ CHAMPS provides com-
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prehensive work details including estimated radiation exposure and ALARA requirements. With "MRF" system information, the control point technicians are able to conduct job specific radiation surveys, determine protective requirements and complete job specific radiation
work permits prior to the arrival of work crew The inspectors con-sidered the licensee's use of this system a positive developmen i
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The MRF system was not used for work in the Fuel Floor area. On the first day of this inspection there was no system to clearly identify '
work. However work activity was minimal in this area. By midweek '
the HP control point was provided with a set of Maintenance Proce-
. dures, work was then identified and scheduled by referencing appro- !
] priate sections of the procedures. The licensee stated that the '
l MRF system could not be used on the Fuel Floor due to other admints-l trative requirement For the outage the licensee has issued a set of guidelines for the l HP/ALARA program listing 19 action items. Many of these actions are
'
required to be performed by the HP-TA, however they were usually delegated to the senior HP technicians at the control points. The
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inspectors judged that the guidelines could enhance the HP program if properly implemented. The licensee advised that outage performance will be reviewed at some future date and certain guidelines may be l incorporated into the station procedure The control points appeared to be manned with adequate numbers of HP
- technicians to control the work in progress. The performance of i
radiation surveys and updates to the RWP's appeared adequate.
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7.3 Issuance And Use Of Respirators The licensee's controls on the issuance and use of respiratory protective equipment by outage workers were reviewed against criteria and guidance contained in:
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Technical Specification 6.11, " Radiation Protection Program";
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HP0/CO-9, " Respiratory Protection Program", Revision 10 (4/21/83);
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HP0/CO-9B, " Respiratory Protective Equipment Selection And Use",
Revision 10 (1/16/85); and
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Regulatory Guide 8.15, " Acceptable Programs for Respiratory
! Protection".
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! The licensee's performance relative to these criteria was determined j by:
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interviews with personnel who issue respirators; !
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review of training and qualifications of respirator users; and
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observation of work in progres Within the scope of this review, no violations were observed. The inspector noted that authorized respirator users are identified by a white sticker placed on the workers' Harshaw dosimeter badge. The sticker does not indicate exact types of respirators authorized for the worker. This information is contained on a separate computer print ou The print-outs generally available at the control points were two weeks old. Several workers using respirators could not be located on this print-out. The control point technicians were able to verify the workers qualifications by telephone conversation with r the training department personnel. Although the control of respirators was adequate, the timeliness of information updates from '
the training department to the respirator issue point could be improve .4 ALARA Progry The licensee's implementation of the station's "As Low As Is Reason-ably Achievable" ( ALARA) program was reviewed against guidance in Regulatory Guide 8.8 and criteria provided in:
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Technical Specification 6.11. " Radiation Protection Program";
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A-83, "ALARA Program Administrative Procedure";
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. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -____ _
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HP0/CO-500, "ALARA Travellers", Revision 4 (7/8/85)
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HP0/CO-501, " Request For ALARA Review", Revision 1(4/26/84);
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HP0/CO-502, " Station ALARA Review Committee", Revision 1 (4/27/84);
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HP0/CO-503, "ALARA Pre-Job Review", Revision 2 (5/29/85); and
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HP0/CO-504, "ALARA Post-Job", Revision 1 (6/19/84).
The licensee's performance in implementing the ALARA program was assessed by discussions with personnel, review of selected RWPs and j observations of work in progres i
.
i Within the scope of this assessment, the following observations were discussed with the licensee:
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ALARA considerations were incorporated in the MRF system. This incorporation integrates ALARA into the work process and ensures attention to dose reduction throughout the planning and execu-
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tion of work activities. This integration of ALARA consider-ation into the maintenance work process is considered an 1 improvement and potential strength over previous licensee ALARA efforts.
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The inspectors noted that most ALARA recommendations were pro-l cedural in nature, e.g. modifications to work procedures to reduce time spent in the radiation fields. While procedural
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recommendations are necessary ingredients in a station ALARA program, procedural recommendations aren't the only ALARA tech-i
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niques that are being employed in other licensee ALARA program More sophisticated ALARA techniques (e.g. engineering changes to l use robotics, special tooling, confinements and containments and I
i radiological techniques including remote visual and radiological monitoring, electronic dose transmitters, etc.) should also be considere At the exit interview on July 26, 1985, the licensee's repre-sentative stated that radiological techniques including remote radiological monitoring have been employed at the station and consideration would be given to their use in future work activitie The inspectors noted that ALARA appeared to be primarily the responsibility and interest of the Health Physics Sectio Other sections within the station seemed to have little or no responsibility for ALARA planning, e.g. operations, maintenance and engineering input to ALARA planning ef forts was not evident.
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_ _ _ _ _ _ _ _ . _ _ _ _ _ - _ __.-- - - - - - - - - - - - " - - - - --"----'^"- " - - - ^ - - - - --
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J 8.0 Radiological And Chemical Confirmatory Measurements
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l The licensee's analytical capability to make consistently accurate radio-
- activity and chemical measurements during normal operations was evaluate .
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Verification tests and calculations were used to evaluate the licensee's measurement capabilities.
. 8.1 Split Samples During this inspection actual water samples from various plant systems were split between the licensee and the NRC:I in order to
'
verify the licensee's chemical measurement capabilities on actual plant water samples. The analyses will be performed by the licensee 1 using normal methods and equipment, and the NRC contract laboratory,
- Brookhaven National Laboratory (BNL). The samples include
- (1) a ,
1 solution of dissolved cation paper to be analyzed for chromium, iron,
! nickel and copper; (2) reactor water to be analyzed for silica and j chloride; and (3) a flush sample to be analyzed for boron. On i completion of the analyses by both laboratories, the results will be
- compared and will be documented in a subsequent inspection repor .2 Confirmatory Measurements 1 The results of an effluent sample split between the licensee and j NRC
- I during a previous inspection on January 28 to February 1,1985 (Combined Inspection Report Nos. 50-277/85-09; 50-278/85-09) were I compared during this inspection. The analyses, which require wet l chemistry, were performed by the licensee's vendor laboratory and by the NRC reference laboratory, Department of Energy, Radiological and
- Environmental Sciences Laboratory (RESL). Joint analyses of actual
effluent samples are used to verify the licensee's capability to measure radioactivity in effluent samples with respect to Technical l
Specification requirements and other regulatory requirement .
The results of the sample measurements comparison indicated that the i Fe-55 and tritium values were in disagreement under the criteria used I for comparing results. (See Attachment II.) The licensee contacted j the vendor laboratory in order to check the vendor laboratory's
results. The licensee discovered at that time that the vendor '
laboratory had experienced problems with the analyses. For example, the chemical yield in the Fe-55 procedure was greater than 100 i percent. The licensee stated that the vendor laboratory was ex-
periencing problems with personnel turnover. The licensee further
stated that they had been aware of the vendor laboratory's problems and were closely following the resolution of the problems. The ,
results of the comparisons are listed in Table ;
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-,,,---e--- ,-. . - - , - *v ew --i--..-,----a,- --
- r-a---+e- n rec.- e %d%-we+w-s----< g.---s-vs qw'-g .v+v-w.-gs-A y -ve.,,s.- -e*w.o~gve e my e 9 -t--- m- 7 --q.- vT - we'+-+- 4----y-d. *g->>
_ _- _ __ __ . _ _ _ . _ _ _ __ __ . _ __ .____
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J As a result of the disagreement, another liquid effluent sample was '
split between the licensee and NRC:I for radioactivity analyses
- requiring wet chemistry. The analyses to be performed are
- Sr-89, Sr-90, H-3, and Fe-55; and will be performed by the licensee's vendor laboratory and the NRC reference laboratory, RESL. The results will i be compared with the licensee's results when reviewed at a later date
'
and will be documented in a subsequent inspection repor No violations were identifie .3 Laboratory Quality Control Program The inspector reviewed the licensee's program for the quality control
- of analytical measurements with respect to Technical Specification requireraents and generally accepted industrial practices (ASTM, ACS).
The licensee maintains control charts on selected analytical instru-
{ mentation, submits periodic unknowns to the technicians for analysis,
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controls reagent preparation, and has implemented a chemistry tech-nician continuing training program. The inspector discussed labor-
, atory QC with licensee chemistry staff personnel. These discussions revealed that the licensee had not yet implemented control charts for
~j all laboratory instrumentation, and had no inter-laboratory QA pro-gram for nonradiological chemical analyses. The licensee stated
- that, for some instruments, data to be used in constructing control i charts was still being obtained, and when all data was available the 1 charts would be constructed. Also discussed was which in-l strumentation and analyses should have control charts, and the i frequency for plotting data on control charts. ' Discussions regarding 1 the interlaboratory program indicated that development of an interlaboratory program with the licensee's other nuclear power station and the corporate central laboratory was under consideratio The inspector reviewed available laboratory QC data for the period i January, 1985 to date. The inspector stated that the implementation l
- of a laboratory QC program was previously identified as an inspector i j follow-up item (50-277/85-06-01; 50-278/85-06-01), and this item ;
would remain open until all control charts and the inter-laboratory ;
program were implemented.
- No violations were identified.
9.0 Audits And Appraisals
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' The licensee's program for audits and appraisals in radiation protection and chemistry were reviewed against criteria provided in:
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Technical Specification 6.5, " Review And Audit";
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10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program";
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10 CFR 50, Appendix B, Criterion X, " Inspection";
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10 CFR 50, Appendix B, Criterion XVI, " Corrective Action";
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10 CFR 50, Appendix B, Criterion XVIII, " Audits";
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ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants";
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Peach Bottom Atomic Power Station Units No. 2 & 3 Quality Assurance Pla .1 Health Physics Management Audits <
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At the Enforcement Conference on March 4, 1985 to discuss the find-ings of Special Inspection No. 50-277/85-11, the licensee stated that health physics professional personnel would review ongoing work :
activities to ensure that radiation work permits and control point operating procedures were being observe Checklists were developed j to support the activity. The inspector reviewed completed checklists and identified findings contained therein and discussed the program with health physics professional personne Within the scope of this review, the licensee appeared to be imple-
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i menting a generally effective management oversight of ongoing work activitie .2 Quality Control Inspections Under the licensee's quality assurance plan, Quality Control (QC)
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personnel provide inspections (i.e. " monitoring") of ongoing work activities. Detailed Monitoring Checklists (DMC) have been developed to list attributes for QC Inspectors. The following Detailed i
Monitoring Checklists were reviewed and discussed with QC personnel:
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DMC 3.5, " Locked Area C5ntrol";
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DMC 4.4, "RWP/ALARA";
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DMC 4.5, " Routine Chemistry Sampling";
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DMC 4.6, " Determination of pH";
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DMC 4.8, " Determination of Soluble Silica";
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DMC 8.2, " Radiation Protection";
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DMC 8.8, " Radiological Containments"; and
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DMC 10.3, " Radiation Survey".
l Selected completed checklists were reviewed as wel Within the' scope of this review, no violations or weaknesses were noted.
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9.3 Quality Assurance Audits Under the licensee's quality assurance plan, Quality Assurance (QA)
personnel provide periodic audits to evaluate the adequacy and '
effective implementation of the radiation protection and chemistry program .3.1 Health Physics Audits The inspector reviewed audits of the licensee's health physics program including:
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AP 85-11 HPC, "PBAPS Health Physics Operations", February 1
- March 12, 1985;
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AP 85-14 HPC, "P8APS ALARA Program", February 14 - March 19, 1985; j
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AP 84-33 HPC, "ALARA Program", June 1 - August 31, 1984;
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AP 84-30 PL, " Contractor Security Screening / Health Physics Technical Qualifications" April 23 - 25, 1984;
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AP 84-48 HPC, " Health Physics Operations and Dosimetry",
July 5, - September 10, 1984; and
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AP 84-97 TR, " Training / Qualifications of Technicians, Craftsman And QC Personnel", December 10 -28, 198 The inspector noted that each audit was conducted by a quali-fied QA auditor and audit findings were tracked until close Within the scope of this review, no violations or weaknesses were note .3.2 QA Audits of Chemistry The inspector reviewed audits of the licensee's chemistry program and other progrems in which chemistry was involve The following audits were reviewed: Audit Report AP85-028HPC dated April 4, 1985, and Audit Report AP84-87HPC dated December 14, 1984. Audit APB5-028HPC covered the licensee's chemistry and radiochemistry activities, and audit AP84-87HPC covered the Unit 3 hydrogen addition water chemistry test. The audits ap-peared to be thorough and complete. The inspector verified that the licensee's chemistry program was on the QA audit sche-dule. No violations or weaknesses were identifie ,
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10. Exit Interview The inspection team met with the licensee's representatives, denoted in paragraph 1, on July 26, 1985, to discuss the findings of this inspectio The licensee's representatives acknowledged the inspection finding At no time during the inspection was written material provided to the licensee. No information exempt from disclosure under 10 CFR 2.790 was discussed in this repor I
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ATTACHMENT I
i Criteria For Comparing Analytical Measurements
!
i j -This attachment provides criteria for comparing results of analytical capabili-
ty test In these criteria the judgement limits are based on the uncertainty l of the ratio of the licensee's value to the NRC value. The following steps are
performed:
.
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(1) the ratio of the licensee's value to the NRC value is computed s
i (ratio = Licensee Value ); (2)
NRC value
'
- the uncertainty of the ratio is propagate ,
If the absolute value of one minus the ratio is less than or equal to.twice the ratio uncertainty, the results are in agreement. (ll-ratio l s 2 uncertainty)
I Z = x, then Sz2 = 3x2 + ~
_ Sy2
. y Z7 X2 y2 i
,
- (From
- Bevington, P. R. Data Reduction and Error Analysis for the Physical i Sciences, McGraw-Hill, New York, 1969)
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&---tvt' FM PM4A- M "P y rar iwh7 e e w = **P--y- -pr45ett y-yq --myyp 9 y e-t > -9 - q ue 4eeg-9p rMwse-gi,~p.- seh %+-,wA-c %m g 9,e 9. eery a -w p we- g s +qu, r wr3=i -wy.yV,ge-y e %-mg.,c-,.--gw;
. . -._- . . _ _ _ _ - - - . . - . ._. .. _ , - . . - .
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a TABLE 1 i Capability Test Results Peach Bottom, Units 2 and 3 Results in parts per billion (ppb)
Chemical NRC License Ratio Parameter Value Value (Lic/NRC) Comparison 2 .4 1 .4 0.893 0.06 Agreement
- Chloride 2 .8 0.12 1.03 0.11 Agreement
!
7 .6 1.03 0.923 0.04 Agreement i
i 253 18 228 t 2 0.901 1 0.01 Agreement 1 Iron 507 21 469 3 0.925 1 0.04 Agreement
l 760 47 725 3 0.954 0.061 Agreement 258 2 257 t 2 0.996 0.01 Agreement Copper 517 8 508 4 0.983 0.02 Agreement 775 8 782 1 1.009 0.01 Agreement i
262 32 249 3 0.950 1 0.12 Agreement Nickel 524 26 497 1 3 0.948 0.05 Agreement 786 15 748 1 0.952 0.02 Disagreement
'
252 21 241 .956 0.08 Agreement Chromium 503 9 476 6 0.946 0.02 Disagreement 755 57 766 6 1.015 1 0.08 Agreement Results in parts per million (ppm)
1014 15 1017 145 1.003 1 0.14 Agreement !
Boron 3047 26 3000 173 0.985 1 0.06 Agreement j 5040 130 4930 0.978 0.03 0 Agreement
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.. - . - - . - . . . - . - -. - - . .- .. .-. . . . _ _ ..
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ATTACHMENT 2
Criteria for Comparing Analytical Measurements This attachment provides criteria for comparing results of capability tests and
- verification measurements. The criteria are based on an empirical relationship
! which combines prior experience and the accuracy needs of this relationship i
which combines prior experience and the accuracy needs of this progra i' In these criteria, the judgement limits are variable in relation to the comparison of the NRC Reference Laboratory's value to its associated un-
certainty. As that ratio, referred to in this program as " Resolution",
a increases the acceptability of a licensee's measurement should be more I
selective. Conversely, poorer agreement must be considered acceptable as the
,
resolution decrease >
Resolution = NRC REFERENCE VALUE RATIO = LICENSEE VALUE REFERENCE VALUE UNCERTAINTY NRC REFERENCE VALUE-
!
Resolution Agreement
)
<3 0.4 - .5 - 2.0 1 8 - 15 0.6 - 1.66 '
i 16 - 50 0.75 - 1.33 .80 - 1.25
>200 0.85 - 1.18 l
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. . . ~ , , -,, _. - , - . -s~,. ...--,-y ~..,,,_,.7_n_.,,.g .,_,.,-,,,.,.,,y,.yy,,,%,, ,,,,,,,,,,m,,,-y,, , , , -,,~..,,.,,y,,..,, .
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TABLE 2 Peach Bottom Unit 2 and 3 Verification Test Results SAMPLE ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON Results in u Ci/mi FDST gross alpha (1 3) E-10 <3.2E-8 No Comparison 2020 hrs H-3 (4.07 0.07)E-3 (3.22 5%)E-3 Disagreement 1/28/85 Sr-89 (1.34 0.15)E-7 (1.7 13%)E-7 Agreement Sr-90 (1.4 4.1)E-9 (2.8 29%)E-8 No Comparison Fe-55 (3.4 0.5)E-7 (1.33 5%)E-6 Disagreement
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