IR 05000277/1986026
| ML20211A263 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/09/1987 |
| From: | Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211A195 | List: |
| References | |
| 50-277-86-26, 50-278-86-26, NUDOCS 8702190128 | |
| Download: ML20211A263 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-277/86-26 50-278/86-26 Docket No.
50-277 anc 50-278 License No.
DPR-44 and DPR-56 Priority Category C
Licensee:
Philadelphia Electric Company ATTN:
J.W. Gallagher, Vice President Nuclear Operations 2301 Market Street Philadelphia, Pennsylvania 19101 Fa-ility Name:
Peach Bottom Atomic Power Station, Unit 2 and 3 Inspection At: Delta, Pennsylvania
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Inspection Conducted: December 15-17 and 29-31, 1986 Inspectors:
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C/ /2 T. Origou, S ior Radiation Specialist aate Facilitie diation Protection Section
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Approved by:
-#P'f. 5 2/9[g'7 M. Shanbaky, Chief
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date Facilities Radiation Protection Section Inspection Summary:
Inspection on December 15-17 and 29-31, 1986 (Combined Inspection Report Nos. 50-277/86-26 and 50-278/86-26 Areas Inspected:
Routine, unannounced inspection of the licensee's radiation safety program including:
routine radiation surveys; radiological defi:.iency-reporting; internal exposure control; and ALARA planning for the Unit 2 outage.
Results: No violations were identified.
G702190128 070210
{DR ADOCK 05000277 PDR
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Details 1.0 Persons Contacted During the course of the routine inspection the following personnel were contacted or interviewed:
1.1 Licensee Personnel b
- D. Smith, Superintendent - Operations' PBAPS
- M. Cassada, Corporate Health Physics
- W. Lorenz, Corporate HP f
- A. Hilsmeier, Senior Health Physicist
N. Gazda, Health Physicist - ALARA
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G. McCarty, HP - Technical Support S. Nelson, HP - Applied M. Dedrich, Dosimetry H. Paust, HP (
D. Rockwell, HP Attended the Exit Interview on December ~31, 1986
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1.2 NRC Personnel
- T. Johnson, Senior Resident Inspector
- R. Urban, Resident Inspector
'2.0 Purpose The purpose :of this routine inspection was to review the licensee's radiation protection program with respect to the following elements:
l Revised Routine Radiological Surveys
l Radiological Deficiency Reporting l
Internal Exposure Control
ALARA Planning for'the Unit 2 Outage D
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Revised Routine Radiation Surve s
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During an inspection in September 1986, the inspector identified signif-icant weakness in the licensees routine radiological survey program. At
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that time the licensee advised the inspector that an effort was in pro-gress to remedy these weaknesses which had been self-identified by the licensee in early 1986. The status of these efforts was determined from
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discussions with the Health Physicist - Applied and a review of revised l
procedures and is as follows:
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3.1 Develop a procedure to effectively control and implement the revised survey program - complete The original survey procedure (HP0-C090) has been replaced by a new PORC-approved (HPO-C0 200 Rev 0) effective December 15, 1986. The inspector noted that the new procedure provides specific and detailed
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instructions for the implementation of the survey program.
This represents.a significant improvement.
3.2 Identify specific plant areas to be surveyed and frequencies - com-plete Procedure HPO-CO-200 describes the type of survey (gamma and neutron dose rate, surface contamination, airborne contamination, special alpha surveys), the plant areas to be surveyed and survey frequency.
3.3 Develop new, procedurally controlled survey data forms - In progress The licensee has arranged with the plant Architect-Engineer to pro-vide special floor plan maps that will be used to record survey. data.
The licensee stated that each map will be issued a document control number and be referenced in procedure HP0-CO-200. A separate effort will compare survey maps with elevation drawings and site plans to ensure that all areas have been evaluated for incorporation into the routine survey program.
3.4 Develop HP technicians guidelines - In progress Approximately 32 Health Physics Instructions (HPI) have been drafted to provide specific guidelines for technicians performing surveys in various plant elevation. The licensee also indicated that several floor and wall spots will be painted with a designation that will require consistent measurements at that spot during each survey.
This data will be analyzed to determine plant radiation level trends.
3.5 Establish record keeping requirements. - complete Procedure HPO-C0 200 describes the processing of survey data and requires supervisory review and concurrence prior to entering the survey data into the permanent file.
The licensee had earlier indicated that the new program would be fully implemented by the end of 1986. The inspector estimated that completion of this effort may occur in January 1987 based on a review of status with licensee management.
4.0 Radiological Deficiency Reporting During the September 1986 inspection, the inspector also noted weakness in the reporting and follow-up of radiological deficiencies using Proce-dure A-86 " Administrative Procedure for Corrective Action".
No violation was issued since the licensee was aware of the weakness and had corrective action in progres +s-,
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On November 17, 1986, the licensee implemented a new procedure HP0/CO-600
" Health Physics Deficiency Report". The inspector reviewed this proce-dure and determined that it provides a complete and comprehensive program for identification, documentation and resolution of radiological defic-iencies. The inspector also reviewed approximately 30 closed-out defi-ciency reports filed per the procedure and concluded that the procedure was properly implemented. Based on these findings, unresolved items 50-277/86-18-04 and 50-278/86-19-04 are closed.
5.0 Internal Exposure Control The licensees programs for respirator maintenance and whole body counting were reviewed with respect to criteria contained in:
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10 CFR 20.103 Exposure of individuals to concentration of radioactive materials in air in restricted areas.
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Regulatory Guide 8.9 Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program"
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Regulatory Guide 8.20 Application of Bioassay for I-125 and I-131
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Regulatory Guide 8.26 Applications of Bioassay for Fission and Activation Products ANSI N343-1978 " Internal Dosimetry for Mixed Fission and
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Activation Products" IE Notice 82-18 " Assessment of Intakes of Radioactive Material
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by Workers"
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Station Procedures HP0/C0 #3, #9, #9C, #26 including Appendix
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A,B, and C, #26A, #100 and HPA-77
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PECO Electric Production Department " Radiation Safety Handbook" dated 4/84
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The licensees performance relative to these criteria was determined from:
Review of MPC-hour calculation and records, whole body count
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records, and reports to individuals Observation of whole body counter routine start-up and oper-
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Discussions with selected personnel.
Within the scope of this review no violations were observed. Minor program-matic weakness was noted as follows:
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There is no guidance provided to HP technicians regarding selection of general area or breathing zone sampling techniques to evaluate worker uptakes.
Procedure HP0/C0-3 (series) is limited to the operational steps required and HP0/CO-100 specifies the respiratory protection required.
The licensee stated that the need for procedural guidance will be evalu-ated. This matter will be reviewed in a future inspection (50-277/86-26-01 and 50-278/86-26-01)
The procedures for operation of the whole body counter does not provide a clear stepwise instructions to the operator for the initial power up, com-puter booting and operational checks of the equipment. The WBC operator was observed using a training lesson plan and notes from the supervisor that provided better information than the HP0/C026 (series) procedures.
Also the actions required and acceptance criteria for the background count and standard source check were not clear.
Licensee action to resolve these matters will be reviewed in a future inspection.
(50-277/86-26-02 and 50-278/86-26-02)
Licensee strengths were noted as follows:
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The licensees approach to the control of uptakes is conservative. The last recordable (small) uptake occurred in August 1985. There has been no uptakes detected by whole body counting for the previous two years.
There is daily reporting to all site supervisors summarizing whole body counts, WBC results, and MPC-how uptakes for the week and calendar quarter.
6.0 ALARA Planning The licensee has scheduled a 10 week Refueling Outage for Peach Bottom Unit 2 to begin in February 1987. The overall station ALARA program is described in procedure A-83 "ALARA Program Administrative Procedure." The inspector determined the status of the ALARA planning for the Refueling Outage from discussions with the ALARA HP Supervisor and review of sel-ected records.
Within the scope of this review, no violations were observed. The inspec-tor noted weakness in the ALARA program as follows:
No exposure goals have been established for the outage. Althcugh the outage work is well controlled and scheduled in the CHAMPS computer pro-gram, the major work involving exposure has not been identified or sched-uled as of approximately two months prior to the start of the outage. The ALARA group has reviewed most of the jobs that have been formally sched-uled but'these did not involve any major radiation exposur.. _ _ _ _ _
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Support and involvement by upper management in the ALARA program appears to be minimal.
For example, the Station ALARA Review Committee chairman is the ALARA Health Physicist (first line supervisor).
There are no long range goals to reduce Peach Bottom exposures which have been consistently above BWR industry averages in recent years.
Corporate ALARA efforts such as formal ALARA reviews of engineering modification job packages was not evident.
The licensee advised the inspector that certain iniatives were planned to enhance the ALARA program. These include:
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a 50% expansion of personnel in the HP-ALARA section, increasing the ALARA staff from 9 to 16.
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increased use of "ALARA Waiting Areas" during outages control of job man-loading by predesignating allwork crew
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members
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decontamination of the scram discharge header.
The effectiveness of these changes will be reviewed in a future inspection.
7.0 Exit Interview The inspector met with the licensee personnel denoted in section 1.1 at the conclusion of the inspection on December 31, 1986. The scope and findings of the inspection were discussed at that time.
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