IR 05000277/1987013

Insp Repts 50-277/87-13 & 50-278/87-13 on 870420-24 & 0527-28.No Violations Noted.Major Areas Inspected:Use of Caution Signs,Training & Qualification of Technicians, Control of Outage Work & Control of Radwaste

ML20216F573
Person / Time
Site:	Peach Bottom
Issue date:	06/22/1987
From:	Dragoun T, Shanbaky M, Wurtz E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216F482	List: IR 05000277/1987013 ML20216F478
References
50-277-87-13, 50-278-87-13, NUDOCS 8706300891
Download: ML20216F573 (8)

Text

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 -    .'U.S. NUCLEAR REGULATORY. COMMISSION  .
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REGION,I-i '

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Repo_rt'Nos. 50-277/87-13 50-278/87-13- .l

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Docket Nos.- 50-277? ~

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50-278'.

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' License Nos. DPR-44 Priority . '- Category C . DPR-56, ,

  ' Licensee: Philadelphia Electric Company 2301' Market Street'

, Phi 1adelphia,' Penn'sylvania' 19101 - Facility Name:' Peach Bottom Atomic Power Station, Units-2 and 3

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  : Inspection At: ' Delta,' Pennsylvania
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c . i 3 Inspection Conducted: April 20-24 and May 27-28, 1987 ' u, 3

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  ' Inspectors: -

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T. Drag 'n, enior. Radiation Specialist 7'date'

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E. Wurtz, ff6alth Phgsteist

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       'date Approvsd by: . Shanbaky,TChie h . cs,
     , - FacilitWs Radiation .

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Protection Section Inspection Summary: Inspection on April 20-24 and May 27-28, 1987 (Combined Inspection Report Nos. 50-277/87-13 and 50-278/87-13).

-Areas' Inspected: . Routine, unannounced inspection of licensee's radiatio . safety: program including: use of caution signs; training and qualification of' contractor technicians; control of outage-work; status of program' enhancements;

&  . control?of.radwaste; and personnel contamination incident p  ,  Results: .Within the scope of this review no violations were identifie DR ADOCK 050 x  .

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n .' , s ,< , DETAILS! a ' ' t1,0" Persons Contactedi , During theTcourse of this' routine inspection-the following personnel were contacted or interviewed: ,, p 1.1; Licensee' Personnel Q **JL Gallagher, VP . Nuclear Operations'

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  **G.*Leitch, Manager, Nuclear Gen,' Departmen ,  **D.: Smith,. Manager,-PBAPS
  *R; Flei schmann ,: Manager, : PBAPS '
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, , .  .* H. Abendroth, Atlantic-Electric C *M.:Cassada,tDirector, Radiation Protection J.; Cotton, Assistant-.Superintendenti- Services N. . Gazda, ALARA HP Technica1 ' Assistant -
,_  :R.MacA11 ester,.HP' Technical (Assistant-J.-:Mit'tman, Radwaste Coordinato .S.. Nelson, Applied HP' Super. visor
  * Phillips,-Public Service Electric and Gas C **D. Potocik, Senior Health Physicist-   '
.,. C.:Potts.,; Instructor,- Training Department
  "* Attended theLexit' interview'on April 24', 19871

, :- ** Attended'the exit interview on'May 28, 1987 r :1[2 NRC 1 Personnel-

  **T.bohnson,SeniorResidentInspector-4e 2.'0 Purpose y

The purpose'of thisLinspection was.to review th'e licensee's radiation protection program with respect to the.fo'11owing' elements:

  * Use of Caution' Signs  . .
  * Training and Qualification of Contractor Technicians
  * Control of Outage Work
  * Status of Program Enhancements
  * Control of Radwaste
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Personnel Contamination Incidents-3.0 'Use'of Caution Signs and Labels 4 l The licensee's use of radiological caution signs and labels was reviewed l with respect to criteria contained in:

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  '10 CFR 20.202 Personnel monitoring
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  '10.CFR 20.203 Caution signs, labels, signals and controls  .
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Information Notice 84-82: ' Guidance for Posting Radiation Areas !

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Station Procedure HP0/CO-11; Rev. 14 '" Establishing and Posting-C

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Radiologically l Controlled Areas"

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The licensee's' performance: relative to.these criteria was determined from

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tours :of the: turbine building, reactor building and drywell and

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independent measurementLof radiation level Within' the scope of-this review no violations:were observe '

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The-licensee uses signs that use standard warning symbols with slots to accommodate additional information to assistLindividuals in minimizing

  . exposure. An audit performed by.a corporate-HP group .found incon-
  'sistencies in use of the. signs. For example, dose rates and: contamination levels.provided.on the posting would exceed the level; required for an.RWP yet "no RWP; required" would be indicated. On April 21, 1987 HP super-vision feviewed al1 postings and corrected.these deficiencie .0 Training and Qualification of Contractor Technicians
  .The licensee's program for the selection, training and qualification =of contractor technicians <was reviewed with respect to criteria contained in:-

Technical Specification 6.3 " Facility Staff Qualification."

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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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  .-1 . Station Procedure HP0/C0-80 "Non-PECo. Health' Physics Technician
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Entry Procedure" Revision 5 V LThe licensect s performance relative t'o these criteria was determined from

  ' discussions with the Applied HP Supervisor, the-cognizant training instructor,and a-review of lesson plans and student quizze Within the scope of the review no violations'were observed.' Program
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l strengths and weaknesses were noted as follows:

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  . Screening and selection of contractor technicians categorized as qualified per the ANSI N18.1 criteria is done by the Applied HP L   Supervisor. There is no licensee screening policy nor guidanc provided to ensure consistency. Navy ELT experience is fully credited against the ANSI two year experience requirement although L   these technicians have never worked at a Boiling Water Reactor site, a   The licensee stated that appropriate screening criteria _would be' i developed and issued. On May 27, the licensee provided the inspector with a contract specification outlining acceptable _ experience for
 , contractor technicians. This matter is now resolve Although training of contractor technicians appears to be adequate, no demonstration of practical techniques is provided. However, the licensee stated that a revised training program is currently being I developed that will include Peach Bottom specific practical factor ..
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 :Thelinspector noted that.the retraining provided to technicians who
,  have'been on-site for more than one year is.very thorough'and well; organized._ This continuing training includes.a dis:ussion of.all ,

revisions to HP procedures, all significant radiological deficiencyj

 , reports (HPDR), licensee event reports (LER) and any NRC notices or Ebu11etins issued during the year. Students must pass a' writte e y  examination on.this material-to maintain the. qualification.- .

t-l5.0' Control of OutagesWork-L The' licenseel s control of outage. work was reviewed with respect-to criteria contained in: "

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10 CFR 19 - Notices, Instructions and' Reports to Workers;. Inspections

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10 CFR 20 - Standard for Protection Against Radiation

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 . Regulatory Guides 8.8 and 8.10
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Technical Specification 6.11 Radiation. Protection Program-J Station Procedure-HP0/CO-4 Radiation Work Permit .j

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The licensee's performance relative to these criteria was' determined from:

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tours of work a'reas during day shif t and backshift

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attendance at work planning and Station ALARA' Review Committee-

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review of documentation such as RWP requests, ALARA reviews, active-RWPs and radiation survey dat , Within the' scope of this review no violations were observe .1 - Use of RWPs The-inspector noted that use of RWPs has improved since-the last . outage. During this outage the RWP's that were reviewed ~were found' to be written for specific-jobs rather than providing vague require-- ments to' allow' application to several jobs. This use of job specific RWP's provides better information to the worker and affords better-control of the wor i

The licensee requires an RWP for work under the following radiological conditions: area dose rates greater than 100' mrem /hr, average surface contamination greater than 10 dpm/100 cm2 , and airborne activity requiring protection. These criteria are less conservative than ' general industry practice. The inspector reviewed the licensee's exposure records for 1983 to date and determined that approximately 80% of exposures were received on jobs covered by an RWP while only 20% was incurred on non-RWP jobs. Although the impact of the RWP criteria appears minimal, the licensee advised that the criteria will be changed to cover a greater portion of-the .; wor J l a i

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,.- 5' w g ~W Control points were found in each p", ant elevation where work was in progres HP. technicians were available as were copies of active e"' RWPs, survey results, and surveying equipment. Work in the drywell , 4

 &nd on.the refuel floor was at a slow pace during this inspection due'to recovery of a dropped control ro .2 Outage Coordination There are many work status and work planning meetings attended by HP'

supervision. This should provide HP supervision with information to ensure that HP technicians are properly assigned and RWP or ALARA reviews are completed. The inspector observed that the effectiveness of these meetings was decreased due to the lack of detailed and accurate work status informatio .3 'ALARA-Although ALARA . reviews for jobs were completed, the inspector observed instances.of poor ALARA practice:

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The lunch room / break room for HP technicians is located in a

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radiation area inside the power block. A frisker could not be located near the lunchroom entrance due to high backgroun A video monitoring / communications panel manned by General Electric personnel controlling undervessel work was located near a scram discharge header creating a 25.mr/hr general area dose rat A worker was observed sitting and dozing inside tne drywell near the access hatch in a 15 mr/hr are The licensee was advised that additional management attention'to

 .ALARA is required. The licensee stated that additional ALARA specialists were hired and expected on site by mid-summe .4 Frisking To improve the control of radioactive. material and reduce the spread of loose surface contamination, the licensee has increased the number of frisking stations in the power block and upgraded the frisking policy. Although a commendable effort, the inspector observed that frisking stations were poorly located, often requiring potentially contaminated personnel to cross high traffic areas to reach the frisker. The licensee was advised that the placement of the frisking stations should be reviewed.

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6.0 Program Enhancements i In October 1986 the licensee issued a comprehensive plan called " Peach Bottom Atomic Power Station Enhancement Program" which included as an objective to " improve Radiological Controls Program". The inspector discussed with the licensee certain changes as follows: 6.1 Unified Power Block Entry

  .The licensee has plans to establish a single power block entry point for Unit 2 and. Unit 3 at the eastern end of the power block. 'All entries will be throucha single control point and require' an RW All HP technicians and field supervisors will be housed in a two story building along with the control' point. Frisking equipment will be upgraded to new automatic scanner This effort is expected to be completed in July 1987. The inspector concurred with the licensee.'s assessment that the'new access point !

will greatly enhance the control of personnel exposures and radio-active' materia .2 HP Procedures Revision The status of a project to upgrade HP procedures and ensure compatibilit9 with the Limerick Station was reviewed. Approximately . 90% of all new HP procedures have been drafted but only 3% have ! received final PORC approval. A review of selected draft procedures ' led to the corclusion that most new procedures are adaptations of i LimeHck procedures. However, the inspector observed that the ,' review of these 'proceoures by an ad hoc "sub-PORC" committee of HP

  '7 supervisors ai!d' managers #ias very thoroug .3 SeniorHealthPhylcist(RadiationProtectionManager)

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The training and experience'of the recently appointed Senior Health

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Physicist was rsviewed. The individual was determined to be fully qualified ad rbqbired by, Technical Specification 6.3 and Regulatory s Guide , 7.0 'Radwaste t , i

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 ,During, tours of the plant equipment areas and the outside yard areas the inspectot noted lcrge accumulations of packaged low level waste. Since (,

1 7> the' licquee recently creatso N separate Radwaste program, the inspector b discussed the status of this program with the site Radwaste Coordinato i The.following was determined:

? / ,- No dry active waste (DAW) has been shipped off-site since the Fall
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L of 1986.

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   : Trash. sorting; compacting operations and oil' solidification have' been Linterrupted/by'various program changes and equipment relocation Since January 1987' an abnormally high. amount'of waste was generated b   .y  by plant; modification The? licensee stated that resolution of these problems is anticipated priorsto the Uni.t 3 pipe replacement outage. This matter will be-p   ,
   . reviewed in~a future-inspection (87-13-02).

b 8.0 Personnel Contamination-Incidents In're'sponse.to three'ficial" contamination incidents occurring between Ma . 5 and May 8' 1987; and subsequent workerfstatements to the news media, the

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u, , inspector reviewed the' licensee's program for the control of; skin contami-

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   : nation with-respect'to-criteria. contained in:

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    -10 CFR 20.'1031 Exposure.of-individuals to concentrations of
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radioactive materials:in air in restricted area NCRP' Report No;i65 " Management of Persons Accidentally Contaminated' with Radionuclides"-

    -Station Procedu'res'HP0/CO-5, HP0/CO-6, HP0/C0-7, HP0/C0-7A,
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, :HP0/CO.-78, HP0/CO-60 .The licensec.'s' performance' relative to these criteria was determined from:

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   -Interviews'with selected' personnel'- -

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 , J'  -ReviewLof' protective clothing selection, issuance and cleaning,
   -Review of selected radiological deficiency. reports and corrective :

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   .Withinzthe scope of the review no. violations were observe There was no significant hazard to the worker , r The' inspector concurred with the licensee conclusion that with a few exceptions, most of the personnel contamin'ation incidents occurred due to poor practices during the removal of the' protective. equipment. . The except-
   ' ions were'due to flimsy plastic "rainsuits".that have been replaced by a 1 sturdier one piece plastic coverall The inspector observed that the-
,    -licensee's method for notification of. higher. level supervision regarding-

_ personnel . contamination' events is weak in that the threshold for notifica-

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   . tion-is high and is delayed by using only. written reports without.immedi -

ate verbal notification. The licensee is aware of this weakness and is

   . reviewing methods to' improve communication . :
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9.0 Exit Meeting The inspector met with the licensee personnel denoted in Set, tion 1.1.on April.24, and May 28, 1987. The scope and findings of the inspection were discusssd at that' time, k k t

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