IR 05000277/1987021

Insp Repts 50-277/87-21 & 50-278/87-21 on 870713-17.No Violations Noted.Major Areas Inspected:Licensee Radiation Safety Program Including Training of in-house Technicians, Organization & Staffing & Total Dose Control Program

ML20237G733
Person / Time
Site:	Peach Bottom
Issue date:	08/20/1987
From:	Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237G677	List: IR 05000277/1987021 ML20237G673
References
50-277-87-21, 50-278-87-21, IEC-80-02, NUDOCS 8709020387
Download: ML20237G733 (7)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report Nos. 50-277/87-21 50-278/87-21 I

Docket Nos. 50-277 Category C 50-278 (

Licensee: Philadelphia Electric Company 2301 Mar (et Street Philadelphia, Pennsylvania 19101 l

Facility Name: Peach Bottom Atomic Power Station, Unit 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: July 13-17, 1987 Inspectors: b A d ) Lt* c1 -8c d lf!/'/!f 7

"date j ff. Dragoun, Senior Radiation / Specialist Approved by: k l ML (c~,

M. Shanaaky, Chief, Fadilities Radiation 8}wlB7 date Protection Section Inspection Summary: Inspection on July 13-17, 1987 (Combined Inspection Report Nos. 50-277/87-21 and 50-278/87-21)

Areas Inspected: Routine, unannounced inspection of the licensee's radiation safety program including: training of in-house HP technicians; organization and staffing; total dose control program; radwaste; heat stress program; control of overtime; QA audits; use of metal detector; and an allegation regarding a Unit 2 drywell entry in 198 Results: No violations were identifie '~

PDR ADOCK 05000277 G PDR

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DETAILS 1.0 Persons Contacted During the course of this routine inspection the following personnel were contacted or interviewed:  !

1.1 Licensee Personnel D. Smith, Manager, PBAPS R. Andrews, Training Coordinator M. Cassada, Director, Radiation Protection l W. Knapp, Director, Radwaste  !

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M. Moore, QA  :'

D. Potocik, Senior Health Physicist G. Stenclik, Instructor Other licensee and contractor employees were also contacted or interviewed during this inspectio All personnel above attended the exit interview on July 17, 198 .2 NRC Personnel T. Johnson, Senior Resident Inspector 1 R. Urban, Resident Inspector I 2.0 Purpose The purpose of this inspection was to review the licensee's radiation protection program with respect to the following elements:

Training of In-House HP technicians

Organization and Staffing

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Total Dose Control Program l Radwaste Heat Stress Program  :

Control of Overtime

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QA Audits Use of Metal Detectors Allegation 3.0 Training of Jn_-House HP Technicians The training qualification program for in-house ' _alth Physics Technicians was reviewed with respect to criteria contained in:

Technical Specification 6.3, " Facility Staff Qualification" Technical Specification 6.4, " Training"

Technical Specification 6.10.2, " Record Retention"

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I ANSI N18.1-1971, " Selection, Qualification, and Training of Personnel for Nuclear Power Plants" Station Procedure HP-100 Rev. 0 " Health Physics Personnel Selection, Training and Qualification."

l The performance relative to these criteria was determined from:

Interviews with the training coordinator, course coordinator and instructor Review of training plan code HPS, HPAT, HPC, HPB and HPA Review of quizzes associated with various training modules and qualification exams Review of three training manuals (qualification folders)

Observation of an AT technician training session Review of training records for initial qualification and retraining provided to the staff Within the scope of this review, no violations were observed. The licensee is conducting an acceptable training program that has been INP0 certifie However, major weaknesses were observed as follows:

1) Training facilities are barely adequate. There is no training laboratory equipped with a multichannel analyzer, counting equipment, computer or other specialized hardware. Students must use operational equipment in the plant on an as available basis for hands-on practice. This may jeopardize equipment needed for routine plant operations and is not an optimum training environmen Classroom space is minima Although large classrooms are available outside the controlled area for in-processing of the work force, the one classroom on-site dedicated to technician training was crampe Retraining of staff technicians is conducted in various small conference rooms on site. Other classroom space on site appears to be fully utilized for various other on-going training program l i

A few years ago, the licensee had advised the inspector of plans to {

use the decommissioned Peach Bottom Unit I facilities for trainin Although the need for facilities was known at that time, no progress has been made. The licensee now advises that most training will be i temporarily moved to an off-site location, to be returned to the i site at some undetermined future date. The status of this program will be reviewed in a future inspection (87-21-01)

2) With the exception of one contracted instructor, the HP training staff is inexperienced. Records were not available onsite to provide evidence of which topics the instructors are qualified to teach. The training coordinator stated that such records will be obtained. This matter will be reviewed in a future inspection (87-21-02). In contrast, the instructors for Chemistry Technician training are experienced and appeared to provide a greater technical depth particularly in retraining / refresher classe !

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4.0 Organization and Staffing

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The organization and staffing of the radiation protection department is ;

shown in Technical Specification Figure 6.2.2. The status of proposed changes in the organization was determined from:

Discussions with the Senior Health Physicist and Assistant Superintendent Review of Organization / Manpower Summary and various Position Guides Changes to the three live functions reporting to the Senior Health Physicist are summarized as follows:

1) Support HP - will remain unchanged with responsibility for instrumentation and control, dosimetry, and respiratory protection as befor ) Applied HP - first line supervision will be substantially changed with the addition of seven HP foreman who will direct activities of the in-house and contractor technicians on all shifts. Second line supervisors are scheduled to be replaced and responsibilities re-define ) ALARA (Rad. Engineering) - additional professional personnel will be added to the staff. Responsibilities will be expanded beyond ALARA to include radiological and computer engineerin {

The licensee indicated that management is giving priority attention to completing changes in the Applied HP function over the next few week ;

The inspector noted that the proposed changes incorporate the  !

l recommendations found in NUREG-0761 end current industry practice l However, not all Position Guides had been developed or revised to reflect l the new organization. The licensee stated that this would be completed by 9/1/87. The matter will be reviewed in a future inspectio (87-21-03)

5.0 Total Dose Control Program In a letter to the NRC dated June 18, 1987, responding to inspection 'l 87-07, the licensee stated that a total dose control program would be I implemented by July 31, 1987. The status of the program was determined from discussions with selected personnel, a tour of the new control point under construction and a review of draft procedures HP-310 " Radiation Work Permits" and HP 601, " Access Control and Dose Tracking."

Management support for this effort was clearly evident. The physical !

facilities and administrative procedures were near completion with rapid progress taking place. The Total Dose Control Program represents a departure from the previous methods used to control personnel and material entering radiologically controlled areas. Impact on all site operations is expected to be substantial with benefits anticipated to the radiation safety progra _ - _ _ _ _ _ - _ _ _ _ _ - . _ _ - _ _ _ - _ _ _ - _ _ _ _ _

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6.0 Radwaste During inspection 87-13 the inspector observed large accumulations of ;

packaged low level waste (dry active waste-DAW) Since that time the licensee has begun moving DAW to the low level waste facility adjacent to the site and super-compacting 55 gallon drum The inspector and Senior Resident Inspector toured the new facility, observed operations in progress and material in storage, and interviewed selected personnel. No violations were observed. A full time HP teccnician provides continuous coverage. Additional technicians provide coverage for specific jobs such as transfer of containers into shipping casks. Radiological controls appeared to be generally adequat A tour of on-site areas revealed that waste stored inside and outside the power block has decreased somewhat. However, a substantial amount remains to be processed. The licensee was advised that continued management attention to this matter is require Inspection item 87-13-02 remains ope .0 Control of Overtime The licensee control on overtime worked by HP technicians was reviewed with respect to criteria contained in NUREG 0737 item I.A.1.3, IE Circular No.80-02, and station procedure A-40, " Working Hour Restriction," Rev. 3. The amount of overtime worked was determined by a review of a log maintained by the Applied HP supervisor and interviews with selected personne In general, adequate controls are exercised and procedure A-40 requirements are met. Instances of requests to waiver the 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per day maximum occurred early in the Unit 2 outage. The technicians !

normally work twelve hours per day for 5 or 6 days in succession during the outag The inspector was concerned because the records show that an excessive amount of overtime is offered to technicians. Most of the overtime is )

declined, keeping the actual work time within reasonable bounds. The inscector also noted that procedure A-40 is less conservative than the recouendations provided in IEC 80-0 )

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The Station Manager indicated his concern that the overtime, although l kept within policy li' nits, should be reduced and that he has been reviewing this matter, l

8.0 QA Audits  !

l In a letter dated June 18, 1987, responding to inspection 87-07, the ;

licensee stated that specific action would be taken to correct QA

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identified HP d;ficiencies. The status of licensee action is as follows:

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1) lip personnel will be trained as auditors and QA auditors will be trained in how to audit H ) Audit instructions will be changed. In June 1987, the licensee issued " Audit Section Instruction for Audits of Health Physics Activities ASI-01HP" which provides detailed instructions and an extensive list of reference ) The Radiation Protection Section is being restructured and will provide assistance. This reorganization is discussed in section The inspector concluded that progress on these commitments is adequat .0 Use of Metal Detectors The inspector observed that the metal detector at the security entrance was alarming frequently. Incoming personnel causing the alarm were pat-down searched by the security guard and" allowed to pass. This approach is one of the options provided in the security and safeguards ,

plan. However, the cause of the alarm is often not discovered during the j pat-down searc '

Security supervisors on site advised that access is granted in these cases based on the pat-down searc Furthermore, instructions would be l l issued to the guards by 7/17/87 to use a hand held metal detector after !

the pat-down in an attempt to locate the metal. This matter will be ;

reviewed in a future security inspection.(87-21-04) I I

10.0 Allegation (RI-87-A-0069)

On June 17, 1987, the NRC received an allegation from a former contractor employee stating that a crew of seven workers were overcome by heat stress and received a high level of skin contamination during an entry

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into the Unit 2 drywell in November or December 1985.

I Information relative to these concerns was obtained as follows:

- Interviews with the site safety coordinator and Applied HP supervisor, both of whom held the same positions at the time of the alleged inciden A review of the .ollowing documents:

Site procedure HP0/C0-24 Access to Primary Containment (Drywell and Torus)

Licensee and contractor records of heat stress cases for this l

period

"A-86" reports

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l The drywell HP control point log The drywell access log All RWP sign-in sheets for the Unit 2 drywell and adjacent ]

area J Unit 2 operating history j The licensee records were comprehensiv The original logbooks were returned via airfreight from the corporate subterranean storage for review by the inspecto The inspector concluded that the alleger did not enter the drywell during the period. In addition, there is no evidence that the alleged events >

occurred. Allegation Rl-87-A-0069 is without basi )

11.0 Exit Interview The inspector met with the licensee personnel denoted in section 1.1 at the conclusion of this inspection on July 17, 1987. The scope and findings of the inspection were discussed at that tim I s

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