IR 05000277/1987026

Insp Repts 50-277/87-26 & 50-278/87-26 on 871019-23.No Violations Noted.Major Areas Inspected:Radiation Safety Program,Including Status of Recirculation Pipe Project,Alara Program,Radwaste,Staffing & Control of Hot Particles

ML20237A339
Person / Time
Site:	Peach Bottom
Issue date:	12/07/1987
From:	Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237A331	List: IR 05000277/1987026 ML20237A329
References
50-277-87-26, 50-278-87-26, NUDOCS 8712140415
Download: ML20237A339 (5)

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i U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-277/87-26 50-278/87-26 i

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Docket N License N DPR-44 1 DPR-56 l

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Licensee: Philadelphia Electric Company 2301 Mar (et Street i

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Philadelphia, Pennsylvania 1910T Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 I Inspection At: Delta,Pennsylva,ng Inspection Conducted: October 19-23, 1987 j Inspectors: 1 , ,s/ ~ ~ -/.1 82 T'. 'F. Dragodnf Senior Radiation date {

Specialist  !

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Approved by: ff/ 3 / d(V M. Shitnbaky,' Chiet /

/2/7[f7 date Facilities Radiation Protection Section Inspection Summary: Inspection on October 19-23, 1987 (Combined Inspection Report Nos. 50-277/87-26 and 50-278/87-26).

Areas Inspected: Routine, unannounced inspection of the radiation safety )

program including: statut of recirculation pipe project; ALARA program; i radwaste; staffing; control of hot particles; and a review of replacement HP procedure Results: No violations were observed. Significant weaknesses continues to ;

exist in the ALARA program (Details, paragraph 4.0).  ;

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8712140415 PDR ADUCK h[O O PDR 77 ,

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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 I

• D. M. Smith, Manager, PBAPS G. Rainey, Superintendent-Plant Services

• D. LeQuia, Senior Health Physicist, Corporate

• D. Potocik, Senior Health Physicist, PBAPS

• J. Mitman, Senior Radwaste Engineer

• A. Dowell, QA Site Supervisor N. Gazda, ALARA Health Physicist D. Schra, Waste Minimization Engineer

• R. Giordano, Radiation Protection Manager, PRPG (GE)

Other licensee and contractor employees were also contacted or interviewed during this inspectio '

1.2 NRC Personnel

• T. Jchnson, Senior Resident Inspector

• L. Myers, Resident Inspector

• Attended the Exit. Meeting on October 23, 1987 2.0 Purpose The perpose of this routine, unannounced inspection was to review the licensee's radiation protection program with respect to the following elements:

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Recirculation Pipe Replacement Project

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ALARA

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Radwaste

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Staffing

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Control of Hot Particles

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Repl6 cement HP Procedures 3.0 Recircy'ation Pipe Replacement Project In Generic Letter 84-07, the NRC established criteria for the replacement of BWR Recirculation Piping and specified that total exposure should not exceed 2000 manRem. The licensee's Unit 3 recirculation pipe replacement project was reviewed with respect to the NRC guidance through:

- Interviews with licensee and contractor personnel assigned to the project.

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- A tour of the U-3 drywell, HP access control facilities, project office and training facilitie Attendance at meetings, review of minutes of meetings, and audit report This preliminary review of the project status found that the contractnr work force (Chicago Bridge and Iron-CBI) and the HP oversight group (Pipe Replacement Project Group-PRPG) were on site, well staffed and well organized. The work in progress consisted of interference removal and equipment preparation. Actual cutting and removal of recirculation piping is scheduled to begin later this year in Decembe The PRPG reports directly to the site radiation protection manager and implements the existing site radiation protection program for the i project. The licensee has assigned four full time HP personnel to audit the project in addition to normal QA and Engineering oversigh Special control point and support facilities for Unit 3 drywell access are complete. A system to control work and the flow of material in and out of the drywell is in plac This project will be reviewed again in a future inspectio .0 ALARA The licensee's ALARA program was reviewed with respect to criteria contained in:

10 CFR 20.1 Purpose Regulatory Guides 8.8 and 8.10 Performance relative to these criteria was determined from:

discussions with the ALARA Engineer (supervisor) and members of the l ALARA group, l

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review of station procedures HP-301, -302, -303, -304 -308,

-309, -311, -312, and -31 review of Unit 2 outage performance, ALARA goals, and status of the employee ALARA suggestion progra !

Within the scope of this review, no violations were observed. However, a major weakness continues to be noted as follows:

There is no corporate ALARA program, no corporate audits of the site ALARA program and no ALARA review of design modification package This weakness has been discussed during previous inspections with the l licensee. The corporate Director of Radiation Protection stated that a l l

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program is being developed and will be. implemented during the next few month This matter remains unresolved and will be reviewed in a future inspection (87-26-01).

Some improvement has been note The site ALARA group has been moved to improved offices in the TVBB building. Four experienced technicians have been assigned to the maintenance, radwaste, laboratory and construction groups to incorporate ALARA early into the planning proces .0 Radwaste During two previous inspections (87-13 and 87-21), the inspector observed large accumulations of packaged dry active waste (DAW) on site. During this inspection, the inspector reviewed the licensee's efforts to control DAW through discussions with supervisors and waste engineers, tour of the site and waste segregating areas, and review of new draft procedure No violations were observed. The licensee's performance in this area has improved. A full time waste minimization engineer has been added to the site radwaste staff. Two new procedures nave been developed: RW. - 130,

" Dry Active Waste (DAW) Minimization Program" which is PORC approved and RW-530, " Operation of HNS DAW Volume Reduction System" (draft). These actions are intended to reduce the volume of waste generated. Resins are now chemically solidified using the AZTEC process. The contaminated lubricating oil, that was stored on site, was processed by a contractor and the clean oil salvaged. Efforts to segregate clean from contaminated scrap are continuing on site by HNS and offsite by Quadrex. Frequent

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shipments are being made to reduce the large accumulation of DAW onsit A tour of the site shows a good reduction in onsite storage of wast ,

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Although licensee efforts are not complete, progress is noticeable goo Inspection item 87-13-02 is therefore close .0 Staffing The Applied HP section of the RP department had recently undergone a major expansion and reorganization. The status of the staffing of this section was determined from discussions with the Senior Health Physicist and a review of selected documents. The key position of Applied HP supervisor has been vacant for several months. The inspector found that the Shift Supervisor positions have been filled by qualified personnel and an offer has been extended to en Applied HP supervisor candidat Job descriptions have been issued for the new positions. Licensee progress in reorganizing and staffing the HP department is acceptabl Progress in this area will be reviewed in a future inspectio .0 Control of Hot Particles The licensee's hot particle program was reviewed with respect to guidance provided in NRC Information Notices 86-23 and 87-39. The status of the program was determined from discussions with the licensee's HP consultant and a review of selected document {

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The licensee has a program ready for implementation. A controlling procedure (Hi'-212. " Hot Particle Detection and Control") is scheduled for PORC approval. Other procedure revisions, such as the frisking procedure, have also been revised. A sticky smear survey of the fuel floors and drywells of both units was completed to characterize the particles. Only hot particles (activated corrosion products) were found while " fuel fleas" (fuel fragments) were absent. Lesson plan for HP technician training, as well as GET, have been develope ;

The inspector concluded that the licensees approach was technically sound to comply with the applicable regulations. The final implementation of the hot particle program will be reviewed in a future inspectio (87-26-02) 4 8.0 Replacement HP Procedures Early in the year, the licensee initiated a project to replace all HP procedures with improved versions. This project is now nearly complete with 143 of 153 administrative and HP procedures receiving a pre-PORC review. The inspector reviewed a sampling of procedures and found them to be generally of high technical quality in a consistent easy-to-use format. The licensee indicated that a cycle of final " tune-up" changes to the procedures will be made based on changes recommended by in-field technician .0 Exit Interview The inspector met with the licensee personne'l denoted in section 1.1 at i the conclusion of the inspection on October 23, 1987. The scope and f findings of the inspection were discussed at that tim >

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