IR 05000277/1988007

Safety Insp Repts 50-277/88-07 & 50-278/88-07 on 880216-19. Violation Noted:Major Areas Inspected:Worker Allegation Re Use of Respiratory Protection & Hot Spot Shielding in Unit 3 Drywell & Retraining Facility Staff in Radiation Protection

ML20151B960
Person / Time
Site:	Peach Bottom
Issue date:	03/31/1988
From:	Dragoun T, Shanbaky M, Thomas W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151B952	List: IR 05000277/1988007 ML20151B949
References
50-277-88-07, 50-277-88-7, NUDOCS 8804120053
Download: ML20151B960 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-277/88-07 Report No /88-07 50-277 Docket N DPR-44 License No. DPR-56 Priority --

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: February 16-19, 1988 Inspectors: '

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gj,3g, W. Themas, Radiation Speci lisl / date Approved by: .- 9 77 64 @.

M. Shanbaky, Chief, Facilities Radiation 2/i//J'8'

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~ date Protection Section Inspection Summary: Inspection on February 16-19, 1988 (Combined Inspection Nos. 50-277/88-07 and 50-278/88-07)

Areas Inspected: Routine, unannounced inspection of the radiation safety program including: a worker allegation regarding use cf respiratory protection and hot spot shielding in the Unit 3 drywell; retraining of the facility staff in radiation protection; calibration and maintenance of health physics instruments; processing of exposure reports to terminated workers; and status of the recirculation pipe replacement projec Results: One licensee identified violation was observed but not cited due to

! prompt corrective actio (Details in Section 5.0)

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DETAILS 1.0 Persons Contacted 1.1 Licensee Personnel

• D. M. Smith, Vice President, PBAPS

• J. Franz, Plant Manager

• C, Anderson, Assistant Superintendent - I&C N. Burkin, I&C Supervisor

"M. Cassada, Director - Radiation Protection

• G. Darbeler, Superintendent - Technical M. Deidrich, Physicist - Dosimetry

• A. Donell, QA

• E. Fogarty, Nuclear Support

• Gazda, Radiation Engineering Supervisor

• Giangiulio, Engineer - Pipe Project R. Giordano, PRPG Radiation Protection Manager

• D. LeQuia, Superintendent - Plant Services G. McCarty, Physicist - Technical Support P. Sawyer, PRPG Operations Manager R. Smith, Physicist - Instrumentation 1.2 NRC Personnel

• T. Johnson, Senior Resident Inspector L. Myers, Resident Inspector

• R. Urban, Resident Inspector Additional personnel were contacted or interviewe * Attended the exit interview on February 19, 198 .0 Purpose The purpose of this routine, unannounced inspection was to review the licensee's radiation protection program with respect to the following elements:

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Worker Allegation

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Staff Retraining

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Maintenance of HP Equipment

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Termination Exposure Reports

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Recirculation Pipe Replacement 3.0 Worker Allegations Prior to the conduct of this inspection the NRC received Allegation RI-88-A-0016 on February 4,1983. Characterization of the two alleged concerns were failure to utilize respiratory protection devices while

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working in the Unit-3 drywell and failure to provide adequate radiation shielding in the Unit-3 drywel .1 Allegation of Lack of the Use of Respiratory Protection Devices During the last week of January 1988, the alleger was removing in-sulation on the 116' elevation of the Unit-3 drywell. The alleger expressed concern that while doing work without a respiratory pro-tective device, other workers were doing work in the same general area with respirators. The RWP controlling his work did not require respirator use while the surrounding work parties wore respirators according to their RWP. The alleger was concerned that he might be breathing radioactive material and unhealthy dust. He stated that his foreman and supervisor were upset about the respirator use policy by the Pipe Replacement Project Supervisors for Unit Inspector Review The inspector reviewed the applicable Radiation Work Permits (RWPs)

which cover the Unit 3 pipe replacement. activities under which the worker worked, interviewed the Health Physics Operations Manager, and attempted to contact the Alleger without success. Also reviewed were Radiation-Contamination- Airborne Survey data sheets, and Air Analysis Data Sheets for the 116, 135, and the 157 foot elevations of the Unit-3 drywell during the alleger's work tim Over a thousand air samples have been taken and analyzed of tha d ry-well atmosphere. Less than 10% of the samples exceed >25% MPC for mixed fission products and none of the samples with greater than 25%

of MPC were taken on the 116' elevation. Other workers using respiratory protection devices were working in close proximity to potential air-borne activity area Examination of the Unit 3 D/W Entry Sheets do not indicate that the alleger has worked in any of these areas. Based on this review, the inspector concluded that respiratory protection equipment was not required for the activities performed by the allege .

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3.2 Allegation of the Lack of Use of Shielding to Reduce Dose, Use of Supplemental Dosimetry and Uncooperativeness of Healtn Physics (HP)

Personnel When A Worker Has A Concern The alleger also stated concerns about the lack of use of shielding to reduce dose when working close to a hot pipe. He worked in an area of the drywell where a pipe had about 2R/hr at contact. He had to remove conduit and in so doing, he had his back against the pip He was wearing no dosimeter on his bac He asked about shielding the pipe and was told by an HP technician that shielding could not be don He finds HP personnel uncooperative when a worker has a con-cer Inspector Review The inspector reviewed HP-603, Use and Placement of Personnel Dosi-metry, HP-621, Issuance of Supplemental Dosimetry, and HP-313, Speci-fications and Use of Temporary Shielding. It was determined that the short time (1 minute) involved in this particular activity did not justify the addition of temporary shielding to the pipe in questio The use of supplementary dosimctry on the back is also not justifiable since the time of exposure was short with minimal radiation exposur With regard to the alleged uncooperativentss of HP personnel, the inspector verified that cooperation between HP staff and other station personnel was good. This part of the allegation is determined to be without basi .0 Training In order to determine whether the licensee ensures that plant employees, contractors, and visitors are adequately trained and qualified to control radiation anc' radioactive material, the inspector reviewed the training, retraining, and qualifications of the facility staf A new Manager, Nuclear Training Services has recently been hired, however, no significant changes in training policies, goals, programs, and methods related to radiation protection activities were identifie Discussions were held with the administrative support coordinator and the training coordinator to discuss the ongoing training program. Additionally, a meeting was held with the training instructors for the various disciplines and a review of lesson plans was conducte The inspector determined from this review that an adequate training and retraining program for facility staff members has been initiate .0 Maintenance and Calibration of Radiation Protection Equipment The licensee's program for calibration and maintenance of radiation protection equipment was reviewed with respect to criteria contained in:

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Technical Specification 6.8 - Procedures

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Technical Specification 6.11 - Radiation Protection Program

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Regulatory Guide 8.4 "Direct reading and Indirect reading Pocket Dosimeters"

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Regulatory Guide 8.25, "Calibration and Error Limits of Air Sampling Instruments for Total Volume of Air Sampled"

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Regulatory Guide 8.28, "Audible-Alann Dosimeters"

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Draft Regulatory Guide OP-032-5, "Test and Calibration of Radiation Protection Instrumentation"

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ANSI-N323, "Radiation Protection Instrumentation Test and Calibration"

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10 CFR 20 - Standards for Protection Against Radiation The licensee's performance relative to these criteria was determined from:

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interviews with supervisors in the Radiation Protection and Instrument Calibration departments.

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a tour of the calibration laboratories and instrument issue cage interviews with various HP and IC technicians

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review of calibration, source check and training procedures and selected record Technical Specification 6.8 requires the licensee to have procedures

to ensure compliance with 10 CFR 2 Within the scope of this review one violation was identified. Section 20.201 of 10 CFR 20 requires licensees to make surveys in order to evaluate radiation hazards. Instruments must be properly calibrated and maintained to provide sufficiently accurate measurements of radiation levels or con-centrations of radioactive material. The licensee did not have formal cali-bration or source check procedures for the IRT PRM-110 Portal Monitor However, during this inspection, on February 18, 1988, the station PORC comittee approved draft procedure HP-429 "Source Response Check for the IRT Portal Monitor". The licensee also produced surveillance test procedure RT 7.32 "Portal Radiation Monitor Model PRM-110 (and PRM-120) Sensitivity and Source Check" dated June 5, 1986 and stated that a separate test and calibration procedure would be developed by March 1,1988. Although the lack of procedures constituted an apparent violation, no citation will be issued due to the licensee's imediate corrective action and in accordance with 10 CFR 2, Appendix C. The implementation of this new procedure will be reviewed during a future inspection. (88-07-01)

Additional program weaknesses were identified as follows:

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The HP instrument issue cage located inside the power block is in an

area of elevated background level of several nr/hr due to nearby crud

traps. This radiation background prevents operational checks of sensitive instrurents such as friskers on their lowest scales prior l

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to issuance. The licensee stated that additional pipe flushing will be performed to minimize the dose rate in the are The training program for I&C technicians is specified in administrative procedure TI-02-50002 "Qualification and Training of Testing and Laboratories (T&L) Division Personnel". This program does not have a module to ensure that technicians are qualified to repair and calibrate HP equipment. The T&L Training Coordinator provided the inspector with a copy of Program Description 2000" Instrument and Control Technician Initial Training Program" dated October 1986 which contains an appropriate module. However, this revised training program was never implemented. The inspector stated that this item will be examined during a future inspection. (88-07-02)

A program strength was noted in that a full time Instrument Physicist is on the staff and the HP field technicians in the instrument issue facility are conscientious in performing daily source check .0 Termination Exposure Reports The licensee's program for providing radiation exposure reports to terminated contractor personnel was reviewed with respect to criteria in Technical Specification 6.10, "Record Retention", and 10 CFR 20.408 "Reports of Personnel Monitoring on Termination of Employment or Work." The licensee's performance was determined by reviewing records for selected subcontractor personnel who had received exposures and terminated for more than 90 day Within the scope of this review no violations were observed. Although the termination exposure reports were sent to the workers within the allocated time, a weakness was noted as follows:

There is no system to notify the dosimetry department that a worker is terminating thereby starting a "clock" to ensure that the report is issued within 90 days. The licensee stated that a formal termination system is being developed. This matter will be reviewed in a future inspection. (88-07-03)

i l 7.0 Recirculation Pipe Project The status of the recirculation pipe replacement project on Unit 3 was reviewed through discussions with cognizant managers and a review of status reports.

l l Control of radiological hazards by the Pipe Replacement Project Group (PRPG)

l group continues to be good. An estimate of man-rem doses at project com-l pletion was made after chemical cleaning of the pipe. This projects that l a total of approximately 1700 man-rem will be expended. The Radiation l Protection Manager is tracking several performance indicators on a daily l and weekly basis to detect abnormal trend No adverse trends were noted.

! New initiatives include the use of videotaped mock-up training and ALARA suggestion awards. Oversight and control of pipe replacement by licensee management also continues to be goo . . . . - _

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8.0 Exit Interview The scope and findings of this inspection were discussed with personnel denoted in Section 1 at the conclusion of the inspection on February 19, 198 . _ . ._ --.