IR 05000277/1988037
| ML20206C222 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/03/1988 |
| From: | Dragoun T, Markley M, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206C214 | List: |
| References | |
| 50-277-88-37, 50-278-88-37, NUDOCS 8811160169 | |
| Download: ML20206C222 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-277/88-37 Report No.
50-278/88-37 50-277 Docket No.
50-278 CRP-44
i License No. ORP-56 Category _C_
I Licensee: Philadelphia Electric Company 2301 Market Street
'hiladelphia, PA 19101 i
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facility Name:
Peach Bottom Units 2 and 3 Inspection At:
Delta, PA i
Inspection Conducted:
Septe3ber 26-30, 1988 l
Inspectors: !.
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// 7 clY T. Drago enior Radiation Specialist, ORSS
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b ~ tion L uMe
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ecialist, Ok55 date M.' Mark gy Approved by:
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[_[3 N
nbaky, ' Chief, Fre ties Radiation cate
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Protection Section, FR$$, OR$5
~ Inspection on September 26-30, 1988 (Combined Report i
Inspection Sumary:
Nos. 66727?/8s!31 and 5D-27s7ss9 7)
Areas Inspected:
Routine, unannounced inspection of the radiation safety program including:
status of previously identified items, post project
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reviews of Unit 3 pipe replacement, general employee training, external and
internal exposure control, survey instrumentation and control of work.
Results: No violations were identified.
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8811160169 881107 POR ADOCK 05000277
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DETAILS
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1.0 Persons Contacted l
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1.1 Licensee Personnel D. M. Smith, Vice President, PCAPS D. LeQuia, Superintendent - Plant Services i
G. Hanson, Regulatory Engineer T. Cribbe, Regulatory Engineer D. Poto:1k, Radiation Protection Manager (
P. $wafford, Health Physics Operations Supervisor t
1.2 NRC Personnel
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T. Johnson, Senior Resident Inspector t
R. Urban, Resident Inspector j
t The above personnel attended the Exit Interview on September 30,
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q 1988. Additional personnel were contacted or interviewed during l
the course of this inspection.
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2.0,Perpose i
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The purpose of this routine inspection was to review the licensee's
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-Status of Preatously idehu f f ed Items; t
j-Post preject Review of Unit 3 Pipe Replacement;
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-General Employee Training;
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-External Exposure Controls:
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-Control of Work;
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-Survey Instrumentation; e
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-Internal Exposure Controls, f
i 3.0 Status of Previously Identified Items fi 3.1 (Closed) Follow Item (277/86-12-09 and 278/86-13-09) Review Health
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Physics (HP) department organization and staffing to ensure effective
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conduct of responsibilities. The HP department has been reorganized
into three sectionst Radiological Engineering; Appited HP; and j
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Support HP. The number of first line supervisors in the Applied HP
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j group was expanded from one to seven.
Some personnel were
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j reassigned. These changes h3ve improved oversight of work activities j
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and timely review of events, j
t 3.2 (Closed) Unresolved Item (277/87-07-02 and 278/87-07-01) Resolve
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delays in resolutions of Health Physics Discrepan:y Reports (HPCR)
i particularly those assigned to the Operation Department.
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June 18, 1987 letter, the licensee stated that corrective action will
include:
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Assigning a Technical Assistant in the Operations Depar'; ment
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to the resolution of HPCRs.
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Assigning additional HP personnel to HPOR resolution, i
These actions are complete.
To prevent recurrence of dilays and i
i to upgrade the progra, in March 1988, the licensee replaced the i
HPDR procedure with a new procedure titled #A-110 "Radiologica)
Occurrence Reports" (ROR).
The new procedure places a 10 to 30
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day limit (depending on severity) on resolution of the ROR. A licensee Quality Assurance audit (#APB8-79-PR) completed in July
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i 1938 found that resolution of old HPDRs took 114 days on average
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while the new ROR were resolved. in 16 days.
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3.3 (Closed) Unresolved Item (277/87-07-03 and 278/87-07 02) Corporate
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HP assessors need formal followup mechanisms.
In May 1988, the
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licensee issued procedure #RP-I-107 "Radiological Assessment
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assessment program and the fortnal resolution on findings.
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3.4 (Closed) Unresolved Item (277/87-07-05 and 278/87-07-04) Tht. RWP i
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procedure was not followed and inadequate surveys were taken during I
i work in the Drum Capping Aisle.
Licensee corrective action was i
j determined to be as follows:
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The "A" level HP technicians were trained and tested regarding
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stop wo"k authority in June 1987, This topic was emphasized i
again by the new HP Operations Supervisor in a "All Hands
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Meeting" in February 1988.
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ALARA personnel received training regarding pre-job evaluations i
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j in July 1987.
Procedure #HP-311 "Pre-job ALARA Review" was
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revised in August, 1937 to provide additional guidance for pre-job evaluations.
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procedures #A-107 "Radiation Work Permit Program" and ifHP-310
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"Preparation and Processing of Radiation Work Permits" were
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revised to clearly delineate stop work authority.
The need for
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compliance with these procedures was emphasl:ed in the February
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1988 "All Hands Meeting",
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j Licensee action on this matter is complete and satisfactory
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3.5 (Closed) Follow Item (87-21-03) Revise job descriptions to reflect
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i the new HP organization. All required position descriptions have j
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ceen issued and included the appropriate technical specification j
training and experience requirements,
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3.6 (Closed) Unresolved Item (87-26-01) Develop a corporate ALARA program.
The ALARA program is described in a manual issued by the Executive Vice President in April 1983.
The program is well structured and raflects a state of the art opproach.
Implementation is underway as reflected by initiation of a station ALARA Council in June 1988 chaired by the Vice President. Monthly meetings have been held since then. This matter is closed.
3.7 (Closed) Follow Item (87-21-02) Qualification records for the training staff should be available on site.
The experience resumes and qualification records for HP and GET instructors are now available on site. Management authorization for courses that an instructor can teach are reflected in these records.
3.8 (Closed) Follow Item (88-07-02) Formally qualify ("Instrumentation" and "Controls") I&C technicians to calibrate and repair HP instruments.
This specific qualification has been added to procedure
- TL-02-50002 "Qualification and Training of Testing and Laboratories Division Personnel" in May 1988.
To date, 32 technicians have completed the on-the-job training "Study Guide 22601P" regarding calibration of Eberline R0-7 ton chamber survey meters. This matter is closed.
3.9 (Closed) Follow Item (88-07-03).
Estabitsh a formal termination procedure to ensure that exposure reports are issued within 90 days.
Procedure #A-106 "Dosimetry Program" issued on 9/20/88 adequately describes the termination procedure.
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3.10 (Closed) Follow Item (88-11-01) Upgrade continuous air monitors.
The Itcensee purchased 24 new Eberline AMS-3 units and placed 19 in service in the plant. A calibration procedure (#TL-12-00528) and operating procedure (#HP-448) are issued for this equipment.
3.11 (0 pen) Follow Item (87-21-01) Upgrade training facilities for HP technicians. Although a new training department has been created en site, no progress regarding training facilities was evident.
3.12 (Closed) 50-277/88-18-01 and 50-278.88-18-01 (Unresolved) Gross ceficiencies in GET training.
Inspector review of General Employee Training (GET) and General Employee Retraining (GRT) indicated that program material required by 10 CFR 19.12 was included in the lesson plans. On September 28, 1988, the inspector attended a GET/GRT training session where the instructor adequately covered the course material.
Specific program modifications and implementation instructions were presented and clarified as necessary.
Thir item is closed.
4.0 Post project Review - (RPR)
The inspector discussed the post job revit
- recently completed Recirculation Pipe Replacement (RPR) with ersonnel.
The preliminary results indicate that worker-recirculation
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and RHR pipe work amounted to 1074 man-rem.
This is about 500
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l man-rem less than the best domestic nuclear plant performance and is le:,s than half of-the exposure expendet for the same work on Unit 2 (2200 nan-rem).
The licensee was comnended for good oversight of the project contractor and achieving this outstanding ALARA success.
The licensee retained certain HP contractor personnel when the RPR organization was disbanded to assist with other work in the Unit 3 drywell.
The same high level of ALARA performance was achieved, by another contractor, during the replacement of the LPRM and PIP cables in the under vessel area.
Both the total exposure and project schedule were about 1/3 of the expenditure at another plant performing the same work.
This was attributed to the application of the same ALARA techniques used I
during the RPR project.
The licensee stated tnat efforts are underway to
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permanently incorporate these successful techniques into the site ALARA l
program.
l Other indicators of good performance included the absence of radioactive material intake by workers and no significent personnel contarr' nations.
j 5.0 General Employee Training Evaluation of the licensee's program for General Employee Training (GdT)
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and General Employee Retraining (GRT) was based on:
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- 10 CFR 19, "Notices, Instructions, and Reports to workers; Inspections";
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- review of site Technical Specification requirements.
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Licensee performance relative to the above criteria was determined from:
- observation of a GET training session; review of training lesson plans;
- review of Peach Bottom Atomic Power Station Audit No. AP88-9BTR;
- discussion with licensee personnel; and rcview of station procedures.
Within the scope of this review, no violations were identified. One open item (50-277/88-18-01 and 50-278/83-18-01) was closed in the course of i
this review.
Staffing was determined to be adequate.
The licensee recently filled two managemerit positions with new personnel.
Specifically, the Supervisor of General Training and the Senior GET/GRT positions were filled.
The instructor staff has romained stable.
It is supplemented with contractor persornel having relevant experience and training.
Review of the GET instructor qualifications indicated no weaknesses.
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Lesson plans wrre noted to include adequate radiological hafety
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guidance.
The program includes instructions to workers, delineation of worker responsibilities, and practical factors training.
Lesson plan guidance was found to be consistent with regulatory requirements i
containt:d in 10 CFR 19.12.
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On September 28, 1988, the inspector attended a GET/GRT training
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session.
The instructor adequately covered caterial in the lesson plans.
Some informaticn presented in the training films was presented
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in a complicated manner such that the instructor had to clarify the (
application.
Specifically, the training film covering surveys and
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contamination expressed radioactivity in confusing and seldom used j
units of measure (epm / square ft. and mR/h/ square ft.).
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licensee administrative exposure 1tmits have been changed but the
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slide presentation has not been updated to include these changes.
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Discussion with the licensee indicated that these changes would be made.
Discussions with the instructors indicated that their attitudes and i
morale was generally poor. Most of the negative attitudes appeared to
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result from conflicts about the training schedule and poor communications
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with other site groups. Although these attitudes were not evident in the
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training session attended by the inspector, concern was expressed to
licensee nansgement that training may be detrieertally affected if poor i
instructor morale persists.
Licensee management stated that they were l
aware of the problems and that it would be resolved.
Inspector evaluation indicated that GET/GRT facilities and equipment were f
adequate.
Training classes are currently held in a grouping of trailers j
pending completion of new facilities at Unit 1.
At the time of inspection, no estimated date of complet. ion was available.
6.0 External Exposure Control The licensee's program for external exposure controls was reviewed I
e p it t criteria contained in the following:
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- 10 CFR 20. "Standards For Protection Against Radiation";
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- site Technical Specifications;
- review of station procedures;
- Information Notice (!N) 86-23. "Excessive Skin Exposure Due to Contamination with Hot Particles";
Information Notice (IN) 87-39, "Control of Hot Particle Contamination
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at Nuc. lear Power Plants".
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Evaluation of licensee performance in this area was based on the k
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- observation of radiological work act1<itit;s;
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- discussions with liceasee personnel; t
performance of independent surveys;
- review of Radiation Work Permits (RWPs) and associated surveys; and
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- examination of radiological survey instrumentation.
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Within the scope of this review, no violations were identified.
l 6.1 Postino and labeling j
Radiological posting and labeling in the facility was generally f
good. However, two anomalous postings were identified,
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J In one area on the 102 ft, elevation of Unit 2 the inspector l
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nieasured general area dose rates ranging up to 6 m4/h outside the
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posted Radiation Area.
The cogni: ant HP techniciar, was notified and immediately corrected the area boundaries.
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The other anomaly involved inconsistent access posting to the
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j lowest elevation of the Unit 2 drywell. One sign indicated that the i
j elevation was an Airborne Radioactivity Area while all other posting
i identified it as being a Respiratory Protection Required area. The f
licensee was informed and corrected the posting inconsistency,
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l 6.2 Control of Work Activities
i Inspector observation of inplant radiological safety indicated that ex$ernal exposure controls were well maintained. Radiation Work,
Permits (RVPs) were adequate in providing protective measures for l
workers.
Radiological surveys were adequate in characterizing the radiological hazards. Health Physics technietans were obterved to j{
be maintaining positive exposure controls. Briefings to workers j
regarding radiological conditions were consistently well done.
Technicians frequently provided detsiled information that was l
not found on the RWP survey maps.
This indicates that technicians j
were vigilant in conducting independent surveys.
Health Phys cs Survey Instrumentation 0,3 Q
I Inspector examination of health physics survey instrumentation I
indicated good licensee performance. All survey instruments were l
fcund to have vaild casibration stickers.. HP technicians were found j
to be kncwledgeable of instrument issue equirements, acceptance i
criteria, and proper use.
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70 Internal Exposure Controls The licensee's program for internal exposure controls was reviewed against criteria contained in the following:
- 10 CFR 20 "Standards For Protection Against Radiation";
- Regulatory Guide 8.15, "Acceptable Programs for Respiratory Protection";
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- Regulatory Guide 8.26 "Applications of Stoas,ay for Fission and Activation Products";
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- ANSI N13.1, 1969, "Sampling Airborne Radioactive Materials in Nuclear racilities"; and
- NURiO-0041, ".up ual of Respiratory Protection Against Airborne Radioactive Materials".
LiceAsee performance relative to the above criteria was based on:
- observation of work activities; review of air sampling and whole body counting records;
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- review of station procedures; and
~ discussions with licensee personnel Within the scope of this review, no violations were idontified.
7.1 Air Sampling The license's program for air sampling is generally good.
However, the inspector identified an area for improvement.
Discussions with the licensee indicated that only one air sample was taken during hydrolazing multiple drywell drains.
Licensne management stated that more air sampling will be have performed during future hydrolazing.
7.2 Respiratory Protection
Inspector review of respirator issue records indicated that all individuals issued respiratory protection equipment were qualified l
for the devices provided them.
Respirators were obser.ed to 'e l
stored in accordance with manufacturer's recomendations, t
l 8,0 Exit Interview The inspector met with the personrel denoted in section 1.1 at the conclusion of t'te inspection on September 30, 1933.
The scope and findings of the inspe: tion were discussed at that time, l
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