IR 05000277/1990011

Insp Repts 50-277/90-11 & 50-278/90-11 on 900430-0504.No Violations Noted.Major Areas Inspected:Radiological Controls Program on Site

ML20043B742
Person / Time
Site:	Peach Bottom
Issue date:	05/10/1990
From:	Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20043B738	List: IR 05000277/1990011 ML20043B737
References
50-277-90-11, 50-278-90-11, NUDOCS 9005310224
Download: ML20043B742 (10)

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REGION I

Report No.

50-277/90-11 & 50-278/90-11 Docket No.-

50-277 & 50-278 License No.

DPR-44 & DPR-56 Licensee Philadelohia Electric Connany P.

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Box 7520 Philadelohia. Pennsylvania 19101 Facility Name Peach Bottom Atomic Power Station l

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L Inspection Att Delta. Pennsylvania I

L Inspector:

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Sherbini, Senior Radiation Specialist date Facilities Radiation Protection Section

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r Approved by:

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lOf90 W. Pas'ciak, Chief, Facilities Radiation dats Protection Section Insoection Summary: Inspection on April 30 - May 4, 1990 (Combined Inspection Report 50-277/90-11 & 50-278/90-11)

Areas Insoected: A routine, unannounced inspection of the radiological controls program on site.

Ensults: Within the scope of this inspection, no violations were identified.

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9005310224 900516

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DETAILS

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s 1.0 Personnel Contacted

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j 1.1 Licensee Personnel i

D. Amuhity, Senior Instructor for Program Administration

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DePasquale, Nuclear Quality Assurance W. Downey, Supervisor, Radiological Engineering

W. Eckman, Nuclear Quality Assurance

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• D. Foss, Licensing Engineer

• M. Kaminski, Corporate Health Physicist

• G. McCarty, Health Physics _ Supervisor J. Oswalt, Senior Instructor D. Pendelton, Instructor s

D. Preston, Health Physics Supervisor

• M. Ryan, Supervisor, Rad Waste

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P. Sawyer, Senior Health Physicist A. Sherwood, Supervisor Training Administration

• R. Smith, Licensing Engineer 1.2 NRC Personnel

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• J. Lyash, Senior Resident Inspector L. Myers, Resident Inspector

• Denotes attendance at the exit meeting.

f 2.0 Dosimetry Records The dosimetry records were inspected for completeness, including the currency of NRC FORM-4 data, exposure notifications to employees, and assignment of adminictrative dose limits. The inspection of records consisted of random

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l selection of personnel folders from the personnel dosimetry files. The records were found to be generally well organized and complete, with no regulatory or procedural violations identified. However, the following weaknesses were found:

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o It was not possible by examination of the personnel folders to determine whether the information they contained was up to date and in compliance with procedural and other

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requirements. Some of the folders included' Form-4's dating back to the 1970's and early 1980's but there was no f

indication as to the current employment status of the individual. The same problem applied to exposure i

I notifications upon termination. In was necessary to view

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computer outputs (screens) pertaining to the individual in

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question to determine his employment status. It was also

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necessary to view a second computer screen to determine the

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employment history of the individual at the licensee's facilities and whether the Form-4 in the personnel folder was updated.as of the date of that person's latest employment.

The licensee stated that they are currently revising the computer program that handles dosimetry data and that the new program will show an improved data grouping and display, o There appeared to be some misunderstanding among site personnel regarding the requirement for completing a Form-4 for new employees. Dosimetry personnel stated that past I

policy was not to require completion of a Form-4 and that those individuals who did not complete the form were limited to a low administrative dose limit. They also stated that the new policy, effective since the beginning of this year,

requires all personnel to complete the form. Other personnel in the health physics organization stated that the form is still optional, or that only company personnel are required to complete the form. The procedures addressing this issue j

imply that completing the form is optional. Administrative

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Procedure A-106, rev 3. states that " Individuals may be required to complete an NRC FORM-4 or equivalent". Health Physics Procedure H-610 states that dosimetry personnel will

... assist the individual in filling out a Form NRC-4 if

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necessary".

It was not possible during this inspection to determine the official policy, but the licensee stated that the procedures i

will be revised shortly to reflect the official policy regarding Form-4's.

A review of the individual exposure records for the current j

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year showed that the highest individual current year-to-date j

exposure at the time of this inspection was less than 650 J

millirem..The year-to-date cumulative site exposure was i

134.1 man-rem, and the current quarter exposure to date was

26.2 man-rem.

3.0 Training i

The General Employee Training (GET) program was reviewed

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during this inspection, as well as the status of changes to improve the training facilities on site. Discussions with i

the licensee indicated that the GET program was recently i

completely changed to incorporate the latest guidance provided by the Institute for Nuclear Power Operations (INPO), and the new program was implemented in November of

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1989. The changes included reorganizing the order of presentation of the information as well as an increase in l

the depth in which some of the topics are discussed. The J

lesson plans were also rewritten. The former Protected Area Access course, roughly three hours long, has been replaced by GET category I, roughly one and one half day long.

Fitness for duty was added to the course, and the industrial safety section was substantially expanded. Rad worker

training, formerly called Basic GET, is now GET Cat II. Cat II is an extension of Cat I and is taught in about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, followed by about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of practical factors. A review of the new lesson plans showed that the material is quite

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comprehensive and addresses all the areas important to a radiation worker in sufficient detail. An exceptional feature of the lesson plans is the inclusion of industry

events to illustrate the material in each of the subject areas. These events are included at the end of each subject

area, and consist of a review of the incident and a discussion of the lessons to be learned from it. The

' i examination questions reflected the organization of the lesson plan, but there were a relatively large number of questions that addressed general knowledge such as the effects of radiation or types of radiations and relatively fewer questions that directly addressed the various requirements for entry into and work in various types of radiologically controlled areas. The licensee stated that these topics are covered mostly during the practical factors l

testing portion of the course. The failure rate in recent examinations was about 20% for Cat I and about 19% for Cat

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5 II. Failure rates for roqualifying workers was lower.

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A previously identified vetakness in the licensee's training program was the poor quality of the training facilities on.

site.1Nt correct this situation, a new training facility is currently being constructed adjacent to the Unit I administration building. This new facility will house all the training classrooms as well'as the access processing

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facilities and personnel. A new training-administration-area h5A 21.so.been-constructed on the third floor of the Unit I atnin!.stration_ building. This area will-house the offices of the training, supervisors, the instructor's offices, a library, and a visual aids production facility. The target date for occupying the new facilities is mid-September of this year.

The licensee also stated that they are encouraging their

. supervisory staff to attend evening review classes-to prepare them to take the certification examinations-offered by the. National 1 Registry of Radiation Protection Technicians (NRRPT).' Registration fees are reimbursed by the licensee.

'5.0 Audits ~and Self Assessment Procrams According to.the Radiation Protection Manual, the Radiation Protection Section ".. shall establish a program for providing technical assessments.of all radiation protection activities.'These include verification of compliance, proactive. involvement in identification of root causes,.

recommendations for program improvement based-on good practices and industry experience,

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The manual also

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states that "These assessments shall be performed at least r

quarterly..".

Quarterly assessments of the program are being performed by the corporate staff in the Nuclear Support Division. The current level of effort in there assessments is 2 man-weeks per quarter, up from one man-beek in the past. Each quarterly assessment is devoted to one program area such that the whole program is audited in a two-year cycle. The licensee stated that the breadth and depth of these audits have been increased to include program assessments rather than concentrating on only procedural and regulatory compliance.

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The radiological' controls program:is also audited by Quality Assurance on a-two-year cycle. Areas audited are divided D

- into four groups: Dosimetry, Bioassay programs,-health physics operations and ALARA, and the respirator program._In-addition, the corporate quality assurance group audits the dosimetry processing operation, which is located off site. A review of some'recent audit reports showed that theJaudits were thorough and done in-depth,.and that significant-program weaknesses were_ identified. Some of the findings in the audit reports:suggest that some areas of the health physics program on site are not being carefully monitored for good practice and procedural compliance. Examples.of these findings are:

.o The manner in which laundry was processed and routed left open the possibility that contaminated laundry could be mistakenly issued as clean laundry, o There was no established routine for checking incoming laundered articles for contamination levels, o The laundry contract was_poorly_ written and poorly administered, with multiple violations of the contract by the-vendor, o Multiple-instances of noncompliance to procedures and work permits, o Some respirator test equipment was not being routinely calibrated.

o Housekeeping in the respirator cleaning and testing facility.was unacceptable.

Discussions with the licensee and inspection of.some of'the facilities involved in the findings showed that action is being taken to correct these deficiencies. The laundry contract has been terminated and a new laundry vendor was hired. Laundry routing has been changed to minimize the possibility of mixing clean and contaminated articles. A procedure is being-developed to address the survey and acceptance of incoming laundry. Operations and housekeeping-in the respirator facility'have improved.

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In addition to the audit programs, a program to identify and correct-radiological incidents is in place. The program is described in Procedure A-110, " Radiological Occurrence Reports". This procedure became effective'in February 1990.

Radiological' Occurrence Reports (ROR) are generated whenever any situation occurs "... with actual or potential consequences-which are not in keeping with Health Physics requirements and good practices". Any person may initiate an ROR, but Health Physics supervision performs _the initial review and takes any necessary immediate corrective actions.

Health Physics'also classifies the'ROR into one of four severity levels, Level I being the most severe. The work.

k group supervisor determines cause and corrective actions for occurrences involving work under his supervision. Corporate Radiation Protection is responsible for root cause analysis

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for Levels I and II RORs; Level III and IV RORs are evaluated by site personnel. RORs are also reviewed by the

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superintendent of the section involved, the Senior Health

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Physicist, and the Services Superintendent. The Plant Manager reviews Level I and some Level II RORs.

A review of the ROR reports generated during 1989 and 1990

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showed that.the' system is apparently effective in identifying problems but is' generally ineffective in identifying and' correcting root causes. There were about 120

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RORs generated in 1989 and about 50'during the first part of N

1990 up to~the-date of this inspection. A large fraction of

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.these reports-address problems of noncompliance to

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procedures, work permits, posted requirements and good practices.' Examples include workers entering contamination areas without the required protective clothing; workers-entering high radiation areas without notifying health physics, as required by procedure; an emergency respirator

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not checked at the required frequency; a foreman instructing a worker to enter an area despite the fact that the entry violated work permit requirements; an individual alarms a

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wholeibody frisker repeatedly then proceeds to clean office areas without. notifying health physics; workers cutting and

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grinding on contaminated components without notifying health physics; and other instances similar in nature. The RORs also showed instances of spills of radioactive liquids on clean floors as a result of overflowing tanks, breaches of contaminated systems, and opening of valves.

The review of the RORs also showed that there was no

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significant root cause analysis following most of these incidents: most of the RORs were closed on the basis of the actions taken immediately following the incident. These actions generally consisted in immediate corrective measures

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such as counseling the involved individuals in the case of

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procedural violations, or mopping up the water and

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decontaminating the floor in the case of spills.

In addition to the above, there is also a weakness in the ROR classification system. The procedure provides little or no guidance on the method to be used to determine the classification level of an ROR. Some guidance is given in the case of Levels I and III. Level I includes any occurrence that is reportable to the NRC. Level III includes any occurrence that involves procedural violation or poor practice. Level IV is "any occurrence of minor radiological consequences..", and Level II is any occurrence that does not fit into any of the other levels. This system is evide'atly not satisfactory since procedurai 'riolations are not rd1 equally severe and may overlap into the Level II and Levsl IV areas. This ambiguity has led to some inconsistencies in ROR classification. For example, some incidents involving violations of entry requirements for high radiation areas were classified as level II and other similar incidents were classified as Level III. One incident that appeared to be of significance was classified as Level IV. This incident involved the discovery that workers had been using a standing work permit to enter the drywell (a locked high radiation area) when in fact the work permit did not allow entries into such areas.

The licensee 7tated that they are aware of the deficiencies

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noted above and have initiated corrective actions. The revised R0h. procedure was one such action that calls for corporate involvement in root cause analysis. The routing of RORs has also been expanded and copies of all RORs are now being sent to the Vice President Peach Bottom as well as to the corporate health physics group and the NRC resident's office. The Operations Section has recently taken action to reduce the number of spills; these actions included equipment modifications and changes in procedures as well as requiring closer review of RORs and root causes. The

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corporate health physics group is now required to review RORs and write quarterly reports on their analysis and trending of the incidents.

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-In-an effort to improve radiation worker practices, the station Manager recently asked each section superintendent-to provide in writing an action plan describing the specific actions-that-the section plans to take.to improve radiation worker practices on site. The. result was a Radiological Worker Practice Action Plan. The plan describes the actions each section-plans to take to effect the improvement.'A review of the-plan showed that the proposed actions should

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provide greater visibilty and importance to RORs and root cause analyses,.and may result in improved radiation worker practices.-However, the following weaknesses were also identified:

o Each section is to implement the actions it proposed to improve radiation worker practices.-This'will lead to nonuniform policies between the various sections on site.

For example,'one section proposed to improve job planning but others did not; one section proposed to include radiological _ performance in their supervisor's performanco-appraisals but other sections did not.

o The proposed actions do not include statements that reinforce insistence on compliance to procedural requirements and good practices. There was no document available during this inspection that. explicitly stated such a policy.

o The proposed actions did not clearly assign the responsibility for proper. radiological control of jobs to the job supervisor and his superintendent. Although this may be inferred from some of the written statements, it is not sufficiently strong and explicit to make the point clear.to everyone concerned.

The licensee stated that they will review these concerns and take appropriate action. These-items will be reviewed during future inspections.

6.0 Exit Meetina The inspector met with the licensee representatives indicated in Section 1.1 of this report on May 4, 1990. The inspector reviewed the purpose and scope of the inspection l

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and discussed the inspection findings.

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