IR 05000278/1981007
| ML20041D395 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/03/1982 |
| From: | Knapp P, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20041D381 | List: |
| References | |
| 50-278-81-07, 50-278-81-7, NUDOCS 8203050288 | |
| Download: ML20041D395 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-278/81-07 Docket No.
50-278 License No.
OPR-56 Priority Category C
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Licensee: _ Philadelphia Electric Company (PECO)
2301 Market Street Philadelphia Pennsylvania 19101 Facility Name:
Peach Bottom Atomic Power Station (PBAPS), Unit 3 Inspection At:
Delta, Pennsylvania
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Inspection Conducted:
February 23-25 and March 16-18, 1981 Inspectors:
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2[3/M u
K. E. Plumlee, Radiation Specialist dats ~
date em
\\s date Approved by:
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msO 1!3 [F2
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P. J. Knapp, Chief, Fac'111ty Ridiological
/date-Protection Section,' Technical Inspection Branch Inspection Summary:
Inspection on February 23-25 and March 16-18,1981 (Report No. 50-278/81-07)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of radiation protection during refueling including:
procedures, advanced planning and preparation, training, exposure control, posting, radioactive and contaminated material control, surveys, independent measurements, and outstanding items. This inspection involved 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> on site by one NRC regional based inspector.
Results: Of the nine areas inspected, no items of noncompliance were identified in eight areas. One item of noncompliance (failure to wear personnel dosimetry-devices - Paragraph 3) was identified in one area:
Region I Form 12 (Rev. April 1977)
8203050288 820216 PDR ADOCK 05000278-G PDR
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DETAILS 1.
Persons Contacted a.
PECO Personnel
- N. Gazda, Radiation Protection Manager S. Grosh, Senior Health Physics Technician
- W. Ullrich, Superintendent, PBAPS J. Valinski, Health PhyW cs Supervisor
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H. Watson, Engineer, Chemistry l
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Rad-Services Personnel, R. Knight, Project Supervi.'or
- Denotes presence at exit interview on March 18, 1981.
- Denotes presence at a management interview on' February 25, 1981, and at the exit interview on March 18, 1981.
2.
Licensee Action on Previously Identified Items (Closed) Unresolved Item (77-01-07 and 77-06-02): Review of licensee evaluation of head exposures received during torus modifications. The ratio of head to chest dosimeter exposures was measured during the 1981 tcrus modification work.
The maximum ratio (head to chest) observed was 1.2 to 1.
Previous exposure results (chest only) were reviewed and
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appropriate adjustments for head exposures were made in dosimetry records
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and in notifications to the workers and to the NRC.
No head exposures exceeding three rem during any calendar quarter were identified by the adjustments. The inspector toured the facility and observed the dosimetry
practices and working conditions inside and outside the torus during this
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inspection.
(Closed) Item of Noncompliance (77-40-04):
Failure to frisk on exiting controlled areas and failure to provide friskers at some of the exits.
The inspector toured the facility and verified the availability of friskers and their use, as well as the licensee's implementation of corrective actions documented in the licensee's letter dated January 27, 1978, and in the Region I letter to the licensee dated May 10, 1978.
(Closed) Inspector Followup Item (78-RN-01):
Verification of the licensee's completion of the required dosimetry records and reports.
The inspector reviewed selected personnel files and verified that the dosimetry records and the reports required by 10 CFR 19.13, 10 CFR 20.408, and 10 CFR 20.409 were complete (paragraph 7.b).
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(Closed) Inspector Followup Item (79-RN-04):
Review of the status of the site radiation protection manager qualifications.
Combined Inspection No. 277/80-18 and 278/80-10 reviewed radiation protection staff qualifi-
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cations. The radiation protection manager assignment was not changed since that time.
(Closed) Inspector Followup Item (79-02-06):
Verification of the correction of a radioactive material transfer record.
The inspector reviewed the corrected records.
(Closed) Unresolved Item (79-06-11):
Revicw of audits and corrective actions. The inspector reviewed two reports by consultants who audited
the radiation protection program during the overlapping periods November 1976 to February 1977; and December 20, 1976, to January 13, 1977. Also, two subsequent audit reports, NUS 3071 and NUS 3236 were reviewed.
Except for long term items that were reviewed during Combined Inspection No. 277/80-18 and 278/80-10, the corrective actions have been completed.
The inspector verified that a health physics investigation report system and a QA/QC noncompliance report system were being maintained and that the identified radiation protection items had been documented and corrected (paragraph 7.c).
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(Closed) Unresolved Item (79-06-02):
Review of the training program.
The inspector reviewed the training provided during 1980 and January and February,1981 (paragraphs 6.c and d).
(Closed) Inspector Followup Item (79-06-04):
Implementation of a quality control procedure for the TLD spike tests.
The inspector reviewed the recent TLD spike tests (paragraph 7.d).
(Closed) Inspector Followup Item (79-18-01): Verification of the incor-poration of a respirator mask refit interval in the procedure.
Review showed that Section 1.2 of procedure HP0/CO-9a, Revision 5 May 12,1980,
" Respiratory Protection Training and Fitting," requires an annual refit.
(Closeo) Item of Noncompliance (79-06-03):
Failure to evaluate and resolve dosimetry discrepancies. The inspector verified that documented corrective actions were implemented (paragraph 7.b).
(Closed) Items of Noncompliance (79-25-03, 79-32-01 and 79-33-08):
Failures to adhere to instructions on RWPs specifying protective clothing requirements, etc.
The inspector verified that corrective actions docu-mented in letters dated December 4, 1979, December 20, 1979, and May 12, 1980, were implemented.
Observation during tours of the facility did not identify any examples of failure to wear the prescribed protective clothing (paragraph 4).
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3.
Wearing of Required Personnel Dosimetry Devices Section 20.202 of 10 CFR 20, " Personnel Monitoring," states:
"(a) Each licensee shall supply appropriate personnel monitoring equip-ment to, and shall require the use of such equipment by:
(1) Each individual who enters a restricted area under such circum-stances that he receives, or is likely to receive, a dose in any calendar quarter in excess of 25 percent of the applicable value specified in paragraph (a) of S20.101...
(b) As used in this part,
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(1)
' Personnel monitoring equipment' means devices designed to be worn or carried by an individual for the purpose of measuring
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the dose received (e.g., film badges, pocket chambers, pocket J
dosimeters, film rings, etc.);..."
Licensee Technical Specification Section 6.11, " Radiation Protection Program," states: " Procedures for personnel radiation protection shall
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be prepared consistent with the requirements of 10 CFR Part 20 and shall
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be approved, maintained and adhered to for all operations involving i
personnel radiation exposure.
Licensee procedure HP0/CO-10a, Revision 3, February 4,1981, " Conduct in Controlled Areas - Minimize Exposure," which is maintained as part of the licensee's actions to comply with the above requirements, states.in section 1, "Always wear provided personnel dosimetry."
i During a tour of the facility, accompanied by licensee health physics supervisors, at about 1:06 p.m. on February 23, 1981, the inspector identified an individual in a controlled area of the Primary Aux'liary Building (PAB), 165 foot elevation who was not wearing personnel dosimetry equipment. The individual was working in an electrical cabinet in a room near the turbine deck where the exposure rate varied up to 2.0 mrem /hr.
The individual stated that he had worked for several months in various
. parts of the facility, and that he had always removed his dosimetry equipment to reduce the shock hazard when he worked in electrical cabinets.
He showed the inspector where he had placed his dosimetry equipment when he removed it in preparation for the above work.
The dosimetry equipment
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u was on the floor a distance of about five feet from the individual.
The individual stated that he always placed the dosimetry equipment where the exposure rate, indicated by posted information, was the same as where he was going to work.
He stated that he had not verified this with a survey meter and had not discussed this with his foreman or with any health physics representative. The individual stated that he had never-
before been corrected regarding this practice.
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The inspector stated that the failure to fully adhere to the above to the above procedure constituted noncompliance with TS 6.11.
(278/81-07-01)
The licensee representative stated that a health physics investigation report will be prepared which will identify any corrections needed in this individual's dosimetry records.
The licensee representative instructed this individual how to wear the personnel dosimetry equipment to avoid shock hazard.
4.
Radiation Protection Procedures a.
Inspection Criteria Part of the inspection effort was to review the availability and adequacy of radiation protection procedures required by the Tech-
I nical Specifications.
Technical Specification 6.8 requires the licensee to meet or exceed the requirements and recommendations of ANSI N18.7-1972, Sections 5.1 and 5.3, and Appendix A of Regulatory Guide 1.33, November, 1972, with respect to procedures.
Technical Specification 6.11 is quoted in paragraph 3 of this report.
b.
Determination of Adherence to Radiation Protection Procedures The inspector reviewed the radiation protection procedures listed below and verified adherence to the procedures by observation of the conduct of regular plant employees as well as numerous temporary workers on site during the outage. The inspector interviewed an estimated 30 individuals. The inspector reviewed appropriate check sheets and records as necessary to verify adherence to procedures.
Procedure Revision Number Number Date Abbreviated Title HP0/C0-1
11/06/78 Area Survey (Radiation)
HP0/CO-2
05/09/77 Area Survey (Contamination)
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05/09/77 Area Survey (Air Sample)
HP0/CO-4
02/04/81 Radiation Work Permits HP0/CO-5
04/30/80 Selection and Use of Anti-C Clothing and Equipment HP0/CO-6
03/30/78 Personnel Contamination Survey
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Procedure Revision Number Number Date Abbreviated Title HP0/CO-9
05/12/80 Respiratory Protection Program HP0/CO-11
11/30/78 Establishing and Posting Radiologically Controlled Areas (RCAs)
HP0/C0-13, -13a, -13b (see paragraph 7.b)
Personnel Dosimetry HP0/CO-26
10/20/80 Personnel Bioassay Further details of reviews of procedures are given in paragraphs 3, 5.a 6.b, 6.c, 7.b, and 7.d.
One example of failure to fully adhere to procedure HP0/CO-10.a is described in paragraph 3.
J One readily correctable record error was identified at about 9:40 l
a.m. on March 17, 1981, when the inspector noticed there was one
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more individual present on a job than had signed on the applicable RWP, No. 3-03-0116, " General maintenance, inspection and cable pull."
As found, these workers were placing shielding on the scram discharge line. The radiation exposure rate was 300 mrem /hr on the exposed part of the line. Constant health physics monitoring was in effect and direct supervision was being maintained on the job.
No problems other than the one omission to sign in were identified.
When shown the sign-in sheets, the worker said that'he had signed inadvertently at 8:40 a.m. on RWP No. 3-07-0130, " Reactor 3 drywell, all elevations," but he said he actually intended to sign in on the RWP on which he was found working outside the drywell.
The licensee representative accompanying the tour removed the individual from the job temporarily in order to obtain an explanation, to admonish the individual, and to require him to correct the record before returning to the job.
Observation of the control point operation where this worker signed the RWP did not indicate there was any contributing cause other than short periods of overcrowding. The control point mission was to verify that workers were clothed in accordance with the RWP.
Review of 20 RWP records and the conduct of work under these RWPs did not.
identify any other problems.
The inspector observed that the procedures generally did not specify supervisory review and approval of completed jobs.
No items of noncompliance were identified.
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5.
Advanced Planning and Preparation for the Outage a.
Increased Health Physics Staff Technical Specification Section 6.3.1 requires that each member of the facility staff meet the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the Engineer-Health Physics who must meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
l Licensee procedure no. HP0/CO-80, Rev. 3, 6/5/79, " Contract Health l
Physics Technician Entry Procedure," specifies the responsibilities
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borne by, and the minimum qualifications required of, a Level II l
" Senior Technician" and a Level III." Crew Leader." The procedure states that no individual with less than 24-months related experience in power reactors is authorized to issue RWPs. Onsite training of these individuals is described in paragraph 6.c.
Level I employees perform less responsible jobs and are closely supervised.
The have minimal qualification and training requirements.
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Review of the procedure did not identify any inconsistency with ANSI N18.1-1971.
The licensee representative stated that one Level III _ crew leader, about 48 Level II, and a few Level I contract health physics personnel were hired to support the outage activities.
This included 15 l
senior health physics technicians who were hired before the outage l
to prepare for major jobs.
These preparations included, among other l
things, preparing procedures, setting up equipment, and placing l
shielding.
I The inspector reviewed 14 resumes of contract senior health physics technicians and one resume of a contract crew leader. The inspector also observed the job performance of 25 technicians.
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b.
Mockups and Special Training i
The licensee representative stated that all procedures, equipment, and personnel involved in high exposure rate jobs were pre-tested outside the high radiation areas. As examples he referred to:
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Removal and replacement of feedwater spargers; Decontamination by hydrolazing; Decladding and pipe cutting; Remote operated in-service inspection equipment; and l
Remote viewers.
c.
Supplies and Equipment The inspector toured the facility to observe the availabiity and use of survey instruments, protective clothing, respirators, shielding, decontamination materials, and special equipment.
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No survey instruments or friskers were identified as inoperative or overdue for calibration. There were no lengthly delays in return of instruments to service when due for calibration or repair.
No items of noncompliance were identified.
6.
Training a.
Escorted Individuals Untrained individuals, such as short term visitors and arrivals, who had not yet attended training were instructed to stay with the escort and follow his instructions.
They were specifically instructed to comply with emergency signals and public address system announce-ments and warnings; and to observe posted information and signs, barriers, and local alarms.
b.
General Employee Indoctrination Review of general employee indoctrination, provided to comply with 10 CFR 19.12, indicated that experienced instructors were provided.
A program outline was followed, and procedure no. A-50, Rev. 6, 5/l5/79, " Training Procedure," was available.
This procedure for-malized the examinations, scores and records.
The inspector observed the conduct of this training and briefly contacted five of the trainees.
c.
Contract Health Physics Technician Training Review of procedure no. HP0/CO-80, Rev. 1, 6/5/79, " Contract Health Physics Technician Entry Program," indicated there was no complete outline or list of the required training.
The licensee representative later described a draft revision of this procedure which listed 37 procedures and 7 types of survey instruments on which each technician may be qualified.
The draft includes a record sheet to show what items the individual had completed.
Review of training records showed that a similar record sheet was in use in 1979 but its use was later discontinued.
The licensee representatives stated that the draft record sheet is being implemented. Based on the licensee's oral description of training it appeared that adequate training was provided during 1980 and 1981; however, the records of training of contract health physics technicians for 1980 and January and February,1981, were not suffi-ciently detailed to verify the scope of their on-site training.
The inspector contacted five individuals who had received the above training prior to February 23, 1981, and no inadequate training was evident during these contact..
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d.
Licensee Employet Health Physics Technician Training i
The inspector verified that the training program that was reviewed during Combined Inspection No. 277/80-18 and 278/80-10, was still in effect.
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No items of noncompliance were identified.
7.
Exposure Control a.
ALARA Considerations
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The licensee representative stated that an ALARA Coordinator had been designated in an effort to further reduce personnel exposures.
This individual stated that the exposure histories of repetitive jobs, involving as much as a man-rem each time, were being assembled.
Planning of each job in this category included reviews of shielding, procedures, tools, and use of remote operators where feasible.
Trend analysis was employed to identify exposure problems as early as feasible, not only on these jobs, but on jobs throughout the
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facility.
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Examples of the ALARA planning included increased use of shielding and improved procedures for incore detector and control rod drive rebuilding (more than forty units have been rebuilt), and pump and
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valve replacemer t and repair.
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Dosimetry Practices The inspector carried out the following activities during a review of dosimetry practices:
(1) reviewed licensee compliance with the requirements of 10 CFR 20.209 (see paragraphs 2 and 3), 10 CFR 20.401, " Records of surveys, radiation monitoring, and disposal," 10 CFR 20.408, " Reports of personnel monitoring on termination...," 10 CFR 20.409, " Notifications and reports to individuals," and 10 CFR 19.13(a), " Notifications and reports to individuals";
(2) toured the facility, including the drywell, refuel floor, reactor building, radwaste facilities'and turbine building in order to observe dosimetry practices on several modification, maintenance and refueling related-jobs; (3) reviewed 20 RWPs to evaluate the instructions for special dosimetry;
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(4) reviewed the computer printout of dosimetry records. The admin-j 1strative limits on exposure were printed out for each individual and the printout flagged the cases requiring attention. The computer was also progammed to print out special lists by organizational group, exposure levels, and dosimetry discrepancy categories.
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latter appeared to complete the commitments described in a licensee letter dated May 18, 1979, and an NRC letter dated August 30,1979.)
(5) reviewed record files of four individuals who had exceeded 1 rems during the calendar quarter and verified that each Form NRC-4 was in order; (6) reviewed an additional 22 record files of individuals who were
either administrativo1y authorized, or likely to be authorized, to exceed 1 rems during the calendar quarter.
(Each Form NRC-4 was either complete or on hold pending receipt of further information.)
(7) verified by examination of 10 personnel files that dosimetry reports were routinely provided to terminated workers and to the NRC;
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(8) contacted 5 departing individuals to verify that the written exposure information required by 10 CFR 19.13(e) was provided promptly on termination.
c.
Review of Licensee Investigation Reports and Performance Deficiency Reports (PDRs)
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i (1) Contaminated Puncture Wound in a Foot
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While working in a contaminated area during August,1980, an i
individual wearing protective clothing stepped on a nail.
After routine wound decontamination the wound was allowed to heal with 40 to 50 nanocuries (nC1) of Co-60 remaining in the area of the wound. The 5.27 year half-life of Co-60.:sults in about a 1.1% per month decay rate or, during 1980 and 1981, a reduction of about 0.5 nCi per month. No other change in the amount of Co-60 remaining in the foot was identified when counted 86 days after the injury. Whole body counts indicated no. transfer of Co-60 to other parts of the body.
The licensee's consultant, in a letter dated October 7, 1980, recommended an action level for " aggressive decontamination" of about 100 nCi and an action level for investigation of the advantages of debridement or-other intervention, in cases of fixed contamination, at about 1000 nCf.
The actual 40 to 50 nCi quantity of Co-60 did not appear to require further wound treatment based on the above.
The inspector had no further questions.
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(2) Other Items The licensee has documented and corrected several-items dis-covered during.the outage.
Review of these documents verified that the licensee maintained a means of documenting and correcting radiation protection problems.
d.
Review of the Implementation of QA/QC Procedures for TLD Spike Tests and for Whole Body Counting i
The inspector verified that the quality assurance commitments doc-umented in letters dated May 18, 1979, and August 30, 1979, were implemented; and that the existing procedures, HP0/CO-32, Revision 3, March 26,1979, " Quality Control of Personnel Dosimetry"; HP0/CO-32a, Revision 0, May 2,1979, " Exposing TLDs for Check Purposes"; and HP0/CO-26A, " Operation of the Whole Body Counter," had been implemented.
Combined Inspection No. 50-277/80-18 and 50-278/80-10 documented the review of the quality assurance program for the TLD program and for whole body counting.
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No items of noncompliance were identified.
8.
Review of Respiratory Protection Programs a.
Adherence to Internal Exposure Limits
The inspector reviewed the implementation of the following pro-cedures to verify compliance with 10 CFR 20.103 and Regulatory Guide-8.15, " Acceptable Programs for Respiratory Protection."
Procedure Revision i
Number Number Date Abbreviated Title
HP0/CO-9
May 12, 1980 Respiratory Protection Program HP0/C0-9a
May 12, 1980-Respiratory Protection Training and Fitting HP0/C0-9b
July 8, 1980 Respiratory Protection Equipment Selection and Use
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I HP0/CO-9c
May 12, 1980 Respiratory Protection
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Equipment Maintenance and Quality Assurance-s HP0/CO-9e
Dec 19, 1980 Quantitative Testing of Masks, Personnel and Filters
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During the review of personnel folders (see paragraph 7.b) the records of physician's findings of fitness to wear respirators were veriffed.
Observation of working conditions during the inspection, and review of records of work permits, air samples, contamination surveys, nasal swipes, skin contamination, and whole body counts did not identify any exposures to airborne radioactive materials in excess of 10 CFR 20.103 limits.
b.
Air Sampline and Bioassay Records The inspector noted that procedure no. HP0/CO-11, Revision 7, November 30, 1978, " Establishing and Posting Radiologically Controlled Areas,"
requires areas to be posted as " Airborne Radioactivity Areas" if unidentified airborne activities exceed 3 E-10 pei/ml, and sets appropriate action levels for identified airborne radioactivity.
Observation of posted areas, and air sampling during the inspection, did not identify any items of noncompliance with the above procedure.
c.
Temporary Engineering Controls The inspector verified that exposures to airborne radioactive materials were controlled by decontamination of surfaces, use of plastic covers and tents to prevent spreading contamination, and use of controlled ventilation systems to prevent exposures to unacceptable concentrations of airborne radioactive materials.
No omissions were identified of the use of such controls on contaminated jobs.
d.
Licensee Evaluations of Controls The inspector noted that the records of the licensee evaluations of controls appeared to verify the selection of acceptable equipment, the use of authorized protection factors, the application of preventive measures, and the evaluation of internal exposures.
e.
Respiratory Protection Training and Respirator Fitting and Testing
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The inspector verified during the review cf personnel files (paragraph 7.c) that the medical check, fitting, and training of-personnel using respirators was documented and the procedures, documented above, appeared to be fully implemented.
Observation of training and fitting did not identify any problems in the qualification of users of respirators.
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Respirator Cleaning and Maintenance In order to verify adherence to the above procedures, the inspector
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observed the collection process for used respirators, and respirator cleaning and maintenance.
The inspector observed the users as they
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checked the respirators before they were donned and as they tested the respirator fit each time the respirator was donned.
l No items of noncompliance were identified.
9.
Posting and Control of Radiation Areas, Airborne Radioactivity Areas, and Contaminated Areas
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In order to verify compliance with the requirements of 10 CFR 20.203,
" Caution signs, labels, signals and controls," the inspector toured the facility on several days of the inspection and verified the adequacy of posted radiological and survey information, barriers and enclosures.
The inspector also surveyed the outdoor radioactive waste storage area fence and barrier ropes, and trailers being loaded with material to be transported The inspector toured the fenceline around the facility and verified that the acces,1ble areas outside the fence did not exceed 0.1 mr/hr.
No items of n, compliance were identified.
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Radioactive and Contaminated Material Control The inspector observed the licensee's management of used protective clothing, contaminated trash, and radioactive waste. The inspector verified container labels, transport information and shipping documents.
The inspector noted that the applicable procedures appeared to be fully implemented and the exposure of personnel to radiation emanating from
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radioactive waste was reasonably limited by barriers, isolation and shielding.
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No items of noncompliance were identified.
11.
Exit Interview
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The inspector met with licensee representatives (denoted in paragraph 1)
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summarized the purpose, scope and findings of the inspection.
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