IR 05000278/1985036

Insp Rept 50-278/85-36 on 851008-11.No Violation Noted.Major Areas Inspected:Licensee Radiological Control Program During Core Spray Sparger Repairs & Radiological Control for Low Level Radwaste Storage Facility

ML20133P941
Person / Time
Site:	Peach Bottom
Issue date:	10/23/1985
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133P922	List: IR 05000278/1985036 ML20133P919
References
50-278-85-36, NUDOCS 8511010272
Download: ML20133P941 (9)

Text

. _ _ _ _ _ - _ _ - - _ _ _ _ _ _ _ _ _ - - _ . _ - - _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - - _ _ _ _ _ - _ _ _ _ _ _ -___ --

. .

U.S. NUCLEAR REGULATORY COMMISSION

'

REGION I

Report N } Docket N License N DPR-56 Priority -

Category C

' Philadelphia Electric Company

'

, Licensee:

2301 Market Street Philadelphia, pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station, Unit 3 Inspection At: Delta, Pennsylvania

.

Inspection Conducted: 0ctober 8-11, 1985 Inspectors: $. b. Ne 10f13 f%~

H. J.'Bicehouse, Radiation Specialist date Approved by: . (~o R (Ma T./d W. J. Msciak, Chief, BWR Radiological ' dat4

'

Protection Section Inspection Summary:

Inspection on October 8-11, 1985 (Inspection Report Number 50-278/85-36)

Areas Inspected: Routine unannounced inspection of the licensee's radiological

controls program during core spray sparger repairs on Unit 3 and radiological controls for the licensee's low-level radioactive waste storage facility. The

'

inspection involved 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> onsite by a regionally-based inspector.

Results: Of the areas inspected, an unresolved item was identified relating l to the adequacy of the licensee's safety evaluation of the low-level radio-active waste storage facility (Detail 7). The licensee's radiological controls

program during core spray sparger work was adequate.

,

I r

8511010272 851025 PDR 0 ADOCK 05000273 pm

-- ____- _ _ _ _ _______ _ _ - - _ _ _ _ _

. .

DETAILS Persons Contacted During the course of this routine inspection, the following personnel were contacted or interviewe .1 Licensee Personnel Mr. 8. Adams, Engineer Mr. N. Alexakos, Maintenance Engineer Mr. A Beward,' Physicist

• Mr. R. Fleischmann, Manager, Peach Bottom Atomic Power Station

• Mr. N. Gazda, ALARA Health Physicist

• Mr. A. Hilsmeir, Senior Health Physicist (RPM)

• Mr. W. Lorenz, Senior Health Physicist 4

• Mr. J. McElwain, Electric Production Quality Control

• Mr. S.-Nelson, Applied Health Physicist Ms. H. Paust, Physicist Mr. R. Scholz, Engineer

• Mr. J. Wilson, Quality Assurance Site Supervisor Other licensee personnel were contacted or interviewed during the cours ' this inspectio .2 Contractor Personnel Mr. C. Burger, Field Engineer, General Electric Company Mr. G. Costomiris, Engineering Manager for Design, Gilbert Commonwealth In Mr. T. MacKay, Project Engineer, Gilbert Commonwealth In Mr. C. Noonan, Field Engineer, General Electric Company Other contractor personnel were contacted or interviewed during the course of this inspectio .3 NRC Personnel Mr. T. Johnson, Senior Resident Inspecto *Mr. J. Williams, Resident Inspector

• Attended the exit interview on October 11, 198 . Purpose The purpose of this routine inspection was to review the licensee's radiological controls during core spray sparger repairs with respect to the following elements:

. _ - - _ _ _ _ _ _ _ .

.

__~

_

. .

,

-

Planning / Preparations for the repairs;

-

External Exposure Control during the repairs;

-

Internal Exposure Control during the repairs; and the

-

As Low As Reasonably Achievable (ALARA) Progra In addition, the licensee's low-level radioactive waste storage facility was reviewed to determine if:

-

quality assurance plans, instructions and procedures had been established;

-

licensee's commitments and guidance provided in Generic Letter 81-38 were being met; and

-

completed construction of the facility was consistent with NRC requirements, guidance in the generic letter and licensee commitment The licensee's outage radiation protection program was reviewed during Inspection Nos. 50-277/85-28; 50-278/85-2 . Planning / Preparation For Core Spray Sparger Repair In late August 1985, the licensee discovered cracks on the 240 degree azimuth core spray sparger "T" box in Unit No. 3 during routine inservice inspections. An air test of the header on August 28, 1985 confirmed a through-wall crack. The licensee decided to repair the core spray sparger

"T" boxes at the 120 and 240 degree azimuths in-vesse Planning and prep-aration for the repair were reviewed relative to guidance provided in Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reason-ably Achievable," and NUREG-0761, " Radiation Protection Plans for Nuclear Power Reactor Licensees."

The. licensee's performance relative to the guidance was assessed by:

-

discussions with cognizant representatives of the repair contractor and the licensee's health physics staff;

-

review of dose projections, mock-up training, special procedures for controlling the work, engineering controls and mitigating measures employed or considered; and

-

observation of repairs in progress from the Unit No. 3 refueling floor on October 8-9, 198 Within the scope of this review, the inspector noted:

-

personnel doses associated with feedwater sparger modifications on Unit No. 2 (1980) and Unit No. 3 (1981) provided the initial basis for dose projections for the repairs;

-

additional underwater radiation measurements were made;

-

mitigating measures including decontamination of .he vessel walls and pipes, construction of a shielded work staticn .nd provision of auxil-1ary ventilation were planned and evaluated; I

. -

i

.

!

L

!

-

a special mock-up was used to train repair workers and assess times l l and locations for personnel dose estimates;

-

an administrative hold was placed on initiation of repair activities :

.

'

until a complete review by the Station ALARA Committee was conducted; !

and  !

-

special work instructions were provided to health physics personnel to control radiological hazards associated with the work and identi-fied during the licensee's pre-job assessment proces ,

Within the scope of the review, the licensee conducted an adequate and

.

generally effective pre-job planning and preparation phase to assess and

!

control personnel doses associated with the repair i External Exposure Controls During Core Spray Sparger Repair '

The licensee's implementation of external exposure controls during the (

repair was reviewed against criteria provided in:

l t

-

10 CFR 20.101, 20.102, 20.104, 20.105, 20.201, 20.203, 20.204 and i 20.401; I -

Technical Specification 6.11, " Radiation Protection Program";

!

-

Technical Specification 6.13, "High Radiation Area";

-

Health Physics Operating / Chemistry Operating Procedure (HP0/CO)-4, j " Radiation Work Permits," Revision 25(8/16/85);

-

.HP0/CO-100, " Health Physics Guides in the Control of Exposure to i Radioactive Material," Revision 19(9/12/85);

-

HP0/CO-101, " Control Point Operating Procedure," Revision 0 l

(7/20/82);

-

HP0/CO-1, " Radiation Dose Rate Survey Techniques," Revision 6 (8/4/84); and

,

l *

-

HP0/CO-68, " Field Use of Alarming Digital Dosimeters," Revision 5 ,

(8/9/85).

The licensee's performance relative to these criteria was determined by: !

-

interviews and discussions with the Applied Health Physicist and i members of his staff;

! -

review of instructions and records relating to personnel / dosimetry l surveys, radiation work permits for in-cavity and in-vessel work and

! refueling floor and drywell control point operations; and ';

l

-

observation of repair work in progres Within the scope of this review, no violations were noted. External exposure controls for the repair operation appeared to be well organized and adequately controlle . Internal Exposure Controls During Core Spray Sparger Repair

'

The licensee's implementation of internal exposure controls during the repairs was reviewed against criteria provided in:

!

!

'

-- --_- _ -_- _ _ _ _ - _ _ _ _ . .

-

10 CFR 20.103;

-

Technical Specification 6.11, " Radiation Protection Program";

-

HP0/CO-2, " Contamination Survey Techniques and Evaluations,"

Revision 3 (9/30/82);

-

HP0/CO-3, " Airborne Activity Survey Techniques," Revision 7 (10/30/84);

-

HP0/CO-4, " Radiation Work Permits," Revision 25 (8/16/85);

-

HP0/CO-5, " Selection and Use of Anticontamination Clothing,"

Revision 6 (4/30/80);

-

HP0/C0-6, " Personnel Contamination Survey Techniques," Revision 5 (3/6/84);

-

HP0/CO-9, " Respiratory Protection Program," Revision 10 (4/21/83);

and

-

HP0/C0-100, " Health Physics Guides Used in the Control of Exposure to Radioactive Material," Revision 19 (9/12/85).

The licensee's performance relative to these criteria was determined by:

-

review of installed auxiliary ventilation used to limit airborne radioactivity, respiratory protection practices, radiation work permits and supporting surveys for in-vessel, in-cavity and drywell operations and training / fitting records for radiation workers assigned to the repair;

-

discussions with workers and health physics personnel; and

-

observations during tours of the refueling floo Within the scope of this review, no violations were note The licensee appeared to be implementing an adequate program to control contamination and prevent internal exposures to workers assigned to core spray sparger

"T" box repair . Implementation of the ALARA Program During Repair Operations The licensee's implementation of the Station ALARA Program during core spray sparger repairs was examined against criteria contained in:

-

Regulatory Guide 8.8;

-

Administrative Procedure (A)-83, "ALARA Program Administrative Procedure," Revision 3 (1/4/85);

-

HP0/CO-500, "ALARA Travellers," Revision 4, (7/8/85);

-

HP0/C0-501, " Request for ALARA Review," Revision 1 (4/26/84);

-

HP0/CO-502, " Station ALARA Review Committee," Revision 2(7/19/85);

-

HP0/CO-503, "ALARA Pre-Job Review," Revision 2 (5/24/85); and

-

HP0/CO-504, "ALARA Post-Job Review," Revision 2 (8/2/85).

The licensee's performance relative to these criteria was determined by interviewing the ALARA Health Physicist and a member of his staff, review-ing ALARA input to two Maintenance Request Forms and associated radiation work permits related to the repair and observation of work in progress on the refueling floo _

-

. ..

Within the rope of this review, it was determined that the licensee had implemented a gecerally effective ALARA program to control exposures associated with repair activities and provide records for use in possible future work on Unit No. . Low-Level Radioactive Waste Storage Facility (Modification 693)

The licensee designed and constructed a low-level on-site radioactive waste storage facility sized to accommodate approximately 2.5 years of solid radioactive waste (including dry active waste and dewatered resins)

resulting from the operation of Units 2 and 3. The purpose of the modi-fication was to. provide a temporary radioactive waste storage site beyond

' January 1986 when shipments to existing low-level burial sites could be curtailed by the individual states. The modification entailed a modular design with the capacity for expansion to store all the low-level radio-active waste for duration of plant lif The design, construction, testing and operation of the low-level radio-active storage facility was reviewed against criteria and guidance provided in:

-

10 CFR 20, " Standards for Protection Against Radiation";

-

10 CFR 50.59, " Changes, Tests and Experiments";

-

10 CFR 100, " Reactor Site Criteria," (as modified in Generic Letter 81-38);

-

10 CFR 50, Appendix I, " Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low as is Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents";

-

40 CFR 190, " Environmental Dose Standard"; and

-

NRC-NRR Generic Letter 81-38 and its enclosure entitled " Radiological Safety Guidance for Onsite Contingency Storage Capacity."

Selected documents related to Modification 693 were reviewed and discussed with the licensee and the licensee's contractor and the facility was toured to determine the licensee's compliance with the criteria and guid-ance above. The following aspects of the design, testing and operation of the facility were reviewed:

-

projected off-site doses from normal operations and postulated accidents;

-

compatibility of stored waste forms and their containers;

-

potential gas generation from radiolytic/ chemical decomposition of stored resins;

-

physical security and personnel protection at the facility;

-

radiological monitoring of potential release pathways;

-

completion of facilities, equipment and preoperational tests of facility / equipment capabilities;

. . . .

, n

,.m i

t

-

administrative controls for facility operation including inventory controh/ limits and operating procedures; and ,

-

oversight of facility operations and inventories by 'the license The inspector noted that the licensee sfPlant Operations Review Committee (PORC) had reviewed the safety' evaluation for the facility and concluded that the modification did not create an unreviewed safety question as defined in 10 CFR 50.59 and did not involve a change to the licensee's Technical Specifications (PORC Minutes 183-148).

Within the scope of the inspector's review, the,following items were

'

'

noted..:

The enclosure to Generic Letter 81-38~ suggests, in part, that facility design and operation should assure that radiological consequences of design basis events (i.e., fire, tornado, seismic event and flood)

should not exceed a small fraction (10%) of 10 CFR Part 100, i.e., no more than a few rems whole body dose. The licensee's safety evalu-ation report (" Safety Evaluation for the Construction of a Low-Level Radwaste Storage Facility, Mod. 693," Revision 1,11/15/83) failed to

. provide an analysis of the consequences of a fire in a storage cel Each storage cell was designed for the storage of up to 360 poly-ethylene *High Integrity Containers" (HICs). Each HIC could contain up to approximately 43.5 curies (Reactor Water Clean-Up resin)

providing a potential radioactive source term up to 15,660 curie The safety evaluation report postulated and analyzed the consequences of_an " unspecified fire" in the Dry Active Waste (DAW) storage. The entire design inventory f6r DAW of 26 curies was assumed to be the source term (of which 1% was assumed to be airborne radioactivity contributing to the accidental release and projected potential off-site dose). The safety evaluation report concluded that this accidental releass was "less than the Technical Specification limit for normal operations" and the "off-sita consequences" were "well within 10 CFR 100 limitations."

PORC Minutes and other./ licensee records were reviewed to determine if the PORC had identified and 4 resolved the question of a fire in the storage cell. The PORC had not apparently raised the question in its review. The inspector noted that the licensee had not stored HICs (containing re ins) in the facilit During the exit interview on October 11, 1985, the inspector discus-sed the apparent need for an analysis of the consequences of a fire in the storage cell with the licensee's representatives. The item was also discussed with a cognizant ripresentative of the li ensee's Engineering and Research Department during a telephone conversation on October 11, 1985 following the exit interview. The inspector stated teat the; adequacy of the licensee's safety review under 10 CFR 50.59 was unresolved pending evaluation of the potential consequences of a fire in a storage cel /85-36-01

+

. ..

The enclosure to Generic Letter 81-38 suggests that gas generation from organic materials in waste containers could lead to container breach and potentially flammable / explosive conditions. Unless storage containers are equipped with special vent designs which allow depressurization and do not permit the migration of radio-active materials, resins highly loaded with radioactive material (e.g., Reactor Water Clean-up System resins) should not be stored for a period in excess of approximately one yea The inspector noted that the licensee's HICs were not equipped with special vents to allow depressurization and the licensee's safety evaluation report did not address venting the HICs. This concern was discussed with the licensee. The licensee stated that the potential problem of gas generation had been identified by the licensee's Engineering and Research Department. A vent design for the HICs had been submitted to the State of South Carolina for review. Additional analyses of gas generation rates were also being complete At the exit interview on October 11, 1985, the inspector stated that the licensee's analysis and resolution of potential gas generation problems with HICs in storage would be reviewed during a subsequent inspection. 50-278/85-36-02

• Regulatory Guide 1.143 (" Design Guidance for Radioactive Waste Management Systems, Structures and Components Installed in Light-Water-Cooled Nuclear Power Plants," Revision 1, October 1979) in outlining a quality assurance program for radioactive waste manage-ment systems recommends, in part, that measures be established to identify items which have satisfactorily passed required inspections and tests or to identify items of nonconformance with procurement documents or applicable codes and standards and the action taken to correct'such items. The licensee's contractor provided preopera-tional testing for systems in the low-level radioactive waste storage facilit However, the result of those tests and dispositioning of test exceptions had not been reviewed by the POR '

At the exit interview on October 11, 1985, PORC review of preopera-tional test results was discussed with the licensee's representatives and will be reviewed during a subsequent inspection. 50-278/85-36-03

• In the licensee's safety evaluation report, operating procedures for the facility were discusse Review of existing licensee procedures and discussions with cognizant personnel indicated that operating procedures for the low-level radioactive waste storage facility had not been complete At the exit interview on October 11, 1985, the inspector stated.that operating procedures would be reviewed during a subsequent inspectio /85-36-04

-

. _ , _ ,

.. ..

8. -Exit Interview The inspector met with the licensee's representatives, denoted in para-graph 1, on October 11, 1985 to discuss the findings of this inspectio The licensee's representatives acknowledged the inspection finding '

At no time.during the inspection was written material provided to the license No information exempt from disclosure under 10 CFR 2.790 was discussed in this report.