IR 05000278/1986002

Insp Rept 50-278/86-02 on 860127-31.No Violation Noted.Major Areas Inspected:Radiation Safety Program,Including Status of Previously Identified Items,General Employee Training & Health Physics Technician Training

ML20210D926
Person / Time
Site:	Peach Bottom
Issue date:	03/18/1986
From:	Dragoun T, Shanbaky M, Tuccinardi T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210D899	List: IR 05000278/1986002 ML20210D897
References
50-278-86-02-01, 50-278-86-2-1, NUDOCS 8603270094
Download: ML20210D926 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-02 Docket N License N DPR-56 Priority -

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station, Unit 3 Inspection At: Delta, Pennsylvania Inspection Conducted: January 27-31, 1986 Inspectors: ,

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T'. [fragou , x diation Specialist / date m 3? c T. Tuccina d . adiation/ Specialist date Approved by: TV/- J ~3//Yk$

M. Shanbaky, Chief / ' date Facilities Radiation Protection-Section Inspection Summary:

Inspection on January 27-31, 1986 (Inspection Report No. 50-278/86-02)

Areas Inspected: Routine unannounced inspection of the licensee's radiation safety program including: status of previously identified items; general employee training; respirator training; HP technician training; and the maintenance hot shop. The inspection involved 78 inspector hours onsite by two region-based inspector Results: No violations were identifie PDR ADOCK 05000278 G PDR

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DETAILS

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1.0 Persons Contacted During the course of the' routine safety inspectier., the following personnel were contacted or interviewe .1 ' Licensee Personnel W. Ullrich, Superintendent, Nuclear Generation Division

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

• J. Winzenried, Superintendent -. Plant Services, PBAPS

• N. Gazda, Health Physicist - Supervisor

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G. Stenclik, Training Department -

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W. Syska,' Physi'cian Assistant T. Wilson, Quality Assurance Site Supervisor

• S. Wookey, Training Coordinator Other licensee personnel were contacted or interviewed during the course of the inspectio .2 NRC Personnel T. Johnson, Senior Resident Inspector

'H. Williams, Resicent Inspector

• Attended the exit interview on January 31, 1986.

) 2.0 Purpose

1 The purpose of the routine inspection was to review the licensee's i radiation protection program with respect to the following' elements:

! * Status of Previously Identified Items;

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• - General Employee Training; .

• Training and Qualification of Respirator Users;

• Technician Progression Training; and

j * Use of,the Adninistration Building Hot Sho .0 Status of Previously Identified Items

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3.1 (Closed) Follow-up Item (83-22-01)

Personnel making entries into

! radiologically controlled areas during emergencies should be qualified

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to wear SCBAs. A list of qualified personnel is maintained in the

auxiliary OSC and is updated weekly.

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3.2 (Closed) Follow-up Item (83-22-02): A management review is required to ensure an adequate system.is implemented to maintain a current

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list and to notify supervision when SCBA requalification is require A computer generated list entitled " Respiratory Qualifications /Whole Body Count Status Report" is provided weekly to senior plant supervisors. This data indicates when requalification requirement is due.

! 3.3 (Closed) Follow up Item (84-22-02): Licensee to provide safety

evaluation for temporary radwaste facilities under 10 CFR 50.59

_ and Technical Specification A contractor study and an

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inhouse safety evaluation were complete and available for revie .4 (Closed) Follow-up Item (84-25-03): Modify the RWP procedure to incorporate criteria for the assignment of extremity and.other supplementary dosimetry. Procedure HP0/CO-4, Revision 25, includes l a checkoff for extremity monitoring on the RWP form. Procedure l HP0/CO-13 provides guidelines for situations requiring additional i dosimetry.

l 3.5 (Closed) Follow-up Item (84-25-04): Modify the Lost Dosimetry _

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Procedure (HP0/CO-13B) to ensure that a dose estimate is made prior

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to the replacement of any lost dosimeter and to specify who can make

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the dose estimate. Procedures HP0/CO-13B.1 through B.3 now provide methods for estimating exposure.

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3.6 (Closed) Follow-up Item (84-25-09): Establish a procedure to monitor i

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daily Harshaw TLD reader calibration data to detect trends which might indicate degraded or unstable performance. Procedure HPA 10D has provisions added for a daily check of the reader system output, i 3.7 (Closed) Follow-up Item (85-11-08): Review licensee's procedure and facilities for personnel decontamination. . Procedure HP0/CO-7, j Revision 6, provides instructions for decontamination of personne i The decontamination facility on the 135' elevation in the radwaste

{ building appeared to be adequat .8 (0 pen) Follow-up Item-(85-28-04): Document contract HP technician training in lesson plans. This effort is approximately 20% complete.

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3.9 (Closed) Follow-up Item (85-31-01): Revise HP0/CO-17C to remove

technical content errors. Revision I to this procedure was issued on November 19,-1985. The sections regarding classification of waste j were changed.

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4.0 General Employee Training l The adequacy.and effectiveness of the licensee's general employee training program was reviewed against criteria contained in:

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10 CFR 19.12, " Instruction to Workers";

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Regulatory Guide 8.13, " Instruction Concerning Prenatal Radiation

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Exposure";

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Regulatory Guide 8.27, " Radiation Protection Training for Personnel j at Light Water Cooled Nuclear Power Plants";

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Regulatory Guide 8.29, " Instruction Concerning Risks from Occupational Radiation Exposure";

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Station Procedure A-50, " Training Procedure"; and

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QA Division Procedures QADP-5 and QADP- t The licensee's performance relative to these criteria was determined from:

Monitoring class lecture presentations;

Review of lesson plans;

Interviews with subcontractor female employees regarding prenatal j exposures; I

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Interviews with randomly selected workers;

Review of instructor qualifications and experience;

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Discussions with the Training Coordinator and instructors; i

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A tour of various training facilities; and I I

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A review of audit rep' ort AP 85-83TR and discussions with the QA

! Site Supervisor.

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l Within~the scope of this review, no violations were observed. However, l

! minor weaknesses were noted as follows:

i j The policies regarding radiation exposure to pregnant women on site were

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not clear to the subcontractor employees or supervisors. The licensee i stated that written direction will be given to subcontractors to clarify l the application of Regulatory Guide 8.13 at the site and to ensure that i

policies encourage early notification of pregnancies. This will be i reviewed in a future inspection. (50-277/86-02-01)

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10 CFR 19.13(b) requires that "At the request of any worker, each licensee shall advise each worker annually of the worker's exposure to i radiation..." A majority of the workers interviewed were unaware of this

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regulation. The licensee stated that this information is already included

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in the lesson plans but the presentation would be revised by March 1986 to provide greater emphasis. This will be reviewed in a future inspectio (5C-277/86-02-02)

A licensee strength was noted in that the instructors appeared to be well prepared, motivated and enthusiastic during the classroom presentations'.

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5.0 Respirator Training The licensee's program for screening and training of respirator users was

reviewed against criteria contained in

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10 CFR 20.103, " Exposure of Individuals to Concentrations of Radio-active Materials in Air in Restricted Areas'," and

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Regulator Guide 8.15, " Acceptable Program for Respiratory Protection."

The licensee's performance relative to these criteria was determined from a review of lesson plans, interviews with students and observation of j training. During the classroom training, the quality of instruction, l classroom facilities, and class attentiveness were examined. Following the classroom training, the inspectors. witnessed a loss of air drill and i a respirator fit test. Within the scope of this review, the following was identifie .

10 CFR 20.103(c)(3) states in part that "The licensee shall advise each respirator user that the user may leave the area at any time for relief i from respirator use in the event of equipment malfunction, physical.or

, psychological distress, procedural or communication failure, significant j deterioration of operating conditions, or any.other condition that might

require such relief."

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! Contrary to the above, a review of the GRT lesson plan revealed the lesson j plan did not mention the respirator user's right to relief from respirator

use in the event of equipment malfunction or procedural failure. Class-i room instruction included the missing material; however, a recent change

- to General Respirator Training LP-GRT-0010 dated December 8, 1984, page 32 of 34, deleted the material. The licensee. indicated the deletion was a j clerical error and would be corrected by March 1, 1986. This will be j reviewed in a future inspectio (50-277/86-02-03)

l j 6.0 Health Physics Technician Training The licensee's progression of training program for inhouse HP technician training was reviewed against criteria contained in:

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Technical Specification 6.3, " Facility Staff Qualification";

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ANSI N18.1 - 1971, " Selection and Training of Nuclear Power Plant

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Station Procedure A-50, " Training Procedure."

The licensee's performance relative to these criteria was determined from discussions with the training coordinator and a review of lesson plan !

The lesson plans were selected from the Catalog of Nuclear Training i Section Programs (NTS-005). This catalog gives a description of each of

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the training courses available to Health Physics Technicians and Chemistry

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Technicians. The description includes the classroom hours, on-the-job training hours, final examination requirements, and summary of course conten ,

From this catalog two lesson plans were reviewed for' content:

1) Assistant Technician, Mathematics Fundamentals, HPAT 0010-011 This course is a portion of assistant technician training, and is a review j of mathematics from basic arithmetic through trigonometry; and

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2) Assistant Technician, Radiation Protection, HPAT 1050-1230. This course is a portion of assistant technician training, and gives the student a good understanding of radiation protection.

The inspector also reviewed lesscn plans from the 1986 Continuing Training

! Schedule for Chemistry Personnel. Two lesson plans were chosen for review:

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1) Chemical Theory - Refresher and Applications (Review), CNHP 85-02A, and j

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2) Chemistry QA/QC Practices - An Introduction (Review), CNHD 85-02 The lessons were found to be complete and of high qualit ,

The inspector monitored the classroom presentation of Chemical Theory in progress. The presentation was made in a professional manner, with good classroom participation, and a positive student attitud Within the scope of this review, no violations were identifie i 7.0 Maintenance Hot Shop

, A radiologically controlled area has been established on the ground floor 1 of the administration building. The need for safety review of this l facility conducted per 10 CFR 50.59 is an unresolved issu t The inspector toured the area, observed work in progress and interviewed the "B" level Hp technician responsible for the area. The following areas of concern were discussed with the licensee:

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1) There are no administrative controls on the radiation levels of equipment brought into the facilit ) There is no shielded storage area for highly contaminated equipmen ) A functional water fountain is located in an area posted as "no crinking."

4) There were no accessible indications to the HP technician to show that the special HEPA air filtration systems were turned o The licensee stated that HP supervision will review these concern The hot shop operations will be reviewed again in a future inspection (50-277/86-02-04).

8.0 Exit Interview The inspector met with the licensee personnel denoted in section 1.1 a the conclusion of the inspection on January 31, 198 The scope and findings of the inspection were discussed at that time, i

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