IR 05000387/1985015
| ML17156A292 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/16/1985 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156A291 | List: |
| References | |
| 50-387-85-15, NUDOCS 8506050697 | |
| Download: ML17156A292 (9) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-387/85-15 Docket No.
50-387 License No. NPF-14 Pri ority Category Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown PA 18101 Facility Name:
Sus uehanna Steam Electric Station Unit
Inspection At: Berwick PA I l':Ml
Inspector:
H. J.
Bi o se, Radiation Specialist date Approved by:
J sc>a
, Chief, Radiation Protection Section, DRS da e
Ins ection Summar:
Ins ection on Ma 1-2 1985 Re ort No. 50-387/85-15 d~:
11,
- dd
1
program associated with steam dryer repair activities including:
planning/preparation; external exposure control; internal exposure contro'1; surveys; and ALARA implementation.
The inspection involved 12 inspector-hours onsi.te by one region-based inspector.
Results:
Within the scope of this inspection, no violations were noted.
The license appeared to be implementing an effective radiation protection program to support steam dryer repair activities.
850b050b9T 850518 PDR ADOCK 05000387
DETAILS 1.
Individuals Contacted The following licensee personnel were contacted or interviewed:
- J. Blakeslee, Health Physics/Chemistry Supervisor M. Buri ng, Radiological Protection Supervisor P. Jaeger, Health Physics Foreman W. Morrissey, Health Physics Specialist - ALARA
- H. Riley, Radiological Support Supervisor D. Shane, Health Physics Assistant Foreman Decontamination S. Strelecki, Acting Health Physics Assistant Foreman
- D. Thompson, Assistant Superintendent Plant Susquehanna Steam E
Station (SSES)
ectric
" denotes those individuals attending the exit interview on May 2,
Other licensee personnel were also contacted or interviewed during course of this inspection.
85.
the 2.
~Pur ose The purpose of this special unannounced inspection was to review th licensee's radiation protection program associated with repairs to Unit 1 steam dryer with respect to the following elements:
e the Planning/Preparation for Steam Dryer Repair; External Exposure Control; Internal Exposure Control; Surveys; and
"As Low As Reasonably Achievable"(ALARA) Implementation.
3.
Plannin /Pre aration emoval Technical Specification 6.5,
"Review And Audit;"
"Procedures And Programs;"
Regulatory Guide 1.33, "guality Assurance Program Requirements (Operation)," Revision 2 (2/78);
The licensee's planning and preparation for the Unit 1 steam dryer r and repair were reviewed against criteria and guidance provided in:
Regulatory Guide 8.8, "Information Relevant Occupational Radiation Exposures At Nuclear Low As Is Reasonably Achievable;"
and NUREG-0761, "Radiation Protection Plans For Licensees."
To Ensuring That Power Stations Will Be As Nuclear Power Reactor The licensee's performance relative to these criteria and guidance was reviewed and assessed by discussions with cognizant licensee personnel and review of the following:
Procedure AD-TY-523, "Unit 1 Steam Dryer And Support Block Repairs,"
Revision 1 (3/8/85);
Procedure TP-162-007,
"Controlling Reactor Vessel Work And Water Level Management,"
Revision 0 (3/16/85);
Procedure TP-235-002, "Filling The Unit 2 Dryer/Separator Pool~To Repair The Unit 1 Steam Dryer," Revision 0 (3/20/85);
and Procedure HP-TP-890,
"Reactor Vessel Decontamination Using The Cleanco System,"
Revision 0 (3/16/85).
Within the scope of this review, the following items were noted:
A planning task force was established (including radiation protection personnel)
for the repair operation; Mitigating measures to minimize radiation exposures to personnel were planned and employed; and Special procedures for work activities were developed, reviewed, approved and implemented.
4.
External Ex osure Control The implementation of the licensee's external exposure control program to steam dryer repair activities was reviewed against criteria provided in:
CFR 20.101, 20.102, 20.104, 20.105, and 20.202; Technical Specification 6. 11, "Radiation Protection Program;"
Technical Specification 6. 12, "High Radiation Area;"
Licensee's Procedure AD-00-700, "Conduct of Health Physics,"
Revision 6 (10/9/83);
Licensee's Procedure AD-00-705, "Access Control And Radiation Work Permit System,"
Revision 6 (ll/12/84); and IR SUSQUEHANNA 85-15 - 0005. '
Licensee's Procedure AD-00-735, "External Dosimetry Program,"
Revision 6 (11/8/84).
The licensee's performance relative to these criteria was determined by review of 8 radiation work permits (RWP) and supporting surveys forj reactor cavity and related refuel floor work on the Unit 1 steam dryer, examination of selected exposure records, discussions with radiatio'n protection personnel and observations and measurements made during a tour of the steam dryer work area.
Within the scope of this review, the following items were noted:
During reactor cavity work under RWP No.85-456, ("Dryer Seismic Block Repair And PT/UT Inspections," 4/9/85),
non-uniform radiation fields were present resulting in higher exposure rates to the I
workers'high area (relative to the trunk and head areas).
The licensee relocated the personnel monitoring devices to the thigh area from the chest area, (i.e.
normal wearing location), to monitor that exposure.
However, it was unclear from the licensee's records exactly which workers and RWP entries were involved in the relocations to the thigh area.
Interviews with cognizant radiation protection personnel and selected workers confirmed that the personnel monitoring devices had been relocated as described.
)he inspector noted that recorded radiation exposures were below
CFR 20. 101 limits when scaled upwarded by a factor 1.5 to account for the difference between chest level and thigh level radiation exposure rates.
The inability of the licensee to di stingui sh between normal personnel monitoring device placement and relocated placement in the records was discussed with the licensee and will be examined in subsequent inspections.
50-387/85-15-01 Observations of work in progress in the Unit 2 Dryer/Separator
~work area on May 2, 1985 indicated that the licensee was maintaining strict control of the high radiation area associated with steam dryer work.
Remote electronic radiation monitoring equipment, time keeper control of stay times and audible alarming personnel dosimeters~ were being used under the control of an assigned, fully.-qualified health physics technician.
Each RWP examined was supported by adequate surveys, ALARA reviews and suggested mitigating measures to reduce personnel exposure.
Observation of work in progress on May 2, 1985 confirmed the implementation of those measures.
IR SUSQUEHANNA 85-15 0006. Internal Ex osure Control
.I The licensee's program for control of airborne radioactive contamination during cutting, welding and grinding operations associated with steam dryer repair was reviewed against criteria provided in:
CFR 20.103; Technical Specification 6. 11, "Radiation Protection Program;"
I Procedure AD-00-715, "Airborne Radioactive Material Concentration Sampling And Evaluation Program," Revision 2 (7/26/83);
Procedure AD-00-720, "Contamination Control, Revision 3 (5/17/84);
Procedure AD-00-725, "Respiratory Protection Program,"
Revision
(10/26/84).
Ii The licensee's performance relative to these criteria was determined by examination of 8 RWPs and associated air sampling measurements, discussions with cognizant radiation protection personnel and observations of work in progress on May 2, 1985.
'ithin the scope of this review, the following items were noted:
Each RWP specified adequate respiratory protective measures and conditions for their use; Auxiliary ventilation was provided to contain and remove airborne particulates; and Air sampling appeared to be representative of the workers'reathing zones.
I
~Surve s
The licensee's surveillance program associated with steam dryer repairs was reviewed against criteria provided in:
CFR 20.201, 20.203 and 20.401; s
Technical Specifications 6. 11, "Radiation Protection Program;"
and Procedure AD-00-710, "Radiation Survey Program," Revision
(2/17/84).
The licensee's performance relative to these criteria was determined by examination of selected survey records supporting RWPs and discussions with radiation protection personnel.
IR SUSQUEHANNA 85-15 0007. ~
~
Wh N
Within the scope of this review, no violations were noted.
The licensee appeared to be implementing an adequate surveillance program to measure and assess the radiological conditions associated with steam dryer repair activities.
7.
ALARA Im lementation 8.
The licensee's implementation of an ALARA program during steam drye'r repair was reviewed against guidance in Regulatory Guide 8.8 and li,censee Procedure AD-00-745, ("ALARA Program,"
Revision 3, 7/25/83).
The licensee's performance relative to this guidance was determined by::
interviews with the Health Physics Specialist-ALARA and a member of his staff; review at
RWPs and the associated ALARA review packages; and observation of work in progress on May 2, 1985.
Within the scope of this review, the licensee was implementing a generally effective ALARA Program for steam dryer repair.
However, the following item was noted:
ALARA total exposure estimates, (i.e.
manrem projections),
were hindered by inaccurate estimates of work time, (i.e. manhours).
On 12 steamj,.dryer repair RWPs/ALARA reviews examined, actual work time exceeded projected work time for 10 of the operations.
Estimates of work times involved were low by factors up to 9.
The licensee's methods for estimating manhours associated with future activities were discussed with the licensee and will be examined in subsequent inspections.
50-387/85-15-02 fl Exit Interview The inspector met with the licensee's representatives (denoted in Se'ction 1) at the conclusion of the inspectin on May 2, 1985.
The inspector summarized the purpose and scope of the inspection and identified findings as described in this report.
At no time during the inspection was written material provided to the licensee by the inspector.
No information exempt from disclosure under
CFR 2.790 is discussed in this report.
IR SUSQUEHANNA 85-15 0008.0.0 l
I