IR 05000387/1985022
| ML17139D145 | |
| Person / Time | |
|---|---|
| Site: | 03019311, Susquehanna |
| Issue date: | 08/21/1985 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17139D143 | List: |
| References | |
| 30-19311-85-01, 30-19311-85-1, 50-387-85-22, 50-388-85-18, NUDOCS 8509030380 | |
| Download: ML17139D145 (14) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
50-387/85-22 50-388/85-18 Repor t No.
30-19311/85-01 50-387 50-388 Docket No.
30-19311 NPF-14 NPF-22 License No.
37-06554-04 Priority C
C Category Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penns lvania 18101 Facility Name:
Sus uehanna Steam Electric Station Units 1 and
Inspection At:
Berwick Penns lvania and Allentown Penns lvania Inspection Conducted:
Jul 14-19
~ 1985 Inspectors:
R.
Nimitz, Senior Ra ati n Specialist da e
Approved by:
J.
p asciak, Chief, BWR, Radiation ection Section da e
Ins ection Summar:
Ins ection on Jul 14-19 1985 Combined Re ort No.
SO-387/8S-22 50-388/85-18 and 30-19311/85-01
~A": "i, i
i f
t Rdi Program during normal operation.
The following was reviewed at Unit 1 and Unit 2:
licensee action on previous inspection findings; radiological controls organization, staffing, and training; audits; reactor coolant chemistry sur-veillancee implementation; process and effluent monitor surveillance implementa-tion; and radioactive waste shipping.
Also reviewed was the licensee's IInterim Low Level Waste Storage Facility.
Upon arrival at the site on July 14, 1985, the inspector toured the controlled areas to examine adherence to applicable Radiological Controls Program requirements.
The inspection involved 39 inspector hours onsite and one hour at the corporate office by one region based inspector.
Results:
No violations were identified.
The licensee was found to have a
generally acceptable radioactive waste shipping program.
Some problems were identified in the area of documentation of corrective actions for findings of corporate audits of the site Radiological Controls Program.
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DETAILS 1.0 Individuals Contacted 1. 1 Penns lvania Power and Li ht J. Blakeslee, Health Physics/Chemistry Supervisor
~H. Riley, Radiological Operations Supervisor
"D. Thompson, Assistant Station Superintendent
~T. Crimmins, Station Superintendent
~H. Keiser, Vice President - Nuclear Operations,
- C. Madara, Health Physics Specialist L. Mittenberger, Health Physics Specialist
- K. Shank, Environmental Group Supervisor - Nuclear
"*C. Kalter, Radiological Group Supervisor
- 'R. Harris, Senior Licensing Specialist 1.2 Nuclear Re ulator Commission
- R. Jacobs, Senior Resident Inspector L. Plisco, Resident Inspector
- denotes those individuals attending
"~denotes those individuals contacted on July 19, 1985.
the exit meeting on July 19, 1985 at the licensee's corporate office 2.0 Pur ose of Ins ection The licensee's Health Physics/Chemistry Supervisor was contacted by'i',the inspector on August 1, 1985 and informed of the results of the inspection findings at the corporate office.
The inspector also contacted other individuals.
The purpose of the routine, unannounced radiological controls inspection was to examine the following program elements.
Unit 1 and
)
Licensee action on previous findings Radiological Controls Organization, Staffing, Training Reactor Coolant Chemistry Surveillance Implementation Process and Effluent Monitor Surveillance Implementation
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Radioactive Waste Shipping
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Low Level Waste Storage Facility 3.0 Licensee Action on Previous Ins ection Findin s
3. 1 (Closed)
Follow-up Item (50-387/84-39-02)
Licensee to:
1) establish pro-cedure controls and/or perform evaluation to ensure compliance with 10 CFR 61.56(a)(4),
(a)(5)
and (b)(3); 2) revise procedures to address lost shipments search/notification requirements of 10 CFR 20.311(d)(8);
'and 3)
revise procedures to ensure compliance with the chelating agent require-ments of 10 CFR 20.311(b).
The inspector discussed the above matte'rs with cognizant licensee representtives, reviewed applicable procedures, reviewed safety evaluations and reviewed controls established to limit introduction of chelating agents into radioactive waste system.
The inspector reviews and discussions indicated the licensee adequately'ddressed these matters.
This item is closed.
3.2 (Closed)
Follow-up Item (50-387/84-39-04; 50-388/84-49-03)
Licensee, to upgrade methodology for quantification of radioactive iodine collected by cartridges.
The licensee modified his iodine analysis methodology to perform multiple counts of the iodine collection cartridges (one count per side)
and average the results.
The licensee also obtained face-loaded ( spiked)
car tridges for use as calibration standards.
Appropriate sample geometries have been established.
This matter is closed.
3.3 (Closed)
Follow-up Item (50-387/85-07-09)
Licensee to upgrade criter'ia for determination of acceptable operation of portable high efficiency particulate air (HEPA) fitler systems.
The licensee retired the
"ho'me made" portable HEPA systems and established acceptable criteria (checks)
for the vendor supplied units.
This matter is closed.
4.0 Radiolo ical Controls Or anization Staffin Trainin 4.1 Site The inspector performed a selected reviews of the licensee's Radiolo'gical Control Organization, staffing and training.
The review was perform'ed to determine the following:
~
the in-place organization is consistent with Technical Specification requirement
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staffing levels are adequate
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properly trained and qualified individuals are acting in respon'sible position The review was with respect to criteria contained in the following:
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Technical Specification 6.2, "Organization" (Unit 1 and 2)
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Technical Specification 6.3, "Unit Staff gualification" (Unit
2)
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Technical Specification 6.4, "Training', (Unit 1 and 2)
and The evaluation of the licensee's performance in this area was based discussions with cognizant personnel, reviews of documentation, and review of normal and backshift personnel staffing and qualifications on klithin the scope of this review, no violations were identified.
7/ithin the scope of this review, the following positive item was noted:
The licensee was preparing for the first refueling outage of Unit
(February, 1986) by:
drafting a proposed radiological control organization to be implemented for the outage estimating numbers of personnel needed to staff the proposed organization The licensee's actions in this area indicate that preplannning is be performed in order to ensure an effective, adequately staffed radiological controls organization is in place to support the outage lng 4.2
~Cor orate The inspector reviewed selected aspects of the Corporate Radiologica Controls Organization.
The review was performed to determine the following:
that the organization was clearly defined via an organization c art that a clear description of organizational responsibilities was established that a clear description of individual position responsibilities was established The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel and review of documentation:
>Iithin the scope of the review, the following was noted:
a clearly described organization chart was established and inplac ~
a Nuclear Support Charter (NDI-1.3.3) has been established which clearly describes the responsibilities of the Radiological and Environmental Services Group and its subgroups.
Within the scope of this review, the following matter remains'open and will be reviewed during a subsequent inspection.
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identification of clearly described responsibilities and authorities for each position of the Radiological and Environmental Services (RES)
Group (50-387/85-22-01).
No clear description of the respon-sibilitiess and authorities of each position in the RES Group was identified.
5.0 Assessments The inspector reviewed the adequacy and implementation of the licensee's Health Physics Assessment Program.
The review was with respect to
'riteria contained in the following:
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NSI-2. 13, Revision 0, "Health Physics Assessment Program",
dated June 6,
1984
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PLI-32452,
"Susquehanna Steam Electric Station Group Assessments",
dated April 13, 1984
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PLI-34505,
"Assessment Schedule",
dated July 26, 1984 Assessments Reviewed Internal Dosimetry, dated March 22, 1984, Portable Survey Instruments, dated April 12, 1984 Respiratory Protection Program, dated May 18, 1983 Solid Radwaste Management, dated September 21, 1983 Health Physics Training, dated July 29, 1983 Within the scope of this review, the following was noted:
the assessment performed by the corporate groups of activities at the site was indepth and thorough.
Within the scope of the review, the following item requiring licensee attention was identified (50-387/85-22-02):
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licensee personnel had not responded in writing to some of the audit findings.
For example no written response was provided by the site
for the portable survey instrument assessment conducted by the',Icor-porate group.
Consequently, it was not clear that all the assessment findings were addressed.
f, Licensee representatives indicated this matter would be reviewed.
6.0 Reactor Coolant Chemistr Surveillance and Process/Effluent Monitor Surveillance The inspector reviewed selected aspects of the licensee's reactor coolant and process/effluent chemistry surveillance program.
The review was performed to determine the following:
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procedures were established for performance of the applicable
'hemi stry surveillance
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the applicable chemistry surveillance procedures were implemented
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appropriate controls were in place to ensure the reactor operation group notified the chemistry staff in a timely manner when sampling was to be initiated I(
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appropriate methods were in place to ensure the licensee's chemistry staff notified the reactor operations group in a timely manner 'of sample results
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applicable procedures/methods were in place to ensure other appropriate chemistry sampling/analysis/notifications or reports, as required by Technical Specifications, was performed.
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process and effluent radioactivity monitors were calibrated consistent with Technical Specification requirements
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appropriate radioactivity standards/sources/geometries were use'd for calibrating process and effluent monitors The review was with respect to criteria contained in the following:,i
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Technical Specification 3/4.4.4,
"Chemistry", (Unit 1 and 2)
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Technical Specification 3/4.4.5, "Specific Activity" (Unit 1 and 2)
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Technical Specification Table 4.4.5-1,
"Primary Coolant Specific Activity Sample and Analysis Program" (Unit 1 and 2)
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Technical Specification 3.3.7. 10, "Radioactive Liquid Effluent I,
Monitoring Instrumentation" (Unit 1 and 2)
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Technical Specification 3'.3.7.11,
"Radioactive Gaseous Effluent Monitoring Instrumentation",
(Unit 1 and 2)
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Offsite Dose Calculation Manual
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Applicable licensee surveillance procedures
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Technical Specification Compliance Matrix Within -the scope of this review no violations were identified.
Within the scope of this review, the following matters were identified (50-387/85-22-03):
The chemistry surveillance test results data sheets, contained, in applicable surveillance procedures, do not identify who is respon-sible for signing off applicable sections of the data.
The data sheets should be revised to clearly identify sign-off requirements.
Some chemistry surveillance test results data sheets do not identify, as shift supervisor action items, all applicable Technical Specifi-cation surveillance requirements which need to be initiated when other chemistry surveillance results indicate they should be ini-tiated.
An example is Procedure SC-276-101 which doesn't identify a Technical Specification action item requiring the frequency of~'pH determination of reactor coolant be increased on high conductivity.
(T.S. 4.4.4.3b).
The licensee should review the surveillance test results data sheets to ensure all other applicable (potentially required)
survei llances are referenced.
This would ensure that'hift supervision is aware that all applicable chemistry surveillance requirements are initiated.
Within the scope of this review, the following matters are unresolved and will be reviewed during a subsequent inspection (50-387/85-22-04; 50-388/85-18-01):
No apparent procedures or guidance were in place for initiation'f reports for increased off-gas levels at the steam jet air ejector (Technical Specification Action Statement 3.4.5C.2 and C.3) (Un'it
and Unit 2)
No apparent procedures or guidance were in place relative to restoration of motive steam jet condenser discharge rate of noble gases when applicable limits are exceeded (Technical Specification 3. 11.2.7) (Unit 1 and 2).
In addition, no apparent guidance was in place to inform or allow reactor operations personnel to readily identify that discharge rates were approaching applicable limits.
(Unit 1 and Unit 2)
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Alarm set-point verification for the Unit 2 Air Ejector Off-gas',
Monitor was not included in applicable routine surveillance procedures.
Such verification is included in Unit 1 procedures.'
7.0 Radioactive Waste Shi in t,
The alarm set point is required by the Offsite Dose Calculation Nanual (ODCM) to be set at a multiple of the background reading.
Consequently if background levels change during routine operation (and between monitor calibrations)
the alarm set point may not be set in accordance with ODCM guidance.
Licensee representatives indicatyd the above matters would be revie'wed and appropriate action taken.
The inspector reviewed selected aspects of the licensee's Radioactive Waste Shipping Program.
The following matters were reviewed.
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personnel training and qualification
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selection and use of appropriate shipping packages
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notifications
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package maintenance
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records and reports Quality Assurance preparation of packages for shipment determination of package curie content The evaluation of licensee's performance in the area was based on:
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review of applicable procedures review of selected radioactive waste shipments independent inspector determination of package curie content discussions with cognizant personnel review of records Within the scope of this review, no violations were identified.
The'icensee was implementing a generally acceptable radioactive waste shipping program for the quantities of radioactive material being shipped.
Within the scope of this review, several matters requiring licensee 1,
attention were identified.
These matters primarily involve compliance with applicable regulatory requirements in the event that the licensee h
wishes to ship larger quantities of radioactive material.
The licensee's action on these matters will be reviewed during a subsequent inspection (50-387/85-22"05):
Licensee personnel, responsible for radioactive waste shipping operations, were using out-of-date regulatory hand-books for reference in monitoring compliance with radioactive waste shipping requirements.
Controlled regulatory documents were available Ionsite but were not being used.
The licensee immediately initiated action to ensure controlled shipping regulatory requirements were provided/obtained by shi personnel.
ppl ng Note:
The licensee's radwaste shipping personnel had recently attended radwaste shipping courses.
Knowledge gained at these courses was used to modify/upgrade shipping procedures.
No examples of the use of "old" regulatory guidance was identified in current procedures.
The program/method for providing information to radioactive waste personnel does not appear to ensure timely transmittal of regulatory guidance information to these personnel.
As of July 19, 1985,IInfor-mation Notice 85-46, dated June 10, 1985 which provided clarifica-tions of regulatory requirements for radioactive shipping package contamination limits, had not been seen by radioactive waste shipping personnel'he licensee should review the program/method to ensure timely transmittal of information flow.
ld The radioactive shipping cask receipt inspection procedure shou include provisions for comparisons to as-built drawings.
Establish procedure guidance for shipment of special form radioactive material.
Revise applicable procedures to provide guidance relative to th advance notification requirements of 10 CFR 71.97.
ntact Use Define the term
"periodic" identified in procedures for determination of average gamma ray energy (Ej).
This energy is used, at times, in the determination of curie content of package The required minimum frequency of determination of this average'nergy should be clearly specified.
Revise procedures to clarify use of limitations of container co radiation dose rates for package curie determination.
LSA box methodology was being used to estimate curie content of liners.
of the methodology resulted in overestimation of curie content.-
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Establish and implement a training program for and/or ensure that security and warehouse personnel, who receive radioactive material, will notify radiological controls personnel of its arrival in 'a timely manner.
Regulations (10 CFR 20.205) specify'time limits relative to radiological monitoring of packages of radioactive material received.
In place controls should ensure the time 11imits are met.
Note:
Licensee representatives indicated that purchase orders for radioactive material specify notification of health physics personnel upon receipt of radioactive material at the sit'e.
Time limitations prevented the inspector from reviewing the adequacy of this method of notification.
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Formalize and approve the training program for radioactive waste supervisory personnel.
The intent of required reading should be defined.
Also clearly defined evaluation criteria should be established to use in evaluating an individual's knowledge of
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procedural requirements.
Note:
Personnel are periodically rotated (as supervisors)
through the radwaste shipping group 8.0 Interim Low Level Waste Stora e Facilit LLWSF The inspector reviewed selected aspects associated with the Low Level Waste Storage Facility.
The following matters were reviewed:
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compliance with the conditions of the facility license
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establishment and implementation of operating procedures for the faci 1 ity
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construction of the facility consistent with the facility safety evaluation report The review was with respect to criteria contained in the following:
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Materials License No. 37-06554-04, its associated Safety Evalua'tion Report and Environmental Impact Appraisal
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CFR Part 20, "Standards for Protection Against Radiation"
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"Storage of Low-Level Radioactive Wastes at Power Reactor Sites"
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Licensee Procedures:
AD-00-448, Revision 0,
"Waste Management" AD-QA-765, Revision 5, "Solid Radwaste Program"
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HP-TP-860, Revision 2, "Transfer of Radioactive Material to the Low Level Radwa ste Holding Facility" I
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HP-TP-844, Revision 2, "Storage of Packaged Radwaste"
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HP-TP-862, Revision 0,
"LLRWHF Container Inspection"
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Procedure (Expired) for Operation of the Low Level Radioactive Waste Holding Facility The evaluation of the licensee's performance in the area was based on:
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discussions with cognizant personnel
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review of procedures
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inspector tours of the facility Within the scope of this review, no violations were identified.
Within the scope of this review the following matters requiring licensee attention were identified.
The licensee's actions on these matters wi 11 be reviewed during a subsequent inspection (50-387/85-22-06):
The operating procedures for the LLWSF have expired.
The licensee should reissue this procedure prior to use of the facility as an interim low level waste storage facility.
The facility operating procedures should be reviewed to ensure the following matters are addressed:
clearly established guidance relative to implementation of the 1% surveillance program discussed in the facility license; all commitments made in the September 23, 1982 and March 1'~,
1983 letters, referenced in the facility license, have been implemented; the responsibilities relative to security of the facility should be clearly described; and definition/interpretation of "trace amounts of special nuclear material",
as referenced in the facility license should be'stablished Small amounts of water appear to be entering the facilities via cracks between concrete floor slab ~
control of radioactive and contaminated material 9.
Plant Tours Unit 1 and
The inspector toured the plant during normal hours and during backshifts.
The following matters were reviewed:
li adequacy of radiological control postings, barricading and access control
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condition of plant
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access control to high radiation areas
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radiological survey/monitoring instrumentation in use was properly calibrated and functioning
~1 The review'as with respect to criteria contained in applicable radiological control procedures, facility license conditions and 10,CFR 20, "Standards for Protection Against Radiation."
The evaluation of the licensee's performance in the above areas was,based on independent surveys performed by the inspector, discussions with~
cognizant personnel and review of documentation.
Within the scope of this review, no violations were identified.
However, the following matter requiring licensee attention was identified:
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the inspector identified a number of deficiencies relative to posting of radiological control areas.
These involved postings to areas found on the floor and non-uniform postings between Units
and 2.
I These matters were immediately corrected by licensee personnel when
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brought to their attention.
Inspector discussions with licensee representatives indicated a posting improvement plan has been established but is not implemented.
The licensee's posting improvement plan will significantly upgrade inplant radiological posting when implemented.
The adequacy of plant radiological posting and implementation of the posting improvement plan will be reviewed during subsequent inspections.
~Ei fl The inspector met with licensee representatives (denoted in section 1)
at the conclusion of the inspection on July 19, 1985.
The inspector summarized the purpose, scope and findings of the inspection.
At no time during the inspection did the inspector provide written material to the licensee.