IR 05000387/1986003
| ML17146A362 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/18/1986 |
| From: | Dragoun T, Shanbaky M, Tuccinardi T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17146A361 | List: |
| References | |
| 50-387-86-03, 50-387-86-3, NUDOCS 8605070116 | |
| Download: ML17146A362 (9) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-387/86-03 Docket No.
50-387 License No.
NPF-14 Priority Category C
Licensee:
Penns lvania Power 8 Li ht Co.
2 North Ninth Street Al 1entown Penns 1 vania 18101 Facility Name:
Sus uehanna Steam Electric Station Unit 1 Inspection At:
Berwick PA Inspection Conducted:
March 11-14 1986 Inspectors:
ou, adiation Specialist, FRPS date Approved by:
T. Tuccina d',
Radi ti Specialist, FRPS M. Shanbaky, Chief, Faci ties Radiation Protection Section date dat Ins ection Summar:
Inspection on March 11-14,1986 (Inspection Report No.
50-387/86-03 A~d.
i,,
d f
protection program, including:
status of previously identified items; training and qualification of contractor HP technicians; control of outage work; ALARA program; and issuance and maintenance of respirators.
Results:
No violations were identified.
8605070116 860421 PDR ADOCK 05000387 PDR
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DETAILS 1.0 Persons Contacted During the course of this routine safety inspection, the following personnel were contacted or interviewed:
1. 1 Licensee Personnel
- D. Thompson Assistant Plant Superintendent J. Blakeslee - Health Physics and Chemistry Supervisor M. Bur'ing Radiation Protection Supervisor
~S.
Denson NQA R. Doty Nuclear Support C. Kalter - Nuclear Support
- R. Kichline Licensing
- V. McGann - Compliance Engineer P.
McGlynn - Internal Dosimetry Supervisor E. McIlvaine -
HP Shift Supervisor W. Morrissey - ALARA Supervisor J.
Reitmeyer Instructor Training Supervisor
- H. Riley Radiological Operations Supervisor
- D. Sadvary Compliance Engineer
- J. White Nuclear Training Group Other licensee or cont,ractor employees were also contacted or inter-viewed during this inspection.
"Attended exit interview on March 14, 1986 1.2 NRC Personnel R. Jacobs - Senior Resident Inspector L. Plisco - Resident Inspector 2.0
~Per ose The purpose of this routine safety inspection was to review the licensee's radiation protection program with respect to the following elements:
~ Status of Previously Identified Items
~ Training and Qualification
~ Control of Work
~ ALARA Program
~ Issuance and Maintenance of Respirators
3.0 Status of Previousl Identified Items 3.1 3.2 3.3 (Closed)
Unresolved Item (84-39-01)
Review the instrumentation cali-bration program deficiencies.
1) The HP site organization now maintains current copies of procedures used by vendors to calibrate instruments.
Service vendors are required to provide all revisions and updates.
2)
A vendor letter dated November 8, 1983 states that acceptances criteria for air samples flow rate was changed to +20%.
3) Procedures HP-TP-286 and HP-TP-270 have been revised to include acceptance criteria for daily checks.
(Closed)
Followup Item (85-07-01)
Update Technical Specification organization for radiation protection.
Amendment 47 to the Tech Spec shows the new organization in Figure 6.2.2-1.
Technical Specification 6.3. 1 includes the qualification requirements for the new position.
Site administrative procedures AD-QA-100 and AD-00-700, 705 and 760 have been updated to show the new position.
(Closed)
Followup Item (85-07-08)
Review contractor HP technician training program.
This program is now documented in procedure NTP-QA-42.4.
Further discussion is contained in section 4 of this report.
(Closed)
Followup Item (85-15-01)
Improve external exposure records to record relocation of personnel monitoring devices.
The licensee has revised procedures HP-TP-215 to clarify the special conditions necessary for the movement of the TLD dosimetry and the recording of exposure data.
3.5 3.6 (Closed)
Followup Item (85-22-02) Corporate assessments not responded to.
Six Nuclear Safety Group assessments were provided with written responses.
The assessment
"Calibration of Portable Survey Instru-ments (PLI-32392)" dated April 12, 1984 was answered by PLIS-21649.
(Closed)
Followup Item (85-22-05)
Radwaste shipping program not fully established.
The licensee has addressed specific inspector concerns as follows:
1)
The HP supervisors, receive biweekly updates of changes to rad-waste regulations from a vendor updating service.
2)
All NRC notices and bulletins related to radwaste were reviewed and incorporated into the procedures.
3)
Each shipping cask has a use procedure that includes QA veri-fication of Certificate of Compliance requirements prior to use of the cas )
All waste is assumed to be in a "normal form" rather than
"special form" to be conservative.
The lower limits in normal form are required in procedure HP-TP-801.
5) 'ype B packaging is not used now nor in the foreseeable future therefore it is not included in the procedures.
If this changes, the licensee will issue appropriate procedures.
6)
Conservative dose rate to curie conversion factors for various packagings have been developed based on generally accepted practice.
7)
Procedure HP-TP-851 has been revised to clarify the term
"periodic".
8)
Procedure AO-gA-710 "Radiation Survey Program" has been revised to include survey requirements for receipt of radioactive ma-terial.
Security Procedure S7-000-033 provides time limitation for security personnel to notify the HP Office of the arrival of material.
All warehouse personnel were trained in radioactive ma'terial handling and notification procedures on January 17, 1986.
9)
A training program was provided to radwaste supervisors.
3.7 (Closed)
Followup Item (85-22-06)
Review interim low level waste storage facility.
Procedure AO-gA-770 has been revised to delineate surveillance requirements and assign security responsibility for the LLWSF.
Work order 563161 was issued to investigate and repair ground water seepage in the facility.
4.0
~Trainin 4.1 Pennsylvania Power and Light Company (PPEL) hired 90 contractor health physics technicians for the Unit 1 outage.
Two contractor technicians plus eight PP8 L health physics technicians were promoted to foreman for control of the added work load during the outage.
Information supplied on resumes of contractor personnel is verified by telephone.
gualification requirements for contractor technicians includes
months or more work experience at private nuclear power plants, or ANSI qualification.
Once hired, technicians must pass an entrance examination, security test, site access training, and the health physics technician examination (HPII).
Further training on specific procedures on site is provided on an as needed basis.
This initial training requires approximately one wee The second week of training includes familiarization with specific tasks such as air sampling and use of instruments.
The training provided to each technician is based on the assigned work.
4.2 The inspectors toured the licensees training facility.
The facility was found to be of excellent quality and well equipped.
The staffing level and resource facilities indicates a strong commitment to train-ing.
Training facilities include 11 class rooms, 4 laboratories, and a reactor control room simulator.
The laboratories included elec-trical, mechanical, inspection and calibration, health physics and chemistry facilities.
4.3 The instructor training process was reviewed, and found to be of excellent quality.
All new instructors are given a "skills inven-tory" to ascertain teaching weaknesses and strengths.
A formal training program is then developed and implemented by station pro-cedure STCP-QA-511, "Instructor Qualification".
Eighteen months is
.
allowed for a teacher to complete the professional qualification.
'uring this period, new teachers use approved lesson plans.
College credits are granted towards a bachelor degree for instructors who complete this program.
New instructors utilize teaching staff development modules on com-puter discs for use in the training center "Apple" and IBM computers.
The licensee has the capability of making video and computer assisted training modules.
Off-station schools and seminars are encouraged.
4.4 The respirator training lesson plans were reviewed against criteria contained in:
CFR 20. 103,
"Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas",
and Regulator Guide 8. 15, "Acceptable Program for Respiratory Protection".
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 from respirator use in the event of equipment malfunction, physical or psychological distress, procedural or communication failure, significant deterioration of operating conditions, or any other condition that might require such relief."
Contrary to the above, a review of "Respirator Initial Training", HP-007, and "Respirator Retraining",
HP-008, revealed the lesson plans do not mention the respirator user's right to relief from respirator use in the event of physical of psychological distress, procedural or communication
failure, significant deterioration of operating conditions, or any other condition that require such relief.
The licensee stated that the appropriate lesson plans would be revised.
This will be reviewed in a future inspection (50-387/86-03-01)
5.0 Control of Outa e Work The licensees program for the control of outage work in radiologically hazardous areas was reviewed against the criteria contained in:
~
CFR 20 - Standards for Protection Against Radiation
~
ANSI N18.7, "Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants"
~
Station Procedure AS-QA-502,
"Work Authorization"
~
Station Procedure AD-00-705, "Access Control and Radiation Work Permit System"
~
Station Procedure HP-TP-320,
"Radiation Work Permits" The licensee performance relative to these criteria was determined from:
~
tours and observations at the five operating control points in regards to adequacy of equipment, supplies and availability of HP personnel
~
A review of active Radiation Work Permits
~
Interviews with HP foreman and technicians
~
A review of postings and control of radioactive material.
Within the scope of this review, no violations were observed.
The licensee has a very effective system for identification of work prior to the outage
, preplanning the work, and closely following the performance of each job dur'ing the outage.
The licensee's program for maintaining radiation exposures during the outage as low as reasonably achievable was reviewed against criteria contained in:
CFR 20. 1 Purpose.
Reg.
Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Mill Be As Low As Is Reasonably Achievable"
~
Reg.
Guide 8.10 "Operating Philosophy for Maintaining Occupational Radiation Exposure As Low As Is Reasonably Achievable"
~
Station Procedure AD-00-745,
"ALARA Program"
~
Station Procedure HP-AL400,
"RWP ALARA R'eviews and Evaluations"
~
Station Procedure A0-00-705,
"Access Control and Radiation Work Permit System"
'he licensees performance relative to these criteria was determined from:
~
Review of ALARA training program for supervisors (HPIII)
~
Interviews with the ALARA Admin Supervisor,'P/Chemistry Supervisor, corporate HP representatives and HP technicians and foreman.
~
Observation of a special Station ALARA Review Committee meeting held to discuss the inspection of steam dryer support blocks in the reactor vessel.
Review of ALARA exposure estimates, dose tracking, and dose saving measures specified on radiation work permits.
~
Review of a lengthy (118 page) report titled "Unit I First Refuel Outage Health Physics Report" which details lessons learned during the previous outage.
Weakness in the licensees ALARA program is indicated by the following:
The radiation exposure goal set for the site (both units) by corporate management for calendar year 1986 is 1500 man-Rem.
Since both units are relatively new, the goal does not compare favorably with similar vintage plants nor does it indicate an aggressive corporate approach to ALARA.
Management was advised of the need to review the exposure goals and to increase the level of performance of the ALARA program.
This matter will be reviewed in a future inspection.
(86-03-02)
7.0
. Issuance and Maintenance of Res irators The licensees program to control the issuance, use, retrieval, maintenance and repair of respiratory protection equipment was reviewed against criteria contained in:
~
CFR 20. 103,
"Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas."
~
CFR 20 Appendix A "Protection Factors for Respirators"
~
Station Procedure AD-00-725 "Respiratory Protection Program"
~
Station Procedure HP-TP-320 "Radiation Work Permits"
~
Station Procedure HP-TP-758 "Respirator Inspection/Repair" The licensee's performance relative to these criteria was determined from:
~
Interviews with control point technicians who issue respirators
~
A review of the respirator repair facility and interviews with the repair technicians A review of the training and qualification of respirator technicians
~
Discussions with the responsible supervisors Within the scope of this review, no violations were observed.
The licensee's program appears to be adequate.
8.0 Exit Interview The inspectors met with the personnel denoted in section 1 at the conclusion of the inspection on Narch 14, 1986.
The scope and findings of the inspection were discussed at that time.
At no time during this inspection effort was written material provided to the licensee by the HRC inspectors.