IR 05000387/1986012
| ML17146A458 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/21/1986 |
| From: | Nimitz R, Shanbaky M, Tuccinardi T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17146A457 | List: |
| References | |
| 50-387-86-12, 50-388-86-12, NUDOCS 8607290180 | |
| Download: ML17146A458 (11) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387/86-12
& 50-388/86-12 Docket Nos.
50-387 5 50-388 License Nos.
NPF-14 NPF 22 Category C
Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penns 1 vani a 18101 Facility Name:
Sus uehanna Steam Electric Station Units 1 and
Inspection At:
Berwick Penns lvania Inspection Conducted:
June 11-13 1986 Inspectors:
P-L 4 R.L. Nimitz, Senior Rad'ation Specialist WCc-c ~c-c L Wc T. E. Tuccinardi, Radi ati on Speci al ist date date
'pproved by:
M.M. Shanbaky, Chief, cilities Radiation Protection Section date Ins ection Summar:
Combined Inspection Nos.
50-387/86-12; 50-388/86-12 Routine, unannounced inspection of the following:
previous findings; ALARA; external exposure control; internal exposure control; post-outage reviews; planning and preparation for the up-coming Unit 2 first refueling outage.
Results:
No violations or deviations were identified.
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DETAILS 1.0 Individuals Contacted 1. 1 Penns lvania Power and Li ht
- J. Blakeslee, Health Physics/Chemistry Supervisor
- D. Thompson, Assistant Station Superintendent
- T. Crimmins, Station Superintendent H. Keiser, Vice President-Nuclear Operations
"W. Norri ssey, Acting Radiological Controls Supervisor C. Kalter, Radiological Group Supervisor 1.2 Nuclear Re ulator Commission R. Jacobs, Senior Resident Inspector
"L. Pli sco, Resident Inspector
" Denotes those individuals attending the exit meeting on June 13, 1986.
The inspector also contacted other licensee personnel.
2.0
~Pur ose The purpose of this routine announced radiological controls inspection was to review the following:
Unit 1 and
Previous Findings ALARA Program Unit
External Exposure Control Internal Exposure Control Post Outage Reviews Unit 2 Planning and preparation for the upcoming first refueling outage at Unit 2
3.0 Licensee Action on Previous Findin s
3.1 (Closed) Violation (50-387/85-07-06)
Licensee failed to tag breathing air systems in accordance with procedural requirements.
The inspector reviewed the implementation of corrective actions described in the licensee's May 2, 1985 letter to NRC Region I.
The licensee implemented the corrective actions as described.
3.2 (Closed)
Follow-up Item (50-387/85-22-01)
NRC to review the descrip-tion of responsibilities and authorities for each position of the corporate Radiological and Environmental Group.
The responsibilities and authorities of the corporate Radiological and Environmental Group as well as each of its subgroups is clearly described.
Each member of the group has a job description.
Minimum position selection criteria are described.
Some job descriptions are generic.
However, specific responsibilities relative to procedure implementation are described.
Verbal assignments are made based on specialty area assigned.
The licensee should consider providing written assignments to specialty areas for those individuals whose job descriptions are generic.
This is important considering the licensee's personnel rotation practices.
3.3 3.4 3.5 (Closed)
Follow-up Item (50-387/85-03-01)
Licensee to review and resolve NRC audit concerns identified in the area of personnel dosimetry.
These concerns will be reviewed in conjunction with follow-up item 50-387/85-07-03 (see item 3.5).
(Open)
Follow-up Item (50-387/86-03-01)
Licensee to review NRC con-cerns identified in the area of ALARA.
This matter is discussed in section 6.0 of this report.
(Open)
Follow-up Item (50-387/85-07-03)
Licensee to fully establish and implement the beta exposure control program.
The licensee is currently establishing the beta exposure control program.
The fol-lowing matters remain open:
establish and implement a-skin dose evaluation program.
establish a clear method for making required notifications to the corporate radiological control group when certain TLDs need to be evaluated for beta dose The following items are transferred from item 50-387/85-03-01:
determine adequacy of TLDs to properly monitor beta radiation encountered at Susquehanna 1 and
evaluate the acceptability of current algorithms used for badge read-out analysis.
4.0 Plannin and Pre aration Unit 2Q The inspector reviewed the adequacy of the licensee's radiological con-trols planning and preparation for the first refueling outage at Unit 2, which is scheduled to start in August 1986.
The evaluation of the licensee's performance in this area was based on discussion with cognizant personnel and review of outage plans.
The following 'matters were discussed:
organization and staffing qualification and training of personnel facilities and equipment ALARA lessons learned from Unit 1 Refueling outage
~Findin s
The licensee is performing acceptable planning and preparation for the outage.
The following positive attributes were noted:
the licensee established a Unit 2 First Refueling Outage Plan.
A Radiological Controls section is included in the plan.
the licensee has determined the number of additional radiological controls personnel that will be needed to augment the Radiological Controls staff.
the licensee has established a man-rem goal for the Unit 2 Outage.
This goal was established using a combination of an "off-the-top" 10% reduction in estimated exposure for task performance and general estimates of exposure to be sustained for the work.
5.0 Post-Outa e Review Unit
5. 1 General The inspector performed a review of selected parameters indicative of licensee performance during the second refueling outage of Unit 1.
The inspector focused on those parameters associated with Radio-logical Controls.
The following matters were reviewe number and resolution of Station Operating Occurrence Reports (SOORs)
number and resolution of Area Contamination Reports number and resolution of Personnel Contamination Reports number and resolution of Health Physics Outage Report findings.
External Exposure Internal Exposure
~Findin s
Within the scope of the review, no violations were identified.
The following sections provide the general findings in this area.
5.2 Area Contamination Re ort ACRs There were 138 ACRs written in 1985.
At the time of the inspection, 64 ACRs had been written for 1986.
The licensee is tracking the number of ACRs as a performance ind-icator.
However, the following was noted:
A program to review ACRs form a generic point of view, and initiate corrective actions in the event a commonality is identified, has not been established.
the inspector identified multiple ACRs apparently resulting from the same causal factor (cog. Turbine Building Condensate Pump Room)
recommendations made by individuals who generate ACRs are not tracked to disposition.
Based on the above findings, improvements are needed in this area.
5 '
Personnel Contamination Re orts There were 212 personnel contamination reports (PCRs) written in 1985.
At the time of this inspection,
PCRs had been written for 1986.
The licensee is tracking the number of PCRs as a performance in-dicator.
Also, the licensee is tracking PCRs,by individual.
How-ever, the following was noted:
A program to review PCRs from a generic point of view, and initiate corrective actions in the event a commonality is identified, has not been established.
Based on the above findings, improvements are needed in this area.
5.4 Station 0 eratin Occurrences Re orts SOORs The licensee is tracking the review, evaluation, and implement'ation of corrective action (as appropriate)
for Station Operating Occur-rences Reports (SOORs).
The radiological occurrences can be tracked by category (e.g. spill).
There were
SOORs issued for spills since 1983.
The following observation was made:
no apparent program is in place to review radiological SOORs from a generic point of view and initiate corrective action in the event a commonality is identified.
Based on the above, improvements are needed in this area.
6.0 ALARA 6.1 General The inspector reviewed the adequacy, effectiveness and implementation of the licensee's ALARA Program with respect to criteria contained in the following:
CFR 20. 1, "Purpose" Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Is Reasonably Achieveable (ALARA)," Revision 3; Regulatory Guide 8 ~ 10, "Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable", Revision 1-R; NUREG/CR-3254,
"Licensee Programs for Maintaining Occupational Exposure to Radiation As Low As Is Reasonably Achievable".
Licensee Procedures:
NSI-2. 14,
"Guidance for ALARA Review of Project Funding Requests and Design Changes to SSES NSI-8. 1,
"Work Project Evaluation", Revision 1,
NSI-2.18, "Implementation and Operation of the PP@L ALARA Program",
Revi sion 0; NSI-2.16,
"Development of Annual Man-rem Estimate",
Revision 0; NDI-6.4.2,
"ALARA Policy and Program",
Revision 1;
AD-00-745,
"ALARA Program",
Revision 4; HP-AL-400,
"RWP ALARA Reviews and Evaluations",
Revision 3; AD-00-705, "Access Control and Radiation Work Permit System",
Revision 7; The evaluation of the licensee's performance in the area was based on the following:
discussions with cognizant personnel, review of applicable documentation, specific reviews of ALARA planning and implementation for the following:
RWP 860128(B) Inservice Inspection, RWP 860138 CRD Removal, RWP 860139 Pre-work set-up for CRD Removal, review of Unit 1 Refueling Outage ALARA planning and implementation, Unit 1 Refueling outage Post-Outage Reviews ALARA pre-planning for the Unit 2 refueling outage.
The following matters were reviewed:
Management system for program implementation, maintenance and evaluation Organization effectiveness Staffing ALARA Optimization Process
M I
C Program Implementation Goal Setting 6.2
~Findin s
The licensee has established a defined ALARA program.
New procedures and revisions to previously existing procedures, have improved the program.
The program provides for work pre-planning, on going job review and post-job evaluation.
The ALARA organization and staffing was considered acceptable.
The licensee is using corporate radiological controls personnel to augment the site ALARA group.
The licensee's performance was com-pared to other plant performance both nationally and internationally.
Reports of performance in the area of Radiological controls including ALARA were provided to senior management.
Action items were deve-loped to address program deficiencies/weaknesses identified.
Within the scope of this review, the,.following.items. for improvement were identified.
These items primarily involve. the establishment of acceptable documents to describe and control the nrogram.
Licensee senior management generated an unrealistically high initial 1986 site exposure goal (9 16QQ man-rem).
The exposure goal of ]600 man-rem did not provide for a challenging rem reduction program for the site.'here is no apparent program for generating goals based on optimum use of ALARA controls.
Program procedures for performing actual ALARA cost benefit analysis are not inplace.
A procedure to perform this function is about 90K complete.
For minor modifications, no apparent clear procedure is in place-to address ALARA aspects of the modification.
s The 'criteria for triggering of additional reviews of on-going work based on excessive man-rem, man-hours, or dose rates are not incorporated into the licensee's program procedure The inspector met with those individuals denote in section 1.
The in-spector summarized the purpose, scope and finding of this inspection.
No written material was provided to the licensee.