IR 05000387/1986026
| ML17146A667 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/03/1986 |
| From: | Kaminski M, Lequia D, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17146A666 | List: |
| References | |
| 50-387-86-26, 50-388-86-27, NUDOCS 8612090668 | |
| Download: ML17146A667 (11) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
86-26/86-27 Docket No.
50-387/50-388 License No.
NPF-14/NPF-22 Priority Category C
Licensee:
Penns lvania Power & Li ht 2 North Ninth Street Allentown PA 18101
111 II: ~hh
.
&2 Inspection At:
Berwick PA Inspection Conducted:
11/3-7/86 Inspectors:
LeQuia Ra tio al ist date
]Z-w- 8L Kaminsk
ati n Specialist Approved by:
M. Shanbaky, ief, Faci li es Radiation Protection Section date date 2 I, I
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h f11 I
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h Radiation Protection Program:
ALARA; survey instrument control and calibration; control of radioactive materials; and status of previously identified items.
Results:
No violations or deviations were noted.
8612090668 86'1204 PDR ADOCK 05000387
DETAILS 1.0 Persons Contacted During the course of this routine inspection, the following personnel were contacted or interviewed:
1. 1 Licensee Personnel
- T. Crimmins Plant Superintendent, PP&L
"J. Blakeslee - Assistant Plant Superintendent, PP&L
- R. Doty - Health Physics/Chemistry Supervisor C. Kalter - Radiological Group Supervisor, Nuclear Support
"H. Riley - Radiological Operations Supervisor
- M. Buring -'adiological Protection Supervisor
"F. Butler Technical Supervisor
- D. McGoan - Compliance Engineer, PP&L
- R. Prato - Licensing
"J. Lindberg - Sr.
NQA Analyst NQA Operations
- D. McGarry Sr.
NQA Analyst NQA Operations E. McIlvaine - Health Physics Foreman - Operations D.
Hagan - Health Physicist ALARA, Nuclear Support M. Rochester - Health Physicist ALARA R.
Hock - Health Physics Specialist - Instruments le2 NRC Personnel
"J. Johnson Section Chief, Operational Programs, DRS
"L. Plisco Senior Resident Inspector
"J. Stair - Resident Inspector
- C. Petrone Lead Reactor Engineer Other licensee or contractor employees were also contacted or interviewed during this inspection.
" Attended the Exit Meeting on November
1986.
2.0
~Pur eee The purpose of this routine safety inspection was to evaluate and review the licensee's Radiation Protection Program with respect to the following elements:
Status of previously identified items o ALARA
~ Survey instrument control and calibration
'ontrol of radioactive materials and contamination, surveys and monitoring
3.0 Status of Previousl Identified Items 3.1 Closed Followu Item 50-387/84-25-03
Licensee to review survey data and correct, as necessary, the neutron exposures for personnel who entered the Unit 1 Orywell at power, The inspector determined from discussions with the licensee, review of applicable survey data, and review of exposure investigation records, that appropriate neutron dose corrections were made for personnel who entered the Orywell at power.
Based on these findings, this item is closed.
3.2 Closed Followu Item 50-388/84-15-03
Resolve open test exceptions for procedure A239. 1A.'omplete testing of the spent resin flush system (per A239. 1B), and the ultrasonic resin cleaner system (per A239.2A).
Inspector review of "Preopera-tional/Acceptance Test Records," verified that the licensee has resolved test exceptions for A239. 1A, and has completed testing of the spent resin flush and ultrasonic cleaner system in accordance with the above referenced procedures.
Based on these findings, this item is closed.
3.3 Closed Followu Item 50-387/86-03-01:
Licensee's lesson plans do not mention the user's rights concerning relief from respirator use in the event of physical distress, procedural or communication failure, significant deterioration of operating conditions, or any other condition that requires such relief.
Inspector review of licensee lesson plans,
"Respir'ator Initial Training" (HP-007),
and "Respirator Retraining" (HP007R),
verified that relief from respirator use is now included in applic-able lesson plans.
Based on these findings, this items is closed.
3.4 Closed Followu Item 50-387/85-07-03
Licensee to fully establish and implement the beta exposure control program.
Elements to include: (1) establish and implement a skin dose evaluation program (2) establish a method for notifying the corporate radiological control group when TLD's need to be evaluated for beta dose (3) determine adequacy of TLD's to properly monitor beta radiation at the plant, and (4) evaluate acceptability of current algorithms used for badge read-out analysis.
The inspector determined from discussions with licensee personnel that a beta skin dose evaluation program has been developed and implemented.
Elements include:
Procedure HP-TP-289, Rev. 0, which provides instructions for calculating the dose received by an individual
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resulting from skin contamination; Procedure AD-00-715, Rev.4, which provides for noble gas sampling and evaluation of skin exposure; Procedure AO-00-735 Rev.
8 (pending),
which requires the Radiation Protection Supervisor to inform the Nuclear Support Group when changes are required to the skin dose algorithm for TLD interpreta-tion due to beta energy changes.
In addition, the adequacy of TLOs to properly monitor beta radiation encountered at Susquehanna 1&2 has been confirmed, and the algorithms currently used for TLD read-out analysis have been determined to be acceptable.
Based on these findings, this item is closed.
3.5 Closed Unresolved Item 50-387/85-07-04 Review the adequacy of the calibration source used to determine beta
'alibration factors for survey instrumentation.
Inspector review of extensive studies performed by PP&L Health Physics and Battelle Laboratories Northwest confirmed the adequacy of the Thallium-204 source.
Based on these findings, this item is closed.
3.6 Closed Followu Item 50-387/85-07-02
NRC to review licensee audits of the internal and external dosimetry program, respiratory protection program, and qualification program for radiation protection personnel.
Inspector review of the follow-ing health physics audits (86-055,'5-67, IA-84-25 and 0-84-19),
and Health Physics Department responses, verified that audits of the above identified program elements have been'onducted.
Based on these findings, this item is closed.
4.0 ALARA The licensee's ALARA program was reviewed against criteria contained in:
CFR 20.1 "Purpose" Nuclear Department Instruction NDI-6.4.2 "ALARA Policy and Program" Procedure AD-00-745 "ALARA Program"
'rocedure HP-AL-400 "RWP ALARA Reviews and Evaluations" Procedure HP-TP-239 "Plant Shielding" Training Course C/I HP079 "Job Specific Training for ALARA Specialist" Susquehanna Steam Electric Station Man-, Rem Reduction Program The licensee's performance relative to these criteria was determined from:
'eviews of ALARA Committee meetings Reviews of RWP's and associated surveys, air samples, and ALARA pre and post job reviews.
4 Review of the Employee ALARA Concerns Program Audits of HP/ALARA Program 86-55, 85-67, IA-84-25, 0-84-19 Dose tracking data for various tasks
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'986 ALARA estimate sheets 1986 Man Rem Reduction Program Review of "Engineering Work Request Book" Discussions with members of the site and corporate HP and ALARA staffs Review of the RWP man-hr/man-rem evaluation done to improve exposure estimates Review of the General Work RWP man-rem estimates Review of the ALARA items action lists
'eview of the RMS active RWP man-rem/man hour summary Review of ALARA in progress review sheet
'eview of the cost benefit analysis for CRD flange shields Review of historic man-rem job comparisons Review of Unit 1 First Refueling Outage Critique
'eview of Unit 1 Second Refueling Outage Critique
'eview of Station man-rem exposure goals and estimating methodology Review of the Index of ALARA evaluations for RWP's
~ Plant Tours Within the scope of this review, no violations were observed.
The licensee'
ALARA performance continues to be good.
The ALARA goal for 1986 was established at 990 man-rem for the site total.
Station manage-ment projects this goal will be made.
From discussions with HP/ALARA staff, and review of practices and procedures, the ALARA program appears to be well defined.
The program has been effective in reducing exposures on Control Rod Drive (CRD) work from 2.03 man-rem per unit to 1.291 man-rem per unit.
'To further reduce the cumulative dose the licensee has initiated action to design and fabricate under vessel flange shields for CRD work.
Another strong point in the licensee's ALARA program is the 1987 man-rem reduction program.
This program',
which had ALARA input from all site work groups, appears to be ambitious and should help to reduce cumulative exposure at the site.
The following weaknesses were identified in the ALARA program.
The licensee's man-rem and man-hour estimating is in need of improvement.
This is seen in the tracking of man-rem and man-hours for various jobs where the actual values differ greatly from the projected values.
There is an apparent lack of management involvement by non-HP departments in conducting in-progress ALARA reviews.
Only 3 of the 96 requested reviews were done by non-HP departments.
This put an additional strain on the ALARA group which was already found to be understaffed in an audit finding.
No investigation was made by management as to why response was so poor.
The inspector determined that the licensee has the basis for a good ALARA program, however, more management attention is necessary to improve program effectivenes.0 Surve Instrument Control and Calibration The licensee's program for the control and calibration of portable survey instruments was reviewed against criteria contained in the 'following:
ANSI-N323-1978 "American National Standard Radiation Protection Instrumentation Test and Calibration" Licensee Procedures:
'P-TP-272
"Use and Operation of AMS-3 Beta Air Monitor"
'H-000-001
"Semi-Annual Radioactive Source Leak Check" HP-TP-101 "Calibration of Eberline Ion Chamber, Model RO-2/2A"
'P-TP-263
"Operation of Eberline RO-2 and RO-2A Ion Chamber" The licensee's performance relative to these criteria was determined from:
Oiscussion with cognizant personnel Tour of the Health Physics (HP) calibration facility
'our of the Instrument
& Control ( IKC) calibration facility
~ Review of semi-annual source leak check records for February and August 1986 Review of Condenser-"R" meter calibration certificates to verify NBS traceabi lity
~ Verified NBS traceabi lity of counting room calibrations sources Reviewed radioactive source decay curves for the sources used in the calibrator Review of 20, R02/R02A calibration certificates
~ Observed performance of instrument source checks
'eviewed calibration certificate for RM-20 ¹HP-463, and verified calibration of the mini-pulser (MP-1) used to calibrate it.
Within the scope of this review, no violations were identified.
The licensee, using a combination of IEC, HP and vendor calibration services, has implemented an effective instrument control and calibration program.
An adequate supply of count rate and dose rate instruments was observed to be available.
No instruments past due for calibration were observed while touring the facility.
All sources used for calibration were NBS traceable, and leak tested as necessary.
Two weaknesses requiring licensee attention were noted:
(1)
The licensee currently uses Tc-99 sources to determine the counting efficiency of Geiger-Muller (GM) tube instruments.
These counters typically have efficiencies of 10%.
However, the licensee has noted an increase of Cr-51 inside the primary system, varying between 16%
to as much as 80% of the smearable activity on primary components.
Since the low energy gamma will not be readily detected by the GM probe, actual activity may exceed detectable activity by a signifi-
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cant margin.
The inspector discussed this item with licensee HP personnel who indicated that they were aware of the problem and were continuing their investigation into the cause and its effect.
This area will be reviewed in a future inspection.
(2)
During a tour of the facility, the inspector noted that a strip charter recorder on AMS-3 ¹HP 522 was printing poorly and that AMS-3
¹HP34, while turned-on, had no air flow through it due to a twisted hose.
Both units had been recently inspected and initialed-off, indicating they were in proper working order.
Since both instruments had readily discernable problems, it appears that quality checks on some instruments are poor.
The HP Technician escorting the inspector took immediate corrective action to resolve these instrument problems.
Licensee management personnel stated they would make ary necessary improvements in this area.
6.0 Control of Radioactive Materials and Contamination Surve s and Monitorin The licensee's program for the control of radioactive materials and contamination, including surveys, monitoring and posting, was reviewed against criteria contained in the following:
CFR 20.201 "Surveys"
CFR 20.203 "Caution signs, labels, signal and controls"
CFR 20.401
"Records of surveys, radiation monitoring and disposal" The licensee'
performance relative to these criteria was determined.from:
Tours of the restricted area Discussion with cognizant personnel Review of Radiation Work Permits (RWP) and applicable personnel sign-in sheets
~ Review of survey records Observation of personnel frisking practices Review of air sample records Observation of dosimetry devices in use Observation of survey instrument source checks and performance of surveys Review of survey and air sample schedule sheets Within the scope of this review, no violations were noted.
The licensee's program for the control of radioactive material and contamination was adequate.
During tours of the restricted area, the inspector noted.that the plant was very clean.
Radiation Areas, High Radiation Areas (HRAs),
and Contaminated Areas were observed to be adequately posted.
All HRA doors checked by the inspector were found to be locked.
Most routine surveys had been completed on time and with sufficient detail.
i
The following weakness were noted:
'wenty-two (22) initials were missing from weekly air sample/radiation survey tracking sheets.
Subsequently, a routine air sample from the Reactor Building (RB) 645'valuation was missed on October 29, 1986.
Failure to complete the tracking sheet and collect the air sample indicates an apparent lack of management attention to detail.
'n the RB 645'levation, a white drum marked as a "clean drum" was found approximately half-full of used protective clothing (PC)
items.
In addition, used PC's were observed on the floor outside of a contaminated area.
The inspector brought these minor concerns to the attention of licensee management personnel, who took aggressive and timely response to rectify identified deficiencies.
7.0 General Comment
'
During the course of the inspection, the inspector observed a significant number of administrative error s, including:
write-overs, cross-outs without initials, missing initials, illegible records and records not being filed in an organized manner.
These deficiencies detract from the quality of the radiation protection program.
These item's were discussed with licensee management, who took action as necessary, to improve this area.
8.0 Exit Interview The inspectors met with the personnel denoted in Section 1.0 at the conclusion of the inspection on November 7, 1986.
The scope and findings of the inspection were discussed at that time.
At no time during this inspection was written material provided to the licensee by the NRC inspectors.