IR 05000387/1989028
| ML17156B512 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/22/1989 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B510 | List: |
| References | |
| 50-387-89-28, 50-388-89-26, NUDOCS 8912060415 | |
| Download: ML17156B512 (23) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
50-387/89"28 Report Nos.
50-388/89-26 50-387 Docket Nos.
50-388 NPF-14.
License Nos.
NPF-22 Priority C
Category C
License:
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 Inspection Conducted:
October 16-20 1989 Inspector:
R.
L. Nimi z, Senior Ra iation Specialist date Approved by:
W. Pasciak, Chief, ciliti s Radiation Protection Section date Ins ection Summar
Ins ection conducted on October 16-20 1989 NRC Combined Ins ection Re ort Nos. 50-387/89-28 50-388/89-26 Areas Ins ected:
This inspection was a routine, unannounced radiological controls inspection during the Unit 2 outage.
The following areas were reviewed:
organization and staffing; training and qualification, previous findings, ALARA, external and internal exposure controls, control room habitability, process and area radiation monitoring, and housekeeping.
Results:
Within the scope of this inspection, two apparent violations were identified.
The first involved failure to adhere to radiation protection procedures.
(Details Section 7.0).
The second involved failure to maintain records of surveys.
(Details Section 7.0).
Unresolved items were identified in the following areas:
installation of HEPA filters in'he control room emergency ventilation system of the control structure, and establishment of a calibration program for area radiation monitors to meet FSAR commitments.
Weaknesses were found in the area of confined space entry.
General findings indicated a need for enhanced attention to detail by personnel.
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Al,n I
DETAILS 1.0 Individuals Contacted I. 1 Penns lvania Power and Li ht Com an
- R. Byram, Superintendent of Plant
"J. Blakeslee, Assistant Superintendent
- Plant
"G. Stanley, Assistant Superintendent
- Outages
- H. Riley, Health Physics and Chemistry Supervisor
- R. Prego, QA Supervisor Operations
"B. Rhoads, Chemistry Supervisor
"J. Fritzer, Radiological Operations Superviso'r
- R. Wehry, Compliance Engineer
'D.
McGann, Compliance
.
~J.
Schmidt, NQA-Analyst
- W. Morrissey, Radiological Protection Supervisor 1.2 Nuclear Re viator Commission S. Barber, Senior Resident Inspector - Susquehanna
- Denotes those individuals attending the exit meeting on October 20, 1989.
The inspector also contacted other personnel.
2.0 Pur ose and Sco e of Ins ection This inspection was a routine, unannounced radiological controls inspection.
The following areas were reviewed:
The licensee's actions on previously identified findings
~The radiological control group organization and staffing.
'The training and qualification of personnel.
I'he performance and adequacy of a'udits.
The internal and external exposure controls program.
~The ALARA program.
~The testing and calibration of area and process radiation monitors.
'The testing of the control room emergency ventilation system.
'The'-'control of radioactive and contaminated materia.0 Action on Previous Findin s
(Cl osed)
Unresol ved Item (50-387/88-13-01; 50-388/88-16-01)
The licensee will evaluate the performance of its whole body friskers that have been repaired with tape.
The licensee performed an indepth evaluation of th'e inspection concern.
The inspector concluded the licensee adequately addressed this matter.
No violations were identified.
This item is closed.
3.2 (Closed) Violation (50-387/88-04-01; 50-388/88-03-01)
The licensee did not post a High Radiation Area as required by Technical Specification 6:12.'1.
The inspector reviewed the implementation of the corrective action outlined in the licensee's April 13, 1988, letter to the NRC.
The inspector's review indicated the licensee implemented the corrective actions outlined in the letter.
This violation is closed.
3.3 (Closed) Violation (50-387/89-12-02; 50-388/89-12-02)
The licensee did not adhere to procedures for control of contaminated material.
The inspector reviewed the implementation of the corrective actions outlined in th licensee'
July 17, 1989 letter to the NRC.
The inspector's review indicated the licensee implemented the corrective actions outlined in the letter.
This violation is closed.
3.4 (Open) Unresolved Item (50-388/89-25-01)
The NRC will review the licensee's dose estimates for personnel who handled or 'came in close proximity to a highly radioactive filter medium on August 31, 1989.
The inspector reviewed:
The licensee's estimates of radioactive material contained'n the filter medium.
The licensee's dose estimates for the individuals who handled or came in close proximity to the filter medium.
'The methods used by the licensee to make dose estimates.
The inspector noted that the licensee collected representative samples of the reactor coolant using the same filter medium handled by the personnel on August 31, 1989.
The licensee performed detailed estimates of the exposure to personnel using the data generated from analyses of the representative samples.
The licensee also used the services of a contractor to perform personnel dose estimates using exoelectron dosimeters.
The licensee's results indicated only the individual who handled the filter medium received any appreciable dose.
The licensee's final dose estimates used the contractor's results.
The exoelectron dosimeter results appeared to be in general agreement with the licensee's dose estimates using computer modeling.
The, final dose estimates for the.individual were indicated to be 260
mil1irem (whole body), 2.3 rem (skin) average over 1 centimeter squared and 60 millirem (extremities).
The whole body and skin doses are for the upper left chest.
The inspector indicated the dose estimate appeared reasonable based on the available data.
However, the licensee was unable to indicate whether all short lived, beta emitting radionuclides were identified during the analysis of the additional samples collected.
Also the licensee could not provide any data to indicate the adequacy of the calibration of the exoelectron dosimeters.
The identification of all beta emitting nuclides and the calibration of the exoelectron dosimeters remains unresolved.
4.0 Or anization and Staffin The inspector reviewed the organization and staffing of the Radiological Controls (RC) Group.
The inspector used criteria contained in the licensee's Technical Specifications and Procedures as acceptance criteria.
Wi:hin the scope of this review, no violations were identified.
The inspector's review indicated the licensee's organization was adequately staffed to support outage activities.
The licensee established several procedures which identified the responsibilities of radiological controls personnel overseeing radiological work activities.
The licensee established and filled the position of work planning and scheduling coordinator in the radiological controls group.
The individual in this position is responsible for coordinating ALARA and radiological controls coverage for work.
The licensee has also established and filled the position of radiological controls consultant.
This individual is responsible for enhancing worker awareness of radiological controls requirements.
The licensee's establishment and staffing of the coordinator and consultant positions indicate good management support of radiological controls.
5.0 Trainin and uglification The inspector reviewed the training and qualification of radiation workers and radiological controls personnel.
The inspector used criteria contained in
CFR 19 and applicable licensee procedures as acceptance criteria.
Within the scope of the review, no violations were identified.
The licensee provided adequate training of radiation workers and radiological controls personne.0 ALARA The inspector reviewed, selected aspects of the licensee's ALARA program.
The inspector used criteria contained in applicable NRC Regulatory Guides and the licensee's procedures as acceptance criteria.
The inspector.
evaluated the licensee's performance by reviewing on-going work activities, by discussing inspector observations with the licensee's personnel, and by reviewing various documents.
The inspector reviewed:
'The establishment of station, group, and work specific exposure goals.
The monitoring of established exposure goals.
'The implementation of ALARA procedures.
~The ALARA planning for work.
'The use of ALARA techniques on job activities.
Within the scope of this review, no violations were identified.
The licensee was implementing a generally effective ALARA program.
The following positive observations were made:
The licensee established and was tracking exposure goals for the'tation, groups, and work tasks.
The goals were reasonable.
'The licensee's ALARA planning for work was generally effective.
OTours of the radiological controlled area by the inspector indicated a good use of ALARA techniques.
The licensee had pre-designated shielding placed in the drywells.
General area radiation levels in the Unit 2 drywell were noted to be about three to four times lower than if the shielding was not'used.
The licensee has established a special procedure for use by radiation protection personnel involved in planning and scheduling work tasks.
A planning and scheduling coordinator has been added to the radiation protection group to interface with work groups.
This addition will enhance ALARA and radiological controls planning for work tasks.
The licensee's three year average accumulated exposure per unit compares favorably with similar facilities.
7.0 External Ex osure Control The inspector reviewed the licensee's external exposure control program.
The inspector used criteria contained in
CFR 20, Standards for Protection Against Radiation, and applicable licensee procedures as acceptance criteria.
The inspector evaluated the licensee's performance
by reviewing on-going work activities by discussing inspector observations with the licensee's personnel,,
and by reviewing various documents.
The inspector's review indi'cated the licensee was aggressively tracking the accumulated whole body exposure of workers.
The licensee was also closely monitoring the radiation exposure associated with each radiation work permit.
The licensee's ALARA personnel reviewed the work whenever a
worker or radiation work permit accumulated exposures approached or exceeded the values identified during initial work planning.
The licensee had established conservative whole body exposure limits.
The granting of worker exposure limits higher than these standard administrative limits was closely controlled.
The inspector's review of radiation exposure documentation for workers indicated the worker's previous exposures were evaluated prior to granting the worker exposure increases.
Whole body exposure data for workers was complete, well maintained, and available; The licensee routinely performs some work underwater by use of divers.
This is an ALARA technique used by the licensee to minimize whole body exposures, especially when working on the steam dryers in the equipment storage pool.
The inspector reviewed documentation associated with repair of the Unit 2 steam dryer, which occurred, on October 5, 1989.
This work was conducted in accordance with Radiation Work Permit No. 89-0608, dated October 4, 1989.
The work involved five separate dives by divers to perform the work on the 'steam dryer.
The divers performed the work while standing on the floor of the equipment storage pool, standing on a work platform or sitting in a special chair suspended next to the dryer.
The inspector performed a detailed review of the radiation surveys made to support the work operation and the dosimetry worn by the workers.
The inspector also reviewed the accumulated exposure sustained by the divers to determine if the divers'ccumulated exposures were consistent with radiation dose rates and stay times.
The inspector's review indicated the licensee performed extensive radiation measurements to determine the magnitude of radiation dose rates emanating from the steam dryer.
The whole body radiation exposures were monitored by self-reading pocket dosimeters and by TLD badges.
The whole body doses of the divers were consistent with stay-times.
The licensee was unable to provide the values of the extremity doses received by the divers when asked by the inspector.
The licensee indicated that based on previous diving results, the whole body dose was limiting and not the extremity dose.
The licensee provided an excellent evaluation of upper extremities versus whole body exposure ratios for previous dives.
However, no data was provide'd for the lower extremitie This data was important because no previous lower extremity dose to whole body dose ratios were available for use in estimating the expected accumulated dose to the lower extremities.
Also, no radiation surveys were available to indicate the magnitude of radiation fields the individuals may have traversed while walking on the floor of the equipment storage pool.
The inspector expressed concern that divers had been walking on the floor of the equipment storage pool and that the licensee could not provide documented surveys of the areas traversed by the divers and could not provided extremity monitoring results for the divers.
The inspector noted that the equipment storage pool communicated with the reactor cavity.and that a potential, for crud or debris (potentially highly radioactive material) to be carried to the equipment storage pool existed.
The licensee was subsequently able to identify personnel who provided radiological surveys for the diving work.
These ipdividuals indicated surveys were made and no unusual measurements were noted.
The licensee also contacted the vendor who provides extremity monitoring services to the licensee.
The read-out of the extremity TLDs did not indicate any unusual exposures.
The inspector noted that
CFR 20.401(b) requires each licensee to maintain records showing the results of surveys required by 10 CFR 20.201(b).
CFR 20 '01(b) requires radiation surveys to be made to ensure compliance with 10 CFR 20.101.
CFR 20.101 provides radiation exposure limits for the extremities.
The inspector indicated.that it was appropriate for the licensee to make radiation surveys of the areas traversed by the divers to ensure compliance with the extremity dose limits of 10 CFR 20. 101, in this case the lower extremities.
The inspector also indicated that failure to document and maintain the results of the surveys was on apparent violation of 10 CFR 20..401(b).
(50"387/89-28-01; 50-388/89-26-01).
The inspector toured the Unit 2 drywell periodically during the inspection.
On October 17, 1989, at about 10:00 a.m.,
the inspector observed an individual enter the annulus area of the Unit 2 drywell (approximately 738 foot elevation).
The inspector noted that a health physics warning sign at the entrance to the area stated
"HP escort required."
The individual entered the annulus area without the required escort.
The licensee's Technical Specification 6. 11 requires that procedures for personnel radiation exposures be established, implemented, and maintained.
The licensee's Radiation Protection Procedure No. AD-00-705, Revision 13, Access Control and Radiation Work Permit System, states in section 4'0, that it is the responsibility of each radiation worker to understand and comply with all Health Physics a'ccess control and radiation work permit requirement The inspector indicated that failure of the individual to adhere to the Health Physics warning sign and obtain the required escort prior to entering the annulus area was an apparent violation of Technical Specification 6. 11 (50-387/89-28-02; 50-388/89-26-02).
The following observations were discussed with the licensee's representatives:
On October 19, 1989, out of date procedures, used to provide guidance for surveying articles to be removed from the radiological controlled area, were found at the Unit 2 Access Control Point.
A technician manning the Control Point provided them to the inspector as procedures used at the Control Point.
On October 19,'989, the Unit 1 and Unit 2 Access Control Points were found to be posted inconsistently.
The Unit 1 Access Control Point did not have a posting which provided guidance for use of the whole body. friskers while the Unit 1 Access Control point did.
Also', the Unit 2 Access Control Point did not have a posting which provided guidance for use of hand held'riskers while Unit 1 Access Control Point did.
The inspector's review of radiation work permits (RWPs) during plant tours found essentially all RWP access sheets to have obliterated protective clothing dress codes.
The dress codes are used in par t to identify types of respirators worn by workers.
One individual, working on the Unit 2 refueling mast on October 16, 1989, was observed to have entered the incorrect dress code on his RWP acces's sheet.
The sign in sheet indicated no respirator was worn when one was worn.
Personnel working on the Unit 2 refueling mast on October 16, 1989, were observed to be wearing full protective clothing including respirator s and hoods.
The worker's hoods were not taped.
The inspector observed the worker's periodically re-adjusting their hoods as the hoods fell away from their necks, exposing the skin of the neck.
The workers were handling highly contaminated objects.
The activity posed a significant potential for contamination of the neck.
The inspector noted that the licensee does not have a policy as to when loose protective clothing should be taped.
The inspector noted that the licensee has established a requirement that the radiation work permit (RWP) to be used by workers to perform a task be indicated on the appropriate work authorization using a
special stamp.
Inspector review of Work Authorization (WA) V99386 for repair of the Unit 2 refueling mast on October 16, 1989, indicated RWP No.
600A was to be used for the job.
The inspector noted, however, that RWP No.
603A was being used by the workers.
When questioned, the Assistant Radiation Protection Foreman covering the job was unaware that the WA specified use of RWP No.
600 Although the RWPs provided'imilar controls, the use of a.second RWP other than that specified on the WA raised questions about the use of, purpose for, and worker attention to the RWP stamp on the WA.
The licensee indicated the above matters would be reviewed.
8.0 Internal Ex osure Controls The inspector reviewed the licensee's internal exposure controls program.
The inspector used criteria contained in 10 CFR 20, Standards for Protection Against Radiation, and applicable licensee procedures to perform the review.
The inspector evaluated the licensee's performance in the area of internal exposure controls by reviewing on-going work activities, by discussing the observations with the licensee's personnel, and by reviewing various documents.
The inspector reviewed:
The use of process or other engineering controls to limit the concentrations of airborne radioactive material.
~The use of respiratory protective equipment by personnel.
Records, reports and notifications of internal exposures.
'The placement of airborne radioactivity sampling equipment.
The assessment of individual intakes of radioactive material.
Within the scope of the review, no violations were identified.
The inspector noted that the licensee used process or other engineering controls to the extent practicable to limit the concentration of airborne radioactive material.
Review of licensee's records indicated individual"intakes of airborne radioactive material were low.
The maximum intake identified during the Unit 1 1989 outage was about 5.8 MPC-hours.
The maximum exposure during the current Unit 2 outage was about 5.2 MPC-hours'he inspector's observations indicated good overall control of airborne radioactivity.
The following observations were brought to the licensee's attention:
'The inspector observed a non-functioning general area airborne radioactivity monitor in the Unit 2 drywell at 10:00 a.m.
on October 17,1989.
'Airborne radioactivity samples did not appear to be properly positioned for monitoring the worker's breathing zone during work on the refueling mast at about 4:00 p.m.
on October 16, 1989.
The licensee indicated these matters would be reviewe.0, Control Room Habitabilit The inspector reviewed the licensee's testing of the control room emergency ventilation system.
The inspector used the criteria contained in Technical Specifications for the review.
The inspector evaluated the licen'see's performance by reviewing completed surveillances, by performing an independent walk-down of the control room emergency ventilation system, and by discussing observations with the licensee's personnel.
The inspector reviewed:
'Testing of charcoal samples.
'Penetration test results for charcoal filters and HEPA filters.
~Performance of test runs of the control room emergency ventilation system.
~Verification of pressure drops across the charcoal and filter trains.
Within the scope of the review, the following matters were identified and were discussed with the licensee's personnel:
'The inspector observed the downstream HEPA filter in the A Train (OF-126A) of the control room emergency ventilation system to be coming apart.
The licensee used duct tape to hold portions of the filters in place.
The tape was peeling away from the filters and falling on the floor of the filter housing.
The inspector was concerned that the train could be partially disabled by clogging of the train with filter debris'his is an unresolved item,(50-387/89-28-03; 50-388/89-26-03)
This matter was immediately brought to the attention of the licensee's control room shift supervisor.
The B Train did not'xhibit this problem.
The inspector expressed concern to the licensee's representatives about using tape to hold filters in place in a safety related ventilation system.
'The inspector noted that six fans (OY-103A and B, OV-115A and B,
OV-117A and B) are used to pressurize and supply ventilation to the control structure.
This structure includes the control room.
During an event requiring use of the control room emergency ventilation system, the control room emergency ventilation system supplies the suction of these fans'he inspector noted there were no testing or operability requirements for the six fans contained in Technical Specification The inspector visually inspected the six fans (discussed above) that are used to pressurize and supply ventilation to the control structure.
The inspector noted a significant amount of work being performed above and around the fans.
The inspector noted loose scaffolding and equipment to be in close proximity to the fans.
Also, the inspector noted some fan housing doors to be secured with only three of nine latches used to secure the doors.
The inspector questioned the attention and care being given the fans.
The licensee immediately initiated a review of the above items.
The inspector indicated the operability, testing, and care requirements for the six fans was an unresolved item (50-387/89-28-04; 50-388/89-26-04).
10.0 Process and Area Radiation Monitor Calibrations The inspector reviewed the licensee'
surveillance testing and calibration of process and area radiation monitors'he inspector used, criteria continued in the licensee's Technical Specifications and applicable procedures for review of the surveillance testing and calibration.
The surveillance testing and 'calibration of the following radiation monitors were reviewed:
~Fuel Storage Vault Area Radiation Monitor.
Refuel Floor Wall Exhaust Radiation Monitor.
'Control Room Emergency Outside Air Intake Process Radiation Monitor.
'Spent Fuel Pool Area Radiation Monitor.
General Area Radiation Monitors.
Within the scope of this review, no apparent violations were identified.
The surveillance testing and calibration of process and area radiation monitors, which were identified in the Technical Specifications, met applicable requirements.
Within the scope of this review, the following matter was identified and discussed with licensee representative:
The licensee has installed general area radiation monitors (ARMs) in Unit 1 and Unit 2 to provide general area radiation monitoring'here are 40 of the ARMs in Unit 1 and 25 in Unit 2.
There are also 10 high range ARMs in each Unit.
Final Safety Analysis Report (FSAR)
Section 12.3.4. 1.6 states that these monitors will be calibrated periodically.
The inspector's review found that, contrary to the FSAR commitments, the monitors are not calibrated periodically.
This was identified by a licensee audit in mid-1989.
The licensee has
-
committed to initiate an 18 month calibration frequency commencing in January 1990.
The licensee's corrective actions for this apparent deviation from FSAR commitments will be reviewed in a future inspection.
This matter will remain unresolved (50-387/89-28-05; 50-388/89-26-05).
11.0 Plant Tours The inspector toured the radiologically controlled area periodically during the inspection.
The following observations were discussed with the licensee's representative:
I The inspector observed the 704 foot elevation'of the Unit 2 drywell to exhibit dirty, dusty, and cluttered conditions.
The inspector observed discarded hard hats, balls of tape, debris, used protective clothing and loose tools and equipment.
The inspector toured the Radwaste Building and observed dirty and dusty conditions in various parts of the building, particularly the 676 foot elevation of the structure.
The licensee indicated these matters would be reviewed.
'During a tour of the Unit 2 drywell on October 17, 1989, the inspector observed an individual enter the annulus area, a posted confined space.
Inspector review found that the entry was apparently not in accordance with safety procedures in that oxygen measurements apparently had not been made as required by Safety Procedure (SP)
No.
13, Confined Space Entry.
In addition, a qualified person was not stationed at the entrance to the confined space when the individual
- entered.
This is also not in accordance with SP No.
13 requirements.
The inspector immediately brought the observation to the attention of the licensee's personnel who initiated an investigation of the observation.
The individual who was observed entering the confined spaces was counselled by the licensee's personnel, Also, the licensee initiated training of all personnel on the incident to prevent recurrence.
12.
The inspector meet on October 20, 1989 with the licensee's representatives denoted in Section 1 of this report.
The inspector summarized the purpose, scope, and findings of the inspectio