IR 05000387/1990022
| ML17157A433 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/14/1990 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157A432 | List: |
| References | |
| 50-387-90-22, 50-388-90-22, NUDOCS 9011280260 | |
| Download: ML17157A433 (19) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387/90-22
~5tl-3 8il 9 0-22 50-387 Docket Nos..
50-388 License Nos.
NPF-14 NPF-22 Licensee:
Penns Ivania Power and Li ht Com an 2 North Ninth Street Allentown Penns lvania 18101 Facility Name:
.Inspection At:
"
Sus uehanna Steam Electric Station Units 1 and 2 Berwick Penns lvania Inspection Conducted:
October 10-15 1990 Inspector:
R. L. Nimitz, Senio adiatio Specialist
<< I>'t lf>
date Approved By:
W. Pasciak, Chief, Facilities Radiation Protection Section
~ll iv o
date Ins ection Summa: Ins ection conducted on October 10-15 1990 NRC Combined Ins ection Re ort Nos. 50-387 90-22 and 50-388 90-22
'I A~t:
Thi i
p inspection during the Unit 1 outage.
staffing; training and qualification, exposure controls, process and area was a routine, unannounced radiological controls The following areas were reviewed:
organization and previous findings, ALARA, external and internal radiation monitoring, and audits.
Results:
No violations were identified. The licensee provided effective external and internal exposure controls for the Unit 1 outage.
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~ri DETAILS 1.0 Individuals Contacted 1.1 Penns lvania Power and Li ht Com an
- G. Stanley, Superintendent of Plant
- H. Riley, Health Physics Supervisor
- D. Roth, Senior Compliance Engineer
- C. Whirl, Assistant Manager, NQA
- G. Kuczynski, Technical Supervisor
- D. Hagan, Radiation Protection Supervisor 1,2 Nuclear Re ulato Commission S. Barber, Senior Resident Inspector - Susquehanna
- J. Stair, Resident Inspector - Susquehanna
- Denotes those individuals attending the exit meeting on October 15, 1990.
The inspector also contacted other personnel.
2.0 Pu e an co e of Ins ection This inspection was a routine, unannounced radiological controls inspection during the Unit 1 refueling outage.
The following areas were reviewed:
organization and staffing; training and qualifications; corrective action system; external and internal exposure controls; ALARA the licensee's actions on previously identified findings the performance and adequacy of audits the testing and calibration of area and process radiation monitors the control of radioactive and contaminated material 3.0 i en ee Ac i n n Previous Findin 3.1 (Closed) Unresolved Item (50-387/89-28-05; 50-388/89-26-05):
The licensee identified that area radiation monitors were not being calibrated every 18 months in accordance with Final Safety Analysis commitments.
The licensee performed calibrations of all area radiation monitors.
The calibrations were performed in
accordance with work orders.
The calibration requirement was included in a periodic surveillance program.
Procedures will be developed to perform the calibration for the next 18 month cycle.
3.2 (Closed) Violation (50-387/89-28-01; 50-388/89-26-01):
The licensee did not document radiation surveys as required by 10 CFR 20.401(b).
The inspector reviewed the matter with respect to the licensee's corrective actions outlined in his December 20, 1989, letter to the NRC. The licensee revised procedures to ensure documentation of surveys and reviewed 10 CFR 20 requirements.
The licensee implemented the actions outlined in his letter.
This item is closed.
3.3 (Closed) Violation (50-387/89-28-02; 50-388/89-26-02):
A worker failed to adhere to radiation protection postings.
The inspector reviewed this matter with respect to the licensee's corrective actions outlined in his December 20, 1989, letter.
The licensee completed the actions outlined in his letter.
These included counseling of the individual, issuance of a station notice, and inclusion of this event summary in station training.
The licensee held pre-outage meetings in August, 1990, to provide management expectations to station personnel regarding outage.
This item is closed, 3.4 (Closed) Unresolved Item (50-388/89-25-01):
Licensee to provide data supporting radiation dose assessments for workers.
This matter was extensively reviewed during inspection 50-387/89-28; 50-388/89-26.
The licensee was not able to show that all potential unidentified nuclides were included in the dose assessment.
The licensee provided data to support the dose assessments.
This item is closed.
3.5 (Closed) Violation (50-388/89-25-02):
The licensee did not make surveys to ensure compliance with 10 CFR 20.201(b). The inspector reviewed the corrective actions outlined in the licensee's December 1, 1989 letter.
The licensee implemented the corrective actions outlined in his letter.
These included revising the radiation work permit and providing of alarming dosimeters for personnel performing sampling operations in the sample rooms.
This item is closed.
3.6 (Closed) Violation (50-388/89-25-03):
The licensee did not provide training to personnel in order to allow them to minimize their radiation exposure.
The inspector reviewed this matter with respect to the licensee's corrective actions outlined in his December 1, 1989, letter to the NRC. The licensee implemented the corrective actions outlined in his letter.
These included development of a chemistry procedure forkey control and training ofchemistry personnel on specific radiological controls practices.
This item is close.7 (Closed) Violation (50-388/89-25-04):
Personnel did not adhere to radiation protection procedures.
The inspector evaluated the corrective actions outlined in the licensee's December 1, 1989, 'letter to the NRC.
The licensee implemented the corrective actions outlined. These included review of standing radiation work permits for adequacy and training of chemistry personnel in radiological controls practices.
This item is closed.
3.8 (Closed) Violation (50-388/89-25-05):
Personnel performed sampling without an approved procedure.
The inspector reviewed the implementation of the licensee s corrective actions outlined in his December 1, 1989 letter to the NRC.
The licensee implemented the corrective actions outlined.
These included development ofa contractor control procedure, training ofpersonnel on procedure requirements, and review ofcontrol ofall contractors on site. This item is closed.
4.0 r aniza i n nd taffin The inspector reviewed the organization and staffing of the onsite Radiation Protection Group with respect to criteria contained in the following:
Technical Specification 6.2, Organization; Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations willbe As Low As Is Reasonably Achievable Evaluation of the licensee's performance in this area was based on discussions with cognizant personnel, review of o'-going work and review of documentation.
Within the scope of the review, no violations were identified. The following observation were made by the inspector:
The licensee established a defined radiological controls organization to support Unit 1 outage activities The licensee recently reorganized the radiological controls organization in order to provide greater focus on chemistry activities. A separate chemistry organization with increased staffing was established.
Previously the organization consisted of a combined radiation protection/chemistry organization.
The licensee has yet to update administrative documents to reflect the reorganization.
The following matter was brought to the licensee's attention:
t
There are no well-defined administrative controls or clear understanding regarding what types of radiological work activities that junior radiation protection technicians may independently perform (e.g., radiological coverage of work activities).
Junior technicians are technicians that do not meet Technical Specification qualification requirements.
Work assignments are made by various supervisors and it was unclear as to what the limitations were as to what work activities the junior technicians could perform.
The licensee initiated a review of this matter.
5.0 Trainin and ualifi ti n The inspector reviewed the qualification and training of members of the Radiological Controls Organization with respect to criteria contained in Technical Specifications.
The licensee's performance in this area was evaluated by review of resumes and training records and discussions with cognizant personnel.
The inspector's review in this area focused on the qualification and training of contractor radiological controls personnel hired to augment the organization during the outage.
The inspector also reviewed the adequacy and effectiveness of the performance of these
'personnel during review of work activities.
Within the scope of this review, no violations were identified.
Contractor personnel appeared to have received adequate training and qualification.
The following matter was brought to the licensee's attention:
There was no clear guidance as to what constitutes acceptable
"equivalent" experience for commercial nuclear power experience when qualifying contractor radiological controls personnel.
The licensee initiated a review of this matter.
The following observation was made:
The licensee developed a special training course dealing with transient radiation areas found in areas called black tag key rooms.
The training was incorporated into the initial radiation protection training program and covers those systems which are expected to produce or may exhibit extremely high radiation levels. The training was also incorporated into the continuing training program for radiation protection personnel.
This was considered a good initiativ.0 xern
n Inern 1Ex r
nr
The inspector toured the radiological controlled areas of the plant and reviewed the following elements of the licensee's external and internal exposure control program:
posting, barricading and access control;as appropriate, to Radiation, High Radiation, and Airborne Radioactivity Areas; High Radiation Area access point key control; control of radioactive and contaminated material; personnel adherence to radiation protection procedures, radiation workpermits and good radiological control practices; use of personnel contamination co'ntrol devices; use of dosimetry devices; use of respiratory protective equipment; adequacy of airborne radioactivity sampling and analysis to plan for and support ongoing work; timeliness of analysis of airborne radioactivity samples, including supervisory review of sample results; installation, use and periodic operability verification of engineering controls to minimize airborne radioactivity; bioassays and personnel airborne radioactivity intakes; records and reports of personnel exposure; adequacy of radiological surveys to support pre-planning of work and ongoing work; and hot particle controls.
The review was with respect to criteria contained in applicable licensee procedures and 10 CFR 20, Standards for Protection Against Radiation.
The inspector independently reviewed on-going work activities.
Within the scope of this review, no violations were identified. The licensee implemented an effective external and internal exposure control program.
The licensee was requiring the use of integrating alarming dosimeters around the spent fuel pool and reactor cavity area The licensee maintained an alarming general area radiation monitor on the refueling bridge The following matters were brought to the licensee's'attention for review and evaluation:
Inspector review ofairborne radioactivity sample analysis results for reactor water clean-up pump work noted that a number of the sample results indicated some unidentified peaks in the gamma scans.
The results were reviewed and approved by a supervisor.
Although subsequent inspector review found that the unidentified peaks were of no radiological significance, individuals who review and sign-off surveys could not readily indicate this information.
The licensee did not have defined guidance for review and evaluation of unidentified peaks.
The licensee indicated the matter would be reviewed.
The licensee's High Radiation Area access control procedures were not clear regarding issuance of keys to remote satellite radiation protection control points and key turnover requirements.
The licensee initiated a review of this matter.
Inspector discussions with contractor radiological controls technicians found one identified technician who did not know the correct pressure settings for a breathing air supply source used at the reactor water clean-up pump cubicle. No work was on-going at the time.
The licensee initiated an immediate review of this matter.
Several radiation work permits (RWPs)
observed in the field provide for radiological monitoring ofwork activities on an "intermittent" basis.
Intermittent was not defined and was subject to personnel interpretation.
The licensee provides personnel dosimetry that is certified by the National Voluntary Laboratory Accreditation Program (NVLAP) in radiation exposure Categories II-VII. The licensee did not certify the dosimetry for Category I radiation exposures because the licensee believed there w'as no creditable scenario where personnel would be exposed to Category I type radiation (average photon energy of 70 Kev with doses ranging from 10 to 500 rads).
The inspector noted however, the Category I was an accident category and that 70 Kev photons may be encountered during an accident situation.
The licensee indicated this matter would be reviewed.
7.0 ALARA The inspector reviewed selected aspects of the licensee's ALARAProgram.
The review was with respect to criteria contained in the following:
Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations willbe As Low As Reasonably.
Achievable; Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable;
NUREG/CR-3254, Licensee Programs for Maintaining Occupational Exposure to Radiation As Low As Reasonably Achievable; NUREG/CR-4254, Occupational Dose Reduction and ALARAat Nuclear Power Plants; Study on High-Dose Jobs, Radwaste Handling and ALARAIncentives.
The evaluation of the licensee's performance in the area was based on review of documentation, discussions withcognizant personnel, and independent observations in the field.
Within the scope of this review, no violations were identified.
The licensee provided effective ALARA planning for work activities.
Accumulated exposure was being monitored and tracked for adverse trends.
ALARA goals developed appeared to be challenging and reasonable.
Appropriate exposure reduction methods (e.g., shielding)
were being used where appropriate.
8.0 A dits n
A e
ments The inspector reviewed the audits and assessments of the radiological controls program.
The review was with respect to criteria contained in Technical Specifications and applicable procedures.
The evaluation of the licensee's performance in the area was based on discussions with cognizant personnel, review ofaudits and assessments, and independent observations made by the inspector.
Within the scope of this review, no violations were identified.
The licensee was considered to have a good audit and assessment program.
Audits and assessments provided a good overview ofradiological controls program implementation and served to maintain overall program quality.
I The following positive observations were made:
'he licensee routinely used outside technical experts to assist in performance of assessments of the radiological controls program Audits were performance-based and reviewed work activities on backshifts and weekends Audits reviewed the findings ofroutine surveillances and outside audit groups for trends or lack of effective corrective action for identified problems The licensee established a
Radiation Advisory Committee to provide an
.independent outside perspective regarding health and safety matters.
The committee members are industry experts in radiation protection matters Station staff members were active in self-identifying and issuing station occurrence reports for identified problems.
The station occurrence reports were evaluated in-
depth with appropriate corrective actions taken where needed.
Examples included improper use of respiratory protective equipment and personnel not adhering to pre-work briefings.
Pr n
Ar R
i inMni r li in The inspector reviewed the licensee's surveillance testing and calibration of process and area radiation monitors. The inspector used criteria contained 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 Refuel Floor High Exhaust 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.
10.D The inspector met with licensee representatives denoted in Section 1 of this report on October 15, 1990.
The inspector summarized the purpose, scope and findings of the inspection.
No written material was provided to the license.
OUTSTANDING ITEHS f)LE SINGLE DOCKET ENTRY FORH REPORT HOURS l. Operations 2.
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