IR 05000387/1993021
| ML17158A079 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/21/1993 |
| From: | Bores B Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17158A077 | List: |
| References | |
| 50-387-93-21, 50-388-93-21, NUDOCS 9401110131 | |
| Download: ML17158A079 (17) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Inspection No.
Docket Nos.
50-387'-387 3-21'0-388/
3-21 License Nos.
NPF-14 NPF-22 Licensee:
Penn lvaniaP werand Li ht Com an 2 N rth Ninth Stree Allentown Penns lvani
1
Facility Name:
Inspection At:
Sus uehanna Steam Electric Stati n Units 1 & 2 Berwick Penn Ivani Inspection Conducted:
N vember 8-12
3 Inspectors:
J. N gle, S r Radiation Specialist Facilities Radiation Protection Section
/> fg date R. Ragland, diation Specialist Facilities Radiation Protection Section
/3 e3 date Approved by:
B. B res, C 'ef, Facility s Radiation Protection Section date
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assessments, outage organization and contractor trauung, and review of outage maintenance work HP coverage and associated satellite health physics (HP) control point activities.
Results:
The licensee's radiological controls program has shown programmatic improvement
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in the HP operations area.
In particular, the new radiation work permit format, adopted in September 1993, was greatly improved and in its implementation contained a good level of 9401110131 9312 PDR ADOCK 05000 87 PDR
radiological controls.
Also, the HP operations staff has conducted a benchmarking effort at several other nuclear power plants and anticipates mahng further program changes in a commendable effort to further upgrade the HP operations program.
Personnel exposures and other radiological hazard indicators were low. Some potential program enhancements are described in the report for the licensee's consideration.
One violation and one noncited violation of Technical Specification requirements pertaining to high radiation area posting and barricade were identifie DETAILS 1.0 Personnel Contacted Licensee Per onnel
- R. Brouse, Health Physics Scheduler
- K. Chambliss, Maintenance Outage Production Supervisor
- T. Dalpiaz, Manager of Nuclear Maintetiance
- D. Hagan, Health Physics Supervisor
- G. Kuczynski, Manager of Nuclear Plant Services
~ D. McGarry, Drywell Coordinator
~ J. O'ullivan, Site Modification Design Supervisor
~ G. Stanley, Vice President, Nuclear Operations
- R. Wehry, Compliance Engineer 1.2 NRC Per onnel
- G. Barber, Senior Resident Inspector
- D. Mannai, Resident Inspector
- Denotes those present at the exit interview on November 12, 1993.
Other licensee employees were contacted and interviewed during this inspection.
2.0 P~uose The purpose of this routine inspection was to review the licensee's radiation control program implementation during outage conditions.
3.0 Or anization and Pro m Ch n e The permanent on-site health physics (HP) staff of 57 personnel has remained constant since the previous inspection.
To accommodate the outage requirements, the licensee upgraded 13 HP Level II technicians to temporary assistant HP foreman positions to act as supervision for the 104 temporary HP contractor technicians.
The licensee stated that they have had a high level of returning HP contractor technicians from outage to outage.
The radiological operations group was divided into satellite HP control points to focus HP oversight into seven central areas of Unit 1:
Reactor Building 818'refueling floor), Reactor Building 749', Reactor Building 719'drywell),
Reactor Building 683', Turbine Building 676', Turbine Building 729', and balance-of-plant coverage.
The HP staffing resources appeared to be very good to meet the additional demands of the outag.0 T inin and uglifications The inspectors reviewed the qualifications of the temporary HP technician workforce.
Approximately 12 HP technicians were selected at random and the inspectors verified that all 12 HP technicians met the ANSI 18.7-1978 experience requirements and had fulfilledthe station's requirements for procedure qualification.
The inspectors reviewed the training program for contractor HP technicians.
The licensee provided a screening examination to all contract HP technician candidates.
This examination was reviewed by the inspectors and was found to contain a good variety of questions, required solution of practical HP problems and was found to be a good test requiring a comprehensive knowledge of health physics subject material.
After successfully passing the HP technician (HFQ screening exam, the HPT candidate undertook three days of HP procedure training that was followed by another examination.
The inspectors reviewed this multiple-choice examination and found it to be very general and with obvious choice answers.
After completing this portion of the training, two days of on-the-job training was provided by the permanent HP lead technician at the various HP control points.
The licensee developed an outline of control point specific guidelines for the refuel floor, reactor building, dryweil and turbine building control points.
The contractor HP technician traiiiing program was considered good, however, while the qualification documentation was excessive, it did not directly indicate what training was actually provided during this term of employment at Susquehanna Station.
Each employee had an individual notebook with each procedure and OJT requirement constituting a page.
Returning employees had a large number of pages indicating that the requirement had been completed during prior employment at the station.
There was no reference or indication when this had occurred and it was difficultto determine what traiiiing had actually been provided during the current term of employment.
The licensee agreed to review the current HPT qualification documentation practice in order to streamline these records.
5.0 Audits and As e ment The inspectors reviewed the latest audit conducted by the licensee of the radiological controls program.
Audit No.93-111 was conducted on August 2 through September 20, 1993 by a team of three auditors and resulted in three findings. Allof three findings were of low safety significance and commitments for closing the findings had been made.
The audit assessed the performance of in-plant work practices and procedural adherence as very good.
The licensee also indicated significant improvements in radiological posting There were approximately 20 quality assurance surveillances conducted between January 1, 1992 and September 1, 1993. A wide range of health physics activities were observed including:
spent resin transfer operations, HP coverage of valve repacking, decontamination of equipment, operations at the Unit 2 radiological controlled area (RCA) access control point, HP instrument calibration status, respirator issue controls, attendance at HP shift turnover meetings and monthly Station ALARACommittee (SAC) meetings, review of radiation work permit (RWP)
packages, and personnel exposure data review.
The surveillances were of excellent scope, but did not contribute many insights or ideas for program improvement.
6.0 Si nificant erational Occurrence Re rts S
Rs The inspectors reviewed the licensee-identified radiological event reports since the last inspection of this area, Approximately 14 radiological events were documented between September 1992 and November 1, 1993.
The events included:
water spillage during a local leak rate test causing three workers to become contaminated; bead resin detected in the reactor cavity during decon; a recombiner room filled with steam from leaking valves; a floor drain in a radwaste sample station room backed up; while depressurizing the off-gas system to repair a valve, one worker was contaminated; radioactive material delivery vehicles were not initiallysurveyed prior to release from the station (twice), although the requirement was subsequently met; the Unit-1 fuel pool hold pump room door was not posted as a radiation area, although the larger reactor building area was posted as a radiation area; a radwaste container was overfilled and contaminated the top of the container during radwaste transfer activities; source inventory of area radiation monitors indicated only one 1.2 pCi Sr-90 source per detector when some contained two, although all controls were met; aild a local power range monitor was removed from the reactor and was not bent in the middle, resulting in a brief elevated dose rate. condition on the refuel floor as the monitor was being moved; and one instance of a slightly late issuance of a termination exposure report to an individual which was corrected by improving the computer software controls.
The above events were of minor safety significance and were well identified and resolved by the licensee.
There were two other radiological events that are discussed in greater detail belo On April 1, 1993, the Unit-1 "C" feedwater heater room was found to be unlocked and was not posted as a high radiation area as required.
This room is normally locked and posted whenever the plant is operating.
During the previous day, the radioactive steam supply was isolated from the Unit-1 feedwater heater room in order to support valve repair activities.
Once the radioactive steam supply was isolated the area was no longer a high radiation area and the room was unlocked and de-posted to effect repairs.
Once the valve repairs were completed, operations reestablished steam supply to the feedwater heater with general area radiation levels climbing back up to 400-500 mrem/hr, which constituted a high radiation area.
The door to the room remained unlocked and unposted for approximately five hours until the deficiency was discovered, Technical Specification 6.12.1 states in part, that each high radiation area shall be barricaded and conspicuously posted as a high radiation area.
The unposted door constituted a violation of this technical specification.
The inspectors reviewed the criteria for the exercise of enforcement discretion as specified in 10 CFR 2, Appendix C.
The violation was an isolated event that was licensee-identified and there were on-going efforts being made to revise the applicable operations department procedures to require the reestablishment of HP controls prior to any operator action that may cause escalated radiological conditions.
In view of these actions, the licensee has met the conditions for a non-cited violation.
The final SOOR report to be discussed involved a November 1, 1993 event when a member of the health physics staff identified a high radiation area barricade (rope)
that was found down and the high radiation area posting was missing from the barricade.
The area was located on the 719-foot elevation of the Unit-1 reactor building next to the south control rod drive scram volume discharge header.
The accessible area contained piping systems with contact dose rates of 800 mrem/hr and general area dose rates of 200 mrem/hr, which constituted a high radiation area.
This is a violation of Technical Specification 6.12.1, which states that any area in which the intensity of radiation is greater than 100 mrem/hr but less than 1000 mrem/hr shall be barricaded and conspicuously posted as a high radiation area (NOV 50-387/93-21-01).
The licensee had initiated an event report, however, no long term corrective actions had been determined or implemented at the time of this inspection.
In general, the licensee has reported relatively few radiological events at this nuclear power. plant between September 1992 and November 1993.
The event reporting and corrective action program has been strong and effective in resolving most of the issues that have been identified.
7.0 In-Plant HP Job Covera e
In order to provide radiation measurement and control activities for individuals engaged in radiological work during the refueling and maintenance outage, the licensee increased the HP operations technician workforce from 40 to 105 (permanent
and temporary workers) and divided the work coverage responsibilities into satellite HP control points that were supervised by permanent station HP senior technicians with a staff composed of both permanent and contractor HP technicians.
7.1 HP Control Points The licensee established four HP control points located in the Unit-1 reactor building and two HP control points in the Unit-1 turbine building. The Unit-1 HP office provided the balance-of-plant work coverage responsibilities.
All areas were staffed continuously during the outage period.
The inspectors reviewed each of the HP control points, took independent radiation measurements in the principal work areas, reviewed radiological surveys, RWPs, and log book entries generated by each HP control point.
7.2 P~stin s
In general, the licensee has implemented an excellent work area posting program.
Areas of elevated general area dose rates were usually posted with a range of dose rate values.
Radiation source signs frequently were placed on the principal radiation source piping within work areas.
Lower dose waiting area signs were also used in most areas.
These posting conventions provided the worker with sufficient information to allow individuals to orient themselves radiologically and minimize their radiation doses while working in radiation areas of the plant.
The work area posting practices observed during this inspection were 'considered excellent.
7.3 diati n W rk Permit The inspectors reviewed a sampling of RWPs in use at each of the HP control points.
The RWPs have been completely reformatted and improved since September 1993.
Previously, the RWPs were pre-issued before radiological conditions were established and contained generic HP procedural requirements with very few specific requirements or controls.
The revised RWP now contains radiological condition information and radiological condition limits.
One page of the RWP is intended for the worker's review and a second page is intended to provide instructions to the HP technician.
Provision was made for an RWP log for recording appropriate waivers from RWP requirements.
Appropriate rules were established for changing RWP requirements via the RWP log.
Increased RWP controls may be authorized by any qualified HP technician.
Decreasing the RWP controls required the approval by HP supervision, and this approval must be documented in the RWP log. Frequent
departures from RWP requirements would result in revision of the RWP or cancellation of the RWP.
The RWPs generally were well written. Most contained a very good level of work control specificity. For example, individual jobs were often divided into five or six sub-tasks listing different protective clothing dress requirements for each.
Also, the HP technician page indicated radiological condition limits that bounded the applicability of the RWP for each sub-task covered by the RWP.
The HP technician page also specified several job coverage instructions on most RWPs.
An area for potential improvement includes segregation of portions of the RWP for ALARAspecialist input and other areas for HP
'perations input commensurate with their respective responsibilities.
Currently, some RWPs were written almost entirely by the ALARAgroup, while others were written almost entirely by the HP operations group.
One area on the majority of the RWPs reviewed by the inspectors that was not well identified was the HP coverage requirement.
The majority of the RWPs that were reviewed specified "intermittent" HP coverage for the work activity.
The RWP procedure, HP-TP-320, Rev. 10, defined intermittent as periodic surveillance by an HP'technician according to the frequency specified on the RWP.
The RWPs only indicated "intermittent" without further clarification of the surveillance frequency.
This is an area for further enhancement.
The inspectors verified that the current RWP procedure change reflects the new program and also verified that the HP Level IItraining for radiation workers also contained training on the new RWP format and its use.
The new RWP program has been greatly improved and is now viewed as an HP program strength.
7.4 Other bservati n
The licensee has significantly improved the RWP contmls.
HP technician training is adequate.
Control point specific, on-the-job training is also adequate.
Control point log books, which have served to communicate the activities and radiological decisions affecting workers in radiological areas to HP supervision and for turnover between shifts, have not appeared to be used with any consistent approach and were very often devoid of radiological information.
Also, air samples were collected by the HP control point staff and final air sample results are filed in the ALARAoffice. High activity air sample results were telephoned to the respective control points; however, lower air activity results were not, Thus, reference to all air sample data was not possible at the control points so trending and the review of past air samples at those locations (for the prediction of future work air activity) was not viable.
Since the responsible HP technician must often make a judgement call on when to require respiratory protection, the availability of past air sample
results would allow a higher confidence level in making these decisions.
Another observation involved the lack of RWP collective exposure information at the control points.
The control point HP technicians are directly responsible for RWPs issued for their work area.
They can prioritize HP job coverage efforts better ifthey are aware of the current exposure status of each RWP in their area of responsibility.
Currently this information is only available to the ALARAspecialists and higher level HP supervision.
7.5 HP Initiative - Benchmarkin The licensee has made a significant effort to self-evaluate the HP operations program during the past year.
The licensee utilized the A T 8c T Benchmarking Process as a methodology to help focus efforts to benchmark the licensee's HP operations program against six "top" nuclear power plant performers in the HP operations program area.
After the data were collected, the licensee analyzed the data using "the Xerox method" as authored by Robert C. Camp in "Benchmarking, the Search for Industry Best Practices that Lead to Superior Performance".
The benchmarking team consisted of three HP technicians, three HP first-line supervisors, and the Radiological Operations Supervisor as the team leader.
The scope of the benchmarking effort included the following eleven topics:
RWPs, staffing, work group interface, ~~,
technology, radiological worker practices, job coverage, management involvement, work flow and job planning, access controls, and radiological surveys.
The six plants visited included:
Hope Creek, Grand Gulf, St. Lucie, San Onofre, Beaver Valley, and V.C. Summer.
Each plant was visited by the entire team for 2-3 days and all plant visits were completed by the end of August 1993.
The final results of these visits have been drafted, however the final report had not been issued at the time of this inspection.
Through discussions with the licensee, the inspectors determined that the effort was successful in determining many areas for improving the performance of the SSES HP Operations program.
Approximately 78 ideas were recommended for implementation that were solely within the purview of the HP organization and involve minimal budgetary impact.
Another 40 recommendations required the cooperation of other station organizations and/or required certain budgetary commitments.
Since the benchmarking team completed the six site visits, some ideas have been implemented, however, most have not.
Progress in this area willbe followed in future HP inspections at this station.
The undertaking of this benchmarking effort reflects the licensee's desire to be an industry leader in this area and is commendabl.0
As Low As is Regs na l Achievable ALARA 8.1 Status The annual station collective personnel exposure for 1993 through the end of October was 275 person-rem, as compared to a station goal of 354 person-rem.
The Unit-1 outage had accumulated 183 person-rem versus an outage ALARAgoal of 233 person-rem.
The highest individual exposure was 1604 mrem for 1993 through November 3, 1993.
The annual collective internal exposure for 1993 through October 31st was 41.7 MPC-hours, with the maximum exposure to an individual of 8.8 MPC-hours. Allparameters indicate very good performance in overall station exposure results. It is commendable that the licensee has set a station annual exposure goal of 300 person-rem per year (150 person-rem per unit) to be achieved by the year 1998.
8.2 The inspectors reviewed the current ALARAprocedure framework and breadth of ALARAprogram development commensurate with station requirements.
The ALARAProgram and Policy, NDAP-00-1191, Rev. 1, describes the licensee's commitment to the ALARAphilosophy through all levels of the organization including corporate nuclear modifications and radiological services groups, and the on-site systems engineering and health physics groups.
Station ALARAgoals and issues are discussed in monthly Station~~ Committee (SAC) meetings, which are attended by zepresentatives of each station department and chaired by the manager of nuclear maintenance.
The initial ALARAaction level requires an ALARAreview forjobs estimated at >
person-rem and, with either high radiation dose rates or with effective dose rates > 5 mrem/hr.
ALARAreviews are also required forjobs estimated at > 5 person-rem.
A second tier of pre-job review is provided by the SAC ifa job is estimated to be >
10 person-rem.
Procedures indicate that in-progress reviews should be performed by the work group supervisor when the job estimate reaches 50% of completion.
Post-job reviews ze required for actual results of > 5 person-rem; >
1 person-rem and, with either an effective dose rate of > 5 mrem/hr or with actual exposures exceeding 125% of the dose estimate.
Post-job reviews are further reviewed by the SAC for those jobs that exceeded 10 person-rem.
These action levels appear to be at a relatively low threshold and to be reasonable for this station.
The "Shielding Installation and Removal" procedure, NDAP-QA-0404, Rev. 0, describes the station process for requesting shielding, systems engineering evaluation and approval, and shielding installation and removal activities.
There is a resource budgetary check in the shielding request process provided by the planning group to
reevaluate the need for shielding ifthe resource allocation becomes excessive.
The procedure allows for consideration of permanent shield modifications by the ALARA specialist using a minor modification candidate (MMC) form and submitting the request through systems engineering, civil group, for prioritization and evaluation.
The procedure directs the HP ALARAgroup to determine what kind of shield (shield design) and how much shielding is required.
The systems engineering group is tasked with the evaluation of system weight loading considerations.
As willbe noted in a later section of this report, the licensee has progressed in some shielding packages (the drywell) to where the shield design has become complex and could profit from appropriate engineering design evaluation.
The current narrowness of the procedure scope in this area could be improved and developed to place shield design responsibility in the engineering group, when appropriate.
The inspectors also reviewed applicable station planning and scheduling procedures to determine the availability of information in order to allow for appropriate ALARA planning to occur.
The inspectors interviewed licensee scheduling personnel and reviewed the followingprocedures.
"Conduct of Plant Scheduling", NDAP-00-0610, Rev. 0
"Outage Planning", NDAP-00-0611, Rev. 0
"Outage Scope and Schedule Development and Control", NDAP-00-0612, Rev.
"Planning and Scheduling", HP-HI-049, Rev. 4 Although preliminary milestone schedules are developed approximately one and one-half years prior to a scheduled refueling and maintenance outage, the final detailed outage site plan is normally issued three months prior to an outage.
This site plan incorporates the detailed scheduling provided by the various maintenance functional group schedulers.
Allplanned work activities are incorporated and each is described with a specific building and elevation location, Allscheduled work activities located in the RCA are screened by the HP organization for RWP and ALARAreview requirements.
The ALARAreviews are based on individual work tasks and the potential dose savings value is applied on a,job by job basis.
Very often multiple jobs occur in the same work area.
The ~@A review for all jobs during an outage occurring in a particular work area often result in a more significant dose estimate and potential dose savings than when approached on an individualjob basis.
For example, work scheduled inside the drywell represents approximately 60% of all outage exposures and occurs in a small area of the plant.
Currently, the licensee does not evaluate potential dose savings in this fashion, The ALd~ group is not provided enough information to determine the estimated dose value of plant areas.
Although the site plan does provide detailed information of each work task, which includes location by building and elevation, it is not normally specific enough to allow a computer sort of discrete areas for ALARApurposes.
The Project/2 scheduling program does provide a location code identification and this room code can be used to
further define the location. In some cases the room code is very broad and general.
For example, Room A26 includes a portion of the refueling floor, all of the primary containment, the outboard main steam isolation valves, and the suppression pool.
Further definition of plant locations and clarification of scheduling requirements necessary to fulfillthe ALARAgroup input requirements from the various scheduling groups could improve the basis for ALARAactions with a better understanding of where personnel exposures are being planned.
Other benefits of better definition of work location and sorting of work location include: establishing tool and equipment common requirements by plant area, establishing contamination lay-down area requirements to accommodate all work scheduled in an area, and scaffold resources, to name a few. The licensee indicated that the current plant system could easily be used to provide the location code information and agreed to review this approach.
8.3 h'i I in The licensee has applied dose reduction techniques through the removal of radioactive deposits inside of piping systems and drains by flushing the applicable systems and through the use of temporary shielding of applicable radiation sources in work areas.
The foHowing six drain lines, two valves, and four pumps were flushed during the outage with the resulting dose reduction factors.
A Recirc Drain B Recirc Drain RPV Bottom Head Drain 31A Drain Line RHR 50B Drain Line Reactor Water Sample RHR 151095 Valve RHR 151096 Valve RHR A Pump RHR C Pump RHR D Pump
7 2.5
12
5
4
6 The flushing program appeared to be very successful and other areas for routine flushing were being actively pursued to include flushing of reactor vessel nozzles in support of in-service inspection /ST of the nozzle welds.
Implementation of the temporary shielding program was reviewed by the inspectors.
Most of the temporary shielding program was focused on the drywell, since the licensee was able to sort drywell RWPs and it was established that 60% of the estimated outage exposure would be spent in this area.
Therefore appreciable
ALARAshielding resources were devoted to this area.
The inspectors made independent dose rate evaluations of drywell shielding and concluded that overall drywell shielding efforts were commendable.
The inspectors noted that improvements could be made in the design of the shield packages installed at the recirculation suction and discharge piping on the 719-foot elevation, and at the reactor water clean-up line on the 738-foot elevation of the drywell.
Approximately 45,700 pounds of lead shielding were used in the Unit-1 drywell this outage, compared to 39,000 pounds of lead during the last Unit-I outage.
The recirculation piping system was fairly well covered with lead blankets for the main work elevations in the dryweH.
The inspectors made independent dose rate evaluations of the shielding and determined that there was some fine tuning needed of the shielding associated with the recirculation suction and discharge pipes for the 719-foot elevation, and a reactor water clean-up line on the 738-foot elevation, 45-degree azimuth was only partially shielded.
Also on the 738-foot elevation, the N2 riser shields were positioned appropriately for shielding workers at the platform grating elevation, however, for workers engaged on maintenance of the main steam relief valves, which were located approximately three feet above the grating level, the N2 riser shielding was too low to properly shield this work. The licensee experimented with shielding only one of the recirculation loops on the 704-foot elevation and achieved a reasonable dose reduction.
The licensee indicated plans to shield both recirculation loops during future outages.
Aside from the few detailed areas discussed, the overall drywell shielding effort appeared to be a good comprehensive effort. There were few common work areas with elevated dose rates.
The licensee indicated plans to concentrate efforts on simplifying the shielding installation and removal operation in the future.
9.D
~iM The inspectors met with licensee representative at the conclusion of this inspection, on November 12, 1993.
The inspectors reviewed the inspection findings and the licensee acknowledged the results.