IR 05000387/1995010
| ML17158A678 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/15/1995 |
| From: | Bores R, Randolph Ragland NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158A677 | List: |
| References | |
| 50-387-95-10, 50-388-95-10, NUDOCS 9505240129 | |
| Download: ML17158A678 (11) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
License Nos.
Licensee:
50-387/95-10; 50-388/95-10 NPF-14; NPF-22 Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name:
Susquehanna Steam Electric Station, Units
& 2 Inspection At:
Berwick, Pennsylvania Inspection Conducted:
April 10 - 14, 1995 Inspector:
Approved by:
R.
C.
ag nd, J., Radiation Specialist
&
Dr.
J.
Bo
, Chief Facilities Radiation Protection Section At'eas Inspected:
Announced inspection of the radiological controls implemented during the Unit 1 refueling outage.
Areas reviewed included audits and appraisals, changes to organization and facilities, training and qualifications, planning and preparation, external exposure control, internal exposure control, control of radioactive materials and contamination, and surveys and monitoring.
In addition, the licensee's response to NRC Violation 50-387/94-24-01 and 50-388/94-25-01 was reviewed.
Results:
Results of the inspection revealed overall very good performance.
Audits and appraisals were being performed to identify weaknesses and make corrective actions; training and qualifications of contract health physics technicians were verified and noted as very good; radiological controls were well planned and effectively implemented; methods for assigning internal dose followed regulatory guidance; and radioactive materials and contamination were well controlled.
Notable items included the extensive use of shielding in the drywell, reactor vessel nozzle flushing for in-service-inspections, and very good implementation of real time dose monitoring.
One weakness with respect to the assignment of responsibility for the performance of receipt of radioactive material surveys was identified.
This item will be reviewed during the next inspection.
(See Section 10.1)
With respect to the review of the response to NRC Violation Nos. 50-387/94-24-
and 50-388/94-25-01 (Failure to provide an employer certification that individuals responsible for certifying the adequacy of radioactive materials shipments were trained in accordance with 49 CFR 172 Subpart HTraining), the corrective actions implemented adequately addressed the violations and identified weaknesses.
No violations of NRC requirements were identified during this inspection period.9505240l29 9505i5 PDR ADOCK 05000387 IS PDR
DETAILS 1. 0 INDIVIDUALS CONTACTED 1.1 PRINCIPAL LICENSEE EMPLOYEES
- K. Chambliss, Manager, Nuclear Operations T. Dalpiaz, Manager, Nuclear Maintenance
- J. Doxsey, Supervisor, Effluents Management
- D; Hagan, Health Physics Supervisor P. Jager, Supervisor, Effluents Management J. Jessick, Health Physicist, ALARA & Operations Support
- G. Kuczynski, Nuclear Plant Services Manager J.
Lex, Training Supervisor C. Lewis, Health Physicist, Effluents Management C. Madara, Assistant Foreman, Health Physics E. McIlvaine, Health Physics, ALARA
- W. Morrissey, Supervisor, Radiological Operations R. Prego, Supervisor, Surveillance Services R. Sutliff, Assistant Foreman, Health Physics
- G. Stanley, Vice President, Nuclear Operations
- R. Wehry, Nuclear Compliance 1.2 NRC EMPLOYEES M. Banerjee, Senior Resident Inspector
- B. McDermott, Resident Inspector
Denotes attendance at the exit meeting on April 14, 1995.
The inspector also contacted other licensee personnel during the course of the inspection.
2.0 PURPOSE The purpose of the inspection was to review the implementation of radiological controls for the Unit 1 refueling outage.
Functional areas inspected included the following:
actions on previous findings audits and appraisals changes to organization and facilities training and qualifications planning and preparation external exposure controls internal exposure controls control of radioactive materials and contamination, and surveys and monitoring station tours
3.0 ACTI NS ON PREVIOU INSPE TION FINDINGS (Closed, NRC Violation Nos.
VIO 50-387/94-24-01 and VIO 50-388/94-25-01)
The inspector reviewed the licensee's response to notice of violation (NOV) 50-387/94-24-01 and 50-388/94-25-01 (Failure to provide an employer certification that individuals responsible for certifying the adequacy of radioactive materials shipments were trained in accordance with 49 CFR 172 Subpart H - Training)
and other weaknesses identified in NRC Combined Inspection Report Nos. 50-387/94-24 (Item 01)
and 50-388/94-25 (Item 01).
Corrective actions included the following:
Criteria to evaluate and certify the adequacy of training with respect to 49 CFR 172.700 Subpart H - Training, were developed and documented in Nuclear Training Procedure NTP-(A-42.6, "Effluents Management Training and Certification Programs" Nuclear Training Procedure NTP-RA-42.6, "Effluents Management Training and Certification Programs" was revised to incorporate the training and training program requirements of 49 CFR 172 HP-1001,
"Radwaste Shipping gualification" retraining requirements were revised to a two-year frequency for Radwaste Shippers, Health Physics Technician Shipping, and guality Assurance - Radwaste personnel HP-1001,
"Radwaste Shipping gualification" course, which was certified to meet the training requirements of 49 CFR 172.700 Subpart H-Training, was provided to personnel in Radwaste Shipping, Health Physics Technician Shipping, and guality Assurance - Radwaste, on January 19, 1995.
These actions were reviewed and verified and were found to be appropriate, timely and adequate to prevent recurrence.
This item is closed.
4.0 AUDIT AND APPRAISALS The inspector reviewed the performance of audits and appraisals for the health physics program.
The evaluation of the licensee's performance was based on a review of the following:
Station Review Committee (SRC)/Nuclear guality Assurance (NgA)
Audit of the Health Physics Program 94-068 (conducted to satisfy SSES Technical Specification Requirement 6.5.2.8.g)
Condition Reports pertaining to radiation protection issues (Condition Reports replaced Non Conformance Reports (NCRs),
Engineering Deficiency Reports (EDRs),
and Station Operating Occurrence Reports
{SOORs))
attendance at a Horning Meeting, a Prejob ALARA review, and a
Station ALARA Committee (SAC) meeting.
The inspector found that SRC/NgA Audit 94-068 probed for programmatic weaknesses, provided assessments of program elements, and made recommendations for corrective actions.
Condition reports also
identified problems requiring corrective actions (e.g.,
procedures, process, or human performance),
and corrective actions were being implemented to specifically address these findings.
Finally, the inspector noted that various elements of the radiation protection program were routinely evaluated during station meetings, resulting in corrective actions.
The inspector concluded that licensee audits and appraisals of the health physics program were very good.
No safety concerns or violations of NRC requirements were identified.
5. 0 CHANGES TO ORGANIZATION AND FACILITIES There were no significant changes, since the last NRC inspection in this program area, in personnel, organization, or facilities that affected the licensee's program for controlling radiation exposures.
However, to support outage work, the licensee had augmented the health physics staff with approximately 107 vendor health physics technicians and clerical support personnel.
In addition, several experienced Level II Health Physics technicians were upgraded to Assistant Foreman to support the ALARA organization and to act as Control Point Leaders for outage work.
The inspector concluded that staffing levels were adequate for planned work and could be adjusted to accommodate changes in work schedule.
No safety concerns or violations of NRC requirements were identified.
6. 0 TRAININ AND ALIFI ATION The inspector performed a review of the training and qualification program provided for vendor health physics technicians at SSES.
The evaluation of the licensee's performance in this area was based on a
review of various lesson plans and training documents, discussions with cognizant personnel, and by a review of training records.
6.1 HEALTH PHYSICS TECHNICIAN LEVELS AND QUALIFICATIONS The licensee has the following three levels of health physics technicians.
Health Physics Technician Level I-2 Health Physics Technician Qualifications should have a minimum of six months related experience hi h school di lorna or e uivalent minimum of two years of related experience hi h school di lorna or e uivalent meets requirements of ANSI N3.1
~
1978 minimum of two years of varied radiological experience in a nuclear power plant or equivalent should have one year of technical related training including six months of radiolo ical rotection material
Level I-l Health Physics technicians perform duties such as the issuance of respirators and alarming dosimetry, data entry, contamination monitoring, and dose tracking.
Level I-2 Health Physics technicians perform duties such as routine radiological surveys, radiation work permit updates, controlled access area set-up, and radiological postings.
Level II Health Physics technicians perform duties such as job coverage activities, and act as control point leader.
The training and qualification program for these contractors consists of the following.
Screenin exam:
Individuals must pass a screening exam which tests knowledge of health physics fundamentals and practical in-plant job coverage activities.
Level I-2 technicians must receive a grade of 70X or greater, and Level II technicians must receive a grade of SOX or greater.
SSES Practices for Contractors:
This course consist of approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of classroom training including SSES procedures, industry events, and self checking.
Onsite uglification:
Health physics technicians are required to complete a standard set of job performance measures (JPMs).
These JPHs require demonstration of knowledge or performance and are evaluated by designated instructor/trainers or an Assistant Foreman.
General Control Point Trainin
Training is then provided on the requirements and expectations for performance while working at health physics control points.
Topics include surveys and documentation, radiation work permits, postings, instrument use, logbooks, air sampling, respirator control and issue, shift turnover, safety, communications, stop work authority, key control, and geperal information.
S ecific Control Point Trainin
As necessary, additional training is provided to technicians assigned to specific control points.
Examples include control rod drive (CRD)
activities, drywell control point, and controls for work on the refuel floor.
Additional instructions are provided to health physics technicians in Radiation Work Permits (RWPs),
and in As Low As is Reasonably Achievable (ALARA) reviews and briefing.2 6.3 REVIEW OF QUALIFICATION RECORDS The inspector performed a review of health physics technician qualification records to determine if work experience documented on resumes for Health Physics Level II technicians, met the requirements of ANSI N3. 1, 1978, and if the technicians had completed required JPHs, including instructor sign-offs.
The inspector randomly selected seven names from a list of 63 active Level II Health Physics technicians (i.e.,
>10% review).
The qual.ification manuals for these individuals were reviewed and evaluated.
gualification manuals were easily retrievable and well maintained.
In each case, documented work experience exceeded ANSI N3. 1, 1978 requirements, and required JPHs were completed by both the Level II technician and the Instructor/Trainer.
DISCUSSIONS WITH CONTROL POINT PERSONNEL The inspector interviewed various health physics control point personnel to evaluate knowledge of radiological control activities for the drywell, refueling floor, turbine building condenser bay, and turbine deck.
7.0 All of the individuals interviewed were knowledgeable of control point responsibilities, RWPs, radiologically significant work being covered by the control points, and of the outage work schedule.
The inspector concluded that the program for training vendor health physics technicians was very good and was noted as a program strength.
Training requirements and expectations for performance were well defined, qualification records were well maintained, and technician knowledge and efforts to inform and update technicians on current and planned work were also very good.
No violations of NRC requirements were identified.
PLANNING AND PREPARATION The inspector performed a review of licensee planning and preparation for outage work.
The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel and direct inspector observations.
The inspector made the following observations.
health physics technician staffing levels were sufficient to support outage work health physics control points were equipped with computer terminals that could access RWPs miscellaneous health physics supplies such as protective clothing, alarming dosimetry, temporary shielding, and radiological postings appeared adequate
ALARA planning for major jobs was very good including drywell in-service inspections, control rod drive work, and refuel floor activities including the "wet lift" system control point technicians were knowledgeable of the outage schedule health physics personnel were assigned to outage planning and maintenance for work order review Based on the above observations, planning and preparation to support the Unit I refueling outage were considered good.
No violations of NRC requirements were identified.
8.0 EXTERNAL EXPOSURE CONTROLS The inspector performed a review of external exposure controls including use of temporary shielding, reactor vessel nozzle hydrolasing, and radiological postings.
Since approximately 139 of the 200 man-rem outage dose goal (i.e.,
>69X of outage dose)
were expected to be accumulated as a result of drywell work, the inspector's review of external exposure controls concentrated on the controls implemented for drywell work.
The licensee's performance in this area was evaluated by a review of procedures and other documents, discussions with cognizant personnel, and direct observations by the inspector.
8.1 TEHPORARY SHIELDING The inspector toured the Unit 1 drywell and observed extensive use of temporary lead shielding.
Lead blankets were utilized in a variety of shielding designs to reduce job specific and general area dose rates.
Shield packages were very detailed, appeared to be very well planned, and were effective in reducing work area dose rates.
The licensee's use of shielding was noted as commendable and demonstrates a significant commitment to radiation exposure reduction.
No safety concerns or violations of NRC requirements were identified.
8,2 REACTOR VESSEL NOZZLE HYDROLASING Hydrolasing accumulated contamination from the thermal sleeves of reactor vessel nozzles is another method that was used to control and reduce dose rates in the drywell during the refueling outage.
Numerous groups benefitted from this ALARA measure including non-destructive examination (NDE) personnel, mechanical stress improvement program (HSIP) personnel, insulators, effluents shielding personnel, scaffolding personnel, and health physics personne The inspector reviewed results of reactor vessel nozzle hydrolasing for the recirculation discharge (N2) nozzles and reactor feedwater (N4)
nozzles.
Pre and post hydrolasing dose rates were documented for the top and bottom and the left and right sides of nozzle thermal sleeves.
Average dose rate reduction factors of approximately 2.0 and 3.6 were obtained for the N2 and N4 nozzles respectively.
These results and the effort put forth to control and reduce external dose were noted by the inspector as very good.
No deficiencies or violations of NRC requirements were identified.
8.3 DRYWELL POSTINGS The inspector reviewed the radiological postings that were used to inform and communicate radiological information to drywell workers.
This included the following.
large drywell maps, with "radiation sources" and "low dose rate areas" highlighted, were posted at the drywell entrance for worker briefings and review
"Radiation Source, Do Not Loiter" signs were posted within the drywell to alert personnel of radiation sources that might otherwise go unnoticed
"lower dose rate area" signs were posted in various areas to alert personnel of areas that could be used to minimize exposure 3-sided dose rate range signs were posted in various locations to inform personnel of general area dose rates high radiation area postings were locally posted at each high radiation area within the drywell high radiation area ribbon was also used as additional boundary rope for each high radiation area boundary The inspector noted that these postings were very effective in communicating radiological information.,
The inspector also commented that although the "high radiation area" ribbon used as additional high radiation area boundary markers was not very durable, it was extremely effective in delineating high radiation area boundaries and has the potential for preventing radiation work permit violations.
The licensee indicated that they were investigating purchasing more durable "high radiation area" ribbon.
No deficiencies or violations of NRC requirements were identified.
8.4 OUTAGE EXPOSURE PERFORMANCE Susquehanna Steam Electric Station (SSES)
had previously set an outage exposure goal of 200 person-rem.
As of 4/13/95, total outage exposure was approximately 133 person-rem (i.e.,
67X of goal).
The licensee felt that greater than 67 percent of work involving elevated radiation exposure had been completed.
However, the outage dose goal was at risk due, in part, to an increased scope of snubber work, higher than anticipated effective dose rates in the turbine building, and higher
9.0 than anticipated exposures were received on control rod drive (CRD)
shoot-out steel work, CRD exchanges, and during mechanical stress improvement and non-destructive examination activities.
Consequently, the licensee had conducted frequent ALARA meetings (ALARA summits) to assess current exposures and identify areas of concern including potential dose reduction applications.
The inspector noted that exposure performance for the outage had been generally good, the licensee was closely monitoring performance versus the outage goal, and the original dose goal was still achievable.
No deficiencies or violations of NRC requirements were identified.
INTERNAL EXPOSURE ONTR LS 9.1 The inspector performed a review of internal dose controls.
Areas reviewed included respirator usage and internal dose assessments.
RESPIRATOR USAGE 9.2 In previous NRC inspections, the licensee reported that respirator use had been reduced by the use of engineering controls and by eliminating unnecessary use of respirators.
As of April 13, 1995, only 134 respirators had been issued for radiological purposes.
No deficiencies or violations of NRC requirements were identified.
INTERNAL DOSE ASSESSMENTS The inspector performed a review of internal dose assessments to determine the following.
if internal dose assessments were performed in accordance with established procedural guidance if internal dose assessments were performed in accordance with regulatory guidance identified in NUREG/CR-4884, "Interpretation of Bioassay measurements" if significant increases in internal dose assignments had occurred as a result of decreased reliance on respiratory protection The inspector reviewed the following licensee procedure and technical basis document.
HP-TP-223,
"Internal Dose Investigations and Evaluations",
Rev.
Health Physics Technical Basis94-005,
CFR 20, Dose Assessment and Tracking, 02/09/94 HP-TP-223,
"Internal Dose Investigations and Evaluations" provided the primary method used for assessing internal doses from bioassay data.
This procedure provided "investigation levels" and forms for calculating
internal dose.
Supporting documentation and guidance were contained in Health Physics Technical Basis94-005,
"Dose Assessment and Tracking".
These documents were found to follow guidance included in NUREG/CR-4884.
The inspector then reviewed the internal exposure evaluations that had been performed during the outage.
The licensee reported that
investigation body counts had been performed in response to established thresholds (i.e., personnel contamination, air sampling data, or estimated derived air concentration hour accumulation).
Six of the
investigation body counts warranted an exposure evaluation.
Although final internal dose assessments had not been completed for these individuals, all internal dose assignments were expected to be less than one percent of the allowable level of intake (ALI).
The inspector then compared the available documentation of the internal dose assessments to licensee procedures and regulatory guidance.
The licensee's preliminary dose assessments for the outage were performed in accordance with HP-TP-223,
"Internal Dose Investigations and Evaluations".
Based on this information, the inspector concluded that management-approved procedures for internal dose assessments were provided and included very good instructions, the internal dose assessments that were performed followed established procedures and regulatory guidance, and the licensee was effectively minimizing internal exposures.
No deficiencies or violations of NRC requirements were identified.
ONTROL F RADIOA TIVE MATERIA AND NTAMINATI N URVEY AND MONIT RIN The inspector performed a review of the control of radioactive materials and contamination, surveys and monitoring.
The inspector evaluated.
licensee performance in this area by a review of procedures and other documents, discussions with cognizant personnel, and by direct observations.
The inspector noted that access to high radiation areas was well controlled.
Administrative and procedural controls were effective in controlling access to high radiation areas.
Doors that were required to be locked were found locked when not in use, and areas were posted and barricaded properly.
Radiological surveys were reviewed at the drywell, refuel floor, condenser bay, and turbine deck control points.
The quality and documentation of radiological surveys were noted as very good.
During plant tours, the inspector observed personnel working within designated contaminated areas.
The inspector observed one individual inadvertently stepping across a contaminated-clean area boundary.
The inspector noted that a health physics technician also observed this occurrence and took immediate corrective actions.
The technician
restricted access, performed contamination surveys, and decontaminated the affected area.
The inspector found these actions to be appropriate and noted that contamination controls were good.
10.1 RECEIPT OF RADIOACTIVE HATERIAL SURVEYS One weakness with respect to the assignment of responsibility for the performance of receipt of radioactive material surveys was identified.
Responsibility for the performance of radiological surveys for the receipt of radioactive sources or material was assigned to different groups in the following procedures.
NDAP-(A-0648, "Shipping/Receiving of Radioactive Haterial" NDAP-00-0621,
"Control of Sources" HP-TP-650,
"Surveys for Receipt and Shipment of Radioactive Haterial" This raises the concern that a radioactive material package with significant dose rates could be received on site, and not surveyed in a timely manner due to the apparent confusion in the assignment of responsibility for the performance of receipt of radioactive material surveys.
This area was being reviewed by the licensee for corrective actions during the week-of the inspection.
This item will be reviewed during the next inspection.
ll.D
~PUWT TOUR The inspector conducted plant tours in the Unit 1 and Unit 2 reactor buildings, and Unit 1 turbine building.
Radiological postings were informative and radiologically controlled boundaries were well defined.
Walkways were uncluttered and areas were well illuminated.
The inspector did point out one industrial safety concern to the licensee.
Two compressed gas cylinders, used in welding, that were not in use, were observed in,the plant without valve protection caps.
Upon notification, the licensee installed valve protection caps on the cylinders.
No violations of NRC requirements were identified.
12. 0 EXIT HEETING The inspector met with licensee representatives denoted in Section 1.0 at the conclusion of the inspection on April 14, 1995.
The inspector summarized the purpose, scope and findings of the inspection.
The licensee acknowledged the inspection findings.