IR 05000387/1995015
| ML17158A755 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/03/1995 |
| From: | Bores R, Randolph Ragland NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158A754 | List: |
| References | |
| 50-387-95-15, 50-388-95-15, NUDOCS 9507100397 | |
| Download: ML17158A755 (11) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
License Nos.
Licensee:
50-387/95-15 and 50-388/95-15 NPF-14 and NPF-22 Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name: 'usquehanna Steam Electric Station (SSES),
Units 1 5
Inspection At:
Salem Township, Pennsylvania Inspection Conducted:
J ne 12 - 15, 1995 Inspector:
R.
C.
Ra 1 nd, Jr.,
Radiation Specialist Approved by:
Dr.
R. J.
res, Chief Facilities Radiation Protection Section Areas Inspected:
Announced inspection of the radiological controls program.
Areas inspected included external dose monitoring; control of contamination; temporary shielding criteria; ALARA performance for the unit 1 eighth refueling outage; station tours; and a review of NRC unresolved item URI 50-387/92-29-04,
"Contamination Event on the B Auxiliary Boiler", and NRC unresolved item URI 50-387/91-10-01,
"Cement Silo Building Contamination Event".
The inspector also reviewed corrective actions that were put in place in response to the August 30, 1994, condenser demineralizer resin regeneration (CDRR) room event, and corrective actions put in place to address a weakness with respect to receipt of radioactive material surveys identified in NRC Combined Inspection Report Nos. 50-387/95-10 and 50-388/95-10.
Results:
The inspection revealed effective programs for external dose monitoring and control of contamination.
Adequate guidance was provided for the use of temporary shielding and very good ALARA performance was noted for the Unit 1 eighth refueling outage.
Two unresolved items were reviewed during this inspection and have been closed.
These were NRC unresolved item Nos.
URI 50-387/92-29-04 and URI 50-387/91-10-01.
The corrective actions that were put in place in response to the August 30, 1994, CDRR room event,,and corrective actions put in place to address a weakness with respect to receipt of radioactive material surveys identified in NRC Combined Inspection Report Nos. 50-387/95-10 and 50-388/95-10 were noted as very good.
No safety concerns or violations of regulatory requirements were observed during this inspection.
'F507100397 950703 PDR ADOCK 05000387
DETAILS 1.0 INDIVIDUALS CONTACTED PRINCIPAL LICENSEE EMPLOYEES 1.2 K. Chambliss, Manager, Nuclear Operations
- T. Dalpiaz, Manager, Nuclear Maintenance
- D. Hagan, Health Physics Supervisor D. Gardenberger, Supervisor, Maintenance Production Services J. Jessick, Health Physicist, ALARA tt Operations Support
- R. Kichune, Project Licensing Specialist R. Kessler, Health Physicist
- G. Kuczynski, Nuclear Plant Services Manager W. Horrissey, Supervisor, Radiological Operations
- G. Stanley, Vice President, Nuclear Operations
- R. Wehry, Project Engineer, Licensing NRC EMPLOYEES 2.0 B. HcDermott, Resident Inspector
- H. Banerjee, Senior Resident Inspector
Denotes attendance at the exit meeting on June 15, 1995.
The inspector also contacted other licensee personnel during the course of the inspection.
PURPOSE The purpose of the inspection was to review the licensee's radiological controls program.
Functional areas inspected included the following.
actions on previous findings external dose monitoring control of contamination and monitoring temporary shielding criteria ALARA results for the Unit 1 eighth refueling outage station tours 3.0 3.1 ACTIONS ON PREVIOUS INSPECTION FINDINGS NRC UNRESOLVED ITEM 50-387/92-29-04, CONTAMINATION EVENT ON THE B AUXILIARYBOILER
.
(Closed)
NRC Unresolved Item URI 50-387/92-29-04 The inspector reviewed the licensee's response to NRC unresolved item URI 50-387/92-29-04,
"Contamination event on the B Auxiliary Boiler".
The item was originally identified in NRC Combined Inspection Report Nos. 50-387/92-29
& 50-388/92-29 (pages 8 and 9).
The cause of the auxiliary boiler contamination was leakage of Unit 1 main steam past motor operated valve HV10752 and check valve 107027.
Hain steam that passed these two valves, condensed at a steam trap which discharged to
the auxiliary boiler deaerator.
Although this event had minimum safety consequences and no violations were identified, an unresolved item was opened to ensure that lasting corrective actions were implemented.
Corrective actions have been completed and they include the following.
Operating Procedure OP-172/272-001 was revised to close manual valve 107077/207077 except when auxiliary steam is required to supply the steam jet air ejectors (SJAE).
Valves HV10752, 107027 (check valve),
and steam trap ST10701 were inspected and repaired as necessary.
A plant modification was performed to re-route the condensate from steam trap ST10702 from the auxiliary boiler deaerator, to the Unit 1 condenser.
These corrective actions appear adequate to prevent recurrence.
This item is closed.
3.2 NRC UNRESOLVED ITEM 50-387/91-10-01, CEMENT SILO BUILDING CONTAMINATION (Closed)
NRC'nresolved Item URI 50-387/91-10-01 On July 8, 1991, contamination was found in the cement silo building which is outside of the radiologically controlled area.
The cement silo building was part of a "retired" cement supply system designed to supply cement for radioactive waste solidification.
The building was normally locked and at the time of the incident had been out-of-service for five years.
The event resulted when a misaligned valve on the flushing line for the cement supply of the mixing pump opened when an electrical panel was temporarily energized.
This allowed water from the condensate transfer system to backup, eventually resulting'n contaminated water leaking onto the floor of the cement silo building.
The inspector noted that no offsite releases or violations of NRC requirements were identified with this event.
The licensee had previously reviewed this system with respect to NRC Bulletin 80-10,
"Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release to the Environment", in 1986 and classified the system as a Priority III system with two or more barriers between the contaminated system and the vented system, with a very low potential for release of radioactive material.
As a result of this event, the adequacy of the licensee's evaluation of potential unmonitored release pathways was questioned, and an unresolved item (URI 50-387/91-10-01)
was opened, pending corrective actions and the licensee's reevaluation of Priority III systems as unmonitored release pathways.
In response to this event, the licensee took the following actions.
An assessment of potential unmonitored release pathways at SSES was performed.
This included an additional
"NRC Bulletin 80-10" system review, and a review of effluent release pathways including Priority III system A modification was performed to remove the contaminated screw conveyors and to isolate the cement silo building from the radwaste solidification system.
A plant modification was performed that blanked off the flowpath between the condensate storage tank (CST)
berm and the storm drain system.
The Offsite Dose Calculation Manual (ODCM) was revised to allow effluent pathways to be classified into categories based upon the potential for effluent release.
NDAP-QA-0727, "Safety Evaluations",
was revised to include an evaluation for unmonitored release pathways.
Training was developed for individuals likely to perform safety reviews using NDAP-QA-0727.
This training is scheduled to be performed in the July 1995 time frame.
The inspector noted that the licensee's review of unmonitored release pathways was very thorough; all plant systems were reviewed with respect to the potential for unmonitored releases, plant modifications were performed as appropriate, procedures and guidance documents were revised as necessary, and training sufficient to implement the associated changes was developed and is scheduled to be performed during the July 1995 time frame.
These corrective actions should prevent recurrence of the cement silo contamination event and adequately address the identified concerns.
This item is closed.
3.3 NRC REQUEST FOR RESPONSE TO THE AUGUST 30, 1994 UNIT 2 CONDENSER DEMINERALIZER RESIN REGENERATION '(CDRR)
ROOM EVENT (Closed)
NRC Review of the August 30, 1994 Unit 2 condenser demineralizer resin regeneration (CDRR)
room event identified in NRC Combined Inspection Report Nos.
50-387/94-21 and 50-388/94-22.
On August 30, 1994, a resin transfer evolution was started in the Unit 2 CDRR room while several workers occupied the room.
The operator performing the transfer recognized the potential for an unplanned exposure and notified the workers in the room.
At the same time, a
health physics (HP) technician who was monitoring the workers also recognized the potential for an unplanned exposure and instructed the workers to leave the area.
While no regulatory requirements were violated, and corrective actions had been initiated at the time of the inspection, the lack of procedural controls to prevent such occurrences raised a safety concern.
Consequently, the NRC requested the licensee to perform a thorough review to assure that similar procedural weaknesses did not exist elsewhere in the station, and to respond to the NRC in a letter that summarized the actions completed and planned to address this safety concern.
The licensee's review of this event, and corrective actions to address NRC concerns have been completed.
Licensee actions included the following.
The event was entered into the Human Performance Enhancement System (HPES) for review and evaluation (HPES94-012).
A Root Cause Analysis (RCA) was performed and an Event Review Team (ERT) was established to perform a broad management assessment of radiological implications.
A letter dated November 28, 1994, was sent from R.
G.
Byram to the NRC which responded to the NRC request for information.
This letter identified the need to review and revise procedures that control operational occurrences that may change radiological conditions at the station, and the need for the development of training for operations and health physics personnel to increase awareness of these evolutions and associated responses to them.
Additional operating procedures were revised to require notifications of health physics personnel during certain operational evolutions.
Operations personnel received training on procedure changes and interfaces with health physics personnel.
Procedural health physics notifications were incorporated into routine operator simulator training.
Health physics instruction HP-HI-073, "Notifications of Plant Evolutions and Expected HP Actions", was developed to provide guidance on actions to take upon notification that certain plant/system evolutions are in progress or about to begin.
Upgrades were made to the health physics work planning process.
The inspector noted that the licensee's response to this event was excellent.
Corrective actions appear sufficient to prevent recurrence and significantly enhance the ability to identify and adequately control evolutions that can change radiological conditions.
The NRC review of this event is closed.
3.4 RECEIPT OF RADIOACTIVE MATERIAL SURVEYS (Closed)
NRC Review of a weakness with respect to receipt of radioactive material surveys identified in NRC Combined Inspection Report Nos.
50-387/95-10 and 50-388/95-10.
A weakness with respect to the assignment of responsibility for the performance of receipt of radioactive material surveys was identified in NRC Combined Inspection Report Nos. 50-387/95-10 and 50-388/95-10.
Responsibility for the performance of radiological surveys for the receipt of radioactive sources or material was assigned to different groups in three different procedures.
This raised 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 an apparent confusion in the assignment of responsibility for the performance of surveys of receipt of radioactive material.
The licensee addressed this concern by taking the following actions.
Related procedures were revised to designate the health physics-operations group as a single point of contact for radioactive material receipt survey Related procedures were revised to assign the health physics-operations group responsibility for the performance of receipt of radioactive material surveys at the warehouse.
Training was provided to health physics personnel on regulatory and procedural requirements and expectations for performance of receipt of radioactive material surveys.
The inspector noted that these actions were prompt and adequately addressed the inspector's concern.
The follow-up review of this item is closed.
4. 0 EXTERNAL DOSE MONITORIN A review was performed of external dose monitoring.
Areas evaluated included procedures, National Voluntary Laboratory Accreditation Program (NVLAP) accreditation for personnel dosimetry, quality control, and use of digital alarming dosimetry.
4.1 PROCEDURES Administrative procedures were reviewed to determine if clear guidance was provided for radiation exposure monitoring, radiation exposure record keeping and reporting, and external dose investigations and evaluations.
Licensee performance in this area was evaluated by interviews and discussions with cognizant personnel, a review of personnel exposure reports, and by a review of the following procedures.
NDAP-00-0625, Personnel Radiation Exposure Monitoring Program HP-TP-221, External Dose Investigations and Evaluations HP-TP-222, Special Dosimetry Issuance and Criteria HP-TP-217, Recordkeeping and Reporting of Occupational Radiation Exposure HP-TP-510, Survey and Dose Calculation Techniques for Radioactive Contamination of the Skin or Clothing HP-TP-511, Hot Particle Controls HP-TP-513, Noble Gas Monitoring Considerations The inspector found that very good procedural guidance was provided for the administration of the radiation exposure monitoring program.
Procedural guidance was clear and detailed, and individuals interviewed were knowledgeable of procedural requirements.
The inspector also noted that procedures were well maintained and controlled.
No deficiencies or violations of NRC requirements were identified.
4. 2 NVLAP ACCREDITATION The inspector 'performed a review to determine if the dosimetry laboratory utilized by the licensee to process radiation dosimetry held a current accreditation from the United States Department of Commerce, National Institute of Standards and Technology (HIST),
NVLAP; and if thedosimetry processing laboratory was accredited in accordance with
ANSI N13.11, "Criteria for Testing Personnel Dosimetry Performance",
test categories I through VIII.
Pennsylvania Power and Light Company maintains a radiation dosimetry processing laboratory at the corporate headquarters in Allentown, Pennsylvania.
The inspector reviewed a facsimile of the NVLAP Certificate of Accreditation for this laboratory.
The NVLAP Certificate of Accreditation was current and effective until April 1, 1996.
The NVLAP "Scope of Accreditation" certificate indicated that the laboratory was evaluated and deemed competent, and was accredited to process the Panasonic TLD model UD802-AT in a Panasonic UD874-AT-1 hanger for ANSI-N13.11 categories I through VIII.
The inspector also reviewed a
NVLAP "On-site Assessment Report" for the dosimetry processing laboratory in Allentown, Pennsylvania.
The assessment addressed the following areas.
organization, management, quality system, documentation staff competency, training facilities, equipment calibration, test methods, procedures records, test reports The NVLAP "On-site Assessment Report" revealed generally very good performance.
However, the report identified one deficiency.
NVLAP requires the dosimetry processing laboratory to have a separate quality manual that states the dosimetry processor's policies pertaining to dosimetry operations.
NVLAP acknowledged that existing procedures were a good start towards development of a quality manual.
NIST/NVLAP set a
date of July 15, 1995, for the completion of a Dosimetry Quality Manual and requested a response from PP&L.
PP&L was working toward achieving these results.
4.3 No violations of NRC requirements were identified.
QUALITY CONTROLS FOR PERSONNEL MONITORING BY THERMOLUMINESCENT DOSIMETERS (TLDs)
4.3.1 The inspector performed a review of quality controls used for personnel monitoring by TLDs.
This included a review of procedures, an evaluation of vendor TLD processing services, and a review of quality control checks performed for the dosimetry processing facility.
Procedure Review The following procedures were reviewed.
NDAP-00-0625, Personnel Radiation Exposure Monitoring Program HP-TP-211, Personnel Dosimetry Performance Testing HP-TP-296, Irradiation of TLDs
NDAP-00-0625 requires "blind" testing of dosimeter processing services to be conducted annually.
Station dosimetry personnel are required to choose appropriate TLD irradiations according to ANSI N13. 11 guidance, enter irradiated TLDs into the readout cycle, and ensure proper assessment of test results.
Procedure HP-TP-211 establishes performance testing of the dosimetry processing systems used by Pennsylvania Power and Light Company.
Procedure HP-TP-296 provides guidance for the irradiation of TLDs.
The procedures were noted as good.
No deficiencies or violations were identified.
4.3.2 Evaluation of Vendor TLD Processin Services The inspector reviewed an audit performed by the Health Physicist-Dosimetry, to evaluate vendor extremity dosimetry processing services.
The audit was entitled,
"Evaluation of THA/Eberline Extremity Dosimetry Processing Services",
and was dated August ll, 1993.
An evaluation check-off list was used and major topics for review included quality control, data processing, and records.
This review included quality control checks performed to evaluate vendor TLD processing services for accuracy and precision.
Extremity TLDs were sent to the SSES health physics-instrumentation group for gamma irradiation by cesium-137, and to the University of Michigan for beta irradiation by strontium/yttrium-90.
After irradiation of the TLDs to known values, these dosimeters were sent to THA/Eberline Extremity Dosimetry Services for processing.
The data were statistically evaluated using a tolerance level of 0.25, which is more restrictive than the values listed in ANSI 13. 11.
All of the results reviewed by the inspector met established performance criteria.
The inspector noted that the licensee had performed a very good evaluation of vendor TLD processing services.
No deficiencies or violations were identified.
4.3.3 ualit Control Checks The Susquehanna Steam Electric Station performs a semi-annual audit on the dosimetry processing facility by irradiating a group of TLDs at the University of Michigan using NVLAP criteria.
The TLDs are sent to the dosimetry processing laboratory where they are processed and the data are reported back to the plant.
Data and the results from this internal audit were discussed with cognizant licensee personnel.
No deficiencies or violations were identifie POCKET ALARMING DOSIMETERS 5.0 The inspector performed an inquiry to determine if any actions, besides general training, were being performed to ensure that station personnel understand and respond correctly to personnel alarming dosimetry.
The inspector was informed of two recent initiatives that addressed personnel response to alarming dosimeters.
The first initiative was a
"Radiological Safety Note" that received wide distribution within the licensee's organization on April 17, 1995.
This Radiological Safety Note addressed personnel response to alarming dosimetry, described radiation dose and dose rate alarms, and reminded personnel to "leave the area if any dosimeter alarm is received and contact Health Physics".
The second initiative was to equip alarming dosimetry with a microphone in order to amplify the audible alarm in noisy environments.
The throat microphone of an MSA CLEARCOM V personnel communication system was attached to tygon tubing with heat shrink tape.
The tygon tubing was then connected to the audible alarm output on the ALNOR RADOS-51 alarming dosimeter.
The Health Physics Instrumentation Supervisor demonstrated the alarm response.
The audible alarm was significantly amplified and could easily be heard in noi'sy environments.
The inspector noted that these initiatives were commendable.
CONTROL OF CONTAMINATION AND MONITORING A review was performed to determine if there were any areas that were made unusable by operational occurrences and of licensee actions that were taken to control and recover such areas.
The inspector was informed that no areas have been made unusable as a
result of operational occurrences.
However, the inspector was informed of a recent effort to control and recover an area that had repeatedly been contaminated with low activity contamination.
The Unit 1 turbine building 656-foot elevation had repeatedly become contaminated as a
result of floor drain back-ups caused by condensate demineralizer vessel fill and vent evolutions.
The inspector was informed that a design change plan modification scoping review had been initiated to identify root causes and investigate alternatives for addressing this problem.
The inspector was informed that based on this review, a plant modification had been approved to redirect the condensate demineralizer high point vent directly to the regenerative waste surge tank.
This will bypass the floor drain system and eliminate the floor drain back-ups on the turbine building 656-foot elevation.
Other changes include placing the high point vent in, a common location for both units, procedure enhancements, and changing the video monitor for the high point vent sight glass to a color monitor.
The inspector noted this effort as a very good initiativ.0 TEMPORARY SHIELDING CRITERIA The inspector performed a review to determine if adequate criteria were provided for the use of temporary shielding.
The inspector reviewed the following procedures.
NDAP-(A-0404, Shielding Installation and Removal HP-TP-239, Plant Shielding These procedures provided good procedural guidance to evaluate shielding effectiveness.
The inspector also reviewed shielding summaries reported in the Unit-2 5th refueling outage, and Unit-1 6th and 7th refueling outages.
The inspector noted that data had been collected in order to evaluate the effectiveness of shielding at designated locations.
Pre-and post-shielding dose rates were obtained using TLDs and a survey instrument with a directional probe.
The inspector was informed that these data were used by the Health Physics Specialist-ALARA to evaluate the optimum use of shielding.
The inspector was informed that although shielding optimization reviews were performed, these reviews were not formally documented.
The inspector also was informed that estimates for person-rem savings for shielding installations were not formally documented on a routine basis.
The inspector pointed out that documented reviews for shielding effectiveness, including estimates for person-rem savings, provide historical information that is useful for the performance of ALARA shielding reviews.
The licensee acknowledged the inspector's comment.
7.0 No violations of NRC requirements were identified.
ALARA RESULTS FOR THE UNIT 1 EIGHTH REFUELING OUTAGE The inspector performed a review of actual personnel occupational radiation exposures for the Unit 1 eighth refueling and inspection outage (IRF08) versus estimated exposure goals.
The person-rem goal for 1RF08 was 200. 1 person-rem.
The actual person-rem exposure measured by personal alarming dosimetry was 183 person-rem.
Accumulated exposures were very close to estimated person-rem goals.
The inspector noted that during the refueling outage, the licensee closely tracked outage exposures and took necessary actions to meet established goals.
Good ALARA performance was noted.
No deficiencies or NRC violations were identified.
8.0 TATION TOURS The inspector conducted plant tours in the Unit 1 and Unit 2 reactor and turbine buildings.
Radiological postings were informative and radiologically controlled boundaries were well defined.
The inspector pointed out one contaminated area with a boundary rope down and notified the health physics staff.
This boundary was immediately correcte Walkways were uncluttered and work areas were well illuminated.
No industrial safety hazards or violations of NRC requirements were identified.
9.0 EXIT MEETING The inspector met with licensee representatives denoted in Section 1.0 at the conclusion of the inspection on June 15, 1995.
The inspector summarized the purpose, scope.
and findings of the inspection.
The licensee acknowledged the inspection findings.