IR 05000388/1988012
| ML17156A661 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/22/1988 |
| From: | Markley M, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156A660 | List: |
| References | |
| 50-388-88-12, NUDOCS 8807050246 | |
| Download: ML17156A661 (7) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
88-12 Docket No.
50-388 License No.
NPF-22 Pri ori ty Category C
Licensee:
Penns lvania Power and Li ht 2 North Ninth Street Allentown Penns 1 vani a 18101 Facility Name:
Sus uehanna Unit 2 Inspection At:
Berwick Penns lvania Inspection Conducted:
Ma 24-28 1988 Inspectors:
M. Markley, Radiati n Specialist date Approved by:
M. Shanbaky, Chief, Fa 'ties Radiation Protection Section date Ins ection Summar
Special, announced inspection to review the radiological controls for the underwater repairs of the Unit 2 feedwater sparger.
Areas reviewed included management and organization, diver radiological safety training, internal and external exposure controls, control of radioactive materials and ALARA.
Also, one worker concern regarding radiological controls for snubber work was reviewed.
Results:
Within the scope of this review, no violations were identified. Diver exposure was well controlled and total person-rem was maintained as low as it was reasonably achievable.
No radiological controls deficiencies associated with snubber work were identified.
8807050246 880623 PDR ADOCK 05000388
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DETAILS 1.0 Persons Contacted 1 '
Licensee Personnel J. Blakeslee, Jr., Assistant Plant Superintendent
- R. Breslin, Maintenance Services Supervisor A. Feldman, Health Physics Specialist Dosimetry
"J. Fritzen, Radiological Operations Supervisor W. Morrissey, Radiological Protection Supervisor H. Riley, Health Physics/Chemistry Supervisor M. Rochester, Health Physicist - ALARA Y. Zukauskas, Assistant HP Foreman -
RWP 1.2 NRC Personnel F. Young, Senior Resident Inspector
- Attended the exit interview on May 28, 1988.
Other licensee personnel were contacted during the course of this inspection.
2.0
~Pur ose The purpose of this special, announced inspection was to review the radiological controls for the underwater repairs of the Unit 2 fe'edwater sparger.
The following areas were reviewed:
organization and management; diver radiological safety training; internal and external exposure controls; control of radioactive materials and contamination; and ALARA.
3.0 Divin Activities to Re air the Unit 2 Feedwater S ar er On May 28, 1988, underwater repairs of the "2S" nozzle on the "C" feedwater sparger were performed by divers.
Inspector review of this area was based on criteria contained in the following:
CFR 19, "Notices, Instructions, and Reports to Workers; Inspections;"
CFR 20, "Standards for Protection Against Radiation";
Site Technical Specifications; Information Notice ( IN) 84-61;
"Overexposure of Diver During Work in Pressurized Water Reactor (PWR) Refueling Cavity";
Information Notice (IN) 82-31,
"Overexposure of Diver During Work in Fuel Storage Pool".
Licensee performance relative to these criteria was based on:
~
observation of diving activities;
~
discussion with licensee personnel;
~
review of Radiation Work Permit (RWP) No. 88-109A and ALARA Review No.88-087, both titled, "Repair of Feedwater Sparger Nozzle";
~
review of training records;
~
review of bioassay and dosimetry records;
~
observation of instrument use and review of calibration records;
~
review of the following procedures and instructions:
TP-262-026, Rev. 0, "Performance of FW Sparger Repair";
TP-262-028, Rev. 0,
"FW Sparger Repair Work Control";
MP-062-029, Rev.
1, "Fuel Access Barrier Installation";
MP-062-030, Rev.
1, "Fuel Access Barrier Removal";
AD-00-705, Rev 10,
"Access Control and Radiation Work Permit System";
AD-00-730, Rev.
5, "Health Physics Training Program";
AD-00-745, Rev.
6,
"ALARA Program";
AD-QA-620, Rev.
2, "Portable Survey Equipment Calibration Program";
AD-QA-760, Rev.
4, "Health Physics Instrumentation Program";
HP-TP-330, Rev. 0, "Conduct of Health Physics in Support of Diving Operations";
HP-TP-501, Rev. 2, "Underwater Surveys";
HP-HI-046, Rev 1, "Conduct of Health Physics in Support of Diving Operations";
PMR/DCP No. 88-3029,
"Feedwater Sparger Nozzle Repair";
.CWO NO.
C88391,
"Feedwater Nozzle Weld Repair".
3. 1 Mana ement and Or anization Inspector observation of the diving evolution indicated positive control of work group activities by the job supervisor.
Management was noted to define worker responsibilities and job locations during individual briefings and collectively. Radiological control instructions and
"stop wor k" directives were reiterated during the final pre-dive briefing (tai lboard).
In addition to work group communications, intergroup communications including Radiological Control and Control Room notifi-cations were good.
The licensee's oversight of the diving activities was effective.
3.2 Diver Radiolo ical Safet Trainin Inspector review of diver training documentation indicated that all divers had received Level II health physics training as required by Procedure AD-00-705 for individuals accessing the Controlled Zone.
Divers and support personnel were provided "mockup" ALARA training.
This training was appropriate for the radiological hazards.
In addition to the training, radiological controls personnel provided full coverage of the diving operation.3 procedure and Work Instructions Inspector review of licensee procedures and Construction Work Orders (CWOs) ind'icated extensive pre-job planning'he inspector. noted these documents to include pre-dive checklists, access control'equirements, stay time restrictions, stop-work provisions, safety, contamination control provisions, and material accountability.
Specific procedures and instructions were drafted for diver barrier control devices.
The diver barrier devices were well designed and installed to preclude inadvertent exposure to the divers.
The licensee demonstrated good initiative in this area.
3.4 Internal Ex osure Controls Inspector review indicated that all individuals had received baseline bioassays (whole body count)
~ Evaluation of breathing air certification documents indicated air quality met Grade D commodity specification requirements.
The inspector noted general area air sampling being performed adjacent to the diving location.
When the first diver exited the control point, he was identified as having a facial contamination.
Survey by direct frisk indicated an activity of 70,000 dpm on the worker's cheek.
He was immediately decontaminated and sent for a whole body count.
The licensee stated that one of the individuals assisting the diver unsuit inadvertently touched him on the cheek.
Skin dose associated with the contamination was minimal'he whole body count indicated external contamination with no apparent internal deposition of radioactive material.
The inspector considered licensee response and evaluation of the contamination incident to be adequate and appropriate.
3.5 ALARA and External Ex osure Controls Inspector review of ALARA provisions and practices indicated good licensee performance.
The licensee fabricated a diver barrier and work cage to limit diver access to high exposure rate areas and enhance material accountability and retrieval.
Other ALARA tools included remote survey instruments and telemetric dosimetry, audio-visual equipment, a material catch screen, and local underwater exhaust'uction to remove maintenance debris as it was produced.
These were good licensee initiatives to minimize worker exposure.
Underwater radiological surveys performed by the licensee included survey instrument measurements, self-reading dosimeter (SRD),
thermoluminescent dosimeter (TLD), and neutron dosimetry measurements.
Only the neutron measurements were outside expected parameters.
The licensee's evaluation determined this to be caused by taking the measurements with the dosimetry string exposed upside down.
Further licensee evaluation determined neutron exposure to be minor as a dose limiting factor.
During the initial entry, the diver performed a
verification survey and confirmed the pre-job measurements and evaluation.
The inspector considered the licensee's surveys and evaluation effective in characterizing the radiological hazards.
Radiological posting and labeling on the 818 ft. reactor building elevation were observed to be consistent.
The inspector noted personnel access and material control to be closely monitored.
3.6 Control of Contamination Inspector observation of diving activities indicated contamination controls to be generally effective.
One diver contamination occurred and is discussed in section 3.4 of this report.
When divers exited the water, they were washed with clean water to remove contamination and possible hot particles.
Then, workers would wipe the diver'
suit with absorbent material prior to assisting him undress from the diving suit.
Some of the personnel assisting the diver were not wearing face shields intended to prevent personnel contamination.
The licensee instructed these individuals to don face shields.
Step-off-pads were appropriately located to control the spread of contamination.
The inspector had no further questions in this area.
4.0 Worker Concern RI-88-A-0025 Relative to Snubber Work On Februar
1988 an individual contacted the NRC Region I office regarding work practices and radiological controls for snubber work.
In'eluded in his concerns were:
the adequacy of tools and supplies, the accuracy of snubber drawing locations, poor ALARA practices in the reactor building,,and high personal exposure for snubber work.
The inspector made observations during this inspection to ascertain the substance of these concerns and in addition an onsite review of these concerns was performed during inspection 88-07.
The following was noted:
Discussions with snubber work crews and observation of work activities indicated no apparent lack of tools or supplies.
Review of maps and drawings posted at the drywell control point indicated that snubbers were identified by elevation and azimuth.
During a tour of the drywell,. the inspector noted azimuth locations to be posted on each elevation.
These postings were in agreement with drawings and maps'
Alara practices associated with snubber work were reviewed during NRC Inspection No. 50-388/88-07.
One weakness involving snubber workers waiting for survey results was identified.
However, overall ALARA controls for snubber work was goo ~
The, inspector reviewed daily exposure records for the time period identified by the individual.
Occupational exposure records were not in agreement with the individual's contentions Specifically, the individual and other work crew member's received less exposure than had been indicated.
No anomalies were identified.
Based on this review, these allegations were not substantiated.
~Ei The inspector met with licensee management listed in Section 1.0 on May 28, 1988, at the conclusion of this inspection.
The findings of the inspection were discussed at that time.