ML17146B053
| ML17146B053 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/25/1987 |
| From: | Markley M, Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17146B051 | List: |
| References | |
| 50-387-87-19, 50-388-87-19, NUDOCS 8712080007 | |
| Download: ML17146B053 (15) | |
See also: IR 05000387/1987019
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
Nos. 50-387/87-19
50-388/87-19
Docket Nos.58-387
50-388
License
Nos.
'HPF-22
Priori ty
Category
C
Licensee:
Penns
lvania
Power and Li ht
Com an
2 Nort
Nint
treet
A
entown,
enns
vani a
18101
Facility Name:
Sus
uehanna
Steam Electric Station, Unit
1 and
2
Inspection At:
Berwick, Penns
lvania
Inspection
Conducted:
October 13-16,
1987
Inspectors:
imitz, Senior
a i tion
pecia ist
M. T.
ar
ey, Radiation
Speci
st
~kl>< tea
ate
/i/z.s ~
ate
Approved by:
M.
M.
S an
a y,
C ie
,
i ities
Radiation Protection Section
tZ
Zs /k'te
Ins ection
Summar
Combined
Ins ection
Nos. 50-387/87-19
and 50-388/87-19
Areas
Ins ected:
Routine,
unannounced
radiological controls inspection during
t e outage.
reas
reviewed were:
organization
and staffing; training and
qualifications,
ALARA, external
exposure controls, internal
exposure controls
and radioactive
and contaminated
material control.
Several
incidents were
also reviewed.
Results:
One apparent violation was identified (Failure to use qualified
personnel
- details
Section 4).
S7>aoSOo07
S7>>SO
ADOCK 05000387
G
DETAILS
1.0
Individuals Contacted
1. 1
Penns
lvania
Power
and Li ht
H. Keiser, Vice-President
- R. Byram, Plant Superintendent
- J. Blakeslee,
Assistant Plant Superintendent
- N. Pitcher,
Construction Superintendent
- H. Riley, Health Physics/Chemistry
Supervisor
- J. Graham,
Senior Compliance
Engineer
- C. Kalter, Radiological
Group Supervisor
- J. Fritzen, Radiological
Operations
Supervisor
1. 2
NRC
- L. Plisco,
Senior Resident
Inspector,
Susquehanna
- F. Young, Senior Resident
Inspector,
Beaver Valley
1
J. Stair, Resident
Inspector,
Susquehanna
- Denotes
those individuals attending
the exit meeting
on
October
16,
1987.
The inspector also contacted
other individuals.
2.
Pur ose of Ins ection
The inspection
was
a routine,
unannounced
Radiological
Controls
Inspection during the outage.
Areas reviewed were as follows:
organization
and staffing
training and qualifications
external
exposure
controls
internal
exposure controls
radioactive
and contaminated
material control
several
licensee
events.
3.
Or anization
and Staffin
The inspector
reviewed the Radiological
Controls Organization
and
Staffing Levels with respect
to criteria contained in applicable
Technical Specifications.
Evaluation of licensee
performance
in this
area
was
based
on discussions
with cognizant personnel,
review of
documentation,
and observations
by the inspector.
~Findin
s
Within the scope of this review,
no violations were identified.
The
following observations
were discussed
with cognizant licensee
personnel:
Over the last two years,
the licensee
has rotated
managers
and
supervisors
of the Radiological
Controls Organization to positions
internal to and external
to the organization.
This was
done to
provide for personnel
development,
improve management
oversight
where
needed,
and fill some vacant positions.
The following
personnel
rotations were noted:
The position of Radiation Protection/Chemistry
Supervisor
has
been filled by at least three different individuals in the last
two years.
The position of Radiological
Operations
Supervisor
has
been
filled by at least three different individuals in the past
two
years.
One of the individuals rotated through the position
twice resulting in the position responsibilities
being
reassigned
four times.
In addition, the individual currently
filling the position does not appear to meet the Technical
Specification qualification requirements for the position
(See Section
4 of this report).
The position of Radiation Protection Supervisor
has
been filled
by two different individuals in the past
two years.
During
this time the position was also vacant for about
8 months.
The
position responsibilities
were not clearly assigned
to any one
individual.
The inspector discussed
the changes
and rotation with licensee
personnel
and indicated that the numerous
re-assignment
of position
responsibilities
appears
to have affected the quality of some
aspects
of the Radiological
Controls Program.
One example of this
was the unnoticed expiration of administrative
procedures
for high
radiation area
access
control.
Licensee
personnel
acknowledged
the inspector's
comments
and
indicated that the personnel
changes
made were temporary pending
certification of several
individuals in the plant certification
program
and assignment of these
personnel
to positions within the
Radiological
Controls Organization.
4.
Trainin
and
uglification
The inspector
reviewed the training and qualification of selected
radiological controls personnel
with respect
to criteria contained in
applicable
Technical Specification requirements.
The inspector also reviewed the training and qualification of workers
relative to criteria contained
in 10 CFR 19. 12, Instructions to Morkers.
Evaluations of licensee
performances
in this area
was
based
on:
discussions
with supervisory
and technician level personnel
discussions
with workers
review of resumes
review of training records.
Findin<is
Within the scope of this review, the following observations
were
discussed
with cognizant
licensee
personnel:
The resume of one contractor radiological controls technician
(individual A) was not sufficiently descriptive to allow assessment
of the work he performed during an
18 month work period.
This
assessment
was necessary
in order to determine if the individual
possessed
the needed
minimum experience for the position.
It was
not apparent that the individual met minimum qualification
requirements.
In response,
the licensee
consulted with the
individual and determined that
he possessed
sufficient
qualifications for the position
he filled (Senior Radiation
Protection Technician).
The licensee
indicated the matter would be
reviewed.
Within the scope of this review, the following apparent violation was
identified:
(50-387/87-19-01)
In January
1987, the licensee
assigned
an individual to the position of
Radiological
Operations
Supervisor.
Because of training commitments
and
position familiarization requirements,
the individual did not fully
assume responsibility for the position until June,
1987.
The individual
ir. the position of Radiological
Operations
Supervisor
oversees
in-plant
radiation protection activities, radwaste
shipping activities,
and
activities.
The licensee's
Technical Specification 6.3 requires that
supervisors
possess
a minimum of four years of experience
in the craft or
discipline they supervise.
The inspector
noted that the individual's
qualifications were reviewed
by licensee
management.
The individuals
qualifications for the position were approved
by management
on September
21,
1987.
The licensee
concluded that the individual was qualified for
the position despite his possessing
only 8 months of applicable radiation
protection experience.
The inspector indicated that the individual did not possess
the four
years
experience
required
by the Technical Specifications
and that
assignment
of the individual to the position of Radiological
Operations
Supervisor is an apparent violation of Technical Specification 6.3.
The inspector
noted that the individual's responsibilities for overseeing
his assigned
program areas
were not limited in any manner in
consideration of his possessing
limited experience.
5.
The licensee's
ALARA program was evaluated
against criteria contained in
the following:
Regulatory
Guide 8.8, "Information Relevant
To Ensuring
The
Occupational
Radiation
Exposures
At Nuclear
Power Stations Will Be
As Low As Is Reasonably
Achievable
(ALARA);"
Regulatory
Guide 8. 10, "Operating Philosophy
For Maintaining
Occupational
Radiation
Exposures
As Low As Is Reasonably
Achievable;"
Regulatory
Guide 8. 19, "Occupational
Radiation
Dose Assessment
In
Light-Water Reactor
Power Plants
Design Stage
Mian-Rem Estimates."
Licensee
performance relative to these criteria was evaluated
by:
discussions
with cognizant personnel;
tours
o
radiologically controlled areas;
review of station
ALARA goals;
review of Station
ALARA Committee meeting minutes;
review of ALARA briefing and
RWP packages;
review of departmental
exposure tracking;
review of station procedures.
~Findin
s
Within the
scope of this review,
no violations were identified:
The
licensee
was implementing
a generally effective
ALARA program.
The following observations
were discussed
with licensee
personnel:
The licensee is within the established
1987 person-rem
goal
and is
performing exposure
tracking
and trending.
Monthly Station
Committee meetings
are being held.
Monthly and weekly reports
are
prepared
and distributed
by the
ALARA staff.
Daily person-hour
and
exposure
printouts are maintained
and used to assess
ALARA Program
effectiveness.
Several
items indicating good licensee
ALARA initiatives were noted:
The steam dryer was repaired
underwater to minimize personnel
exposure.
(Approximately 100 person-rem
was saved
by
performing the repair underwater.)
The licensee
developed
and used Control
Rod Drive flange
shields.
Use of the shields resulted in about
a
50~ reduction
in total personnel
exposure for removal
and reinstallation of
drives
as
compared to the previous outage.
The licensee installed additional
permanent
shielding support
braces
in the Drywell
for use, with reuseable
shielding.
The
braces will reduce shield installation time and thus personnel
aggregate
exposure
during future Drywell work.
The following areas for improvement were discussed:
The licensee's
ALARA Program provides for briefing of workers
on the
ALARA controls established
for particular work
activities.
However, the
ALARA Program procedures
did not
clearly assign responsibility to any particular individual
(e.g. job supervisor or ALARA engineer) for ensuring that the
briefing of all workers occurs.
Licensee
personnel
indicated
this matter will be reviewed.
unnecessary
exp
6.0
External
Ex osure Control
The licensee's
procedures
do not clearly describe
the program
elements for performing on-going job ALARA reviews.
Such
reviews typically are
used to quickly identify performance
weaknesses
or other concerns
resulting in increased
or
unnecessary
personnel
exposure.
Licensee
personnel
indicated
this matter would be reviewed.
(Note:
Inspector review did
not identify any apparent
examples of personnel
receiving
osure).
The inspector
reviewed the following elements of the licensee's
external
exposure
control program:
adequacy
and implementation of radiation work permits;
adequacy of radiation surveys to support work activities;
use
and placement of personnel
dosimetry devices;
adequacy
and implementation of high radiation area
access
controls;
posting
and labeling of radiation
and high radiation areas.
The review was with respect to applicable criteria contained in
10 CFR 20, Technical Specifications,
and licensee
procedures.
Evaluation of licensee
performance
in this area
was based
on:
observations
of ongoing work and access
control during plant
tours;
discussions
with licensee
personnel;
performance of independent
surveys;
review of documentation.
~Findin
s
Within the scope of this review,
no violations were identified.
The
following observations
were discussed
with cognizant licensee
personnel:
A licensee administrative
procedure
states
that high radiation
area
keys are controlled by radiological controls personnel.
The licensee
had allowed an implementing procedure for control
access
keys to expire.
The procedure,
HP-HI-008,
Work Instruction for Key Control, had expired about
two months
ago (licensee
estimate).
The procedure
provided
detailed
guidance for issuance,
return
and audits of high
radiation area
access
keys.
No current inventory of keys was
available.
Consequently it was not apparent
whether all keys
were present.
The licensee
immediately reissued
the procedure
and initiated
a
formal audit of the status
and inventory of all high radiation area
access
keys.
All keys were found present
and accounted for.
The licensee's
procedures
for the control of high radiation area
keys is considered
an unresolved
item (50-387/87-19-03).
Several
inconsistencies
in posting of the access
points to the
Refuel Cavity (Pool Area) were brought to the licensee's
attention.
The licensee
immediately initiated action to
correct this matter.
The following positive observations
were made:
radiation surveys
were adequate
to assess
radiological
conditions;
personnel
dosimetry was used
as specified
on applicable
radiation work permits;
up-to-date radiological
surveys
were posted for personnel
information;
personnel
exposure
reports
were updated
and distributed in a
timely manner.
7.0
Hot Particle
Ex osure Control
Pro
ram
The inspector
reviewed the status of the licensee's
"hot particle"
exposure control program with respect to criteria contained in the
following:
10 CFR 20, "Standards for Protection Against Radiation;"
Information Notice
( IN) 86-23,
"Excessive
Skin Exposures
Due to
Contamination with Hot Particles;"
dated April 9, 1986;
Information Notice
( IN) 87-39, "Control of Hot Particle
Contamination at Nuclear
Power Plants,"
dated
August 21,
1987.
Evaluation of licensee
performance
was
based
on:
discussio'n with supervisory
and technician-level
personnel;
review of station procedures.
~Findin
s
The licensee
has not yet established
and implemented
a program to control
personnel
exposure
to hot particles.
The licensee
has not established
the program procedures.
Also, personnel
are not trained in the
radiological
hazards of hot particles.
Current licensee
personnel
contamination monitoring practices
are
considered
less
than adequate
to effectively monitor for hot particles.
Licensee action
on the area of hot particles is considered
not timely in
that licensees
were initially notified of problems with hot particles via
an April 1986
NRC Information Notice.
As of October
1987,
no hot
particle program is in place at Susquehanna
Station.
The licensee
is currently developing
a hot particle exposure
control
program.
8.0
Internal
Ex osure
Control
and Assessment
General
The licensee's
program for control of internal
exposure
was reviewed
against criteria contained in the following:
10 CFR 20. 103, "Exposure of Individuals to Concentrations
of
Radioactive Materials in Air in Restricted Areas;"
Regulatory
Guide 8. 15, "Acceptable
Programs for Respiratory
.
Protection;"
NUREG - 0041,
"Manual of Respiratory Protection Against Airborne
Radioactive Materials;"
The licensee's
performance
was determined
by:
discussions
with cognizant personnel;
review of whole body counting
(WBC) records;
inspection of the
WBC facility;
review of radiation work permit
(RHP) records;
review of respiratory
issuance
records
and user qualifications;
and
review of exposure
reports for terminated workers.
~Findin
s
The following observations
were discussed
with cognizant licensee
personnel:
Licensee job specific real time air borne radioactivity
monitoring inside the Drywell was limited.
The licensee's
airborne radioactivity monitoring/analysis
techniques
did not
provide for real time or "quick sort" methods of analysis of
samples
to identify increased
airborne activity in a timely
fashion.
The responsibility for periodic verification of acceptable
operation of HEPA ventilation systems
was not clearly assigned.
Inspector
discussions
with Radiation Protection
Foremen
who
issue
Radiation
Work Permits, indicated
a lack of knowledge of
some regulatory requirements
regarding the issuance of
respiratory protection equipment.
Specifically, personnel
were unaware of requirements
prohibiting the selection
and use
of respiratory protection equipment for airborne concentrations
that would exceed the equipment's
Protection
Factor (PF).
The inspector
noted that one Radiation
Work Permit, for entry into
the Reactor Hater Heat Exchanger,
allowed individual entry with a
full face respirator (protection factor 50) with floor contamination
levels of up to about
120 millirad/hour removable contamination.
Such contamination, if dry, could result in high airborne activity
due to resuspension.
Initial entry was
however made into the room
with airline respirators
(PF 1000).
Licensee
personnel
indicated these matters
would be reviewed.
The following positive observations
were made:
whole body count
and respiratory protection equipment
use
personnel qualification records
were well maintained
and
readily available;
whole body counting instrumentation
was calibrated with sources
traceable
to the National
Bureau of Standards;
the licensee
was making extensive
use of engineering controls
to minimize airborne radioactivity.
High efficiency
particulate air
(HEPA) filtration systems
and containment
systems
were extensively used.
g9.0
Radioactive
and Contaminated
Material Control
The inspector toured the controlled areas
and reviewed licensee control
of radioactive
and contaminated material.
Personnel
frisking practices
and housekeeping
were also reviewed.
10
The review of this area
was with respect
to applicable regulatory
requirements
and licensee
procedures.
Evaluation of licensee
performance
was based
on observations
during plant
tours,
independent
radiation surveys
performed
by the inspector,
and
discussions
with cognizant personnel.
~Findin
s
Within the scope of this review,
no violations were identified.
The
following were discussed
with cognizant licensee
personnel:
Personnel
exiting the Drywell were observed
performing improper
frisking.
Individuals were moving the frisker probe rapidly over
their bodies.
This was considered
a poor practice in that
no other
whole body frisks were required to be performed prior to exiting the
station.
Althouah individuals do pass
through whole body portal
monitors prior to exiting the station,
the sensitivity of these
monitors is limited.
The inspector
noted there were about
4 radiation protection
technicians
at the Drywell control point.
Their oversight of
frisking practices
was considered
poor.
The licensee
immediately initiated action to correct poor frisking practices
at that location.
A technician
was assigned
to monitor
frisking practices.
Also, frisking instructions
were posted at
the frisl ing station.
Personnel
involved in removing equipment
from the Steam Dryer
Storage
Pool demonstrated
poor contamination control practices
as follows;
Personnel
in close proximity to each other wore different types
of protective clothing.
Some wore full plastic suits while
others
wore cloth coveralls.
As equipment
was
removed from the water, water dripped
on
'he
pool railing and floor.
The floor was not covered to
contain the contaminated
water.
Also personnel
with cloth
coveralls
leaned
on the rai lings at the location.
A radiation protection technician
was observing the
activity and did not correct the situation, indicating
poor technician oversight of work activities,
The radiation work permit did not provide effective
contamination controls to prevent contamination of personnel,
equipment
and facilities for the work activity.
Health physics technicians
were observed entering the Unit
1 Health
Physics Office via a door posted
"Use Portal Monitor Prior to Entry"
without using the Portal Monitor prior to entering the door.
This
indicated lack of regard for contamination control.
The licensee initiated
a review of the above matters.
Radiolo ical Events
The inspector
reviewed the circumstances,
licensee evaluations,
licensee
corrective actions,
and personnel
exposures
associated
with several
radiological incidents which recently occurred.
The licensee
had issued
a Significant Operating
Occurrence
Report
(SOOR)
for each of the events.
However, the- SOORs
have not yet been closed.
The events
reviewed
and inspector findings are
as follows:
Event
1
The Waste Mixing Tank overflowed on October 5,
1987
(SOOR No. 1-87-279)
resulting in floor contamination of 646'levation of the
Radwaste
Building.
~Findin
s
The floor was decontaminated
in a timely manner.
No internal
exposures
or personnel
contamination occurred.
An area contamination report
(ACR)
was also issued.
The licensee attributed the spill to an improperly
positioned valve.
The onsite
NRC resident staff is reviewing the operational
aspects
of
this matter.
The
SOOR has not been closed
by the licensee.
Event
2
The Refuel
Floor (elevation 818')
was contaminated
due to exfitration of
contaminated air from a tent enclosure
on September
5,
1987.
(SOOR No. 1-87-238)
~Findin
s
The floor was decontaminated
in a timely manner.
No internal
exposures
or personnel
contamination of the skin occurred.
The occurrence
was
identified via review following identification of shoe contamination.
The licensee's
review indicated the suction
dampers of the High
Efficiency Particulate Air (HEPA) filter drawing suction
on the tent
had
been closed
by unknown persons.
12
The licensee
had established
a long term corrective action plan to
provide for better control
and operability of HEPA filter units.
However,
no short term corrective actions
were identified.
The inspector
noted that no clear assignment of responsibility for
periodically checking operability of HEPA units during
a work activity
was apparent.
The licensee initiated
a review of this matter.
Event
3
Contaminated air dischared
from a hose
on September
30,
1987
(SOOR
No. 1-87-276) resulting in floor contamination of the 719'levation of
the Reactor Building and external
contamination of several
individuals.
~Findin
s
The floor area
was decontaminated
in a timely manner.
The licensee
was
unable to determine
how the hose
became
contaminated internally.
All
airline hoses
in the Drywell were replaced with new hoses.
Several
personnel
sustained
limited contamination of their skin.
An Area
Contamination
Report
(ACR) was issued.
No personnel
intake of
radioactive material
was identified.
The
SOOR has not yet been closed.
The licensee
plans to review and
enhance
the control of hoses.
Event
4
Identification of three contaminated
rags, outside of the Radiological
Control Area.
Instance
1, April 8,
1987
(SOOR No. 1-87-103), Oil soaked
brown rag
found in the Waste Accumulation Area.
Instance
2, September
23,
1987,
(SOOR No. 1-87-267),
Brown rag found
in the Waste Accumulation Area.
Instance
3, October
2,
1987
(SOOR No. 1- 87-277)
Brown rag found at
exit of Unit 2.
~Findin
s
The licensee
closed the initial SOOR (April 8, 1987).
The licensee
.attributed the removal of the rags
from the radiological control area
(Instance
1)
(RCA) to weaknessess
in frisking of material to be released
as "clean trash".
No other examples
were found.
Personnel
were
retrained in proper trash frisking techniques
following the event.
The
licensee
reviewed all exit points from the
RCA and concluded that
no
change in the exits from the
RCA was needed.
13
The licensee
is currently reviewing the second
and third instances.
Regarding
Instance
2 the licensee
issued
a
SOOR for the event.
The
licensee
believes
the second
instance
resulted
from an individual
removing the rag from the
RCA without properly monitoring the rag.
All
unnecessary
RCA exits were closed to normal
personnel traffic.
The
licensee
also halted all trash sorting operations.
The licensee
has initiated action to provide tighter controls over the
"brown rags"
used for general
cleaning
purposes
in the
RCA.
The licensee
has labeled containers for their storage.
Also the licensee is phasin9
the "brown" rags out and is considering
using "yellow" rags.
Inspector review of these
events
indicated the following weaknesses:
The licensee
assumed
the cause of the first instance
was inadequate
monitorinq nf trash being sorted for disposal.
A contaminated
rag
was included with "clean" chemical
waste for disposal.
It was not
apparent that this was the cause of the event.
The licensee's
corrective action for the first occurrence
included
sending all surveyed
"clean" trash through portal monitors
as
a
final "check" of the material prior to removal
from the
RCA.
The
licensee
had not evaluated
the sensitivity of the monitors for this
purpose.
It was not apparent that the monitors were adequate
for
this purpose.
The licensee
did not strenghten
control of release of material
from
secondary exits from the
RCA following the first instance.
The
licensee
concluded
the second
instance
occurred
due to removal of
material via
a secondary exit.
The licensee's
action
on the control of radioactive contaminated
rags/material
is unresolved
and will be reviewed during
a subsequent
inspection.
(50-387/87-19-02)
Event
5
At about 6:00 p.m.
on October
12,
1987 several
workers received skin
contamination while installing shielding
on the 719'levation of the
Drywell.
The contamination
was identified when the individuals
identified "dust" dropping
on them from a higher elevation.
This dust
was subsequently
determined to be contaminated.
Licensee
review
indicated
two workers, wearing full face respiratory protection
equipment,
were removing contaminated
insulation
on the 730'levation
directly above the workers.
The insulation
had apparently
"disintegrated" into dust when handled.
~Findin
s
The licensee
evacuated
the Drywell and decontaminated
the workers.
Airborne radioactivity samples
indicated
no significant airborne
radioactivity.
Morker s in the area were whole body counted.
No intake
of radioactive material
was identified.
Inspector review indicated that as of October
14,
1987
no significant
corrective actions
were taken to control
removal of contaminated
insulation to prevent
a recurrence of the event.
The licensee
had not
provided any guidance to radiation protection personnel
regarding this
operation.
The licensee
immediately generated
a work instruction
covering this matter
and provided it to appropriate
personnel.
The
licensee is reviewing the problem with this type of insulation
and is considering replacing it.
General
Observation of Radiolo ical Events
The licensee
generated
significant operating
occurrence
reports
(SOORs),
personnel
contamination reports
(PCRs)
and area contamination reports
(ACRs) as appropriate for the events.
The following was noted:
The licensee
issued
119
as of August 31,
1987.
Of the number,
75(i.e 63K) were issued
as of September
2,
1987 (Start of Outage).
There is no review of PCRs to identify generic concerns
associated
with the personnel
contamination
events.
The licensee
issued
67 ACRs as of August 31,
1987.
Of the
number,
42 (i.e 62K) are attributed to operations
concerns.
There
is no review of ACRs to identify generic
concerns
associated
with
the area contamination
events.
There
does not appear to be an effective method of documenting
radiological incidents or events which:
1) are not significant
enough to be addressed
by the
SOOR process,
and 2) are neither
ACRs
or PCRs.
Consequently, it was not apparent that
a method for
documenting,
and tracking to resolution, radiological controls
concerns
(e.g.
procedure violations) was in place.
The above matters
were discussed
with licensee
personnel
who acknowleded
the inspectors
comments.
The licensee
indicated the above matters
would
be reviewed.
1 l. 0 ~Ei I
The inspector
meet with licensee
personnel,
denoted in section
1 of this
report, at the conclusion of the inspection
on October
16,
1987.
The
inspector
summarized
the purpose,
scope
and findings of the inspection.
No written material
was provided to the licensee.