ML17157A715
| ML17157A715 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/03/1991 |
| From: | Mann D, Markley A, Noggle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17157A714 | List: |
| References | |
| 50-387-91-03, 50-387-91-3, 50-388-91-03, 50-388-91-3, NUDOCS 9106180210 | |
| Download: ML17157A715 (43) | |
See also: IR 05000387/1991003
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.
50-387
50-388
License Nos. NPF-14 NPF-22
Licensee:
Penns Ivania Power and Li ht Com
an
Units 1 and 2
2 North Ninth Street
Allentown Penns lvania
18101
Facility Name:
Inspection At:
Sus
uehanna Steam Electric Station
Berwick Penns lvania
I
9
I
C
d
d:
~AI 19-19
1991
Inspectors:
5gf g(
J. Noggle,
ation Specialist,Team Leader
d te
FacilHies Radiation Protection Section
D. Mann, Radiation Specialist
Facilities Radiation Protection Section
r
A. M
kley,~
adiation Specialist, R III
date
5 go 'l/
date
Accompanied by: B. Dionne, Brookhaven National Laboratory
Approved by:
W, Pasciak, Chief, Facilities
Radiation Protection Section, DRSS
g-Z-0/
date
Ins ection Summa: A routine radiological controls and ALARAinitiative inspection was conducted
on April 15-19, 1991 (Report No. 50-387/91-03 and 50-388/91-03)
x
A~Id:Add Ill p
I
y ldd*':py
ly
identified items, instrumentation, housekeeping
and radiological postings, vendor staff
qualifications, and procedures
associated with these areas.
The ALARAinspection scope
reviewed the following areas:
ALARAbackground, station dose history, management
involvement, training, ALARAgoals, audits, initiatives and practices, planning, and
ALARAprogram implementation.
Results:
Within the scope of the radiological controls inspection, one non-cited violation
was identified.
DETAILS
Personnel Contacted
Licensee Personnel
- K. Chambliss, Maintenance Production Supervisor
'T. Dalpiaz, Assistant Superintendent
- Outages
- T. Fedder, Safety and Health Consultant
- J. Fritzen, Radiological Operations Supervisor
- M. Golden, Acting Technical Supervisor
'D. Hagan, Radiation Protection Supervisor
'E. Herstman, Corporate - ALARA
- C. Kalter, Corporate Radiological Group Supervisor
- R. Kichline, Project Licensing Specialist
- J. Lex, Nuclear HP/Chemistry Training Supervisor
- D. McGarry, Radiological Safety Consultant
- L. O'eil, Supervisor Engineering - Nuclear
- R. Prego, Supervising Engineer - Audit and Assessment
- H. Riley, Health Physics - Supervisor
- M. Rochester,
Senior Health Physicist
- D. Roth, Senior Compliance Engineer
- K. Roush, Supervisor - Nuclear Maintenance Services
"T. Ryder, Power Production Engineer
- R. Saccone, Reactor Engineering Group Supervisor
- M. Schelbner, Engineer
- G. Stanley, Superintendent of Plant
- T. Steingass,
ISI Supervisor
'B. Veaju, Site Instrument and Control
- H. V'ebb. Supervisor Nuclear Maintenance Services
NRC Personnel
- G. Barber, Senior Resident Inspector
- W. Pasciak, Chief FRPS, Region I
- J. Stair, Resident Inspector
- Denotes those present at the exit interview on April 19, 1991.
Other licensee employees were contacted and interviewed during this inspection.
2.0
Review of Previousl
Identified Items
During a previous inspection, the inspectors questioned the respiratory protection
fit test operator certification process.
The inspectors observed that technicians
were qualified to operate the Dynatech/Frontier Model 260 Fit Booth using a
proceduralized certiGcation process (NTP-QA-42.4 Rev. 1, Health Physics
Contractor Technician Training and Certification Program).
However, the
technicians were qualified to operate the Dynatech/frontier Model 264 Portable
Fit Test Instrument and Tent by On-Job-Training (OJT). The inspectors also
noted that the Model 260 had an active OJT guide form that was not used in lieu
of the more formal certification process.
The licensee agreed that technicians should be qualified to use the Model 260 by
the formal certification process.
Therefore, the licensee inactivated the OJT guide
form for this instrument.
The licensee also agreed that technicians should be
qualified to use the Model 264 by a formal certification process.
The licensee
developed
and implemented this process.
Upon implementation of the Model 264
formal certification, the licensee inactivated the OJT guide form for this
instrument.
The licensee-has
recently begun using the TSI PortaCount, instead of
the Model 260 or Model 264, to perform quantitative respirator fit tests.
The
licensee stated that they were using a OJT guide form to qualify the technicians to
use this equipment.
However, a procedure revision is underway to include a
formal certification process into NTP-QA-42.4 Rev. 3. The OJT guide form will
be inactivated when the formal certification process
is instituted.
A review of this matter during the current inspection indicated that the licensee
had successfully implemented the formal certification process in NTP-QA-42.4
Rev. 2 and deleted the OJT guide forms for both instruments.
A procedure
revision is underway to also include the TSI PortaCount Instrument.
This item is
closed (387/89-80-01 and 388/89-80-01).
3.0
uglification and Trainin of Technicians
The licensee recently implemented HP-HI-014, "Screening and In-processing of
Contract Health Physics Technicians".
This procedure outlines the minimum
qualifications required for a technician in accordance with ANSI N18.1-1971.
Attachment A of this procedure specifies the methodology for evaluating the
experience level of contractor health physics technicians., Some of the experience
levels are-in part as follows:
1
'C
Navv ELT
Time is counted, one for one up to a maximum of 3 years.
The
technician must also have at least 6 months of commercial
experience to be a senior technician.
Shi
ard Article 108
uglified
Time is counted on a one for one basis with no time limit.
o
National Laborato
~
Time is counted on a one for one basis, up to a maximum of one
year, when the description of duties performed are comparable to
the duties encountered
at a commercial power plant.
o
Fuel Re
rocessin
Facility
Time is counted on a one for one basis, since the radiation and
contamination levels encountered
are comparable, ifnot more, than
encountered
at a commercial facility.
o
Non-Power Reactors
Time is counted on a one for one basis up to a maximum of 1 year.
The inspector found this procedure to be excellent. A random sample of
contractor technician resume's
was reviewed to compare the experience levels
indicated on the resume to those outlined above.
Within the scope of this review,
no discrepancies
were identified. The licensee stated that appro>imately 70% of
the contractor technicians had worked at the site during previous outages.
Therefore, the technicians were very familiar with plant specific items and site
personnel.
The inspector found the licensee's practice of supplementing
their'utage
staff with returning contractor technicians to be very good.
The inspector reviewed the lesson plans for the Health Physics Level I and Level
II training and retraining.
The inspector also reviewed the lesson plans for the
respirator training and retraining.
No discrepancies were identified.
The lesson plan HP-076 "SSES Health Physics Practices for Contractor Technicians"
was reviewed.
This course covered specific health physics practices such as responses
to lost/offscale dosimetry and posting practices at SSES.
Also included in this, lesson
plan were lessons learned through-out the industry.
The inspector found the course
outline to be very good.
Procedure NTP-QA-42.4,'ealth Physics Contractor Technician Training and
Certification Program was reviewed.
It was noted that Attachment 3 of this procedure
contains a list of the certification forms required to be completed as a minimum for
outage contractor health physics technicians.
No discrepancies
were noted.
The on-the-job training guide for "BWR Unique Systems for Contract Health Physics
Technicians" was reviewed.
The purpose of this guide is to provide contract health
physic technicians, who are less familiar with the BWR steam cycle, to a brief
introduction to selected BWR systems including the radiological concerns associated
- with each system.
This guide was found to be very good.
4.0
Internal Ex osure Controls
h
The inspector reviewed the operation and quality control of the Whole Body Counters
(WBC). The licensee maintains a Canberra "FASTSCAN" and a Canberra
"ACCUSCAN". The FASTSCAN consists of 2 4" x 4" x 16" sodium iodide (NaI)
detectors behind a shadow shield and associated
electronics.
The ACCUSCAN
consists of one 4" NaI detector,
a moving bed, and associated
electronics.
A valid
geometry is checked at several energies on a monthly basis to insure that the
calibration efficiencies remain acceptable.
This is required in procedure AD-00-740,
Internal Dosimetry Program.
A daily quality control check is performed to ensure
counter stability over an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> counting period.
Quality Control charts are generated
monthly to establish trends in counter performance.
The inspector reviewed records
of recent monthly and daily QC tests and noted that the WBC obtained acceptable
results.
Procedure AD-00-740, section 6.1.5 states in part that non-routine bioassay's
are to be
performed when it is suspected
that an individual may have received an internal
deposition of radioactive material.
In accordance with this, the licensee reviews,
Radiation Work Permit (RWP) data to select a pool of individuals who may have been
exposed to airborne radioactive material.
From this. pool, individuals are randomly
selected for whole body counts.
The inspector reviewed one such random
investigation and concluded that in this case appropriate measures were taken to
prevent the bodily intake of radioactive material.
The inspector reviewed the MPC-hr evaluation forms for three (3) positive whole
body counts.
No discrepancies
were noted.
The licensee used comparative fit-testing as the basis for accepting the TSI
PortaCount fit-test system.
The study demonstrated
that the PortaCount system
was comparable to the corn-oil systems.
The inspector reviewed the hand
calculation performed using ANSI Z88.2 methodology which verified that the TSI
computer algorithm generated appropriate fit factors.
The calculation
demonstrated
correlation factors of essentially one to one for fit factors less than
1,500.
The inspector also noted that greater than 98% of the individuals tested
achieved an acceptable fit factor.
The respirator maintenance
and inspection program was reviewed.
Within the
scope of the review, no discrepancies were identified. The respirator issue
program was reviewed and a spot check performed.
Procedure HP-TP-761, Rev.
7, Issuance
and Control of Respirators, section 9.1.4 states in part; "Determine if
the individual is qualified using a current 'Qualified Respirator User List'." The
inspector compared the "Respirator Issue Log" with the "Qualified Respirator
,User List". From this comparison, it was determined that at two control points,
respirators were issued during the preceding 1-2 days using an outdated "Qualified
Respirator User List". This was determined to be an isolated incident, was a low
severity level, was not a willfulviolation, and was corrected immediately. It
therefore meets the criteria in 10 CFR 2, Appendix C.V.A for issuing a non-cited
violation.
5.0
External Ex osure Controls
A review of portable survey instruments revealed that a source check is performed
on all scales using a '"Cs irradiator. The instruments are logged out on a paper
log sheet.
The information in the log is transferred to 'a card catalogue and also
entered into a computer tracking system,
This system is to track the instrument
calibration due date.
None of the instruments reviewed were found to be in use
and out of calibration.
The instruments may be signed out for the duration of a job. Therefore, the
'0
The licensee maintains a systematic review and concurrence chain from increasing
levels of management
to administratively extend-an individual's quarterly exposure
limit. A review of selected administrative exposure extensions was performed.
The
inspector noted that no administrative exposure extensions had been given for an
.individual to exceed
1500 mrem/quarter.
Those exposure extensions reviewed showed
the complete exposure history was on file and the concurrence signatures from the
appropriate levels of management
were correct.
The inspector reviewed the relocation of the permanent whole body thermoluminescent
dosimetry (TLD). Procedure HP-TP-222 Rev. 5, Special Dosimetry Issuance and
Criteria, section 9.1.5 states in part that placement of the relocated permanent whole
body TLD for individuals shall be documented
on the RWP sign-in-sheet when not
specified by the RWP.
This allows the technician covering a job to observe the work
pattern and position of the workers in relation to a non-uniform source and then
'elocate the permanent whole body TLD to monitor the point of highest exposure if
necessary.
The inspector felt this was a good licensee program.
Reviewed the actions taken when an individual egressing from the protected area
'larms
the portal monitor.
Procedure AD-00-720 Rev. 9, section 4.9.1 states in part
that:
The Supervisor of Security is responsible for "assuring in the event of a portal
monitor alarms at the gatehouse,
that personnel re-exit via the portal monitor, and, if
a second alarm is activated, that the Health Physics Section is contacted and the
person activating the alarm is detained until Health Physics arrival". The licensee
stated that in each case where a portal monitor actually alarmed in the gatehouse,
it
was the result of the medical administration of a radioisotope.
6.0
P~tant Tour
Tours of the licensee's facilities were conducted during the inspection.
Areas toured
included the Reactor, Turbine, and Radwaste buildings, the whole body counting,
instrument calibration, and dosimetry calibration facilities.
The tours showed
housekeeping
within these areas to be good.
Postings and access control to the
controlled areas were also found to be good.
~ g
yt
7.0
-
Dose Evaluation
'.1
Collective Dose
The collective dose f'rom 1986 to 1989 for SSES was compared with that
for the average U.S. Boiling Water Reactor (BWR). SSES was consistently
below the average throughout this time period.
Occupational Dose Comparison for
Pennsylvania Power & Light's Susquehanna
Steam Electric Station
versus
Average U.S. Boiling Water Reactors (BWRs)
Collective Dose per Reactor (Person-rem/Year)
1986
1987
1988
1989
1990
Susquehanna
1, 2
414
313
258
352
Average BWR
652
513
529
439
% of Average
Rank (Lowest)
36%
11 out
ot 30
Q9%
25 out
of 33
-51%
11 out
of 34
-19%
15
out'f
36
- Data unavailable
7.3
Avera e Individual Dose
A review of the average individual dose was performed for the period 1986 to 1989, to
again'compare
SSES exposure against other U.S. BWRs.
SSES average individual dose
was 34% below the average individual dose for BWR radiation workers (with measurable
exposure) in 1986.
This changed to 39% below the average BWR in 1987, 40% below in
1988, and 5% below in 1989.
10
Annual Individual Dose (mrem/year) (NUREG/CR-0713)
1986
1987
1988
1989
1990
Susquehanna
1, 2
276
243
270
280
Average BWR
% of Average
420
400
450
-40%
360
-5%
- Data unavailable
7.4
Daily Collective Dose
A review of the daily collective dose was performed to determine ifthe average daily
dose being expended during non-outage and outage periods was lower than that at other
BWRs.
SSES daily dose per reactor was 139% higher than the average BWR during
non-outage periods and 13% lower during outage periods.
Daily Collective Dose per Reactor (mrem/day) (Hinson, 1990)
Non-Outa
e Dose Rate
Outa
e Dose Rate
Susquehanna
1, 2
(1 986-88)
Average BWR
% of Average
1056
441
139%
3460
4000
-13%
The inspectors did not investigate the reasons for the apparently high non-outage
doses to
licensee staff. It is, however, an area the licensee may wish to review for potential reductions.
11
7.5
Ex osure Rate
nd D
s
E
iv len R
e
In an attempt to determine ifthe decreased
collective dose was due to lower than
average exposure rates, a comparison was performed of SSES radiation levels during
shutdown with those radiation levels in the open literature for.other BWRs. By
comparing SSES with data published in N clear T chn I, the contact and general
area dose rates around major components
and systems appear lower than those at other
BWRs.
76
Re eiiveHi hD seJ
s
To further identify the potential causes for the lower collective doses,
a review of
repetitive high-dose jobs that were conducted during outages and during routine
operations was performed.
The collective doses for SSES repetitive high-dose jobs
conducted during the first through fifth outages of Unit 1, and the first through third
outages of Unit 2, were compared against the data for other GE BWRs report in
All of the collective doses reviewed for SSES high-dose jobs
conducted during refueling outages were below the average values for GE-BWRs. In
addition, the collective dose trend for these repetitive jobs appears to be decreasing
instead of increasing with plant age.
7.7
Non-Re etitive Hi h-Dose Jobs
. A review of the non-repetitive high-dose jobs was performed to determine if a lower
amount of non-routine radiological work resulted in the low annual collective doses.
Because special maintenance
activities typically constitute the largest percentage of the
worl'ategory doses reported to the NRC in accordance with Regulatory Guide 1.16, the
impact of the non-repetitive activities on SSES doses was examined.
The collective doses
per reactor were adjusted to exclude the dose reported during that year for special
maintenance.
The resulting collective dose per reactor excluding special maintenance
is
as follows:
12
Year
1986
1987
1988
1989
1990
SSES Adjusted
Collective Doses
(person-rem)
405
275
218
318
199
U.S. BWR Adjusted
Collective Doses
(excluding special maintenance)
(person-rem)
378
345
8.0.
ALARAPro ram Or anization
8.1
B~kd
The licensee first formally implemented
a program to maintain occupational exposures
as
low as is reasonably achievable in 1978 during plant consfruction.
The first corporate
radiological engineer was hired in 1978, and shortly thereafter initiated the corporate
ALAI'ommittee. The ALARApolicy statement, NDI-6.4.2, "ALARA-Policy and
Program," was approved by the senior V.P. nuclear on December
17, 1981.
This nuclear
- department instruction established
the responsibilities and the foundation of the SSES
ALARAprogram.
The first station ALARAspecialist was hired in 1981, with the station
ALARACommittee convening its first meeting on October 25, 1985.
The ALARAjob
review procedure HP-AL-400 entitled, "RWP ALARAEvaluations," was first approved
on August 15, 1980.
The first ALARAdesign review was documented
on April 16, 1985.
8.2
ALARAPro ram
As previously mentioned, SSES ALARAprogram was initiated during the construction
phase and was in place for the. first refuel outage on unit 1. As a result of this first
outage being radiologically significant, the program has been continually strengthened
and optimized.
The current ALARAprogram is described in NDI-6.4.2, Rev. 3,
"ALARAPolicy and Program," and NSI-2.1.5, Rev. 1, "Implementation and Operation
V
13
of the PPScL ALARAProgram." Allthe major elements of an ALAI'rogram
described in NUREG/CR 4254 were utilized at SSES.
The implementation of these
elements and their relative effectiveness willbe described in the following sections.,
9.0.
~Trainin
The various job-specific ALARAtraining programs were reviewed.
This included a review of
the lesson plans, discussion with the respective training instructor, tour of the training facilities,
and selected review of the various attendance
sheets.
The types of job-specific ALARAtraining
given at SSES included general employee (GET-01), radiation worker (HP001), radiation
protection technician (HP010), administrator and supervisor (HP003), and design engineers
(EG011).
9.1
General Em
l vee ALARATrainin
The current lesson plan for training new employees, which conforms with 10 CFR 19.12
.requirements,
is GET-01, General Employee Training, dated 2/11/91. A review of this
lesson plan and discussion with the instructor indicated that the needed ALARA
objectives were covered.
For general employees, the ALARAconcept is defined, the
management polic'or ALARAis stated, the function of the ALARAprogram is
described, the workers'esponsibilities
towards ALARAare described, and they are
informed not to enter areas bearing radiation symbols unless they have been trained and
have radiation dosimetry.
The ALARAaspects of this training program were considered
adequate.
9.2
Radiation W rker ALARATrainin
The current lesson plan for training radiation workers, which conforms with 10 CFR 19.12 requirements
is HP002 Health Physics Level II dated 3/13/91. A review of this
lesson plan and discussion with the instructor indicated that the needed ALARA
objectives were covered.
In addition to the information described above, radiation
workers also receive training in methods to reduce dose such as time, distance, shielding,
and contamination control ( i.e., containment, filtration, ventilation, and
decontamination).
The ALAI'spects of this training program were considered
adequate.
14
It should also be noted that the licensee has developed impressive mockup facilities for
training workers in radiological areas and on specific components ( e.g. CRD exchange,
LPRM exchange, RWCU pump, undervessel shoot-out steel, SRM/IRM calibration, and
MSIV mockups).
9.3
Radiation Pr
ec i n Technician ALARATrainin
The current training program for radiation safety technicians is documented in NTP-QA-
42.1, Health Physics Section Training and Qualification Program, dated 9/16/88.
This
procedure describes the knowledge, skills, prerequisites,
and qualifications needed to
become
a radiation safety technician. Allhealth physics technicians receive ALARA
training in one or all of the following: (1) HP003 - Health Physics Level III; (2) HP010-
Administrative Procedures for Health Physicists; or (3) HP621 - OTT RMS for ALARA
Programs.
Specialized ALM<Atraining is given to the ALARAspecialists in training
module HP079, Job Spec ALARAspecialist.
These training modules are conducted by
instructors in the Nuclear HP/Chemistry training group.
The content of this ALARA
training was considered
adequate.
A review of attendance
records indicated all level II
HP technicians had received the required ALARAtraining.
94
Adminis rator and Su ervisor ALARATrainin
The job-specific training requirements for administrators and supervisors in ALARAare
specified in NDI-6.4.2, "ALARAPolicy and Program," dated 1/14/91.
This training is
documented in HP003 Health Physics Level III, revised 8/13/90.
This training is
conducted by instructors from the Nuclear HP/Chemistry training group. A review of
the ALARAtraining lesson plan and discussions with the training instructor indicated
that the content and objectives were adequate.
Topics covered included:
(1) ALARA
policy and management
commitment; (2) procedural requirements for ALARA;(3)
Supervisor's ALARAresponsibilities; (4) dose and contamination reduction techniques;
(5) ALARAjob review process; and (6) practical applications.
The ALARAtraining
program developed for supervisors provides the needed motivation and knowledge to
enable them to apply dose and contamination reduction techniques during the planning
and implementation of their work in radiological areas.
A review of the attendance
records for the maintenance
department indicated that all
but one supervisor attended the required HP003 ALARAtraining. This maintenance
services supervisor should attend the required training.
'
9.5
En ineer ALARATrainin
15
The current training requirements for design engineers in the ALARAconcept is
described in the training curriculum for Nuclear Plant Engineering (NPE); approved
8/10/90.
This training matrix and NDI 6.4.2, "ALARAPolicy and Program," dated
1/14/91, requires that all design engineers shall receive training that present design
considerations,
cost considerations,
and methods to be used to minimize personnel
exposures.
This training is documented in instruction EGO11, "~6MDesign
Training," revised July 20, 1989.
This training is conducted by the Nuclear Training
Department.
The AL&MDesign training lesson plan was found to be thorough and of good scope.
A review of the attendance
records for EGO11 training indicated that not all the design
engineers
have received this training. The licensee should consider having all design
engineers attend the ALARAdesign training course.
The licensee indicated that the various procedures
and associated
instructions that
describe how ALARAreviews of modifications are performed are currently being
revised.
This revision was initiated as a result of the improvements being made by NPE
in the method of processing plant modifications.
The licensee agreed to consider revision
~of the ALARAdesign training program to reflect the new and improved modification
process.
10.0
Mana ement's Collective Dose Goals
The inspectors reviewed the licensee procedure for establishing annual goals on collective dose,
along with the 1990 performance results.
The procedure which describes how these goals are
formulated and tracked is described in AD-00-745, "ALARAProgram," dated 4/4/91, and NSI-2-
1.5, "Implementation and Operation of the PP8.L ALARAProgram," dated 2/22/88.
Management involvement was evident in that these goals are approved by the plant manager
and senior vice president
- nuclear.
Collective dose goals are established for the station and for
the major departments/sections
on an annual basis.
The annual collective dose goal for the
station in 1990 was 425 person-rem.
The 1990 collective dose for SSES for Units 1 and 2 was
440 person-rem.
Although the 1990 goal was exceeded
by 3.5%, this was the lowest annual
collective dose recorded since the first year of operation (1985).
A listing of the various department section goals and actual collective dose total for 1990 are:
16
1990 Annual Collective Dose Goals (person-rem)
Department
Quality Assurance
Nuclear Services
(ISI)
Instrumentation 8 Control
Health Physics/Chemistry
Tech Group
Maintenance
Decontamination
Operations
Outage Mgmt/IEG
Chemistry
Nuclear Plant Eng (NPE)
Construction
Other
Goal
9
15
11
44
3
43
34
19
1
4
2
239
1
Actual
10
15
16
52
3
55
37
26
13
4
2
205
2
% of Total
2.3
3.4
3.6
11.8
0.7
12.5
8.4
5.9
2.9
0.9
0.5
46.6
0.5
425
440
The method of establishing, monitoring, achieving, and reporting collective dose goals appeared
adequate.
11.0
ALARAPro ram Or anization
The licensee's ALARAprogram is described in Nuclear Department Instruction NDI-6.4.2,
ALARAPolicy and Program and AD-00-745, ALARAProgram.
NDI-6.4.2 is a corporate
procedure that describes ALARAresponsibilities, ALARAinterfaces, the implementation of
collective dose goals, and ALARAjob reviews.
This procedure established
the management
commitment to ALARA. The procedure
is well laid out and appears
to cover most facets of an
operational ALARAprogram.
An attachment to this procedure included a copy of a specific
policy statement that defined an apparent strong management
commitment to ALARA, The
inspector noted that the detail and comprehensiveness
of NDI-6.4.2 was very good.
I
I
v <'
g ~
17
AD-00-745, ALARAProgram, is a plant procedure that describes ALARAresponsibilities for
site organizations; the ALARACommittee Charter; interfaces; and the ALUMreview and
evaluation process, including: pre-job review, during job review and post job review criteria,
dose reduction methods and process and engineering controls for consideration.
The plant ALARAorganization utilizes two structures, one for non-outage and one for outage
conditions.
The non-outage ALARAorganization consists of a health physics foreman-ALAI',
an HP planner/scheduler,
and two HP specialists.
During outages, the ALARAorganization
expands to include three additional specialists and an assistant HP foreman for backshift
ALARAand external dosimetry support,
These positions are staffed generally from within the
licensee's organization.
As noted previously, one to two individuals from the corporate radiation
protection group are utilized as ALARAspecialists.
The other positions are filled by upgraded
Level II HP technicians or by contractors.
During recent outages the licensee has reduced its
reliance on contractors in order to develop and retain experience within its own staff.
'
The licensee indicated that the maintenance
department reorganized into job area functions
approximately two years ago.
In response to the maintenance
reorganization, the ALARA
outage group was reorganized.
This resulted in the assignment of~~ specialists to the
following areas of coordination:
drywell, valves, balance of plant, and inservice
inspection/snubbers.
Since the maintenance,
construction, engineering and other work groups
are focused in this manner, consistent lines of communications and established
interfaces appear
to enhance ALARAperformance.
The ALARAcommittee is composed of plant group supervisors from various plant
departments.
Notably, the chairman of the ALARACommittee is the Maintenance Supervisor.
The ALARAcommittee is responsible for: reviewing planned activities and modification tasks
that are estimated to exceed
10 person-rem; identifying engineering, training, or licensing
support which may be necessary for exposure reduction activities; designating groups responsible
for performing tasks to present plans to the committee; and reviewing and recommending
resolution of employee identified ALARAconcerns.
The inspectors also noted that the licensee benefits from a consistent highly experienced work
force.
Many of the maintenance,
instrumentation and controls, and construction personnel have
worked at Susquehanna
Steam Electric Station (SSES) since plant startup,
The licensee utilizes
its own maintenance
"travel crew". These included machinists, welders and other support
personnel who have had previous experience
at SSES.
Contractor personnel also included high
proportions of returnees with previous SSES experience.
Interviews with licensee personnel
18
also indicated that worker attitudes toward exposure minimization have improved over the last
four to five years.
Licensee personnel did acknowledge that improvements are warranted with
respect to minimizing personnel contaminations and improving contamination control
performance.
Through discussions
and interviews with corporate, HP, maintenance,
construction, chemistry
and engineering management
and technical personnel, the inspectors were able to evaluate the
work environment at SSES.
There appears to be a supportive environment which facilitates
and promotes individual responsibility and individual development of solutions to plant
problems.
This includes numerous inventions, site manufactured equipment, and improvements
in practices.
This was evidenced by the development of reactor vessel nozzle shielding by a
contract decontamination technician, the snubber support tool developed by maintenance,
the
feedwater nozzle hydrolazing tooling and cleanup methods used by the inservice inspection
personnel,
and the scaffolding and insulation coordination methodology developed by
construction.
12.0
M na ement Involvement
The functional ALARAorganization at the corporate office consists of two health physicists and
a health physics (HP) specialist.
This group performs an annual ALARAassessment
of the
plant ALARAprogram, ALARAreviews for designs initiated at the corporate department
level, tracking and data management,
coordination of the person-rem goal setting process and
evaluation of source term reduction programs.
The licensee does utilize long term planning for
dose reduction improvement projects.
Most of this planning is coordinated with other
departments.
Implementation of new technology and robotics is coordinated with corporate
maintenance
engineering.
Improvements to the steam plant and condensate
system water
quality performance
is coordinated with corporate chemistry.
The corporate office also
provides operational support for the plant ALARAprogram.
Corporate personnel indicated
that their activities focused on building trust and communications between the plant and
corporate organizations.
The corporate radiation protection effort is augmented
by a corporate radiological engineering
function. This effort is supported by a licensee employee who functions as a radiological
engineering consultant,
This function provides quantitative radiological engineering and
,
analytical support to the Nuclear Department and is responsible for the design bases for SSES.
This support includes ALARAprogram direction and support, source term, shielding and
compartment
dose analyses
and provision of the bases for technical training in radiological
19
calculation and evaluation.
An area that is currently receiving attention is a technical
specifications change to allow greater leakage tolerance for main steam isolation valves (MSIV).
This would permit reduced outage time. Another area of support includes the gathering of
data, techniques, and calculational methods for source term reduction.
One to two individuals from the corporate radiation protection staff are given rotational
assignments to the plant to serve as ALARAspecialists during refueling outages.
These
personnel are trained on plant procedures
and processes
in the area of ALARA. Although
additional management
oversight may be required for some of these individuals, depending on
experience,
this is viewed positively. This type of assignment builds relationships and facilitates
communications between these groups.
Rotational assignments
have also been utilized at the,
intermediate to senior management
level. Reportedly, rotations have included the following:
corporate positions, radiation protection groups supervisor, environmental group supervisor, and
maintenance
supervisor.
One area that appears
to merit consideration for improvement is management
support for a
corporate'wide incentive program, into which ALAI'uggestions could be input. The current
incentive program comprise a worker suggestion to-'supervisor program and a bonus system that
rewards plant employees for plant achievement of designated
goals.
The plant achievement
award was made in terms of a percentage of salary for plant wide achievement of management
goals for plant performance.
These goals included regulatory, operational, safety, and
radiological performance.
These were measured
by industry recognized indicators of
performance.
The worker suggestion
system requires the individual to submit his/her
recommendation
to his/her supervisor.
The supervisor would evaluate the recommendation
and
then decide whether to push or reject the idea.
Licensee personnel indicated that upper
management
basically was opposed to incentive systems and that there was no mechanism to
present an idea outside of the normal chain of command.
l
J
20
ALARAInitiatives
ractices
13.1
Source Term Reduction
The licensee is engaged in several significant source term reduction projects.
Although it
was noted that several of these projects appear to be motivated for reasons other than
ALARA,ALARAwould benefit from their implementation.
Water chemistry has a great effect on the production of activation products which
contribute to station source term. Fuel handling and fuel history influences the addition
of fission products to the station systems and thereby contributes to station source term.
At SSES there have been only three fuel rod leakers during ten fuel cycles.
This
indicates excellent fuel integrity and minimal contribution to station source term. In an
effort to minimize shock to the fuel rods, SSES has implemented a fuel ramping
procedure during reactor shutdown and startup.
This involves gradual control rod
movement rather than a scram or sudden rod withdrawal and adds an extra day to the
refueling outage;
a good initiative.
The licensee has changed out 48 control rod drive blades during this outage
approximately one year before end of life. The primary motivation for this change
appears to be minimization of radwaste disposal costs.
The old control blades contained
cobalt bearing stellite rollers that contributed, to the source term in the reactor coolant
system (RCS).
Since the replacement blades do not contain stellite, ALARAwill benefit
from this change out.
The licensee is currently involved in a program to improve feed water chemistry
performance.
This include modifications to the condensate
demineralizers to eliminate
spent resin residues, improved operational utilization of the ultrasonic resin cleaning
system, and installation of erosion resistant replacement piping. Most of this effort in the
steam and condensate
portion of the plant is focused on reducing the amount of iron in
the condensate
water.
The licensee indicated that unlike most boiling water reactors,
which have approximately 90% of its source term due to ~Co, SSES's source term was
composed of appro>imately 75% ~Co and 25% '~Fe and ~Mn. The licensee is also
experimenting with different anion to cation resin ratios as well as different types of resin
for improved performance.
The licensee also indicated that the bid specification was
being developed for the development of a lay up program for temporarily inactive liquid
radwaste systems in order to minimize corrosion.
21
The licensee has performed some initial evaluations of zinc injection and hydrogen water
chemistry methodologies for source term reduction.
These evaluations indicated that
both methodologies result in higher shutdown radiation levels and hydrogen water
chemistry results in higher operating radiation levels.
This appears to be consistent with
the limited,amount of industry experience to date.
The licensee indicated that the source
term was already in the range anticipated with the use of zinc injection and would not
appreciably benefit from this methodology.
The licensee stated that they had adopted
a
wait and see approach until the industry has had more experience with these methods of
source term reduction.
While the licensee's
resources
have been engaged with cobalt reduction efforts in the
reactor core and will be heavily engaged with the snubber reduction program, there has
been little management
support given to cobalt reduction in reactor plant systems and.
components.
No evidence was presented
by the licensee to indicate that the EPRI
method had been utilized to evaluate and systematically reduce the cobalt content of
plant systems and components.
The challenges
associated with the aforementioned
efforts is acknowledged; however, attention is merited for cobalt reduction in reactor
plant systems and components.
~Shieldin
According to SSES data, nearly 60% of all outage radiation exposure occurs inside the
drywell. The station's approach to shielding this area was reviewed.
During the current
unit 2 fourth refueling outage, 73 out of 95 shielding packages were dedicated to the
drywell. Approximatel 32,000 pounds of lead blankets were hung on chains
as shadow
shields or wrapped directly on the drywell radiation sources.
The target for the drywell
shielding was to reduce the whole body dose rate fields below 100 mR/hr for all work
areas.
The licensee has estimated
6 person-rem for'nstallation and removal of drpve]1
shielding for this outage.
Due to the drywell shielding program, there has been a net
reduction of 25% in drywell radiation exposures
since the shielding efforts began.
is building an experience base of standard drywell shield packages.
Permanent
lugs have
been installed at many locations to simplify shield installation. A conveyor belt was used
this outage to transport lead blankets through and into the drywell. To date, most'of the
shielding efforts are for temporary shielding.
Overall the station appears to exhibit a
strong shielding program.
22
13.3
Snubber Reduction
The licensee has appropriated funds and committed to implement a snubber reduction
program.
This willinvolve a reduction of approximately 60% of the station's snubbers.
Over half of the snubber reductions willcome from the drywell which was estimated by
the licensee to reduce personnel exposures by 40 person-rem per outage.
While this will
involve a commitment of exposure and resources to complete, ALARAwillbenefit from
a significant reduction of maintenance
and inservice inspection work in the drywell over
the life of the plants.
13.4
Decontamination Techni
ues
Hydro]azing has been used extensively to perform feedwater nozzle decontamination,
cleaning of cavity drain lines, floor drains and scram discharge lines. The WEPA system
has been used for reactor cavity decontamination.
Steam cleaning has been utilized to
clean concrete after resin spills, reactor water cleanup (RWCU) system heat exchanger
end bell and for reactor cavity decontamination.
The licensee also indicated that
grit/bead blasting was used for turbine rotor and blade decontamination.
Chemical
decontamination
had been evaluated and found not to be cost justified.
The licensee is planning a renovation to the decontamination
shop.
Currently,
decontamination of tools and equipment is performed by hand scrubbing with water,
water spray, vibrator finisher, Maytag dishwasher, freon and electropolishing.
The freon
unit will be decommissioned
to reduce the generation of mixed waste.
13.5
Robotics and automated E ui ment
The licensee began experimenting and evaluating automated equipment in 1987.
The
licensee has utilized the Little Andros robot for unplugging waste sludge from the phase
separator flow eductor, surveying the RWCU phase separator tanks and recovery from
overflow from these tanks.
The super scavenger robot has been used for unit two resin
regenerative
surge tank cleaning and unit one equipment pool decontamination.
A Mini
Rover ROV was used to support the condensate
storage tank cleaning and hydrolazing of
the feedwater nozzles in the reactor vessel.
The licensee also utilizes an eight stud reactor pressure vessel tensioner/detensioner
carousel.
An improved local power range monitor detector removal tool has been
acquired.
Automated valve packing removal tooling has received a mixed review. This
tool is not suitable for all types of valve packings.
An automated vessel seam weld
23
inspection rig was used to perform inservice inspections on reactor vessel beltline seam
The licensee indicated, that a manipulator arm was being evaluated for
radioactive waste shipping activities. This device would be utilized to install and remove
lines and to attach and detach liftrigs to radioactive waste liners.
Generally, the
licensee was actively pursuing the use of remotely operating equipment for high dose job
applications.
13.6
ra i nal Prac ices
Video equipment has been used to monitor activities on the refueling floor and in the
reactor cavity, main steam isolation valve work, RWCU work, residual heat removal
valve work, on the N8 nozzle work, and for suppression
pool access control. During non-
outage conditions, video equipment is used to monitor the RWCU pump oil level bulb,
the resin regenerative tank and resin surge tank levels to minimize the need for an
operator to enter these high radiation areas.
Communication equipment and headsets with base station setup have been used to
coordinate drywell and refueling floor work. The licensee also indicated that the
maintenance
department
has its own communication gear for refueling and control rod
drive (CRD) maintenance
activities.
Sump cleaning was accomplished
by the use of spargers
and added water to slurry sump
contents.
The contents were pumped to the radioactive waste system.
Temporary filters
were not used to support fuel pool cleaning activities.
Spent fuel pool cleanup was
accomplished
by the use of undenvater vacuums that exhausted
to the fuel pool skimmer
system.
No discrepancies
were noted.
13.7
Reactor Water Cleanu
Pum
s
The inspectors evaluated the licensee's
maintenance history with the RWCU system.
A
history of RWCU pump seal failures that goes back to 1986 is evident.
Since 1986, the
following provides a summary of RWCU pump seal failures:
24
YEAR
Unit 1
P~um
A
Unit 2
~Pum
B
P~um
A
P~um
'B
1990 - 8/31/90
1989
1988
1987
1986
3
2
0
3
1
3
4
4
4
2
TOTAL
17'0
While the licensee did improve procedures,
provided training of maintenance workers,,
required the performance of mockup training the day immediately preceding seal
replacement,
and implemented an improved 0-ring design, RWCU pump seal failures
continued to occur.
The licensee indicated that there were 10-12 modifications made to
the original vendor design to "fix"the pumps.
This culminated in a decision that was
made in 1990 to replace the RWCU pumps with sealess
pumps of greater reliability. It
was noted by the inspectors that there was industry experience regarding reliability
problems with these pumps prior to 1982.
While the decision to replace these pumps
with a sealess
design appears to be a good decision, radiation exposure could have been
reduced had they been replaced earlier.
The timeliness of this action was not evaluated
by the inspectors.
e
14.0
Self Evaluation Assessments
The licensee performs three types of assessments
that originate from the corporate radiation
pr'otection group.
Five programmatic assessments
are scheduled over a three year period.
These generally consist of an evaluation of a particular aspect of the radiation protection
program, such as external exposure control, internal dosimetry, health physics surveillance and
instrumentation.
These usually involve contractor support and include the development of the
objectives, conduct of interviews and participation by a member of the corporate radiation
protection group.
This effort results in a report in which the evaluated site group has input as
to the results of the evaluation.
25
The second type of assessment
involved the evaluation of vendor programs for technical and
regulatory adequacy.
It was unclear whether these assessments
were in addition to, in support
of, or in lieu of quality assurance
vendor audits.
The third type of assessment
was the walk
through assessment.
This involved a member of the corporate radiation protection group
visiting the SSES to observe a particular job or program activity.
In addition to the licensee's program of self assessments,
a Radiation Advisory Group is
utilized. This group is composed of several industry notable personnel that meet four times a
year.
This group willperform independent evaluation of the licensee's programs, licensee
performance,
and significant changes in industry thought, such as latest studies on health effects
of radiation.
The results of these evaluations are then reported to the Senior Vice President-
Yuclear
Plannin
and Schedulin
Major outage work requirements
are determined over one year in advance for two refueling
outages at a time. Draft outage plans are issued consecutively with a minimum lead time of
seven months previous to the, outages.
The outage scheduling group issues the draft plans to all
station departments
including the ALARAgroup for review and comment.
Due to a licensee
initiated Organization Effectiveness Review, the maintenance
department
was reorganized
along plant functional lines in 19S9 (i.e. valves, YSSS, balance of plant, snubbers
and ISI,
maintenance
services, electrical, and I 2 C). Each of these functional maintenance
groups has
its own planner and scheduler.
As the outage work is inherited by each maintenance
group,
each group's planner/scheduler
works to detail the planning within the allotted general outage
scheduling framework.
The ALARAgroup also has a planner/scheduler
who has access to all
of the scheduled work packages
as they are developed.
Lists of work packages
are screened for
radiologically significance afterwhich the ALARAspecialist begins his or her outage planning
activities.
The dedicated position of HP planner/scheduler
is viewed as a good station initiative. This
function allows for early job identification which provides significant lead time for the
application of ALARAtechniques and resources.
There are two computer systems which do
not currently interface with each other; the Plant Maintenance Information System (PMIS) and
the Radiological Management
System (RMS) ~ Allof the maintenance planning/scheduling
is
done from the PMIS whereas all of the ALARAplanning/scheduling functions are performed
using the RMS. Due in part to this limitation, the station schedule does not provide job
progress measurement
data for the ALARAdose tracking system.
The general outage schedule
has basically standardized
an outage approach which includes a four day ALARAwindow
before general work commences
inside of primary containment (drywell). This time period
~
s ~
P'
V
26
allows for the identification of hot spots, flushing of these hot spots, drywell decontamination,
installation of shielding and installation of temporary services (e.g. electricity, lighting,
instrument air, etc.).
This demonstrates
management
resolve to minimize personnel exposures.
16.0
ALARAPr
ram Im lementation
,'I
Formal pre-job reviews were required for any job estimated to cost one person-rem or greater.
The ALQV pre-job review checklist was well developed and of appropriate scope.
The pre-
job review consisted of a four page checklist, meeting attendance
sheet documenting the pre-job
review meeting, and a detailed job person-rem estimate,
From these reviews, and resulting
dose estimates the level of ALARApriority and resources were determined.
According to the ALARAProgram procedure AD-00-745, Rev. 9, for all jobs estimated over
one person-rem
an "in progress" review is required at the half way point. This ALARAreview
is to be completed by the work group supervisor.
Upon review, very few in progress reviews
were completed by the work group supervisor and of those that were, approximately 907o
contained no written comments at all ~ In general, this "in progress" review initiative is not
working. For operational ALARAcontrols, the dose tracking system (RMS) does compare
actual person-rem and actual person-hours to the estimates which would effect an investigation
as soon as an estimate is exceeded.
Currently the operational ALARAreviews do not
incorporate
a measure of job completion to compare the person-rem and person-hours
to.
Apparently, the difficultyin interfacing the PMIS and RMS computer systems prohibits the
current availability of the outage schedule information for ALAI'ontrolpurposes.
'In
general, the operational ALARAcontrol measures
could be enhanced.
A list of current RWP's w'as used to select various ALARAjob review packages from the unit 2
fourth refueling outage.
Six ALARAjob packages
represented
17 different RWP's.
Since the
ALARAjob packages
normally precede the RWP issuance it is the ALARAjob packages which
are reviewed and approved by appropriate levels of management.
The divergence from a single
ALARApackage to several RWPs can cause the need for a post-job review to be missed.
The
station procedure requirement for a post-job review during an outage is any job which
accumulates
five person-rem or greater'. AIARAjob package no.90-095 governing limitorque
testing was broken into four RWPs of which the highest individual RWP resulted in 4.55
person-rem.,This ALARAjob package received no post-job review. The cumulative actual job
exposure for all four RWPs was approximately seven person-rem which should have received a
post-job review. This particular job was well under estimated
exposure. however there is a
27
potential for not reviewing significant exposure expenditures.
When a particular scope of work
is designated
as an ALARApackage and presented to the station ALAI'ommittee as such,
the package should continue to be regarded
as the same unit throughout the post-job review
process.
Dose reports are published twice a day during outages and weekly during routine operations.
The information is obtained from RWP sign-in sheet pocket dosimeter data and is updated with
TLD data when available.
To meet the specific needs of the Electrical and Structural (E 2 S)
Construction group, a dose report program was written for their use by the~~ group.
This custom report was administered and distributed by E 2 S construction as needed.
It was
not clear to the inspectors
whether appropriate training,was provided to the work group
supervisors in order to maximize the use of these dose reports.
An ALARAjob package no.90-113 covering RPV disassembly/reassembly,
recommended
that
RPV stud tensioning be reduced from three passes to two passes
as a dose reduction lessons
learned.
This recommendation
was carried through in the outage health physics report and the
inspector verified its incorporation into current outage practice.
The post-job reviews are captured
as lessons learned in the Outage Health 'Physics Report
which is distributed to all station departments.
This document also provides comprehensive
dose, man-hour, and dose rate data by task and work group cate'gories.
A running historical
basis provides trend comparisons
and evaluations.
There is enough detail in the report to
provide for future dose estimating and planning needs.
In general, the Unit 1 fifth refuel
outage report dated January 2, 1991 was a well developed and useful comprehensive ALARA
outage report.
17.0
Exit Meeting
The inspectors met with licensee representative
at the conclusion of this inspection, on April 19,
199'1.
The inspectors reviewed the purpose and scope of the radiological controls inspection
and discussed
the inspection findings. The inspectors also reviewed the purpose and scope of
the ALARAreview and discussed
the findings.
v
~