ML20033A319
| ML20033A319 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/11/1981 |
| From: | Knapp P, Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20033A311 | List: |
| References | |
| 50-277-81-10, 50-278-81-11, NUDOCS 8111250175 | |
| Download: ML20033A319 (8) | |
See also: IR 05000277/1981010
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
50-277/81-10
Report No.
50-278/81-11
50-277
Oc:ket No.
50-278
C
License No.
Priority
Category
C
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Licensee:
Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania 19101
Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3
Inspection at: Delta, Pennsylvania
Inspection conducted: April 14-16, 1981
Inspectors:
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R. L. Nimitz, Rad M tion Specialist
dite signed
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date signd
Approved by:
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P. J. Kpdpp, Chief, Ficility Radiological
Tate ' signed
Protection Section
Inspection Summary:
Inspection on April 14-16, 1981 (Combined Inspection Report Nos. 50-277/81-10
and 50-278/81-11)
Areas Inspected:
Routine, unannounced inspection by one regional based inspector
of the radiation protection prcgram during refueling including: qualification
of personnel; radioactive and contaminated material control; posting and control
of radiation areas; radiation work permits; surveys; respiratory protection; and
review of April 14, 1981 in plant Unit 3 water spill. Upon arrival at approxi-
mately 7:30 am on April 14, 1981, areas where work was being conducted were ex-
amined to review radiation safety control procedures and practices. The inspec-
tion involved 24 inspector-hours onsite by one regional based inspector.
Results: Of the seven areas inspected, no items of noncompliance were identified
in five areas; one item of noncompliance was identified in each of the remaining
two areas.
(Failure to collect suitable airborne radioactivity concentration
samples as. required by 10 CFR 20.103, Paragraph 6; Failure to follow radiation
protection procedures (2 instances) as required by Technical Specification 6.11, Paragraphs 5 and 7).
8111250175 81110F
PDR ADOCK 05000277
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DETAILS
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Persons Contacted
- W. T. Ullrich, Station Superintendent
- N. Gazda, Health Physics Engineer
T. King, Chemistry Supervisor
D. Barron, Technical Assistant, Dosimetry
C. Lauletta, Training Coordinator
J. Valinski, Health Physicist
USNRC Resident Office
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- A.-R. Blough, Resident Inspector
- C. J. Cowgill, Resident Inspector
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- denotes those persons present at the exit interview on April 16, 1980.
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The inspector also interviewed several other licensee employees, including
members of the Health Physics (H.P.) staff (station and contractor) and
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reactor operation and maintenance personnel.
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2.
Qualifications of Personnel
The inspector reviewed the qualifications of selected censee and contracted
radiation protection personnel. The individuals selected by the inspector
were those providing responsible radiation orotection oversight of various
work in the controlled area.
The review of personnel work in the field, individual resum6s and discuss-
ions with the selected per onnel and licensee radiation protection repre-
sentatives inaicated the licensee was selecting and utilizing personnel
in accordance with ANSI N18.1-1971, " Selection and Training of Nuclear
Power Plant Personnel". The review also indicated the licensee appeared
to be adhering to the requirements of Health Physics Procedure HP0/CO-80,
Revision 1, " Contract Health Physics Technician Entry Procedure."
No iteins of noncompliance were identified in this area.
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3.
Radioactive and Contaminated Material Control
The inspector toured the controlled area upon arrival and at other times
during the inspection and reviewed radioactive and contaminated material
posting, labeling and control with respect to the following:
10 CFR 20.203, "Ca.ution signs, labels, signals and controls";
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Health Physics Operating Procedure, HP0/CO-11, Revision 7, " Establishing
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and Posting Radiologically Controlled Areas"; and,
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Health Physics Operating Procedure HP0/C0-14, Revision 3, "Identifica-
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tion and Control of Tools and Equipment Used-in Radiologically
. Controlled Areas".
The inspector tours indicated the licensee was posting, labeling and
controlling radioactive and contaminated material in accordance with the
above.
No items of noncompliance were identified in this area.
4.
Posting and Control of Radiation Areas
The inspector toured the controlled areas making radiation intensity
measurements where necessary to verify licensee adherance to the following:
10 CFR 20.203, " Caution signs, labels, signals and controls";
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Technical Specification 6.13, High Radiation' Area; and,
Health Physics Operating Procedure HP0/C0-11, " Establishing and
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Posting Radiologically Controlled Areas".
The inspector tours indicated the licensee was postino, barricading and
controlling radiation and high radiation areas in accordance with the
above.
No items of noncompliance were identified in this area.
5.
Radiation Work Permit Review
Technical Specification 6.11, Radiation Protection Program, requires that
procedures for personnel radiation protection be prepared consistent with
the requirements of 10 CFR 20 and be approved, maintained and adhered to
for all operations involving personnel radiation exposure.
During tours of the controlled area, the inspector reviewed worker and
radiation protection personnel adherance to the requirements of Health
Physics Operating Procedure HP0/CO-4, Revision 16, " Radiation Work Permits".
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The radiation work permits (RWP's) reviewed were as follows:
RWP No.
Work Description
2-94-0139A
"Decon Tools and Equipment and Machine Faces on
Poppets and Associated Work," dated March 24, 1981
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3-94-0106
"TB-3, AB&C RFPT Rooms and Bays General Mai.iten-
ance, Inspection and Survey", dated March 8, 1981
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3-01-0120A
"TB-3, CV and MSV Area Gneral Maintenance and Repair
of CVs and Inspection", dated March 19, 1981
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-3-94-0194A
"TB-3, Turbine Deck Tent Area-General Maintenance.
and Inspection"
'3-94-0108A
"TB-3, Turbine Deck General Maintenance Inspection
and Surveys"
3-01-0140B
"TB-3, B LP Turbine' Spindle and Related Work",
dated March 24, 1981
3-03-188A
RX-3 CRD Rebuild Room " Rebuild CRD's in Rebuild
Room, Store and Leak Test", dated April 6, 1981
3-94-0214
RX-3 Refuel' Floor, " Perform General Maintenancs,
Construction, Inspection and Surveys and Operate
Refuel Bridge", dated April- 14, 1981
3-04-0180
RX-3 Drywell, " Install 8 inch Relief Valves,
Seismic Supports and Associated Work With
M00-536", dated April 1, 1981
3-07-0168A
RX-3 Drywell, "Inpections and Surveys", dated
April 13, 1981
HP0/CO-4 requires in part in Section VI, "Using a Radiation Work Permit,"
that among other ' data, the individual using the RWP is to provide, prior
to entering, a pocket dosimeter " dose in", time in and upon exiting, a
pocket dosimeter " dose out", time out.
This data is to be entered on the
RWP Access and Exposure Control form.
The review of the above RWP Access and Exposure Central forms indicated
the following:
RWP No.
Number of Individuals flot Signing Out Properly
3-94-0194A
4/13/81
- No dose in or out
1
No dose out
2
3-04-0108A
4/13/81
- No dose out or time out
1
4/7/81
- No time out or dose out
1
4/6/81
- No time out or dose out
1
3-94-0214
4/15/81
- No time out or dose out
2
The inspector discussed the above with licensee representatives and
indicated that failure to adhere to the requirements of Health Physics
Operating Procedure HP0/CO-4 as required by Technical Specification 6.11
constituted an item of. noncompliance.
(50-277/81-10-01; 50-278/81-11-01)
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6.
Surveys
The inspector reviewed selected RWP's and associated radiation.and airborne
radioactivity surveys made by the licensee prior to commencement of RWP
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work and those surveys made during the course of selected RWP work,
10 CFR 20.103, Exposure of individuals to concentrations of radioactive
materials in air in restricted areas, requires in part in paragraph
(a)(3) that, for purposes of determining compliance with the requirements
of this section, the licensee shall use suitable measurements of'concentra-
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tions of radioactive materials in air for detecting and evaluating airbrne
radioactivity in restricted areas.
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During review of airborne radioactivity sampling made during welding of
the Control Rod Drive (CRD)-under vessel winch on April 15, 1981 (RWP No.
3-03-188A), the inspector noted that the welding was performed in the CRD
Rebuild Room with a portable ventilation exhaust hose over the head of
the welder. This hose position resulted in the welding fumes being drawn
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up and away from the weld area.
Review of the radiation and contamination
surveys of the piece being welded indicated removalable surface contamina-
tion of'300 dpm/100 cm2 (beta / gamma) with fixed contamination up to 8
millirads/ hour.
Review of the airborne radioactivity sampler position indicated that the
position of the sampler would preclude a suitable measurement of airborne
radioactivity concentration being collected, in that the sampler was at
least 10-15 feet from the welder's breathing zone.
Further, the air
sample location, relative to the ventilation arrangement, was upstream of
the welding operation and thus could not be representative of the activity
to which the worker was exposed.
The inspector discussed the above with the radiation protection technician
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monitoring the work in progress. The technician indicated that the
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sampler could not be positioned closer to the workers breathing zone
because it kept " plugging up."
This was apparently due to excess filter
loading.
The_ inspector discussed the above with licensee representatives and
indicated that failure to perform suitable airborne radioactive material
sampling was noncompliance with 10 CFR 20.103(a)(3) (50-277/81-10-02;
50-278/81-11-02).
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7.
Respirctcry Protection
The inspector reviewed selected portions of the licensee's respiratory
protection program with respect to the following:
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10 CFR 20.103, " Exposure of individuals to concentration of radioactive
materials in air in restricted areas";
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Technical Specification 6.11, Radiation Protection Program;
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ilealth Physics Operating Procedure HP0/CO-9, Revision 8, " Respiratory
Protection";
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Health Physics Operating Procedure HP0/CO-9A, Revision 5, " Respiratory
Protection Training aad Fitting";
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Pealth Physics Operating Procedure HP0/CO-98, Revision 6, " Respiratory
Protective Equipment Selection and Use"; and,
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Technical Specification 6.11, Radiation Protection Program.
Equipment Use
Technical Specification 6.11, requires that procedures for personnel
radiation protection be prepared consistent with the requirements of
10 CFR 20 and be approved, maintained and adhered to for all operations
involving personnel radiation exposure.
Radiation Protection Operating Procedure HP0/CO-98, Section 6.2.3,
specifies, that when utilizing a constant flow air line, the manifold
pressure is to be checked and regulated to 35-40 psi for the constant
flow valve.
This is to ensure workers are receiving the appropriate
airflow and not receiving less than minimum or in excess of the
maximum allowable.
During review of main steam line relief discharge line (180 ) grinding
(RWP No. 3-04-0180) in the drywell at approximately 3:00 pm on April
15, 1981, the inspector noted two individuals to be utilizing full
face constant flow airline-supplied respiratory protective equipment.
The review of the equipment use indicated the pressure being supplied
the workers was 50 psi.
Further review indicated that the apparent
cause for personnel not conforming to the procedural requirements
was inadequate personnel training.
10 CFR 20.103 requires in part in Section (c) that when respiratory
protection equipment is used to limit the inhalation of airborne
radioactive material, the licensee may make allowance for such use
in estimating exposures of individuals to such materials provided
that such equipment is used as stipulated in Regulatory Guide 8.15,
" Acceptable Programs for Respiratory Protection."
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Regulatory Guide 8.15 requires in prt in Regulatory Position C.4
that the licensee is to maintain and implement a respiratory-protection
program that includes, as a minimum, written operational and administra-
tive procedures for control and prr.per use of respiratory protective
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equipment. Also required are written procedures to ensure proper
training of personnel using respiratory protective equipment.
Health Physics Operating Procedure HP0/CO-9A, Revision 5, " Respiratory
Protection Training and Fittings," states in Section 1, " Personnel
who may be expected to use respiratory protective equipment in the
course of their duties at Peach Bottom and supervisors who direct
respirator wearers shall be trained in the proper use of such equipment."
Further, Section 1.1 requires this training to be given by a qualified
individual who has been interviewed and certified by the Respiratory
Protection Administrator or his designee.
In reviewing the licensee's control and use of continuous flow
respiratory protective equipment, the inspector noted, in discussing
the topic with licensee representatives, that for a time during the
beginning of the outage, contractor workers were responsible for
ensuring the breathing air manifolds and hoses were set up in accord-
ance with procedural requirements. However, at some time prior to
this inspection, the contractor firm was.apparently no longer tasked
to monitor breathing air system hook-up and use. As a result,
workers were responsible for their own breathing air system hook-up
and use.
Inspector review of the training given to the workers in proper use
of continuous flow respiratory protective equipment indicated no
formal training was given in set-up and proper use of the' continuous
~ flow breathing air supply system.
Rather, as determined in discuss-
ions with licensee training representatives responsible for respira-
tory protective equipment training, training was given only for use
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of the face piece,
i.e., doning of equipment, loss of air supply,
mask removal, etc..
The inspector noted during tours of the controlled areas that workers
were apparently responsible for set-up and use of their own equipment.
During the tours, radiation protection technicians monitoring work
in progress were noted to indicate they were not responsible for
oversight of the systems. Worker supervisors indicated that the
worker was responsible for set-up of their own system.
The tours also identified several continuous flow breathing systems
which although not being used at the time, did not appear to be
set-up for operating in accordance with procedural requirements.
This included leaking manifolds and excessively high breathing air
manifold supply pressures. .The inspector noted that failure to
train personnel in the use of respiratory protective equipment in
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accordance with Procedure HP0/CO-9A was noncompliance with Technical Specification 6.11 (50-277/81-10-01; 50-278/71-11-01).
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The above items were immediately brought to the l'icensee's attention
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who subsequently took action to ensure the subject breathing air
system problems were corrected prior to use of the above units.
8.
Water Spill (Additional Item)
10n April 14, 1981, at approximately 10:00 am, flooding was visually
identified in the Unit 3 High Pressure Coolant Injection (HPCI) Room.
The water filled the room to a depth of approximately 4 feet and caused
the Cardox (CO ) fire protection system to activate in that araa.
This
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resulted in generation of an oxygen deficient atmosphere in the lower
elevations of the reactor building.
The inspector, upon hearing the evacuation alarm, went to the Reactor
Building main. access control points and observed Itcensee actions relative
to the spill. The inspector noted the following during the observation
of activities:
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guards were positioned at the Reactor Building main access points to
prevent inadvertent personnel access to the evacuation area;
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utilizing recently inspected self-contained breathing apparatus,
teams of personnel entered the evacuated area to evaluate the spill
and ensure complete evacuation of personnel; and,
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airborne radioactivity, oxygen, carbon dioxide and radiation surveys
were performed during the entries.
Subsequent to the_ event, the inspector reviewed plant radiation and
airborne radioactivity surveys and applicable process radiation monitor
readings.' No unusual conditions were noted.
The inspector discussed the event with licensee representatives and noted
that all personnel had been evacuated and no extensive personnel contamina-
tion, injuries or unusual incidents had occurred.
This matter will receive additional review by the NRC resident office and
will be documented in combined inspection report 50-277/81-11; 50-278/81-12.
9.
Exit Interview
The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on April 16, 1981. The inspector
summarized the purpose, scope and findings of the inspection.
Licensee representatives made no comments other than no commitments
relative to corrective action would be made.
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Maine Yankee Atomic Power
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Company
007 3 0 1981
incorporated as far as possible into a separate part of the affidavit.
If we do
not hear from you in this regard within the specified periods noted above, the
report will be placed in the Public Document Room. The telephone notification
of your intent to request withholding, or any request for an extension of the 10
day period which you belieYe necessary, should be made to the $Upervisor, Files,
Mail and Records, USNRC Region I, at (215) 337-5223.
Should you have any questions concerning this inspection, we will be pleased to
discuss them with you.
Sincerely,
Original Signed Iht:
Eldon J. Brunner, Chief, Projects
Branch #1, Division of Resident
and Project Inspection
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Enclosures:
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1.
Appendix A, Notice of Violation
2.
Office of Inspection and Enforcement Inspection
Report Number 50-309/81-24
cc w/encls:
E. Wood, Plant Superintendent
E. W. Thurlow President
J. H. Garrity, Director, Nuclear Engineering & Licensing
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Infonnation Center (NSIC)
NRC Resident Inspector
State of Maine
bec w/encls:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encls)
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OFFICIAL RECORD COPY
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