ML20033B517
| ML20033B517 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/13/1981 |
| From: | Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20033B470 | List: |
| References | |
| NUDOCS 8112010486 | |
| Download: ML20033B517 (8) | |
See also: IR 05000277/1981010
Text
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ATTACHMENT 5
13 APR 1981
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MEMORANDUM FOR:
File, Docket Nos. 50-277, 50-278
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P.J. V.napp, Chief, facility Radiological Protection Secti(h ( h -
THRU:
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.FROM:
R.L. Nimitz, Radiation Specialist
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SUBJECT:
REGIONAL. REQUEST FOR RADIATION PROTECTION INSPECTION AT
PEACH BOTTOM
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This memorandum will serve to document the regional request for a special radi. i ~ .n
protection inspection at the subject facility.
This inspection will be conduc t J
to review the circumstances and cause of workers apparently failing to folicw
radiation protection procedures.
If such failure is found, appropriate correcti.r.
action'will be requested of the licensee.
The inspection (Combined Inspection No. 50-277/81-10, 50-278/81-11) is scheduled
for April 14-16, 1981 and will primarily involve review of controlled area work-
in progress.
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R. L. Nimitz
Radiation Specialist
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cc:
T.T. Martin, Acting Director, DETI
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J.H. Joyner, Chief, TIB
R.R. Keimig, Chief, PB#2
E.C. McCabe, Chief, RPS 2B
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C. Cowgill, Resident Inspector
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8112010486 811109
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PDR ADOCK 05000277
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Attachment 6
The following paragraphs provide a brief description of each Technical Specification 6.11 citation issued to Peach Bottom since September 1979, the
licensee's response and a short narration evaluating that response.
1.
Report 50-277/79-23; 50-278/79-25
Inspection conducted September 1-30, 1979.
Enforcement letters issued
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November 14, 1979 (Radiation Support concurrence).
a.
T.S. 6.11 Report Item 1
Failure of two individuals (September 17, 1979) to tape coverall
openings as required by their RWP.
Licensee Response
The workers were pouring fresh decon solution into a decon machine
when they were identified as failing to adhere to their RWP. The
licensee's corrective action was to interrupt and re-instruct the
workers in adhering to their RWP.
Comments
No radiation or contamination levels were presented in the
inspection report. However, based on review of similiar operations
no health and safety concern would appear to be present by merely
pouring solvent into a decontamination machine.
b.
T.S. 6.11 Report Item 2
Failure of 11 individuals to sign out all data required by RWP.
Licersee Response
Individuals were identified and requested to provide information.
The individuals were also instructed at this time to use correct RWP
procedures.
OFFICIAL RECORD COPY
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Comment
Failure to sign out does not represent a health and safety matter.
No indication was given in the report as to airborne or radiation
levels,
c.
T.S. 6.11 Report Item 3
Failure of two individuals to sign in on RWP.
Licensee Response
Area entered exhibited radiation and contamination levels less than
that required for an RWP.
Individuals had read the permit but had
just not signed in. Workers were re-instructed in requirement.
Comment
Failure to sign in on a RWP is considered a matter with health and
safety significance.
Regarding long term facility wide correction action for the above
items, the licensee indicated training was made aware of this item
and was to upgrade their training program to place more emphasis on
the importance of RWP-adherence. Additionally, routine QA audits
would continue to be made of RWP compliance.
NOTE:
During discussions with training personnel at
Peach Bottom on April.14-16, 1981, it was determined that
the training department was placing special emphasis on
RWP adherence.
2.
Report 50-277/79-29; 50-278/79-32
Inspection conducted November 1-30, 1979.
Enforcement letter issued
February 8,1980 (No Radiation Support Section concurrence on report or
acknowledgement letter).
T.S. 6.11 Item
Failure of one operations staff member to sign in on RWP on November 8,
1979.
Licensee Response
Operator was responding to possible emergency situation (steam leak).
The individual was knowledgeable in halth physics and entered the area
with a survey meter.
The RWP procedure contains certain provisions for
entering a radiation area to expedite work or inspection without filling
out a RWP first.
OFFICIAL RECORD COPY
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Operations staff and operating personnel were reminded of the importance
of following RWP procedures.
In order to clarify the circumstances for
which an expedited entry is permissible,- a review of the procedure will
be performed and appropriate revisions made as required.
Comments
The report does not indicate if the individual signed the RWP after his
exit. Since the individual was apparently knowledgeable in health
physics and had a survey meter, no health and safety concern is apparent
by not signir, in on the RWP.
3.
Report 50-277/79-30; 50-278/79-33
Inspection conducted December. 1-31, 1979.
Enforcement letter issued
April 21, 1980 (Radiation Support concurrence on report and
acknowledgement letter).
T.S. 6.11 Item
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Failure of one individual to tape coveralls as required by RWP.
Licensee Response
Individual immediately re-instructed to tape openings.
Several station
staff members have recently conducted formal lectures with site personnel
to re-emphasize this need.
Comment
No contamination levels were presented in the report.
4.
Report 50-277/80-01; 50-278/80-01
Inspection conducted January 1-31, 1980. . Enforcement letter issued July
31,1980 (Radiation Support Section concurrence)
T.S. 6.11 Item
One of two individuals found (January 7, 1980) in an RWP area without
dosimetry. Also no RWP was in effect.
Licensee Response
Work was halted. The licensee worker and contractor worker involved were
counseled. A training program was held in April 1980 to re-familiarize
contractor and utility personnel with Health Physics related procedures
and information.
OFFICIAL RECORD COPY
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Comment
Radiation and contamination levels were low in the area ( < 2 mR/hr < 600
dpm/100 cm ) and the area did not need a RWP. However, because the area
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(Hot Tool Room) was subject to changing condi.tions a RWP was required.
This failure to wear any dosimetry and obtain a RWP represents a
significant health and safety matter.
5.
Report 50-277/80-05; 50-278/80-05
. Inspection conducted March 1-31, 1980.
Enforcement letter issued
September 24, 1980. (Radiation Support concurrence)
T.S. 6.11 Item
Failure of one individual to wear required dosimetry in turbine building
165' elevation.
Licensee Response
Health Physics Investigation initiated. Worker. stated it was an
inadvertent action.
Copy of report forwarded to worker's supervisor.
Comments
Report does not present radiation dose rates that the individual was
working in.
No long term, facility wide corrective action taken. The
November 19, 1980 acknowledgement letter does not address this matter.
May represent a health and safety matter if high radiation area entered.
6.
Report No. 50-277/80-08; 50-278/80-07
Conducted April 1-30, 1980. Enforcement letter issued October 28, 1980
(Radiation Support Section concurrence).
a.
T.S. 6.11 Item 1
Evidence of smoking in non-approved general plant smoking areas.
Licensee Response
Regulations concerning
4.. . Jng, eating and drinking were discussed
during the employee refresher training held during April and May.
All site personnel will be receiving written instructions on use of
proper smoking, eating and drinking areas.
OFFICIAL RECORD COPY
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NOTE:
Licensee in letter dated December 4, 1980 indicated
personnel would by December 31, 1980 receive copies of
"Special Nuclear Plant Rules". This is an instructional
booklet containing various do's and dont's for nuclear
plant work.
Comment
Corrective action appeared adequate.
Smoking, eating and drinking
in non-approved areas is a significant health and safety matter.
b.
T.S. 6.11 Item 2
Three individuals working on April 8,1980 at the Unit 2 CRD control
station had not read, signed in on or provided required data prior
to working at the station.
Licensee Response
Individuals re-instructed in requirements.
Refresher training given
dcring April and May of 1980. Additionally, Special Nuclear Plant
rules which will address, among other items, the necessity to adhere
to radiation protection procedures is to be distributed to
personnel.
Comments
This item had health and safety significance. The licensee's
actions appear to be adequate to preclude recurrence.
7.
Report 50-277/80-11; 50-278/80-11
Inspection conducted April 22 to May 19,1980 (N. Dubry, RIII Radiation
Specialist).
Enforcement letter issued September 24, 1980.
T.S. 6.11 Item
Three individuals failed to perform negative pressure test of
respirators.
Licensee Re.ponse
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The three individuals were not identified by the inspector so immediate
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counseling was not possible.
The requirement to perform a negative
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pressure test is covered in classroom instruction as well as the
equipment fitting phase of respiratory training.
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OFFICIAL RECORD COPY
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Comments
Report does not indicate that the individuals commenced work without
performing the test. The licensee's response does not indicate that this
item will be reinforced. However, our acknowledgement letter dated
November 19, 1980 indicates the respirator training program will be
modified to place more emphasis in this area. .This is a health and
safety matter.
NOTE:
During review of respirator fitting at Peach Bottom
on April 14-16, 1981, workers were noted to be required to
demonstrate a negative pressure test and were instructed
when to perform such a test.
8.
Report No. 50-277/80-26; 50-278/80-19
Inspection conducted July 24-28, 1980.
Enforcement letter issued-
September 24, 1980 (Radiation Support concurrence).
a.
T.S. 6.11 Item 1
Failure to properly post a contamination area.
Licensee Response
It appeared that a decontaminatien crew removed the barriers and
signs, decontaminated the area and was awaiting an H.P. technician
to survey and clear the area when the inspector identified the
unposted area. The crew leader was counseled and instructed to
remain aware of activities in his area of responsibility and conduct
them in accordance with approved procedures.
Comments
Pre decontamination survey indicated contamination levels ranging
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from 1,000 to 8,000 dpm/100 cm . This is below the licensee's
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current limit (10,000 dpm/100 cm ) requiring an RWP.
The
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contamination did not represent a signficant health and safety
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hazard.
Licensee corrective action did not address long term
facility wide corrective action.
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b.
T.S. 6.11 Item 2
Failure to wear proper dosimetry. Two workers had their own Harshaw
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badges but had inadvertently switched their Eberline TLDs with one
another.
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0FFICIAL RECORD COPY
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Licensee Response
Exchange had occurred after'their exit frem the drywell at a change
area.
Individuals were re-instructed in requirement to use own
dosimetry.
Security-force re-instructed in requirement to ensure
personnel have proper dosimetry. Also the licensee conducted an
audit of approximately 1,200 badges and found no other. instances of
exchanged dosimetry.
-Comment
Since the workers did have other correct dosimetry on, the item did
not represent a significant health and safety hazard.
9.
Report No. 50-277/80-33; 50-278/80-26
Inspection conducted November 8-30, 1980.
Enforcement letter sent March
3, 1980 (No Radiation Support Section concurrence on report or-
acknowledgement letter)
T.S. 6.11 Item
Three individuals crossed a rope barrier (November 25,1980) without
reading the instruction.
Barrier set up was for a Radiation Area while
the boundary of a High Radiation Area was being established therein.
(Two contractor H.P. technicians, one worker, no meter).
Licensee Response
A Radiation Protection technician inside the rope barrier was maintaining
pcsitive control of. the area and it was expected that te would have
encountered, and properly directed, the three individur.ls who were
instead identified by the inspector. All individuals who are employed on
site receive General Employee Training which includes instruction to read
and obey all posted signs, including those associated with radiation
areas.
Comment
Because the area was posted as a Radiation Area and a technician had
positive control of this area, this item does not appear to be a
significant health and safety item. However, in general, failure to
adhere to posting and barricading, particularly High Radiation Area
posting and barricading is a significant health and safety matter.
The licensee's corr?ctive actions did not address long term facility wide
measures to prevent recurrence e.g. stressing of adherence to posting and
barricading in future radiation protection training programs.
OFFICIAL RECORD COPY