IR 05000277/1993019

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Insp Repts 50-277/93-19 & 50-278/93-19 on 930802-06.No Violations Noted.Major Areas Inspected:Alara,External Dosimetry,Nuclear Quality Assurance Audits & Shipping of low-level Wastes for Disposal
ML20057E792
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 10/01/1993
From: Eckert L, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20057E789 List:
References
50-277-93-19, 50-278-93-19, NUDOCS 9310130155
Download: ML20057E792 (23)
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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos.

50-277/93-19, 50-278/93-19 Docket Nos.

50-277, 50-278 License Nos.

DPR-44, DPR-56 Licensee:

Philadelphia Electric Company (

Nuclear Group Headquarters

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Cormspondence Control Desk P. O. Box 195 l

Wayne, Pennsylvania 19087-0195

Facility Name:

Peach Bottom Atomic Power Station (PBAPS)

l Inspection Period:

August 2-6,1993

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S LM 7/A'/13 Inspectors:

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L. Eckert,' Radiation Specialist Date Facilities Radiation Protection Section

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Approved By:

.M Mh

/c - f' f.J W. Pasciak, Chief Date i

Facilities Radiation Protection Section

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i Amas Inspected: Changes to the radiological controls program, Radiological Occurmnce Reporting (ROR), ALARA, external dosimetry, Nuclear Quality Assurance audits, and shipping of low-level wastes for disposal.

Results The Unit 3 mini-outage was successful from an ALARA standpoint, the audit program was well implemented, and external dosimetry discrepancy evaluations were appropriately handled. However, one area was noted that warrants attention to assure resolution. The lack of comprehensive corrective actions for some radiological discrepancies

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developed under the ROR process was considered a significant radiological controls program weakness. Similar issues were identified in the most recent and the previous audits of the radiological controls program by the licensee's Nuclear Quality Assurance group. No violations of regulatory requirements were identified.

9310130155 931004 PDR ADOCK 05000277 O

PDR

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DETAILS

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1.0 Personnel Contacted 1.1 Station Personnel

  • H. Abendroth, Atlantic Electric Site Representative
  • J. Armstrong, Senior Manager Plant Engineering S. Baker, Manager Radwaste
  • J. Carey, Public Service Electric and Gas F. Crosse, Manager Radwaste Services
  • D. Dicello, Manager Radiological Engineering
  • R. Farrell, Manager Support Health Physics
  • G. Gellrich, Senior Manager Operations
  • E. Hlavacek, Training
  • M. Horvatinovic, Radiological Engineer

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G. Johnston, Manager, Nuclear Maintenance Department (NMD)

  • B. Knieriem, Site Representative, Delmarva Power
  • S. Lee, Engineer, Nuclear Quality Assurance (NQA)
  • D. Miller, Vice President PBAPS
  • R. Moore, Manager Radiation Protection J. Orlando, Fomman Reactor Services, NMD
  • R. Smith, Regulatory Engineer
  • B. Wargo, NQA Other licensee personnel were contacted during the inspection.

1.2 NRC Personnel

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  • S. Miangi, Nuclear Engineer
  • Denotes attendance at the exit meeting.

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2.0 Plant Tours The inspector observed fuel pool clean-up activities. In panicular, control rod blade cut-up work was observed. No discrepancies were noted. No housekeeping concerns were noted..

3.0 Changes to the Program A change was made to the licensee's Emergency Plan to provide the radiological controls department with additional flexibility concerning Radiological Controls Technician (RCT)

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utilization. The licensee's Emergency Plan commitment concerning their Emergency Response Organization was changed from staffing six RCTs around-the-clock to three RCTs around-the-clock, enabling the licensee to assign more RCTs to the day shift. This particular j

change to the licensee's Emergency Plan meets the guidance promulgated in NUREGs 0654 and 0737.

The following table provides the developmental status (as of August 1,1993) of radiation protection procedures common to the Limerick Generating Station and PBAPS. The change to common procedures is considered important, as a significant number of Philadelphia Electric Company (PECo) personnel have responsibilities at both stations. For example, the Nuclear Maintenance Department serves PECo as a roving outage work group.

SCHEDULED PLANNED NEW CNP*

DUPS*

CNP CNP in Progress DELETIONS (GOAL)

DELETED COMPLETED 1991

2

2

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1992

25

23

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1993

28

19

1994

20

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1995

7

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TOTALS 230

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CNP Common Nuclear Procedure DUPS Duplicates The Radiation Protection Manager (RPM) planned to modify the radiological controls organization for the upcoming unit 3 refueling outage. A flowchart was provided and is included as Attachment 1. The main difference between the normal and outage radiological controls organization is the addition of the HP Outage Manager who will directly report to the RPM.

During the conduct of NRC Inspection Nos. 50-277/93-13 and 50-278/93-13, the RPM provided the inspector with their 1993 radiological controls program self-assessment. This assessment noted current strengths, watch areas, and weaknesses, as assessed by licensee staff. This assessment is included as Attachment 2. The assessment denotes RCT utilization as a weakness area; this has been addressed through the above noted change in the licensee's Emergency Plan. In response to the concerns raised by the self-assessment, the RPM prepared a presentation which was given to station management on August 6,1993 (see Attachment 3). Further efforts in communicating health physics expectations to all station staff was planne '

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4.0 Radiological Occurrence Reporting (ROR)

i 4.1 ROR and Reportability Evaluation / Event Investigation Form (RE/EIF) Processes The ROR process is the system by which radiological discrepancies are evaluated by the radiological contmls staff. The RE/EIF pmgram is a station-wide pmcess which provides a comprehensive investigation for discrepancies of greater safety-significance. Many RORs were escalated to the RE/EIF pmcess (see section 4.3).

Subsequent to the inspection, the inspector discussed discrepancy evaluation / processing with the Radiation Protection Manager (RPM). The RPM stated that a new system for l

discrepancy evaluation called the Performance Enhancement Program (PEP) had been implemented. This new process will be reviewed in a future inspection.

4.2 Corrective Actions Developed under the ROR Process a

For the RORs reviewed, event investigation and causal analysis was well performed by the i

licensee. Also, the inspector noted that the RE/EIF process has provided for well-detailed

analysis of radiological discrepancies. However, the inspector concluded that additional fo-cus/ emphasis should be placed on issues identified during the ROR pmcess that relate to areas of regulatory non-compliance. The licensee's pmcess for resolution of RORs appeared to result in corrective actions of limited scope. In several cases, they address only pmblems associated with the specific event. Corrective actions developed through the licensee's RE/EIF process were more bmad-scoped than those developed through the normal ROR process.

4.3 ROR Overview

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RORs from November and December and from January 1,1993 to June 15,1993 were reviewed (93-001 to 93-029), and are listed in the following table. The inspector noted that ROR 93-019 and ROR 93-025 investigated radiological discrepancies that were similar in nature. Corrective actions taken in regards to ROR 93-019 were limited to the particular workgroup causing the discrepancy. Also, there have been several instances (RORs93-005, 93-020,93-028, and 93429) in which individuals have failed to sign in on the appropriate i

Radiation Work Pennit (RWP). Timeliness of implementing corrective actions was adequate, and except for the examples indicated above, corrective actions were generally adequate. See section 4.5 for an overview of Locked High Radiation Area (LHRA)

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Description Event Date RE/DP Response Closure Due Date Date 93-001 Clean area contaminated by floor drain 1/4/93 Yes 3/7/93 3/22/93 93-002 LHRA door found unlocked 2/2/93 Yes 4/15/93 4/22/93 93403 Misinterpretation of TIP log (see Section 6.0)

2/4/93 Yea 2/5/93 5C0/93 93-004 Filter precoat tank overflow 2/8/93 Yea 5/6/93 5/4/93 93405 Work on improper Radiation Work permit (RWP)

2/23/93 No 4/8/93 4/8/93 93-006 Radioactive material moved without the presence of a RCT 3/1/93 No 5/14/93 5/14/93 93407 Abnormal radiological condidons around chemical waste tank 3/9/93 No 6/17/93 7/28/93 93408 RDe 3/10/93 N/A*

N/A N/A

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l 93409 Improper radioactive material storage 3/22/93 No 6/18/93 6/15/93 93-010 UIRA found unlocked 3/22/93 Yes 5/7/93 5/4/93

93-011 RD 3/25/93 N/A N/A N/A I

l 93-012 Failure to return unused respiratory protection equipment 4/7/93 No SC1/93 SC6/93 I

93-013 Contamination found inside an RCA clean area 4/8/93 No 5/21/93 4/8/93 93-014 RU 4/16/93 N/A N/A N/A 93-015 Personnel crossed contamination boundary 4/19/93 No 6/3/93 6/3/93 93416 RD 4/19/93 N/A N/A N/A 93417 RD 4C6/93 N/A N/A N/A 93-018 Clean area contaminations caused personnel contaminations 5/4/93 No 6/17/93 6/3/93 93 019 High Radiation Area (HRA) rope boundary moved 5/5/93 No 6/19/93 6/17/91 93-020 Workers not on RWP at low isvel Radioactive Waste Facility 5/6/93 No 6/20/93 7C8/93 (LLRWF)93-021 Operator action contaminated personnel 5/11/93 Yes 5/6/93 Open*

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93422 Inadequate coverage during movement of items in spent fuel pool 5/12/93 No 6/30/93 5/20/93 93-023 sesvan found unlocked 5/17/93 No 7/30/93 7/28/93 i

93-024 LHRA key found uncontrolled 5/17/93 No 6/30/93 5/21/93 93-025 Radiological postings moved 5/26/93 No 5/27/93 5/27/93 93426 RD 5/26/93 N/A N/A N/A 93427 loose contamination on snubbers inside warehouse 6/4/93 No 8/6/93 Open 93-028 Workers not on RWP at main stack 6/14/93 No 7/29/93 7/8/93 93429 Worker on fuel floor not on RWP 6/15/93 No 7/30/93 6/30/93 93-033 LHRA door unnecured 6/30/93 Yes 8/21/93 Open N/A not applicable

Open open at time of inspection RU rejected as having no radiological concerns

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4.4 Drywell Head Tensioning Personnel Contamination Event On July 15, 1993, four personnel working in the unit 3 reactor fuel floor cavity received facial contamination. The work activity being performed was torquing the drywell head

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flange bolts. The facial contamination levels ranged fmm 500 to 1200 cpm and were removed by decontamination. Follow-up whole body counts identified that two of the four personnel had positive whole body counts. The individual with the largest body burden was assigned 4 MPC-hours. While well within the regulatory limit (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in 10 CFR 20, appendix B, table I, C Nmn 1), these were unplanned intakes of mdioactive materials.

Immediate corrective actions included: a discussion of the event with the Plant Manager on July 15,1993, resulting in the initiation of a RFJEIF (3-93-113); conduct of follow-up whole body counts and urinalysis; discussion of the event between radiological controls and NMD management to ensure the adequacy of immediate corrective actions; discussion of the event at a radiological controls staff meeting on July 15,1993, which resulted in an interim directive issued by the Plant Manager requiring manager level appmval to deviate from planned radiological controls; and conduct, by the Vice President, PBAPS, of a meeting with first line supervisors and above on July 22,1993 to discuss expectations concerning field changes of job plans.

Licensee investigation under the RE/EIF process determined the following root causes.

Turnover communications were less than adequate.

e The original work plan was not followed.

High levels of loose contamination in the outer bellows existed.

Workers failed to follow instmetions given by radiological controls personnel.

e Workers were provided with oral instmetions not to enter the cavity bellows area, as the bellows areas had not been decontaminated. In interviews conducted with the job NMD Supervisors, these individuals stated that they had reemphasized this instruction prior to cavity entry. Two NMD workers on different shifts placed their feet into the outer bellows despite the pre-job briefing instructions pmvided by radiological contmis technicians (RCTs).

In both instances, the RCTs present in the cavity took appropriate corrective actions by immediately removing these individuals from the cavity.

As described by the licensee, long-term corrective actions are to include: conducting joint shift meetings during unplanned outages in a manner similar to scheduled refueling outages, evaluating the feasibility for decontaminating the cavity bellows area as part of cavity decontamination, evaluating the use of hydraulic guns (for stud tensioning /detensioning) or porting the muffle exhaust, and reviewing the generated RFJEIF report with radiological

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controls, NMD, and outage planning personnel prior to the stan of the unit 3 refueling outage.

l The licensee was taking actions in regards to improving radiation worker practices prior to this event taking place (see section 3.0). The results of these effons will be evaluated in the l

upcoming unit 3 refueling outage.

l 4.5 LHRA Boundary Discrepancies i

l At the time of the inspection, three MRA boundary discrepancy events had occurmd since January 1,1993. These event were all investigated by the RE/EIF process. The following bullets provide a brief description of these discrepancies.

  • ROR 93-002 WRA door found unlocked / unguarded. The initial corrective action was to secure the door with a chain and padlock. The fm' al action was to install door knobs in order to provide a better locking mechanism and to achieve better uniformity with the other GRA boundaries throughout the station.
  • ROR 93-010 LHRA door found unlocked / unguarded. The locking mechanism was found to be in a degraded condition. After this discrepancy, the licensee came to the conclusion that generic implications pointed to equipment degradation and/or a door design problem.
  • ROR 93-033 LHRA door found to be inadequate in that a push-pull action caused the door to become insecure. The door hinges were found to be in a degraded condition.

In conclusion, the licensee determined that there was a need for preventative maintenance on LHRA doors in addition to LHRA barrier integrity surveillances (which were being conducted). To addmss this, a surveillance procedure was under development at the time of the inspection. LHRA boundary controls will be the subject of future inspection effons.

4.6 ROR Summary The lack of comprehensive corrective actions for some RORs developed under the ROR process was considered a significant radiological controls program weakness. Subsequent to this inspection, the licensee initiated changes to improve the evaluation of radiological discrepancies. These changes will be reviewed in a subsequent inspection.

Another weakness noted in this inspection was in the area of radiation worker attention to detail (section 4.3) and adherence to instructions provided by radiological controls staff (section 4.4). Section 4_3 notes several RORs in which workers have either failed to sign in i

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on a RWP or have not signed in on the corrat RWP as required. This was also identified by the licensee (see section 7.0). Improvement in these areas is needed.

5.0 ALARA/ Outage Planning 5.1 ALARA Performance in Unit-3 Mini-Outage Thme jobs conducted during the mini-outage met the licensee's minimum criteria for initiation of an ALARA pm-job review. These pm-job ALARA reviews were developed for the following jobs.

Deccatamination of Reactor Cavity and Equipment

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Dose savings accrued during this work as compamd to other outages was incurred as a result of a new strippable coating material which is easier to mmove than what was previously used.

  • Disassemble / Reassemble Reactor and Move Fuel Dose savings accmed as a result of ventilating the air space under the reactor head with a HEPA equipped with charcoal filtration prior to head removal and, therefore, no respirators wem needed or used.
  • Build / Remove Scaffold and Replace Transverse Incore Probe "A" Indexer Job planning was based on indexer rebuilding and not on indexer replacement. The job was completed in 43.8 person-hours at a cost of 0.526 person-rem. Initial estimate was that the job would take 93.0 person-hours at a cost of 1.4 person-rem.

The inspector concluded that these pre-job reviews had been conducted in acconiance with HP-C-324, "ALARA Job Reviews," Revision 0,5/10/93.

l 5.2 ALARA Program Controls i

As part of this inspection, the following procedure and policy statement controlling ALARA planning were reviewed.

"ALARA Manual", Revision 2,4/91

HP-C-324, "ALARA Job Reviews," Revision 0, 5/10/93 No specific ALARA review criteria were provided by HP-C-324 concerning airborne

radioactive materials concentration or smearable contamination levels. At the time of the l

inspection, the Radiological Engineering Manager was evaluating the need for such criteria.

l Other risk balancing criteria (such as heat stress) were under consideration for inclusion into

job planning procedures in preparation for the new 10 CFR 20 regulations. The licensee l

planned to implement the new 10 CFR 20 regulations on January 1,1994.

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5.3 Source Term Reduction The licensee has completed a study on the cobalt source term. This study and maintenance / design pmcedures developed to provide guidance in selection of low-cobalt replacement components will be reviewed in a future inspection. Notwithstanding, a recent licensee audit determined that management prioritization of ALARA initiated modification was weak and cobalt reduction efforts have been slow.

j The inspector reviewed pmcedure AIAG-CG-601, " Valve Internal Cleanliness During Maintenance", Revision 0,7/3/92 which pertained to source tenn reduction. This procedure was noted to provide sufficient guidance for planning and minimizing the cobalt input from J

primary system valve maintenance.

Also, the lic~ee's action to remove fuel assemblies (in a recent unplarmed unit 3 mini-

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outage) that were thought to have degraded / leaking fuel pins was considered a good source term reduction initiative.

5.4 ALARA Program Initiatives At the time of the inspection, several notable initiatives pertaining to the licensee's ALARA program were underway or planned.

A Radiological Engineer was assigned full-time as a single point of contact for job o

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planning. This Radiological Engineer screened work requests using the maintenance work onier system for the need to develop RWPs and/or ALARA packages. At the time of the inspection, the ability to screen emergent work requests had become available. The ability to properly plan for emergent work using the maintenance work order system will be evaluated in the upcoming Unit 3 refueling outage.

The licensee purchased a surveillance mbot and is learning how and where to apply

this new resource.

The licensee acquired a Teledose system (a remote monitoring system which e

communicates by radio) for use during the unit 3 refueling outage, The Radiological Engineering Manager stated that efforts would be made to impmve e

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the ALARA suggestion process.

These items will be reviewed in a future inspection.

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5.5 ALARA Planning for Unit 3 Refueling Outage A goal of 500 person-rem has been established by the Radiological Engineering Manager.

This was based on a 52 day unit 3 refueling outage. The Radiological Engineering Manager was provided with a three-shift (12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) window to be used for shielding emplacement in the drywell. Additional shielding as compared to pre';ious outages will be used this

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refueling outage. In particular, plans called for shielding of the recirculation headers this outage. Two radiological engineers have been assigned to the drywell.

The following pmvides a brief overview of majorjobs to be conducted in the upcoming unit 3 refueling outage.

  • Reactor Vessel (RV) Assembly / Reassembly:

The Radiological Engineering Manager stated that dose incurmd as a result of these activities would be reduced by keeping the steam dryer and moisture separators submerged under water, keeping the outage shorter, and using a different strippable coating to decontaminate the cavity (the new paint should facilitate quick decontamination of areas previously thought unacceptable to decontaminate through means of strippable coating). The Radiological Engineering Manager informed the inspector that the Nuclear Mainicuance Department (NMD) had been tasked with an action item to evaluate the feasibility of replacing and/or modifying methods and/or equipment used to tension /detension RV studs.

Drywell Main Steam Isolation Valve (MSIV) Seat Refacing:

e This task was performed at a cost of 16 person-rem (four valves) the last time this work was performed. Plans were to work on four valves this outage. The Radiological Engineering Manager planned to mduce dose through the use of additional shielding on components within the drywell. A new tool to be used in MSIV disassembly has been acquired.

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Recirculation Seal Replacements:

e This work is being planned with engineering contmls rather than with respirators as has been previously done.

Contml Rod Drive Rebuilding and Replacement (CRDs):

e During this outage, the licensee planned to clean certain drive components in a lower dose field outside the CRD rebuild room rather than cleaning all components in the

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CRD rebuild room.

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In-Service Inspection (ISI):

Dose incurred as a result of ISI is e.vpected to be less as the licensee plans to limit inspection scope.

Main Steam Relief Valve (MSRV) Replacement:

At the time of the inspection, no significant difference was expected in the ALARA plan developed for this work as compared to pmvious outages.

This job is a pmparation action in regards to two new 100% RWCU system flow l

capacity pumps which will replace the thme existing 50% RWCU system flow

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capacity pumps. Initial scoping of the work estimated a cumulative exposure of about l

50 person-rem without controls. With controls emplaced, the Radiological l

Engineering Manager felt that the cumulative exposure should be about half this amount.

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One of the more-notable planning measures for this job has been in the area of prefabrication. Twenty-three welds will be done outside the RCA and another fifteen need to be done inside the RCA. The licensee estimated that prefabrication will save about 8 person-rem. Also, fire watch activities will be conducted by remote monitoring. The licensee also planned to use electropolished piping in the RWCU pump rooms which will help maintain future work in the RWCU rooms ALARA.

This modification was intended to maximize RWCU pump reliability and minimize exposure in conducting RWCU pump maintenance (about 20 person-rem incurred per year).

  • RWCU MO-18 Valve Overhaul At the time of the inspection, no significant difference was expected in the ALARA plan developed for this work as compared to previous outages.
  • RWCU System ISI At the time of the inspection, no significant difference was expected in the ALARA plan developed for this work as compared to previous outages.
  • Torus Hard Vent Modification This work has been completed on Unit 2 at a cost of 12.6 person-rem. The Radiological Engineering Manager was evaluating component prefabrication to reduce the collective dose for conducting this work on Unit 3.

5.6 ALARA Program Summary

Notwithstanding radiological discrepancies found in regards to work conducted during the mini-outage (see section 4.4 and NRC Inspection Report Nos. 50-277/93-15 and.50-278/93-15). the inspector concluded that the mini-outage was successful from an ALARA standpoint.

At the exit meeting, the inspector stated that this conclusion should not be taken to minimize any concerns on radiological discrepancies / poor practices (in particular, radiation worker practices) noted during the conduct of this inspection nor those brought up recently by the resident inspectors.

6.0 External Dosimetry At the time of the inspection, the HP Support Manager planned to conduct a study to determine the neutron energy spectrum in 1994.

The inspector selected Exposure Discrepancies Reports and Personnel Exposure Evaluations (mechanisms by which the licensee evaluated lost dosimetry and other dosimetry discrepancies) conducted in the second quarter of 1993 to determine whether dosimetry discrepancies were properl; uraluated for possible inclusion / modification of doses of record.

Of the cases reviewed, there were no safety significant issues involved. Of those cases selected by the inspector, no investigations concluded that modification of an individual's

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dose of record was needed. The inspector concluded that these occurrences were properly evaluated and closed.

The Philadelphia Electric Company's dosimeter processing facility handles personnel dosimetry from both PBAPS and the Limerick station. The licensee was accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) in all eight test categories.

NVLAP conducted an on-site assessment March 30-31,1993. No deficiencies were found.

The NVLAP assessor found that the licensee was conducting a program within the guidelines of NVLAP criteria. The NVLAP report also found that, in general, the dosimetry program was very good and responsible personnel made a concerted effort to provide quality dose evaluations. The individual assigned with the overall responsibility for dosimetry processing was the individual designated as the laboratory official. In practice, the licensee contracted the services of a vendor to supply and evaluate neutron dosimetry. That vendor was accredited in NVLAP test category VIII (photons and neutrons).

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7.0 Nuclear Quality Assurance (NQA) Audits The NQA radiological controls audit was conducted at PBAPS from June 9,1993 through July 2,1993. The audit team was comprised of two assessors with plant health physics expertise and utilized four technical experts. NQA considered this audit as very significant in that the last NQA audit conducted two years ago identified repetitive program deficiencies and poor radiation worker practices. Thus, emphasis was placed in the audit to evaluate adequacy of corrective actions. The audit team noted that improvement opportunities still exist in the corrective action and self-assessment process. The previous radiological controls audit identified a significant breakdown concerning radiological controls program oversight.

In summary, audits were well-performed, well-detailed, and where possible, performance based. As the radiological controls staff had not had sufficient time in which to provide responses to audit discrepancies by the time of this inspection, licensee response to audit issues will be evaluated in a future inspection.

8.0 Shipping of low-level wastes for disposal, and transportation The inspector observed the preparation for shipment of radioactive waste shipment 46-93.

No discrepancies were noted.

Identirration No.

Activity Description dot Type 46-93 73 Ci solids. oxides on resin LSA On August 10,1993, an empty fuel shipping cask received on-site had external contamination levels in excess of the 10 CFR 20.205(b)(2) limit of 0.01 microcurie (22,000 dpm) per 100

cm. The empty cask was shipped to the site from the Scientific Ecology Group's facility in Oak Ridge, Tennessee. The cask arrived covered with a tarp. The initial survey indicated

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that the exterior of the tarp was clean. The cask was transported to the low level radiological waste storage building where the tarp was removed. A survey of the cask performed by the Health Physics (HP) technician with an Rhi-14 Beta / Gamma detector found

the maximum contamination level to be 43,955 dpm/100 cm. The licensee notified the NRC and the delivering carrier of the problem. Because the cask had been covered by a tarp that was found fme of external contamination, the licensee concluded that no release or public health or safety hazard occurmd.

The licensee completed a smear collection efficiency evaluation using the methodology describe. hiRC Information Notice 85-46, " Clarification of Several Aspects of Removable Radi' ; cim Surface Contamination Limits for Transport Packages." A collection efficiency of 61% was determined empirically, themby giving an adjusted maximum non-fixed

contamination level result of 7200 cpm /100 cm. Themfom, the inspector concluded that the fuel cast stupmcat mceived on 8/10/93 by PBAPS personnel was in compliance with 49 CFR 173.443, 9.0 Open Items CLOSED (NCV 50-277/93-02/01) Failure to follow procedures.

This item and associated events were detailed in NRC Inspection Report 53-277/93-02 and 50-278/93-02. This was a reactive inspection conducted as a result of a licensee identified incident involving the breakdown of personnel access controls associated with Transverse Incore Probe (TIP) synem operation.

The following long-term corrective action commitments were reviewed.

  • Communicate lessons learned from the event to plant personnel.

Revise procedure RE-35, "TIP System Operation," to clearly indicate the reactor

engineer's responsibility to review the TIP logbook and also to require HP notification when abnormally long TIP activation events occur.

  • Establish procedural guidance for the HP section on actions that should be taken when

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notification of abnormally long TIP operations is received.

Review other HP pmcesses that contml personnel exposure to determine if the e

processes contain adequate defense-in-depth.

Review the format of other logs used as administrative controls for HP processes to e

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ensure that they are pmrly controlled and human factored.

In addition to these long-term corrective actions, the licensee agmed to re-evaluate the TIP

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room Area Radiation hionitor (ARhi) dose rate alarm setpoint.

These actions have been completed and the item is closed on this basis. The inspector found the change to the TIP room ARM dose rate alarm appropriate. Licensee representatives stated that it would not be desirable to place the ARM alarm serpoint at a level which would alarm during a " normal" TIP run due to the limitations in the control room ARhi annunciator logic design. Licensee radiological controls staff stated that the ARhi annunciator logic design does not provide for multiple signal inputs, i.e. the control room ARM annunciator

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would not re-alarm upon inidation of another ARM signal. The inspector had no further questions on this matter at this time.

10.0 Exit Meeting I

l The inspectors met with licensee repmsentatives at the end of the inspection, on August 6,

1993. The inspectors reviewed the purpose and scope of the inspection and discussed the findings. The licensee acknowledged the findings and stated that actions would be taken to

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l resolve the weaknesses identified in section 4.5 of this report.

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HEALTH PHYSICS OUTAGE ORGANIZATION RPM Mark Moore RAD ENG MGR HP SUPPORT MGR

>b Dave Dicello Dick Farrell

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HP OUTAGE MGR

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Bill Downey

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FUEL FLOOR SUPV DRYWELL SUPV BHIFT SUPV

])ALANCE OF PLANT SUPV Mark Dedric.)

Steve Kohlbus Ned Weissenrieder Gdry Smith g

Hal Trimble Rennie Poteet

Ed Tucker Doug Duer Gerry Posey t

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SD STRENGTHS People Processess Physical HP Training Shielding Plant painting &

Council Program floor resurfacing g

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HP teams Bioassay Program Radiological l

postmgs

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New/ diversified PCR reduction Supervisory Staff

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People Processess Physical Procedure 10CFR20 Lock high rad compliance implementation.

door controls Technician RWP writer technical guidance knowledge Rad worker HP Instrument

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practices Calibration &

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People Processess Physical Shift EP staffing HP involvement None with planning /

scheduling HP tech utilization Job performance standards

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Expectations Communicate with the HP Techs

  • Involve HP in shift turnover meetings
  • Tell HP what your doing
  • Tell HP whats coming
  • Follow the RWP and ALARA guidance e Get buy-in before proceeding I

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  • Provide feedback to HP Supervision on HP performance

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  • Let HP know when activities went well

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Enforce good radworker practices

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  • You and your teams are the largest part of

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the Rad Protection Program

  • First line supervisor must help

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  • Place the same priority on radworker practices as placed on safety and procedure compliance
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