ML20057E792
| ML20057E792 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| 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) | |
See also: IR 05000277/1993019
Text
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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.
Licensee:
Philadelphia Electric Company
(
Nuclear Group Headquarters
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Cormspondence Control Desk
P. O. Box 195
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Wayne, Pennsylvania 19087-0195
Facility Name:
Peach Bottom Atomic Power Station (PBAPS)
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Inspection Period:
August 2-6,1993
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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
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Facilities Radiation Protection Section
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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
ADOCK 05000277
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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
,
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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- B. Norris, Senior Resident Iespector
1.3
Commonwealth of Pennsylvania Bureau of Radiation Protection Personnel
- 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.
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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
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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 in Progress
DELETIONS
(GOAL)
DELETED
COMPLETED
1991
6
2
41
2
-
1992
55
25
43
23
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1993
47
28
16
19
11
1994
36
20
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1995
86
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TOTALS
230
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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 planned.
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4.0
Radiological Occurrence Reporting (ROR)
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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
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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
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For the RORs reviewed, event investigation and causal analysis was well performed by the
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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
)
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
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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)
boundary discrepancies.
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ROR #
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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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
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93-011
RD
3/25/93
N/A
N/A
N/A
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93-012
Failure to return unused respiratory protection equipment
4/7/93
No
SC1/93
SC6/93
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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
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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.
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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.
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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.
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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
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upcoming unit 3 refueling outage.
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4.5
LHRA Boundary Discrepancies
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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
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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.
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5.2
ALARA Program Controls
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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
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inspection, the Radiological Engineering Manager was evaluating the need for such criteria.
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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
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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.
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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
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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
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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
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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
,
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.
Reactor Water Clean-Up (RWCU) Header Removal:
This job is a pmparation action in regards to two new 100% RWCU system flow
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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
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50 person-rem without controls. With controls emplaced, the Radiological
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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.
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.
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5.6
ALARA Program Summary
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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
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
2
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
2
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
2
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
,
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
,
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
'
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
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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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resolve the weaknesses identified in section 4.5 of this report.
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HEALTH PHYSICS OUTAGE ORGANIZATION
Mark Moore
RAD ENG MGR
HP SUPPORT MGR
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Dave Dicello
Dick Farrell
.
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
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Hal Trimble
Rennie Poteet
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Ed Tucker
Doug Duer
Gerry Posey
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STRENGTHS
People
Processess
Physical
HP Training
Shielding
Plant painting &
Council
Program
floor resurfacing
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HP teams
Bioassay Program
Radiological
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New/ diversified
PCR reduction
Supervisory Staff
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WATCH AREAS
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People
Processess
Physical
Procedure
Lock high rad
compliance
implementation.
door controls
Technician
RWP writer
technical
guidance
knowledge
Rad worker
HP Instrument
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Calibration &
Maintenance
ARW program
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WEAKNESSESS
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People
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Physical
Shift EP staffing
HP involvement
None
with planning /
scheduling
HP tech utilization
Job performance
standards
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Health Physics
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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
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Dose Management
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- Equally spread exposure among teams and
team members
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Work the Plan / Schedule
- Outage / work schedule
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Control RCA activities
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- Ensure workers know their work order
and task numbers
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- Ensure workers are knowledgable of work
area radiation and contamination levels
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Provide feedback to Health Physics
- Provide feedback to HP Supervision on
HP performance
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- Identify areas for improvement
- 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
.
- Place the same priority on radworker
practices as placed on safety and
procedure compliance