ML20058D343
| ML20058D343 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/23/1993 |
| From: | Bores R, Eckert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058D270 | List: |
| References | |
| 50-277-93-27, 50-278-93-27, NUDOCS 9312030133 | |
| Download: ML20058D343 (15) | |
See also: IR 05000277/1993027
Text
i
j
-
,
,
.
i
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Repon Nos.
50-277/93-27, 50-278/93-27
Docket Nos.
50-277, 50-278
l
License Nos.
'
Licensee:
Philadelphia Electric Company (PECo)
Nuclear Group Headquaners
Cormspondence Control Desk
,
i
P. O. Box 195
,
!
Wayne, Pennsylvania 19087-0195
Facility Name:
Peach Bottom Atomic Power Station (PBAPS)
Inspection Period:
October 4-8, and November 8-10,1993
Inspectors:
Sl;C
11
3
L. Ecken$ Radiation Specialist
ate
Facilities Radiation Protection Section
R. Fernandes, Reactor Engineer, Reactor Projects Section 2B
'
'
Approved By:
// /2.3 /PS
R. Bores, C4ief
Date
Facilities Radiation Protection Section
l
Areas Inspected: The first portion of the inspection included ALARA, planning for
,
radiological work, radiation worker practices, traiaing and qualifications, and shipping of
l
l
low-level wastes for disposal. Additional inspection was conducted to evaluate PECo's
2
actions associated with entries into high radiation areas and a respintory protection required
1
!
area without satisfying radiological safety reqmrements.
1
l
l
Results: Good performance was noted by the radiological engineering and radiological
controls technician (RCT) staff. No radiation worker practice discrepancies were noted
J
during the first ponion of the inspection. A weakness was noted concerning the ability to
j
provide emergency response information in accordance with 49 CFR 172. No violations of
'
regulatory requirements were identified in the first ponion of the inspection. Based on the
results of the second portion of the inspection, the two improper high radiation entries and
the improper respiratory protection required area entry are apparent violations.
9312030133 931124
ADOCK 05000277
G
I
,.
-
-
-
. ..
..
-=
.
. -
..
..
.
..-
_
i.
!
-
4
j
i-
!
l
!
!
i
2
r
i
DETAILS
'
.
h
i
1.0
Personnel Contacted
i
i
'
f
1.1
Station Personnel
'
!
' H. Abendmth, Atlantic Electric Site Representative
{
S. Baker, Radwaste Manager
2
j
L. Beddy, Senior Radiological Controls Technician (RCT)
j
M. Blasciak, Senior RCT, Bartlett
i
!
O. Brown, Materials Manager
l
J. Carey, Public Service Electric & Gas Representative
}
J. Curran, Maintenance Supervisor
,
j
M. Dedrich, Health Physics (HP) Supervisor
i
2
j
- D. Dicello, Radiological Engineering Managei
!
D. Droddy, Radiological Engineer
j
' B. Downey, HP Supervisor
]
8 W. Eckman, Acting Manager Nuclear Quality Assurance
52
j
G. Edwards, Plant Manager
j
R. Farrell, Support Health Physics Manager
'2
D. Ferguson, Senior RCT, Banlett
3
j
'# G. Gellrich, Senior Manager Operations
D. Goodell, System Manager
d
G. Haney, Plant Equipment Operator
f
C. Hardee, HP Instructor
2
W. Harris, Radiological Engineer, Limerick Generating Station
j
M. Horvatinovic, Radiological Engineer
2
B. Jefferson, Shift Supervisor
t
l
S. Kohlbus, HP Supervisor
2
q
S. Lee, Nuclear Quality Assurance (NQA) Engineer
l
L. MacEntee, Shift Supervisor
.
' G. McCarty, Services Training Manager
l
B. Miller, Radiological Engineer
' D. Miller, Vice President PBAPS
,
i
J. Mitman, Component Engineering Manager
l
'# M. Moore, Radiation Pmtection Manager (RPM)
j
T. Niessen, Engineering Director
l
D. O'Connell, Radiological Engineer
j
M. Parcell, Senior RCT, Banlett
' Denotes attendance at the second exit meeting held on November 10, 1993.
i
j
2Denotes attendance at the first exit meeting held on October 8,1993.
i
1
I
1
<
.
.
-
,
3
{
J. Purcell, Senior RCT
,
R. Simpson, Engineer
2 G. Smith, HP Supervisor
32 R. Smith, Regulatory Engineer
D. Stein, Senior RCT, Banlett
!
2 A. Stuan, Balance of Plant Engineering Manager
D. Sware, Radiological Engineer
2 H. Trimble, HP Supervisor
1
B. Wallace, Senior RCT, Banlett
2 B. Wargo, Nuclear Quality Assurance (NQA) Assessor
T. Wasong, Experience Assessment Manager
.
!
M. Weaver, Shift Manager
C. Whitaker, Senior RCT, Banlett
i
Other licensee personnel were contacted during the inspection.
!
(
1.2
NRC Personnel
i
P. Bonnet, Resident Inspector
i
R. Bores, Chief, Facilities Radiation Protection Section
'
' R. Fernandes, Reactor Engineer
I
i R. Lorson, Resident Inspector
i W. Schmidt, Senior Resident Inspector
2.0
Purpose and Scope
The October 4-8,1993, ponion of this inspection was to review the overall safety
effectiveness of the licensee's implementation of its ALARA program, planning for
l
radiological work, radiation worker practices, training and qualifications of radiation
j
'
protection personnel, and shipping of low-level radioactive wastes for disposal.
The purpose of the November 8-10,1993, ponion of this inspection was to review two
entries into posted high radiation areas and an entry into a respimtory protection equipment
required area without satisfying the radiological safety requirements. The NRC reviewed
these three events and PECo's response primarily to assure that radiological protection of
plant perennel was being maintained.
,
The NRC review during both ponions of the inspection included interviews with cognizant
personnel, including supervisors and managers; review of applicable technical specifications,
i
procedures, and instructions; documentation; and observation of activities in progress. In
!
!
l
!
_ _ _ _ _ _ _ _ - .
.
. .
.
4
addition, the second ponion of the inspection included analysis of the physical barriers in
place at the time of each event.
3.0
ALARA/ Work Planning
Good planning and control of radiological work was noted in the reactor water cleanup
(RWCU) in-senice inspection (ISI) and control rod drive (CRD) exchange jobs. The ability
to develop radiation work pemlits (RWPs) in an efficient manner for emergent work was
evident.
The inspector also observed a " rad hold" placed by the drywell HP Supervisor on a drywell
151', O degree RWCU insulation removal job. Additional shielding was to be emplaced the
following day and delaying the job was determined to have no effect on the seturn to critical
path. This action was assessed by the inspector as appmpriate and was indicative of good
ALARA awareness on the working level.
The inspector attended a Schedule Discipline Meeting and noted that it was a goad work
planning initiative which will help avoid wasted dose, i.e., dose accrued as a result of
preparing for a job more than once prior to its actual initiation.
At the time of the first ponion of the inspection, the accmed dose on the drywell ISIjob was
observed to be exceeding the radiological engineering staff's expectation and would likely fall
well outside the dose goal for the job. The inspector did note appmpriate radiological
engineering staff response in that a Work In Pmgress (WIP) review was initiated and a
Station ALARA Committee (SAC) meeting was held as the revised dose estimate to complete
the job exceeded 25 person-rem. In a future inspection, the inspector will review the lessons
learned from this outage and the licensee's plans for implementing these lessons learned to
minimize future accmed dose as a result of drywell ISI work.
A more detailed evaluation of the licensee's ALARA performance will be undenaken in a
subsequent inspection.
4.0
Radiation Worker Practices
At the time of the first portion of this inspection, the inspector noted that there had been few
refueling outage related Personnel Contamination Repons (PCRs) and Performance
Enhancement Program (PEP) repons generated to that point in the outage. As previously
noted in NRC Inspection Repon 50-277/93-19, the PEP discrepancy resolution system has
replaced the Radiological Occurrence Reponing (ROR) and Reportability Evaluation / Event
-
-_
-
-.
.--
.
-
.
1
i
l -
!
l
,
h
5
!
Investigation Fonn (RE/EIF) systems. Most of the more radiologically challenging work
l
was completed by the end of the first ponion of this inspection. No poor radiation worker
j
'
practice wonhy of note was found by the inspector during this ponion of the inspection.
The inspector also noted that the RCTs were aggressive in helping to ensum good radiation
worker practices. Seveml senior RCTs were interviewed to detennine the quality of working
'
level relationships with other station groups. The RCTs expressed general satisfaction in the
!
mlationship with those work gmups and, also, with station management.
l
5.0
Training & Qualifications
Twenty individuals passed the National Registry of Radiation Protection Technicians
,
(NRRPT) exam, including one health physics trainer, one physicist, and 18 RCTs. The
inspector noted that this was a good initiative.
i
The inspector reviewed 18 contractor resumes to detennine whether the individuals wem
appropriately qualified to carry out their outage-assigned responsibilities. The inspector
j
noted that the licensee was conservative concerning accmditing time status for senior
radiological controls technicians in accordance with ANSI /ANS 3.1 - 1981. No
discrepancies were noted.
6.0
Shipping of Low-Level Wastes / Materials for Disposal, and Transportation
The inspector conducted an off-hours test of the licensee's ability to provide information in
accordance with 49 CFR 172. Funher positions / guidance in this mgard were promulgated in
NRC Infonnation Notice 92-62. The test was intended to be open-book, and focused on the
i
adequacy of emergency response procedures and how the shift staff were trained on these.
Also, the shift-staff were not denied the ability to contact outside expenise (in this case
members of the station's radioactive waste branch). The licensee's Radiological Engineering
Manager observed this activity.
In summary, the test posed was as follows.
The inspector informed the shift staff that a test was being conducted and.that they-
should not activate their emergency response facilities in response to the test.
The shift staff were informed that one of the licensee's radioactive waste shipments
(the shipment number was provided) had turned over in Nonh Carolina and the trailer
bed was on fire.
The driver was incapacitated by the accident.
i
!
--
_
-
-
.
._.
.
.-.
1
l
!
6
The shift staff were informed that the inspector was acting as the lead fire chief who
had responded to the accident.
The shift staff were asked to provide the appmpriate emergency response information.
Time
Action
1017
The inspector made the first call to the control room. The line was busy.
1024
The inspector reached the Shin Administrative Assistant (SAA). The inspector described
the incident to the S AA.
1025
The SAA concluded that she was unable to handle the question and had the Shin Technical
Advisor (STA) ansuer the phone. De inspector described the incident to the STA.
1026
The STA concluded that he u as unable to handle the question and had the Shift Manager
(SM) answer the phone. The inspector described the incident to the SM. The SM asked
numerous questions concerning the shipment (the inspector was later informed that the
shipment manifest was raw readily available in the control room).
1034
The SM informed the inspector that he needed to hang up and would call back. The
inspector stated that he should hurry and call back as the mformation was needed before
fighting the simulated fire.
1043
SM called back to provide the appropriate emergency response information.
While the call demonstrated adequate licensee capability in this area, the call did, however,
provide the following indicators that merit licensee consideration from the viewpoint of
determining whether training (and/or associated tests) should be strengthened or re-oriented
to better assure maintenance of the ability to respond to this type of event, as noted in the
Infonnation Notice cited above.
The licensee needs to ensure that appropriate emergency response information is
provided within 15 minutes.
Licensee staff should not hang-up on the caller.
Shipment manifests need to be more readily available to whomever has the
responsibility of providing off-hours emergency response information for radioactive
waste / materials shipments.
This area will be re-examined during a subsequent inspection.
{
l
7.0
Event Descriptions
)
l
l
i
!
7J
October 27.1993 Hich Radiation Area (HRA) Entry
On October 27,1993 two senior contractor RCTs discovered a plant equipment operator
(hereafter called opemtor) exiting a high radiation area on the Unit-3165'-elevation by the
1
l
l
1
i
l
'
'
i
.
>
.
7
fuel pool (FP) coolers. The RCTs challenged the opemtor on whether all requirements had
been met prior to entry. The RCTs interpretation of the operator's response was that the
operator had been given permission to enter the area by the operations RCT. Alsa, it
i
appeared to both RCTs that this individual possessed a digital alarming dosimeter (DAD).
One of the contractor RCTs chose to ensure that all pmcedural requirements had been met
and initiated a call to the operations RCT. At that time, the operations RCT conveyed that
l
the operations RCT had not provided the required briefing for entry into the FP cooler HRA.
The RCTs then discussed this situation with the on-shift HP Supenrisor who initiated a PEP
at that time. By chance, the same RCTs were in the HP instmment cage when the opemtor
turned in a DAD. Funher investigation on the pan of the contractor RCTs showed that the
DAD had been set to alarm at a cumulative exposure of 256 mmm rather than at the typical
setting (typically set at 128 mrem when provided to an operator) provided by operations
RCTs. Also, they found that the alarming dosimeter had not been signed out that evening.
This information was also conveyed to the HP Supervisor.
The inspectors interviewed the HP Supen'isor who explained how he initiated the PEP. In
summary, as the operator was found by contmetor RCTs who were not familiar with this
particular indis ' tal, the HP Supenisor discovemd the identity of the operator by security
l
key card entries.
!
The inspectors interviewed the operator who conveyed that he recognized that he was
entering a HRA, he had been previously briefed on what the dose rates were in the area (but
not this shift), and planned to complete his task within a couple of minutes. The operator
also conveyed that he did not contact the operations RCT nor any other RCT to receive a
briefing prior to the HRA entry. The operator also stated that he was not in possession of a
DAD as the RCTs had believed. When questioned by the inspectors, the operator conveyed
that his radiation worker training had been adequate and that there was no dictate from
,
l
management to complete the job within a specified time period.
12
October 28.1993 HRA Entry
On October 28,1993, operations personnel were attempting to restore the Unit-3 service
water system to service. Personnel were sent to several service water vent valves to close
them in suppon of the restoration process. At about 1725 hours0.02 days <br />0.479 hours <br />0.00285 weeks <br />6.563625e-4 months <br />, Opemtor 1 pmceeded to
the Unit-3 reactor building near the fuel pool heat exchangers in order to verify that tygon
tubing (direct discharge into floor drain) which had been attached to a FP heat exchanger
l
vent was still in place. Upon arrival, Operator I noted that the tygon tubing had blown off
and a senice water leak of 20 to 30 gpm was in pmgress. Operator I contacted the contml
mom and reponed the leak to Shift Supervisor (SS) 1.
--
.
. - -
.
8
i
l
SS 1 then contacted SS 2 and the Service Water System hianager to have them mspond to the
leak. Meanwhile, RCT 1 arrived in the area while conducting a routine tour. Operator 1 -
and RCT 1 then left the area to make preparations for the HRA entry to shut the vent valve.
At 1729 hours0.02 days <br />0.48 hours <br />0.00286 weeks <br />6.578845e-4 months <br />, SS 2 arrived at the FP heat exchanger area and mdioed the operations RCT
(RCT 2) requesting that the RCT respond to the area with a DAD. The System hianager
also arrived at the area at about this time. Without pausing to fully contemplate his actions,
the System Manager proceeded to climb the ponion of a rigging scaffold that was outside the
l
HRA and proceeded across the vertical plane of the HRA boundary to shut the vent valve.
At this time, Operator 2 arrived in the area after hearing a repon of the problem. Shonly
themafter, the System hianager secured the leak. Operator 1 and RCT 1 returned to the
r
'
area. After a discussion, it was determined that additional actions were needed. At 1733
hours, the RCT 2 arrived and questioned Opemtor 2 on whether he had entered the HRA.
l
Operator 2 informed RCT 2 that he had not entered. RCT 2 did not pursue the matter
'
further.
Once licensee evaluation of the events described in Sections 7.1 and 7.3 of this repon
l
became common knowledge throughout the station, the individuals involved in the above
i
event re-evaluated their own actions and whether their msponse had been appropriate. After
discussing the situation with Operator 1, SS 2 mitiated a PEP.
'
,
The inspectors interviewed the System hianager (and other individuals involved in this
event). When questioned the System hianager conveyed that he did understand the
preparatory requirements associated with HRA entries and that his radiation worker training
'
was sufficient for him to carry out his assigned duties. The System hianager also conveyed
that he did not fully contemplate the situation prior to carrying out his actions.
i
The inspectors concluded that the System hianager understood the ramifications of his actions
,
i
and the imponance of following good radiation worker practices.
l
Figure 1 provides a licensee dmwing created after the rigging scaffold had been removed.
l
All individuals interviewed by the inspectors agreed that this drawing was representative of
the scaffolding and HRA boundary locations.
2J
October 29.1993 Respiratory Protection Requimd Area Entry
On October 29,1993, an engineer prepared to evaluate insulation within the Unit-3 drywell
and take pictures of a residual heat removal (RHR) testable check equalizer valve and three
other similar valves. These pictures were needed to assist in trouble-shooting deficiencies
found as a result of pmssure testing these valves.
l
_
_ _ . . _ . _ _ _ _ _ _
.
__ -_.-
. .
.
_.
__
,
i
!
i-
!
.
i
'
!
l
!
!
'
I
i
!
9
!
I
{
Prior to drywell entry, the engineer was briefed by RCT I (a contractor). The engmeer was
i
told to stay below elevation 157' due to in-progress fuel movement and above 135' due to
l
]
contamination concerns below that elevation. RCT 1 also pmvided information on the
!
j
radiological conditions near the RHR testable check equalizer valve noted above. The area
!
j
around this valve was roped-off and posted "mspiratory pmtection equipment required",
!
since the insulation had been recently removed in the area. RCT 1 told the engineer that he
j
should not enter this roped-off area. The engineer was also told that air samples had been
'
taken (approximately 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />) and the results would be available later. At that time, the
l
1
engineer felt that taking the pictums fmm outside the roped-off ama would meet his needs.
i
!
Prior to entering the drywell, RCT 2 who was monitoring radiation worker undressing,
,
j
reaffirmed to the engineer that he should not enter the roped-off area and also offemd to take
l
l
the pictures for tia engineer. The engineer declined this offer. Upon entering the drywell,
l
4
RCT 3 (the drywell RCT mver) also conveyed to the engineer that he should not enter the
!
'
roped-off area. The engineer attempted to take pictures from outside the roped-off area, but
could not get acceptable pictures because insulation blocked part of the valve from view and
j
the distance was too great.
2
i
1
During the inspectors' interview with the engineer, he conveyed that he decided to find out if
l
the airborne sample results had been obtained and whether the respiratory protection
i
equipment mquirement could be removed. He exited the drywell and proceeded to the first
j
step-off pad and attempted to get the attention of a drywell control point RCT. The engineer
j
conveyed that the RCT was very busy at that time and the engineer decided not to interrupt.
l
At this time, RCT 3 was conducting a survey on drywell elevation 116' and RCT 1 was
j
counting the air samples taken after insulation removal.
4
j
The engineer then re-entered the drywell. The engineer proceeded into the roped-off area to
i
take the pictures. During the inspectors * interview with the engineer, the engineer conveyed
'
that he had reasoned that since the insulation had been mmoved about a half-hour before and
the drywell ventilation system was operating, there was little likelihood of any suspended
{
radioactive material remaining in the mped-off ama. Subsequently, the engineer was found
j
in the roped-off area by RCT 3, who told him to leave the area. The engineer asked if it
j
would be acceptable for him to remain in the drywell to take other pictures. RCT 3 allowed
j
this to take place and did not exercise stop work authority.
RCT 3 then informed RCT 2 of what had taken place. Subsequently, RCT 2 informed RCT -
1, who had by this time returned from the air sample counting facility. RCT 1 then took
j
action to remove the engineer from the drywell and informed the drywell HP Supervisor of ~
]
the event. This information was then conveyed to the Radiation Pmtection Manager and a-
j
PEP was initiated at this time.
i
4
i
j
1
i
a
- .
,
-
-.
- -.
_ _ - _
10
When questioned by the inspectors, the engineer conveyed that his radiation worker training
had been adequate, but he had made very few drywell entries since PECo's reorganization.
The engineer also conveyed that although there was pressure to complete the outage, <mtion
management had neither dictated nor condoned avoiding safety requirements in order to
complete tasks more quickly. The engineer confirmed that he had been instructed by RCTs
1, 2, and 3 not to enter the respiratory protection required area and that RCT 2 had offered
to take the pictures for him. The engineer confirmed that he entered the respiratory
protection required area without a respirator.
The inspectors concluded that the radiological safety significance of the event was low since
the insulation removal team lapel air samples ranged from 1.3 to 3.3 MPC-hours at a nearby
valve. The low-volume air sample result was 0.6 MPC-hours and the general area air
sample result was < 7.5x10' microCi/cm gross activity. These samples were taken at
3
least forty minutes prior to the engineer's entry into the respiratory protection required area.
The engineer successfully frisked out of the radiologically contmiled area and was not whole
body counted.
Figure 2 provides a licensee drawing of the 135'-elevation respiratory protection required
area. The engineer agreed that this drawing was representative of the boundary as it existed.
One radiological controls weakness was noted in the response to this event. The drywell
roving RCT allowed the engineer to stay in the drywell to take pictures of other drywell
areas, instead of using stop work authority when appropriate.
8.0
NRC Conclusions
11
Aoplicable Requirements
Licensee Procedure A-C-107, " Radiation Work Permit and Radiological Controlled Area
Access Requirements", requires that individuals be responsible for the following.
Complying with established posting in the RCA.
a.
b.
Complying with the requirements of the appropriate RWP.
Notifying HP of any radiological problems encountered during RCA entries.
c.
d.
Notifying Health Physics of any change in radiological conditions during RCA
entries.
Complying with written and oral radiological instructions given by HP.
e.
,
4
)
4
11
l
Technical Specification (TS) 6.1I states that " procedures for personnel radiation protection
4
shall be prepared consistent with requirements of 10 CFR Pad 20 and shall be approved,
maintained and adhered to for all operations involving personnel radiation exposure."
,
TS 6.13.1 states, in pan, "In lieu of the " control device" or " alarm signal" required by
paragraph 20.203(c)(2) of 10 CFR 20, entrance into an HRA shall be controlled by issuance
,
of a Radiation Work Pennit. Any individual or group of individuals pennitted to enter such
,
areas shall be provided with or accompanied by one or more of the following.
j
3
1.
A mdiation momtoring device which continuously
'
indicates the radiation dose mie in the area.
2.
A radiation monitoring device which continuously integrates the radiation dose
-
rate in the area and alanus when a preset integrated dose is received. Entry
into such areas with this monitoring device may be made after the dose rate
levels in the area have been established and personnel have been made
knowledgeable of them.
3.
An individual qualified in radiation protection procedures who is equipped with
'
a radiation dose rate monitoring device. This individual shall be responsible
for providing positive control over activities within the area and shall perfonn
]
periodic radiation surveillance at the frequency specified by the plant health
'
physicist or his designee on the Radiation Work Permit."
i
M
October 27.1993 HRA Entry
4
i
The entry into the FP heat exchanger HRA by the plant equipment operator without pmper
HRA controls, proper briefing, and proper adherence to the HRA posting constitutes an
apparent violation (50-277/93-27-01).
The incident was promptly and properly reported to NRC.
The violations were self-identified by the licensee.
j
The results were of low radiological safety consequence.
)
Licensee event investigation was very good. Nothing additional of great relevance
'
was learned in the interviews conducted by the inspectors.
Significant disciplinary actions have been taken.
M
October 28.1993 HRA Entry
.
The entry into the FP heat exchanger HRA by the system manager without pmper HRA
controls, proper briefing, and proper adherence to the HRA posting constitutes an apparent
violation (50-277/93-27-02).
,
e
_ _ _ _ _ _ _ _ _ _ _
. .
. ..
.
..
..
.
.
..
.
12
The incident was promptly and properly reported to NRC.
The violations were self-identified by the licensee.
The results were of low radiological safety consequence.
Licensee event investigation was very good. Nothing additional of great relevance
was leamed in the interviews conducted by the inspectors.
At the time of the second ponion of the inspection, the licensee was still investigating
this issue and had not detennined whether disciplinary actions wem appropriate in this
case.
8.4
October 29.1993 Resoiratory Protection Recuimd Area Entry
The entry into the drywell 135'-elevation RHR valve 46B respiratory protection mquired area
by the engineer without the proper respiratory protection area controls, proper briefing, and
proper adherence to the posting constitutes an apparent violation (50-277/93-27-03).
The incident was promptly and properly reported to NRC.
The violations were self-identified by the licensee.
The results were of low radiological safety consequence.
Licensee event investigation was very good. Nothing additional of great relevance
was leamed in the interviews conducted by the inspectors.
Significant disciplinary actions have been taken.
!L5
Rverall
The inspectors concluded that the radiological safety consequences of the three events were
minimal. However it appears that, some radiation workers wem not properly sensitized to
radiation health and safety. The inspectors found that this was a causal factor to some
degree in all three events. Also, some radiation workers were not properly sensitized to the
importance of compliance with instructions provided by radiological contmls staff.
NRC considers these events as significant because of the following reasons.
Two of the events appear to be willful in nature.
Although the events were of low safety consequences, any failure to comply with
established radiological safety controls is important.
The three events happened in a short period of time.
Previous examples of complacency towards radiation health and safety have been
identified.
PECo and NRC have identified worker complacency toward radiation health and safety as a
causal factor in several events over the past several years. It is recognized by the NRC that
licensee management had attempted to address this problem in preparation for the Unit-3
i
'
.
!
I
a
13
refueling outage by using broad methods, applicable to all station personnel. Such attempts
included formal communication fmm upper management and enhanced supen'ision. Based
on the concems identified above, the inspectors concluded that PECo has not been fully
effective in maintaining proper worker sensitivity toward radiation health and safety.
It is also important to note that in all three cases those involved had rationalized the
radiological safety consequences of their actions to some degree prior to carrying out the
actions described in Section 7.0, rather than deferring such decisions to those personnel
trained and experienced in dealing with the hazard.
With the exception of the failure to exercise stop work authority noted in Section 7.3, the
'
licensee radiological controls staff's response to these three events was appmpriate.
9.0
Exit Meeting
The inspectors met with licensee representatives at the end of the first part of the inspection,
on October 8,1993. The inspectors reviewed the purpose and scope of the inspection and
discussed the findings. The licensee acknowledged the findings and stated their intention to
address the issue contained in Section 6.0.
Additional inspection of the licensee's radiological controls progam was conducted on
November 8-10,1993. The findings for this portion of the inspection were pmvided on
November 10,1993. The licensee acknowledged the findings and stated their intention to
address the issues contained in Section 8.0.
,__
__
!
I
Figure 1
I
,
PsAPI - RADI AlION - CONTA':INATION - SURVEY RECORD
'
SURVETCP
REP NO
WRF NO
DATE
II WE
UNll 2 ( ) UNIT 3 (X) RW t i EL E Vt ,$ts'_0"
DESCRI PTI ON: FPCW HE AT EXCHANCER ARE A
ARE A A R3-40
RE A$CN FOR SURTEY
. . . .
R!tyTINE l l $PECI AL { j UPD ATE t 3 RmP,c
1
!
RADIAT20N
CDN T A MI N A TI DN
--
_--AI R S AWPLE RESULTS
INSTRuvENT TYPE
5.h.
C A L.DUE
INSTRUWENT TYPE
I .N.
C A L.DUE
SAMPLE
5.N._ CAL DUE
/J_
__
/ /
_./ /
EAWPLE f
i
_ J _/_ .
__!_
'
SANFLE E
l
_ _
J._ J_
_
/
J_ $ A WPL E 0
,
i
- * *
. . '
. , . ' , '
I
h '." ?
- *
P*.
ITEu
Rtsplts
'
/
l
NO.
mR /hr
l dpm/100ce'
'
,
JcN
hvrac>amtv sc A.reost)
2
. ji
b.
c coev usucnoo
'
a
'
d
hNTr
We
a
ceme, @ThT
i:t" **4
l
5
l
,
e
s
i
3
I
'
l
5'
'I
'
h
1 Se.V 3
~ E
1
l
y [,
'
,
'
E
3
C
]
E
J
in
'
11
e
2
i
'
'
12
- i
-
-
l
8-
ts
a
14
j
,p
T
l
is
'
,
,
O
-!
!
1'
!
18
\\ct>W DoWlx
C.LAMT.>ET) l
l
1s
Outo twEl
l
20
i
21
1
% c., Mrfo.b 8:
y
'
e
i
I
e
f
II
I
a
Y
a
u
l
%,
l
<
,,
l
houwW k
l
2s
&
l
27
'"
e
s
e
as
!
s
s
l
in
i
ac
'
at
f
,
l
l
3r
j
37
-
sl -
i
33
l
!
34
'
,
l
as
'
..
,
.,
m
,
8
8
se
!
i
i
e
e
e
37
l
l
sn
as
,
e
i
40
0
t
i
e
41
s.__________________________________________.s
q
3.h=d=H
EWEAR
i
sog NOTE S CCMT Act RE ADING IN eR/hr UNLE3S NOTED.
1.
X-X-X * T APE AND RDPE
2.
XXXX = ROPEC ARE A
4. ~#: r C.A.
5.411
7. s. *Jll r
7,#/#: g/r o.a.
a. $ #/ A'=
y/r
s. * # / # = (/r
s o.
i t, [T/s1. A r n s A wet E
y 5 t a"
- /#
F/y 9 18"
REWARK32
RE VIEWED BYt
DATE:
/
/
PACE:
R3-40 news sistros
,
_
a
r*
-
-
-
- - - -
~
l
Figure 2
-
'
196-89207(9'89)
PBAPS - RADI ATIDM - CDNTAli! NATION - IURVEY RECORD
RTP NO
WRF NO
DAir
i
i
yg ge
.
suRVEYDR
.
UNIT 2 ( l UNIT 3 (I) RW t i ELEv 13 E'-D*
DESCRIPTIDus ERYWELL PLATFORW CEN ARE A
ARE A 8 0/F 3-13 TD 24
' RE AIDN FDR SURVET
ROUTINE I 1 IPEDI AL I I UPD ATE i 1 RsPoe
I
i
l
-RADI4TIDM
CONT A MIN ATI DH
/ * P. S AWPLE RESULTS
!
IRSTRUnENT TTPE
3.N.
C AL JUE
IN31RUWENT TTPE
3.N.
DA L.DUE
SAMPLE
!.N.
CAL DUE .__/ i
_ _._ / /_
i
r_ _.IAMPLE f
i , __ S AMPLE 8
,,,,___/__/_
i
l
._/_ /_
/ _/
3AWPLE #
l
'
l$HEET 1l
l
bemur ov e h.vou e
h
j
I
ITEM
RESULTS
b9
7O
N!1
sA/hr
don /lDDee'
j
78-
l
k'." ? -)Y
@N 3EW\\1stbq.
330
J.'.N [
.%'.
'
1
-
i
hcznoo
2
,
. . . .
!
. *h'*
3 0* [*.
Ok3 10-2-%
s
%-
-v. . .
4
l On 3-13
M @ @.
D/V 3-24
g
.
- \\
!
Y
L
8
r
q
!
l
T
.3
"
,-
,.
.,
,
00
~!
D/W 3-23
.s.
9
'/5.
/
g g *k ,
10
j
y.,
D/a 3-14
'
,
l
- d
N
-
"
"
s
,
!
%rna
14
D/W 3-22
i R9R
15
.
O
i
" " ' - ' '
> +
,
V. h
b
.*..
J
e o-
'
?
- q
.._..4...._.(f.i
g,,
-
{
,
RD*
(
,,
w
p'.
[
k,
-
-
2
i
DN 3-21
22
l
g ,, ,
Tes
,_
2B
f'.*-
!
',5 w i (
.
y
'
'
' M R'
24
,,
,
1s
je:.
,
.-v
- s
as
,
.
,
.
!
'
{.,.
DN 3-18 l DN 3-18
120' ,.'N
27
. e.<
.i: .: -
1e
'
.
I'.(fD
$
0/W 3- 7
>/ g
28
D/W 3-20
b
3
-
-
c
88
Y
_s
u
I
-
s
32
2:
l
~
~
3a
~
'
~E
l
34
isi
Wwm
/
=
.
3s
.
.
$.)
2 D*
l
, . , ,
,.g
%%
v.
-
,,
. c.
W.1..
3,
ibh4.
,,
3e
as
4D
41
42
L
- CENDTES CDNT ACT RE ADING IN mR/hr UNLESS NOTED.
1.
X-I-I = T APE AND RDPE
2.
EXKX = RCPF.D AREA
3. @ =
WEAR
J
.R = r D.A.
E. *J = r
G. 1.l=. r
7.#/N= F/r D.A.
8.ikHl.L= s/r
s._tRJ L= v/r ID
=
N
4.
11. E = AIR S AWPLE
- Y 01E*
- /#
f/r 8 18"
REWARK$2
__
REVIEWED BT
EATE:
/
/
PAEE:
D/W 3-13 ID 24 atrW sitt/st
1