ML20096G008
| ML20096G008 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/31/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8409100310 | |
| Download: ML20096G008 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.Cl. 3OX 8699 PHILADELPHIA. PA.19101 SHIELDS L DALTROFF August 31, 1984 ELECTRIC PRODUCTION Docket No. 50-277 Mr. Thomas T. Martin, Director Division of Engineering & Technical Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Your letter of August 3, 1984, forwarded Inspection Report 50-277/84-18.
Appendix A addresses two items which do not appear to be in full compliance with Nuclear Regulatory Commission requirements.
These items are restated below along with our response.
A.
Technical Specification 6.4, " Training", requires, in part, training program for the facility staff meeting the requirements of Section 5.5 of ANSI N18.1-1971.
Section 5.5 of ANSI N18.1 requires, in part, special training sessions for replacement personnel.
A training program shall be established which maintains the proficiency of the operating organization by periodic training exercises, instruction periods and special training sessions.
Contrary to these requirements, licensee's Procedure No.
HPO/CO-80, used to train and qualify contractor-supplied l
Health Physics Technicians assigned to pipe replacement, did not include four approved radiation exposure control procedures developed specifically for pipe replacement.
These Health Physics Technicirns were responsible for implementing these radiation exposure control procedures.
This is a Severity Level I/ violation (Supplement IV).
8409100310 840831 PDR ADOCK 05000277 G
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~2 1'Mr.. Thomas T. Martin' August 31, 1984 Page 2 l
Response
- Atithe time the' training for contractor Health Physics K
Technicians:was administered in accordance with Procedure I'
HPO/CO-80, "Non-PECo Health Physics Technician Entry Procedure",cRev. 3, approved copies of procedures HPO/CO-501,
" Requests for:ALARA. Reviews", Rev. 1, and HPO/CO-503, "ALARA' E
Pre-Lab Review",.Rev. O, had not yet been distributed to the F'
' appropriate training personnel.
During this training, the 7
-technicians received training in draft versions of HPO/CO-501
- andLHPO/CO-503 which were1 included in the lesson plan.-
.A training _ session will be conducted for the contractor.
g HealthfPhysics Technicians.who did not receive training in the approved procedures. HOP /CD-501.and HPO/CO-503 and will be documented on the HP'Techn' ian Training Qualification Record of HPO/CO-80.
This. training will be completed by September.
^
14, 1984.
'Following this inspection,.the Chicago Bridge.and Iron ALARA i
Administrator for pipe ~ replacement activities instructed contractor Health Physics personnel on the content of. ALARA Program, Instruction No. 1, " General Program. Instruction for Maintaining Occupational Exposure to Radiation As Low As Is
-Reasonably Achievable - (ALARA)" and. ALARA Program Instruction No.12, " Specific Program Instruction for Maintaining 9
L
~ Occupational Exposure to' Radiation As Iknt As Is Reasonably Achievable ( ALARA) ".
This training-was accomplished by distributing-_an instruction manual-to the contractor -Health Physics technicians for their review. prior to conducting a classroom session on these.
7 L
procedures.
Attest was administered to the technicians' prior
~
L to :the start of the. classroom session and evaluation.of the F
performance.of the technicians.inLthe quiz and classroom discussion is documented and maintained by the Peach Bottom Support Health Physicist.
' Procedure HPO/CO-80 will be revised.to include procedures
'HPO/CO-501 and:HPO/CO-503.- Additionally, it will be_ revised L
so that. the. Peach Bottom Support Health Physicist may specify unique training requirements for contractor prepared Health
. Physics procedures to be utilized at Peach Bottom for special It is: expected that the revision to HPO/CO-80 will'be E
- jobs.
-completed by October 1, 1984.
p
'B.
. Technical Specification 6.11, " Radiation Protection Program,"
requires, in part, adherence to procedures for personnel p'
radiation 1 protection.
Licensee's Procedure No. HPO/CO-4 U
~I.
. _ _ _. _ _ _ _. ~. _ _., - - -.. -. _ _. _ _ _ -.... _. _ _. _. _,..... _., _ _. - -,
I Mr. Thomas T. Martin August 31, 1984 Page 3 requires, in part, a-radiation work permit containing specific requirements for radiological exposure controls.
Contrary to the above, on several occasions during May and June 1984, Radiation Work. Permit No. 2-94-0290, " Unit 2 Drywell, Pre-Decon Work, " was used for the removal of hydraulic snubbers by contractor personnel and did not provide specific radiological exposure contro...
This~is a Severity Level IV violation (Supplement IV).
Response
Radiation Work Permit (RWP) No. 2-94-0290 was prepared to cover all contractor pre-decontamination work in the Unit 2 drywell.
This included removal of 25 snubbers to facilitate
. pipe replacement.-
The use of this single RWP for predecontamination activities in lthe drywell did not provide for specific radiological controls due to the large variance of radiological-conditions throughout the drywell during this phase of work.- Therefore, Health Physics Technicians were required to provide the specific radiological controls for each task to be performed.
As a result of this Inspection Report, use of the single RWP for the pre-decontamination tasks was terminated on June 21, 1984.
In accordance with Health Physics procedure HPO/CO-4,
" Radiation Work Permits," specific RWP's were prepared for each task to be performed prior to pipe decontamination which contained survey data and radiological exposure controls unique to each task which was performed.
Should you have any questions or require additional information, please do not hesitate to contact us.
Very truly yo rs,
='
j
- cc:
Mr. A. R. Blough, Site Inspector li