ML20154Q197
| ML20154Q197 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 05/25/1988 |
| From: | Shabansky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154Q182 | List: |
| References | |
| 50-146-88-01, 50-146-88-1, NUDOCS 8806060214 | |
| Download: ML20154Q197 (9) | |
See also: IR 05000146/1988001
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U.S. NVCLEAR REGULATORY COMMISSION
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50-146/88-01
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License No.
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Saxton Nuclear Experunental f orporation / GPU Corporation
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FM.Hity Neme: Saxton Reactor
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Inspection At: Saxton, PA and TMI Nuclear Station, Harrisburo PA
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Inspection Conducted: April 27-29 and May 3, 1988
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Inspector: 7 . [f
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1.h K.M.5h .nbaky, Chief, FaciiilTes Radiaf;13
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Inspection Sugary:
Inspection on April 27-29 and May_3 l983(96-146/88-01)
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Areas Inspeckeh
Routine, unannounced inspection by onc region-based inspector
to review raciahhn protection activities associated with the decontwination of -
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t'.Maxton Wucl e ar i Ex peri me n t al Cc epcra ti or. J (SNCC ) .
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surve (section
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Deficiencie; w *re also noted with the level o /
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pre-p anning,tection activities.' management oversi? tit, .wd attention to detail ass piat.?d
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DETAILS
1.0 Persons Contacted
1.1 Licensee Representatives
S. Acker
SNEC Radiation Safety Officer-designee
- +J. Auger
PWR Licensing Engineer
- +G. Baker
SNEC General Manager
- +0. Etheridge
SNEC Radiation Safety Officer
- +J. Garry
Saxton Site Supervisor, GPUN
+J. Hildebrand
Emergency Preparedness and Environmental
Controls Director, GPUN
- D. Husking
- +S. Molello
GPUN Environmental, Oyster Creek
- C, Pollard
Radiological Assessor, GPUN
- M.
Roche
-Vice-President, SNEC
- H. Teichmann
- G.
Tomb
Media Relations Manager, GPUN
1.2 NRC Representatives
A. Adams, Jr.
Saxton Project Manager, NRR
- +M. Shanbaky
Chief, Facilities Radiation Protection Section
Region I
- +A.
Weadock
Radiation Specialist, Region I
- Attended the exit interview on 5/3/88.
+ P;..ticipated in a telephone conference call on 5/16/88.
Othe licensee personnel were also contacted during the ' course of this
inspaction.
2.0 Purpose
The purpose of this routine, unannounced inspection was to review radiation
protection activities associated with the Saxton Nuclear Experimental
Corporation (SNEC) reactu site.
The following areas were included in this
review:
- status of previously identified items,
- status of decontamination efforts,
- status of ongoing rclease survey effort,
review of SNEC records maintained at the TMI E0F in Harrisburg, PA,
- revicw of radiological status of the Saxton site soil.
.During the course of this inspection the NRR Project Manager visited the
site on April 28, 1988 for familiarization purposes.
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3.0 Status cf Previously Identified Items
(Closed) Violation 146/86-02-01): Failure to submit 15 day written
follow-up reports fo(r three Containment Vessel sump water samples in
3.1
excess of 10 CFR 20 activity concentrations in accordance with
Technical Specification requirements.
In response to the above violation the licensee initiated the use of
already existing GPUN procedures governing regulatory correspondence
at Saxton to insure required reports are made.
The inspector reviewed
Containment Sump sample results and corresponding 15 day reports for
sump samples collected during the last quarter of 1986, all of 1937,
The inspector did note, however, quired for
Reports were generated as re
and the first quarter of 1988.
thnt the
all high activity samples.
'me from sample collection to report generation was typically
.approximately 30 days rather than the 15 day notification as required
bytheTechnicalSpecIfications.
This apparent untimeliness was also
noted and reported by the licensee's Operations QA group.
The inspector discussed the above timeliness concern with the
licensee. The licensee indicated that, due to the site's rcmote
location and need to ship samples back to TMI for analysis,
significant delays could occur between sample collection and analysis.
The licensee indicated they felt the "15 day clock" started when they
received the sample analysis results from the lab.
This was often 2-3
for delay and considered the licensee's response reasonable. potential
weeks after sample collection. The inspector recognized the
This
item is closed.
3,2
(Closed
Inspector Follow-up Item (146/86-02-02): Review Saxton
Radiolo ical Environmental Monitoring Program (REMP) annual reports
for 198 , 1983, and 1984.
NRC Inspection Report No. 50-146/79-01 identified specific areas
outside the Saxton site fence but within the PENELEC fence where soil
radioactivity concentrations ()rimarily Cs-137) were above background.
Review of the above licensee REMP reports also indicated above
background levels of Cs-137 activity are present in the soil within
the Saxton fence. The status of the Sexton soil and licensee plans
for additional evaluation are discussed in section 7.0.
This item is
closed.
As of the date of the inspection, REMP reports for 1985 and 1986 were
not available.
The licensee indicated that although samples had been
collected and analyzed for these periods, results had not received
final review and the final reports had not been issued.
The licensee
indicated an individual has been detailed to complete these reports
and stated during the conference call on May 16, 1988 that a
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comprehensive REMP report would be available by May 31, 1988.
This
report will be reviewed during a subsequent inspection.
4.0 Status of Decontamination Activities
From approximately July, 1987 to February, 1988, decontamination work was
p(erformed by the licensee in the Radioactive Waste Disposal Facilitythe Control
reduce), surface contamination levels to Regulatory Guide 1.86 limits.
RWDF
Easily removable items (partitions, vent ducting, etc.) were surveyed by
Health Physics (HP) technicians and released when appropriate. Material
above the release limits (including scabbled concrete and the sectioned
Refueling Water Storage Tank) was shipped offsite as radioactive waste for
burial or for additional decontamination / volume reduction.
The inspector reviewed radiological controis associated with the above
activities by the following methods:
- review of applicable SNEC procedures,
- review of the SNEC HP logbook,
- discussion with cognizant personnel,
- review of selected Operations QA monitoring reports,
- review of selected surveys,
- tour of the SNEC site.
Within the scope of the above review, one apparent violation, concerning a
failuvo to document a release survey, was identified and is discussed
below.
4.1 Failure to Document , Survey.
During a tour of the site the inspector noted that decontamination
activities in certain areas had been extensive; for example, certain areas
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of floor had been excavated in the CAB and RWDF.
During the tour the
inspector noted a residual cut section of a large (approx. diameter 22")
pipe jutting out of the pipe tunnel.
The licensee indicated the pipe,
which was originally approximatelv 20 feet long and ran below-orade from
the RWDF to the pipe tunnel, had been exposed and surveyed in August, 1987.
Approximately half of the pipe was released as clean material at that time.
The 1:censee indicated the remaining section of pipo (excluding the
resiQ al portion) was surveyed and released in March, 1988.
The inspector reviewea the survey perfor.ned in August,1987 and noted the
portion of pipe released at that time was clearly shown to meet SNEC
release criteria (i.e., less than 100 net cpm).
This survey showed the
remairing section of pipe included measurable activity above release limits
(200 net cpm).
The licensee stated that when this remaining section of
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pipe was released in March,1988, a suryny was performed and all sections
of pipe above r' lease limits were cut out of the pipe and disposed of
separately as radioactive waste. The licensee stated, however, that the
survey performed in March, 1988 was not documented.
10 CFR 20.201(b) requires the licensee to perform surveys as necessary to
demonstrate compliance with the regulations and as are reasonable to
evaluate radiation hazards.
10 CFR 20.401 requires the licensee to
maintain records showing the results of surveys performed to comply with 10
Based on collaborating evidence by several individuals
CFR 20.201(b)he pipe survey and disposal occurring in March,1988, the
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involved in t
inspector concluded that the licensee did in fact survey the pipe prior to
disposal but failed to document this survey.
Failure to document the
survey of the pipe demonstrating it met release criteria prior to its
disposal constitutes an apparent violation of 10 CFR 20.401 (146/83-01-01).
The licensee stated that it was felt the above deficiency in survey
documentation was an isolated instance and not a generic concern.
The
licensee also stated, however, that a review would be performed to insure
additional lapses in survey documentation had not occurred for material
that had been released.
The licensee also indicated that efforts would be
trada to retrieve the subject portion of pipe from the landfill to verify it
had been adequately surveyed.
Licensee efforts in this area will be
reviewed in conjunction with the licensee's response to the violation,
4.2 Audits of_ Radiation Protection Activities
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Both the TMI Radiological Assessor and the Operations QA group provided
independent assessments of activities at Saxton during the decontamination
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work. The inspector reviewed selected QA reports and noted that they
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identified repeated HP deficiencies, including the following:
- individual failing to frisk upon exit from a contaminated area,
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- individuals wearing clean protective clothing outside the site fence,
- repeated failure to appropriately label and seal drums containing
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scabbled concrete,
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- Inappropriate control of a drun containing scabbled concrete.
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Due to the low levels of contamination involved, the above instances do not
represent violations of NRC posting and labeling requirements. They are
indicative,however,ofalackofappropriatemanagementoversightand
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control of the decontamination work. The licensee s organization to
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support the work .nay have contributed to this lack of eversight: tath the
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decontamination workers and the HP technicians responsible for maintaining
radiological controls were supplied by the same vendor.
Consequently,
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there was not an effective organizational separation and independence of HP
and production personnel,
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The licensee indicated that upper management became aware of radiological
control concerns at Saxton and that personnel changes and upgrades were
made to' improve oversight. These included appointment of a new Radiation
Safety Officer and establishment of a GPUN qualified HP technician at the
site as lead technician.
The inspector noted these improvements were of
limited effectiveness; several deficient conditions reflecting a lack of
management attention were still observeable during the inspection and are
discussed in section 5.0.
The overall level of QA and Radiological Assessor involvement at Saxton was
noted to be a licensee strength and appeared to be effective in identifying
significant concerns.
5.0 Status of Release Survey Effort
The licensee started performing surveys to demonstrate the CAB, RWDF, and
the pipe tunnel are within the contamination limits of RG 1.86 (i.e.,
tsuilding release surveys) on February 1, 1988.
Surveys were still being
performed durin
The licensee is using
NUREG/CR-2082, g the time period of this inspection. Monitoring for Compliance Wi
Survey Criteria," as guidance for the performance of these surveys.
Completed surveys are reviewed by a qualified HP technician and then by the
Saxton RS0 or his designee to insure compliance with licensee procedure
9400-ADM-4500.12, "Radiological Surveys: Requirements & Documentation."
The insoector reviewed the licensee's performance in this area by the
following methods:
- discussion with cognizant personnel, including individuals performing
release surveys,
- review of selected release surveys
- review of selected Operations QR mo,nitoring reports,
- review of selected l'icensee procedures.
Within the scope of the above review, several significant deficiencies were
noted which collectively question the adequacy of the release surveys
parformed up to the date of the inspection.
The following specific
deficiencies were noted by the inspector:
o No specific procedure was in place to control the performance of the
building release surveys.
The inspector noted the licensee had approved
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both a radiation and contamination survey procedure; however these were
noted to be general in nature and did not address specifics being performed
during the building release surreys.
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The licensee stated that a draft "final survey" procedure ~had been produced
but that significant changes in survey methodology kept occurring which
created difficulties in keeping the draft up to date.
o Training for individuals performing building release surveys was informal
and incomplete. The inspector noted the licensee was using a practical
factor sign-off form, which indicated that individuals had demonstrated
proficiency in instrument use, as documentation that surveyors were
qualified to perform their activities. The inspector noted, however, that
no procedure was in place recognizing this sign-off form and that no lesson
plan or procedure was available to indicate how reviewers judged the
individual's proficiency before signing the form.
The inspector also noted
numerous surveys had been completed by individuals using instruments they
had not been signed-off on.
o Formal procedures did not exist for calibration of several of the
instruments used during the performance of the release surveys.
no approved calibration procedure exists for the PRM-6 and
Specifically,dditionally, although a calibration procedure is currently in
the ASP-1. A
place for the PRS-1 and PRS-2, these instruments were used prior to the
development of a calibration procedure.
For the above instruments,
calibrations were performed using the vendor manual as a guide.
This
concern was originally identified by the licensee's QA group,
o Completed building release surveys were of poor quality and did not meet
the requirements or standards of the licensee's survey documentation
procedure (9400-ADM-4500.12).
In addition to poor overall legibility, the
following deficiencies were noted:
- non-standard forrrs were used; consequently, required information
concerning instrument type, calibration date, etc., was not present
on each page of each su~rvey,
- survey information was given in pencil, rather than the industry
standard of indelible black ink,
- correction fluid was used to make corrections on some of the
surveys, rather than a single line-out with initials,
- extraneous comments not relevant to the survey had been included on
some of the survey sheets.
The inspector noted the above deficiencies existed on surveys that had
already passed initial and in some cases secondary review by the licensee.
In light of the above weaknesses in 3rocedures, training, instrument
calibration, and overall survey legi aility and level of review the
inspector concluded that the adequacy of the building release surveys
performed up to the present date was extremely questionable.
The inspector
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noted that the potential existed for several apparent violations of
Technical Specifications section 4.d which requires in part that radiation
surveysbeperformedinaccordancewithwrittenprocedures.
The inspector
"unofficial,however, that the status of the above release surveys was still" in that n
recognized
and the licensee had not formally submitted them to the NRC for review.
The licensee stated that the above deficiencies with the building release
surveys had already been recognized by licensee management.
During the
week of this inspection the Radiological Assessor and Saxton RSO held a
previously scheduled meeting to review the release surveys and assess their
adequacy and whether or not they could be used. During the exit meeting
senior licensee management stated that the following actions would be
completed:
- overall review of surveys would be completed,
- procedures for instrument calibration, c.Jalification of surveyors,
and for performance of the release sur"ey would be developed and
approved,
- all questionable surveys would be redine.
The status of the licensee's final building release surveys will remain
unresolved pending review of the above improvements (146/88-01-02).
The inspector stated during the exit meeting that licensee performance
during the decontamination and surveying activities was not commensurate
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with that seen at other GPU facilities and reflected a lack of effective
planning and management involvement. The licensee noted this concern and
stated that effective control may have been hampered, in part, by the
remoteness of the location and the heavy reliance on an extremely transient
contractor workforce.
The licensee indicated that several steps had
already been taken to improve the level of management control upon initial
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identification of performance deficiencies at Saxton (see section 4.0).
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6.0 SNEC Record Review
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On April 27, 1988, the inspector reviewed SNEC files maintained at the TMI
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E0F in Harrisburg, PA. No deficiencies were noted.
The inspector was
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unable to find, and consequently requested from the licensee the following
documents:
- copies of original site construction plans showing the location of pipes,
tanks, etc. in the site yard,
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- copy of the original site release survey performed in 1973.
The licensee indicated they would search their records and provide the
requested information if available.
7.0 Radiological Status of the Saxton Soil
A telephone conference call was held between the individuals denoted in
section 1.0 on May 16, 1988 to discuss radiological status of the soil in
and around the Saxton site fence.
During that call, the licensee indicated
the following:
- Contamination within the Saxton site fence appeared to be restricted to a
dark, flyash-like soil . The licensee indicated maximum activity levels
in this flyash-like soil ranged from 50-60 pCi/g.
The licensee
indicated typical background levels ranged from 2-4 pCi/g.
The inspector
noted that the licensee's 1982 REMP report showed an 870 pCi/g sample
taken within the "ro ed-off" area within the Saxton fence.
The licensee
was a more represent tive,ple result but indicated the 50-60 pCi/g range
acknowledged this hi h sam
repeatable value.
- Soil activity was primarily due to Cs-137 which appeared to be tightly
bound to the flyash-like soil.
- Surveys performed by the licensee outside the Saxton fence but within the
PENELEC fenca in 1986 identified several areas of localized soil activity
above background.
The maximum level identified was 2200 pCi/g Cs-137.
The licensee stated that soil in these localized areas was dug up and
disposed of as radioactive material.
The licensee also indicated during the call that they were currently
negotiating contracts to have additional characterization studies performed
on the Saxton site and immediate environs.
Planned studies include an
extensive aerial or ground radiation survey, a geophysical analysis of the
flyash-like soil and sub-soil at the site, and additional radiological
analyses of the soil.
Results of these studies will be reviewed during a
subsequent inspection.
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8.0 Exit Meeting
The inspector met with licensee representatives, denoted in Section 1.0 of
the report, on May 3, 1988. The inspector summarized the purpose of, scope
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and findings of the inspection at that time.
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