ML20215G399
| ML20215G399 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/18/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8706230240 | |
| Download: ML20215G399 (11) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET 1
4 P.O. BOX 8699 PHILADELPHI A, PA.19101 '
- (215184 8 5C21 4
. aossen w. sattaowsa June 18,'1987
.m........n...
50-278 Mr. William F. Kane,~ Director Division of Reactor Projects
, =
' Region I
.U.S.
Nuclear' Regulatory-Commission ATTN:
Document Control Desk Washington, D.C.
20555
SUBJECT:
Response to Combined Inspection Report 50-277/87-07 and 50-278/87-07
Dear 1Mr. Kane:
Your letter dated May 12, 1987 transmitted Combined Inspection Report 50-277/87-07 and 50-278/87-07 for the inspection period of February.1, 1987 to March 13, 1987 at the Peach Bottom. Atomic Power Station.
During this inspection
-period, an in-depth review of the radiological controls area was o
conducted.
As a result-of this1 review, it appears that one activity was not being conducted in full compliance with Nuclear Regulatory Commission requirements as set forth in the Notice of Violation, identified as Appendix A of the Inspection Report.
Additionally, a number of-weaknesses were observed in the implementation'of our radiation protection program.
These weaknesses are identified in the cover letter of the Inspection Report. to this letter is our response to the Notice of Violation. is our response to the identified weaknesses.
As discussed in the Inspection Report, Philadelphia Electric Company is implementing positive changes in the radiological controls area at the Peach Bottom Atomic Power Station and at the corporate office in the Radiation Protection Section.
These changes reflect an effort by Philadelphia Electric Company management to upgrade the programmatic and field implementation aspects of the overall program.
The commitments
. presented in this response reflect our efforts to continue the upgrading process.
60 8706230240 87061B I
l PDR ADOCK 05000277 f
G PDR 1/
Mr. William F. Kane Page 2 The commitments contained in our response will be included in the Peach Bottom Commitment to Excellence Program tracking system.
Further discussion of our improvements in the radiological. controls program will be submitted for your review and approval as part-of the plans for restart of Peach Bottom j
Units 2 and 3 in accordance with the " Order Suspending Power
{
Operation and Order to Show Cause",
dated March 31, 1987.
This Inspection Report was originally due to the Nuclear Regulatory Commission on June 11, 1987.
Mr. W. M. Alden (Nuclear Licensing, Philadelphia Electric Company) discussed the need for a one week delay in responding to this report with Mr. J.
Linville, of your staff.
This extension was found acceptable.
If you have any questions or require additional information, do not hesitate to contact us.
Very truly yours, i
Attachments cc:
Addressee T. P. Johnson, Resident Site Inspector l
ATTACHMENT 1 PagD 1 of-4 3
Violation.
10 CPR 20.202(b)(3) defines a "High. Radiation Area" as any area, accessible to personnel, in which'there exists radiation originating in whole or.in part within licensed material at such levels that a major portion of the body-could receive in any one hour a dose in excess of 100 millirem..
10 CFR 20.203(c)(1) requires that each high radiation area shall be conspicuously posted with aLsign or signs bearing the radiation caution symbol and the words " Caution" or
" Danger - High Radiation Area."-
ContraryLto the abovej on February 11,'1987, the upper platform of the drum capping station on the 135' elevation of the radwaste building'was not posted as a High Radiation Area.
Survey measurements performed inside the area indicated general area' dose rates up.to 220 millires/hr.
'This is a Severity Level IV Violation (Supplement IV).
- Admission or Denial of the Violation Philadelphia Electric Company acknowledges the violation as stated.
I Reason for the Violation This violation resulted from the upper platform of the drum capping station in the Radwaste Building not being posted with a " Caution - High Radiation Area" sign.
On February 9, 1987, a survey of the upper platform of the drum capping station was performed by a Health Physics Technician.
This survey was performed _in response to resin flushing which occurs in the area.
A statement was made by i
the Health Physics Technician that the area was posted with a
" Caution - High Radiation Area" sign.
It is suspected that 1
between February 9, 1987 and February 11, 1987 (identification of the violation), the " Caution - High Radiation Area" insert fell from the sign pocket which is attached to the rope barrier.
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F.
ATTACHMENT-1 Paga 2 of 4
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This lack of posting violated the requirements-of Health Physics Operating Procedure EPO/CO-ll, entitled " Establishing.
' and Posting Radiologically Controlled Areas".
-In' addition, plant personnel failed to reattach the rope barrier while accessing the area.
This is believed to have contributed to the insert! falling from the pocket.
Extent or Significance of the Violation The upper platform of the drum capping station is not a major-walkway or frequently populated ~ area.
Additionally, a ladder must be climbed to access the area.
Considering these factors in addition to the lengthy amount of time _needed to receive a significant exposure, this area does not present a significant high exposure risk to individuals.
- However, Philadelphia Electric Company does recognize that the failure to properly post a high radiation area is a potentially i
serious condition.
Corrective Actions and Results Achieved The area was promptly resurveyed and properly posted as a high radiation area.
Additionally, the post used to hold the rope barrier has been modified to hold the sign.
This will preclude the sign from being removed when the rope is
' detached for access.
1 This violation was investigated and dispositioned in Health Physics Deficiency Report No. 87-0119.
t Actions to Prevent Recurrence The following actions are being taken to prevent recurrence:
1.
A health physics team has completed visual inspection of all radiological control areas to identify any other posting and barricade problems.
Posting and barricade inconsistencies identified have been corrected.
2.
Station Health Physics Technicians have been reinstructed concerning the importance of correct postings and barricading for area radiation control in accordance with station procedures and 10CFR20.
They L
were also reinstructed in their responsibility in accordance with plant procedures to ensure that correct posting is maintained depending on changes in radiological conditions.
j
' ATTACHMENT 1~
Paga'3 of 4=
g
- ~
3 3.
? Plant' procedures concerning the routine' survey program have been revised and are under review.
These procedures will. enhance the control of station postings
'by:
T a. -
Requiring more understandable and conspicuous postings.-
a, b.
Incorporating more permanent methods 1for holding selected radiological signs and halting the routine use'of radiation rope for this purpose.
c.
-Increasing localized postings where needed.in order 2
to better define radiological hazards in the work-areas.
4.
A health-physics professional has been assigned the responsibility to monitor the posting and barricades at the Peach Bottos Atomic Power Station.
He will interface ~with management and~ technicians as necessary to upgrade the-overall posting program.
His responsibilities will include _ procuring better-quality and more prescriptive postings as appropriate.
These efforts'will continue until enhanced posting methods have become consistent'and routine.
5.
As a result of the identified weaknesses in the radiological _ program, Philadelphia Electric Company management has begun a comprehensive and systematic overall program upgrade.
All weaknesses in_the radiologicali controls area identified by the Nuclear i
Regulatory Commission, American Nuclear Insurers, and Institute of Nuclear Power Operations in addition to our own QA/QC and Radiation Protection Section Assessments are being tracked and scheduled for resolution.
Additionally, each major radiological area is currently under review for-necessary policy, program, manual, and/or procedure changes.
Management tools utilized as guidelines for the systemmatic enhancement of the radiological protection program include the MORT (Management Oversight Risk Tree Analysis) Appraisal Techniques as recommended in NUREG 0855, " Health Physics Appraisal Program," and other guides such as INPO 85-004, " Guidelines for Radiological Protection at Nuclear Power Stations," and INPO 85-029,
" Performance Objectives and Criteria for Corporate Evaluations".
Additionally, procedures are being developed which will track and trend health physics program performance
)
indicators.
This process will bring an increased degree
ATTACHMENT 1 Pigs 4 of~4 of. senior management awareness and involvement'into the ongoing program.
6, Health Physics' Technicians will be advised that failure
'to properly execute survey and posting procedures is considered to be a serious infraction and subject to appropriate disciplinary actions.
i i
ATTACHMENT 2 Prgs 1 of 5 Weakness:
"your radiation work permit system had significant weaknesses (paragraphs 9.4.1, 9.4.2)"
l Specific weaknesses identified with'this item are as follows:
l 1.
Survey requirements i
2.
ALARA review l
3.
Abuse of the " escort survey" method to reinstate a suspended Radiation Work Permit 4.
Radiation Work Permits are too broad in scope to control the work 5.
Inconsistencies between the Radiation Work Permit and associated ALARA reviews Philadelphia Electric Company has reviewed the identified weakness and considers it to be accurate.
Philadelphia Electric Company is upgrading the Radiation Work Permit system at Peach Bottom Atomic Power Station in order to eliminate inconsistencies in the system.
Additional program requirements will be derived from INPO 85-004, " Guidelines for Radiological Protection at Nuclear Power Stations" and INPO 85-029, " Performance Objectives and Criteria for Corporate Evaluations".
In response to these specific weaknesses, we have examined the entire Exposure Control System and are taking the following corrective actions to prevent recurrence:
{
1.
Health Physics Technicians are being given retraining in the f
proper preparation and use of Radiation Work Permits in l
accordance with plant procedures.
This training will be completed by July 15, 1987.
2.
The Radiation Work Permit procedure has been rewritten and is under review.
The intent of the new procedure is to eliminate the " escort survey" as an option in lieu of pre-job surveys.
Other identified inconsistencies will be eliminated by the new procedure.
ATTACHMENT 2 Pign 2 of 5 3.
ALARA personnel will receive additional training and will be responsible for ALARA pre-job review requirements as identified in. plant procedures in order to improve the effectiveness of the ALARA reviews.
This training will'be completed'by-September 1, 1987.
4.
The Health Physics Technicians will receive specific retraining with emphasis on responding to changing radiological conditions and exercising the stop work authority.
This retraining will be completed by July 15, 1987.
5.
' Currently active Radiation Work Permits requiring ALARA reviews have been analyzed for inconsistencies.
The results of this review have been used as an aid in. identifying weaknesses'and deficiencies in the ALARA review program.
6.
Philadelphia' Electric Company is implementing a system of total dose accountability and Radiation Work Permit required access control by July 31, 1987.
As part of this program, all areas designated as radiologically controlled areas will require a general or specific Radiation Work Permit for entry.
Precautions will be taken to ensure that general Radiation Work Permits are not used where a job specific Radiation Work Permit is necessary.
Weakness:.
" deficiencies noted in Quality Assurance Department audits had gone uncorrected for over a year (paragraph 9.2)"
Specific weaknesses identified with this item are as follows:
1.
QA audits require additional expertise for in-depth 1
reviews of more technical areas.
2.
No formal system or procedure exists which: a.)
identifies the significant program elements in the health physics area, and b.) requires that each element be audited every two years as required in 10CFR50, Appendix B.
3.
Internal audits which identify concerns are not corrected by the station.
4.
The Corporate Radiation Protection Section needs to
)
provide more formal involvement in the ongoing audit program of the station radiation activities.
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ATTACHMENT 2 Pega 3 of 5
~'
Philadelphia Electric Company has reviewed the identified weakness and' considers it be accurate.
Philadelphia Electric Company-is in the process of taking the
'following corrective actions to prevent recurrence of these specific weaknesses:
1.
Professional health physics personnel from the Radiation Protection Section have been trained on QA/QC procedures for performing audits.
These personnel are providing additional expertise to the Quality Assurance Department for in-depth reviews of technical areas of health physics.
Additionally, a health physics ~ training professional has been retained to provide a training course-on performing audits of radiation protection programs. 'This training will be provided to members.of the Radiation Protection Section'and QA/QC Groups by-July 31, 1987.
2.
'The QA Division Audit Section Instructions for' Health Physics Audits will be revised by' July 3, 1987, to describe significant program elements in the health physics area and require that these elements be audited over a two year interval.
3.
The Radiation Protection Section is_being restructured to include experienced personnel to increase the support provided to the station health physics program.
This group will provide oversite, tracking, and assistance as necessary to ensure that QA and other auditing group concerns are resolved in a timely manner.
Weakness:
"there was a perception that Operations Department personnel would not respond to health physics deficiencies (paragraph 9.1.4)"
Specific weaknesses identified with this item are as follows:
1.
A timely resolution of Health Physics Deficiency Reports sent to responsible Senior Engineers or work groups are not always apparent, i.e., Operations Group responses.
f ATTACHMENT 2' Paga 4 of.5 L
1 d
[2.
' Interviews.withzHealth-Physics. Technicians indicate:
there'is a perception that it is futile to generate a Bealth Physics Deficiency Report against'the Operations Group since'it will be ignored.
I' 3.
Prioritisation'for_ review of Health Physics Deficiency Reports-under investigation does not appear to reflect the significance ~of the Health Physics Deficiency g
Reports due to the lack of personnel, i
- Philadelphia Electric Company has reviewed the identified weakness and: considers-it to be accurate.
Philadelphia Electric Company is in the process of taking the following corrective actions to prevent recurrence of these-specific weaknesses:
l.-
An Operations Technical Assistant has-been added to the Plant Operations Group and will be responsible for expediting the resolution of Health Physics Deficiency Reports concerning the Operations Group.
- 2.
The Support Health Physics Supervisor has assigned additional personnel to handle the prioritization, investigation and resolution of Health Physics Deficiency Reports.
Weakness:
"the performance of surveys and the use of alarming dosimeters in high radiation areas were weak (paragraphs 9.4.3 and 9.4.4)"
Specific weaknesses identified with this item are as follows:
- l..
Follow-up on updating documentation is not timely.
2.
There is a lack of available alarming dosimeters at the instrument cage.
3.
Workers received no direction concerning the use of one alarming dosimeter to cover a group.
4.
Technicians appear to be individually interpreting requirements for High Radiation Area controls based on situational considerations and their experience at the
-last plant where they worked.
5.
Procedure EPO/CO-68 provides insufficient guidance on j
the use of alarming dosimeters.
l 1
Philadelphia Electric Company has reviewed the identified I
weakness and considers it to be accurate.
ATTACHMENT 2 Prga.5 of 5 c
As a' result of these specific weaknesses, Philadelphia Electric is in the process of implementing an extensive survey and posting program upgrade.
The following specific items will be included in this upgrade:
1.
A new procedure is in the process of being developed for the control and use of alarming dosimeters.
Station personnel will be trained on-this procedur's by July 31, 1987.
2.
A revised health physics organization is expected to be in place by September 1, 1987.
This will' include the addition of six first line supervisors and other professional staff upgrading.
3.
A procedure requiring first line supervision to review, initial, and date all survey data, and health physics log entries will be approved upon completion of staffing-the revised Health Physics Organization.
4.
Additional instructions in survey performance and documentation will be provided to Health Physics Technicians by July 31, 1987.
This instruction will emphasize the need to be aware of current and changing radiological conditions.
5.
The radiological controls surveillance program at the Peach Bottom Atomic Power Station is being upgraded to include the~ usage of preprinted or sketched survey maps to more graphically represent radiological conditions.
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