IR 05000277/1989009

Insp Repts 50-277/89-09 & 50-278/89-09 on 890307-10.No Violations Noted.Major Areas Inspected:Radiation Safety Program Including:Auditing,Training,New Dosimetry Sys & Respiratory Protection Program

ML20245B442
Person / Time
Site:	Peach Bottom
Issue date:	04/19/1989
From:	Dragoun T, Geyer A, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20245B439	List: IR 05000277/1989009 ML20245B438
References
50-277-89-09, 50-277-89-9, 50-278-89-09, 50-278-89-9, NUDOCS 8904260110
Download: ML20245B442 (6)

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION I

.50-277/89-09

. Report N /89-09 50-277 Docket N DPR-44 License No. DPR-46 Priority -

. Category C Licensee: Philadelphia Electric Compary P. O. Box 7520 Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: March 7-10, 1989 Inspectors: / _

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b ( _Lon y /9 /c/G T.~ Drag Senior Radiation Specialist / date/

b YM A.GeyW,fadiationSpecialist /

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Approved by: M. 5 / M M. Shanbak9, Chief, F6cilities Radiation

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~/ dit'e Protection Section Inspection Summary: Inspection on March 7-10,1989 (Combined Inspection Report Nos. 50-277/89-09 and 50-278/89-09 Areas Inspect ! Routine, unannounced inspection of the radiation safety program incluu- 9: auditing; training; the new dosimetry system; and the respiratory protection progra Results: No violations were observe '

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DETAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted:

1.1 Licensee Personnel

• D. M. Smith, Vice President, PBAPS E. Till, Superintendent of Training

• A. Sherwood, Supervisor - Training Services

• E. Barnett, Senior HP Instructor

• G. McCarty, Supervisor - HP Support D. Rockwell, Health Physicist - Respiratory Protection H. Paust, Health Physicist - Dosimetry J. McFadden, Corporate Radiological Health M. Kaminski, Corporate Radiological'. Assessments

• J. Cockraft, NQA Superintendent

• M. Moore, NQA D. Charles, Performance Assessment Division (Corporate)

P. Swafford, Supervisor - Applied HP 1.2 NRC Personnel

• R. Urban, Resident Inspector ,j

• Denotes attendance at the Exit Meeting held on March 10, 198 Additional personnel were contacte .0 Purr se l The purpose of this routine, unannounced inspection was to review the following elements of the licensee's radiation protection program:

-Audits and Assessments of the Health Physics (HP) Program-General employee training, general respiratory training, and ,

HP Technician Training-Changeover to the Panasonic Dosimetry System-Respiratory Protection 3.0 Audits Requirements for the conduct of audits and assessments are contained in Technical Specification 6.5.2.8 " Audits" and 10 CFR 50 Appendix B. The licensee recognized the need to improve self-assessments in the " Plan for Restart of Peach Bottom Atomic Power Station" submitted to the NRC in April 1988. In addition, the Radiation Protection Manual states that the Corporate Director-Radiation Protection Section ensures periodic assessments of HP program The inspector reviewed the status of the auditing programs through:

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-interviews with individuals from Nuclear Quality Assurance (NQA),

Corporate Radiation Protection Section (RPS), Corporate Plant Assessment Division (PAD), and site HP Supervision-raview of audit reports and the results of an in progress NQA audit of ALARA and work controls-review of the management analysis of Radiological Occurrence Reports (ROR)

Within the scope of this review no violations were observe The audits conducted by the NQA satisfy the base linc T9chnical Specification requirement Use of the ROR to identify pro 1rammatic weaknesses has significantly improved. Prompt corrective ac ion is now required for i RORs, while the Applied HP Supervisor conducu. i root cause analysis for ';

long term corrective action and to identify trends. Certain trends have been tentatively identified, including poor worker practices, procedural violations and RWP violations. Licensee action on these trends will be reviewed in future inspection Performance of corporate assessments as described in the " Plan for Restart of Peach Bottom Atomic Power Station"Section I has significantly change The Corporate Director of Radiation Protection Section (RPS) had previously stated that each quarter a formal team inspection by technical experts would be conducted and a formal audit report would be issue (Reference Inspection Report 50-277/87-07 and 50-278/87-07) These efforts i were reoriented after losses and transfers of RPS personnel. The revised approach is now reflected in Nuclear Group Administrative Procedure (NGAP)

No. 05A00 Quarterly assessments are now conducted by one assessor and l the results provided to the line manager at the statio Followup on open l items is done by the assesso !

The effectiveness of this new approach in achieving the April 1988 Restart Plan goals will be reviewed in future inspection .0 Training The licensee training programs for HP technicians and general employee training were reviewed with respect to the criteria contained in:

-10 CFR 19.12 " Instruction to Workers".

-Regulatory Guide 8.29 " Instruction Concerning Risks from Occupational Radiation Exposure".

-Technical Specification 6.3, Facility Staff Qualific6 tio Technical Specification 6.4, Trainin ANSI N18.1 1971 " Selection and Training of Nuclear Power i Plant Personnel".

Licensee performance relative to these criteria was determined from observation of classroom training, a tour of training facilities, review i

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1 of selected documents and interviews with personnel. No violations were _

observe Strengths and weaknesses were noted as follows: i The Applied HP Supervisor stated that future HP Technicians must meet the I criteria of ANSI 3.1-1987 to be fully qualifie This latest standard requires more training and experience while limiting credit for 3 non-commercial and military experience. -

The training program is now well documented in Training Procedures (TP).

Lesson plans are backed by a detailed job task analysis. This results in a well structured approach to training. Observation of refresher training for HP technicians indicated a good technical depth of material and good presentatio The facilities continue to be poor. Temporary trailer buildings are used for offices and classrooms. There is no " laboratory" environment for use by instructors and HP Technician trainee The Station Vice President stated that a permanent training facility for general employees and HP Technicians will be designed by July 1989, construction will begin in August 1989 and occupancy will ' occur in July 1990. Progress will be reviewed in future inspection The training staff has been certified through an in-house qualification progra However, a review of resumes indicated that one instructor lacked sufficient academic training and applicable experience. The 4 Superintendent of Training stated that this instructor has been placed in an individualized upgrade program. In addition, the certification process has been improved and new procedures issued. The existing staff will satisfy the new requirements by the end of April 1989. These  ;

matters will be reviewed in a future inspectio '

Of five training supervisor positions, two are filled. Contractors are used to develop procedures and lesson plan Key positions continue to be vacant. The organization structure is different from other stations in that Maintenance, I&C, GET, GRT and HP Technician training are lumped in the same line organization creating an excessive span of control for one superviso The licensee stated that some staffing and organization realignments are being considered to improve trainir.g. The Station Vice President stated that vacant training department positions will be filled by September 198 This matter will be reviewed in a future inspectio .0 Replacement Dosimetry System Early this year the licensee replaced the dosimetry of record with a Panasonic 4-chip TLD Model #80 The inspector reviewed the implementa-tion of this new system through interviews with the site Dosimetry Supervisor and the Corporate Radiological Health Branch Supervisor and a review of procedures and selected records. Within the scope of this

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review no violations were observed. The dosimetry program is adequate to ensure compliance with the requirements in 10 CFR 20.202, Personnel Monitorin Dosimetry badges are collected on site monthly by dosimetry clerks and new dosimetry is issued at the same time. Pre-numbered trays are used that match the configuration of the trays in which the security badges are kept. This ensures that the correct dosimeter is attached to the worker's security badge. An independent, random QC check is performed by another cler This system works very wel Collected TLDs are sent to the NVLAP certified corporate laboratory for processing. Each batch contains 50 control badges that are spiked on site with combinations of gamma and beta doses. The laboratory processes the-TLDs using commercial equipment and NVLAP-approved algorithms, developed by Battelle, to assign exposures. Data is transmitted to the site via computer. TLD glow curves are retained for several months in. case anomalies must be investigated. The processing appears to be well-controlle The following procedures were reviewed and within the scope of this review were found to be adequate:

-RP-I-510 Personnel Qualifications for the Corporate TLD Processing Program-RP-I-520 Irradiation of Panasonic TLD Badges-RP-I-521 Calibration of the Williston-Elin Model 2001 Irradiator-RP-I-523 Operation of the Eberline Model R0-2 Portable Ion Chamber-RP-I-524 Routine Survey Program for the WE-2001 TLD Irradiator and TLD Processing Facility .

-RP-I-530 Calibration of the Panasonic UD-710A Automatic TLD Reader-RP-I-535 Operation of the Panasonic U9-710A Automatic TLD Reader-RP-I-550 Quality Control Testing of the Corporate Panasonic ,

TLD Processing System '

-HP-610 Issuance and Control of TLDs-HP-611 Receipt & Shipment of TLDs-HP-614 Record TLD Quality Control 6.0 Respiratory Protection Program L

The licensee's respiratory protection program was reviewed with respect to i criteria contained in 10 CFR 20.103. The licensee's program was assessed I by:

f I-observation of the inspection and repair of respirators-witnessing the fit testing of a worker

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-tour of the respirator. issue area-observation of a training session for.the use of SCBA respirators-interviews with selected personnel-inspection of the air compressors in plant No violations were observed. An acceptable program for the control of respirators is in place. Most of this program was previously administered by a contractor. Except for the on-site movement of respirators and training, the program is now under direct cognizance of permanent station personne The air compressors supplying Grade D breathing air to the distribution system in plant are marginally adequate. The compressors are prone to frequent breakdown and there is no in-line monitoring of air quality. The licensee has firm plans to replace these compressors and install a continuous air quality monitoring system. This matter will be reviewed in a future inspectio .0 Exit Interview The inspectors met with the personnel denoted in Section 1.0 at the ennclusion of the inspection on March 10, 1989. The scope and findings of

.the inspection were discussed with licensee management at that tim _ _ _ - _ _ _ _ _ _ _ _ _ -