IR 05000275/1992026
| ML20059C946 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/24/1993 |
| From: | Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| References | |
| OLA-2-I-MFP-118, NUDOCS 9401060260 | |
| Download: ML20059C946 (20) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION g g7gn USNRC" iggg i .j REGON v RECEIVED k , , , , , #' WALNUT CREE , FO NI 94596-5368 N NOV 131992 NOV 2'O 1992 Dockets 50-275 and 50-323 DDS UTION Licenses DPR-80 and DPR-82 @CHRON l RMS ON Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Attention: G. M. Rueger Senior Vice President and General Manager Nuclear Power Generation SUBJECT: NOTICE OF VIOLATION NRC INSPECTION REPORT 50-275/92-26 AND 50-323/92-26 During the weeks of September 16 - 22, 1992 and October 5 - 9, 1992, Mr. Chaney and Mr. L. Coblentz of this office conducted a routine inspection of activities authorized for your Diablo Canyon Power Plant. On September 22, Mr. H. Chaney discussed the findings of the first week of inspection with members of your staff. At the conclusion of the inspection, on October 9, M Coblentz discussed the findings of the second week of inspection with members of your staff. Meeting attendees are identified in the enclosed repor Areas examined during this inspection are described in the enclosed repor Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progres Based on the results of this inspection, certain of your activities appear to be in violation of NRC requirements, as P scribed in the enclosed Notice of Violation (Notice). Your overall control of radiological hazards encountered during steam generator work in the Unit 1 outage appears exemplary; however, we are concerned by the recurrent generation of unanticipated airborne radioactivity resulting from the failure to establish and implement procedural controls during shot peening operation You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken for each violation and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with 10 CFR 2.790(a) of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject 9401060260 930024 PDR ADDCK 05000275 AC4;O)Co O PDR
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1993G3
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to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. 96-51 ,
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Sinc el ,
I am s H. Reese, C ief I
Facilities Radiological Protection Branch i
i Enclosure Notice of Violation Inspection Report 50-275/92-26 and 50-323/92-26 i i
cc w/ enclosure: 1
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J. A. Sexton, PG&E J. D. Townsend, Vice President / Plant Manager, PG&E l C. J. Warner, Esq., PG&E
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D. A. Taggart, Director, Quality Assurance, PG&E B. Thomas, News Service, PG&E T. L. Grebel, Regulatory Compliance Supervisor, PG&E State of California B. Hendrix, County Administrator l cc report only:
Sandra Silver
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199363 NOTICE OF VIOLATION l
Pacific Gas & Electric Company Dockets 50-275 and 50-323 Diablo Canyon Power Plant Licenses DPR-80 and DPR-82 During an NRC inspection conducted September 16 - 22 and October 5 - 9, 1992, a violation of NRC requirements was identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C, the violation is listed below:
Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the applicable vocedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 197 RG 1.33, Appendix A lists, in part, the following procedures: Procedures for Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure) Radiation Protection Procedures (3) Airborne Radioactivity Monitoring l (4) Contamination Control Licensee Procedure MRS-2.4.2-GEN 35 (Steam Generator Shot Peening Procedure),Section 9.7.13.5.2, established September 27, 1992, applied
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I certain rules in order to control airborne radioactivity and contamination. These rules required that, with ventilation interrupted to the steam generator cold leg for longer than 15 minutas, either: Shot peening could be temporarily terminated, or With ventilation switched from the cold leg to the hot leg, !
I and dry air supply switched from the hot leg to the cold leg, shot peening could continu l Contrary to the above, on October 2, 1992, eddy current and shot peening operators failed to implement the provisions for control of radioactivity as given in MRS-2.4.2-GEN 35, Section 9.7.13.5.2, in that ventilation was interrupted to the steam generator cold leg for one hour, and shot peening continued without switching of the ventilation and dry air supply as required. This failure to implement the procedure resulted in the unanticipated spread of airborne radioactivity.
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This is a Severity Level IV violation (Supplement IV).
' Pursuant to the provisions of 10 CFR 2.201, Pacific Gas and Electric Company is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATIN: Document Control Desk, Washington, , with a copy to the Regional Administrator, Region V, and a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting l
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this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Commission may issue an order or a demand for information as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response tim Dated at Walnut Creek, California this @ day of W 1992
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report: 50-275/92-26 and 50-323/92-26 Licenses: DPR-80 and DPR-82 Licensee: Pacific Gas and Electric Company (PG&E) ;
l 77 Beale Street l l
San Francisco, California 94106 1
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l Facility: Diablo Canyon Power Plant (DCPP), Units 1 and 2 Inspection location: San Luis Obispo County, California l eptember 16 - 22 1992 and October 5 - 9, 1992 l Inspection duration:
Inspected by: p b o[I6[4F l on Specialist Date Signed l L.pb z $e 'or i u IG [AV fp dia 'on Specialist Date Signed ny Sen' r I Approved by: (w / f id4[W Jampt/H.,/ fteese, Chief / Date Signed Factyitt/s Radiological Protection Branch Summary:
Areas Inspected; Routine inspection of occupational exposure controls during ,
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outage periods. Inspection Procedures 83750, 83729, 92700 and 92701 were use Results- The licensee's programs for control of occupational exposure during l
outages, in the aspects inspected, were adequate to protect the public health and safety. The overall degree of radiological controls in place to safely perform major outage tasks was exemplary. One matter was identified for inspector followup, regarding qualifications of a respiratory protection instructor (Section 2.c(1)). In addition, one violation of NRC requirements was identified, regarding the recurrent unanticipated generation of airborne radioactivity resulting from the failure to implement procedural controls to maintain a negative steam generator bowl pressure relative to the Containment ,
Building atmosphere during shot peening operations (Section 2.c(3)). l I
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DETAILS l. Egrsons Contacted Licensee
- S. Bandon, Director, Plant Engineering
- Barkhuff, Director, Quality Control
- Boots, Director, Chemistry
- D. Chen, Engineer, Chemistry
- Crockett, Manager, Technical Services
- R. Exner, Coordinator, Steam Generator Project
- R. Flohaug, Senior Quality Assurance Supervisor i H. Fong, Engineer, RP _
. g R. Gray, Director, Radiation Protection (RP)
- C. Groff, Technical Services
- V. Jensen, Specialist, Quality Control
- D. Miklush, Manager, Operations Services
- M. Somerville, Senior Engineer, RP
- D. Taggart, Director, Quality Assurance
- R. Thierry, Senior Engineer, Regulatory Compliance
- J. Townsend, Vice President / Plant Manager
- J. Woop, Auditor, Quality Assurance HB_C
- C. Myers, Reactor Inspector (*) Denotes those individuals who attended the exit meeting on October 9, 1992. The inspectors met and held discussions with additional members of the licensee's staff during the inspectio . Occupational Exposure Dut ...a Extended Outaaes (83750. -83729)
The licensee's radiation protection program was examined to determine compliance with the requirements of Technical Specifications (TSs) 6.3, 6.4, 6.5.3, 6.8, 6.11, and 6.12 for Units 1 & 2; and agreement with the commitments contained in Section 12 of the Updated Final Safety Analysis Report (UFSAR) for Units 1 & 2, and NRC Regulatory Guides 8.8, 8.10, and-8.1 Audits and Aooraisals:
The inspectors reviewed the licensee's schedule of RP-related audits and surveillances for the Unit 1 RS. outage (IRS). At the time of the inspection, Quality Assurance had performed two surveillances, regarding: (1) very high radiation area controls and doors, and (2) monthly change-out of thermoluminescent dosimeters (TLDs). Four other surveillances were either in-progress or scheduled for completion before the end of the outag ;
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A licensee internal audit was also in progress, covering special work permits, surveys, and RP coverag In addition, Quality Assurance was conducting an investigation of incidents related to control of airborne radioactivity generated by steam generator (SG) shot peenin Audit and surveillance plans reviewed were thorough and comprehensive. Surveillance findings were technically sound, and corrective actions were being appropriately addressed (see Section 2.b(2), below). No discrepancies were observe b. External Exposure Control The inspectors examined the licensee's control of radiation, high radiation, and very high radiation areas in the Units 1/2 Auxiliary Building and Unit 1 Reactor Containment. In addition, the inspectors reviewed the licensee's use of dosimeters (electronic and passive), training, shielding, stay times, and physical controls for limiting personnel exposures during the IR5 outag The following licensee procedures were used in assessing the licensee's program implementation:
e RCP D-221, " Control of Access to High Radiation Areas and Very High radiation Areas," Revision 10 e RCP D-240, " Radiological Posting,' Revision 2 e RCP D-260, " Radiological Control for Steam Gr.:rator Repair and Maintenance," Revision 1 e RCP D-270, " Control of Radiography," Revision 1 e RCP D-520, " Westinghouse /EPRI Standard Radiation Monitoring Program," Revision 2
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e RCP D-951, " Operation of the XETEX Teledose Remote Alarming Dosimeter / Receiver System," Revision 1 The inspectors made specific observations related to radiological posting, dosimeter multi-pack controls, high radiation area controls, and SG nozzle dam installatio l (1) Radiological Posting The inspectors noted that the licensee had installed high- i visibility warning signs in selected Auxiliary Building and
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Containment areas where extra recognition was needed due to l
changing plant conditions, (e.g., for system draining or specific operations of the residual heat removal system or
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l (2) Dosimeter Multi-Pack Controls ~
The licensee informed the inspectors about an incident in-which one radiation worker was thought to have used the-multiple dosimetry package -(multi-pack)- of another radiation worker. The licensee's investigation _ revealed that, in fact, the multi-packs had_been worn by the proper individuals; however, the incident-demonstrated the potential for confusion due to the method'of tracking dosimeter user The licensee's. measures to -address. the problem were prompt and aggressive. . Controls,for. access.and egress to the Unit:
1 Reactor Containment were changed to eliminate the possibility of switching multi-pack .
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(3) }{4.h Radiation Area- Controls -
The licensee informed the inspectors of two incidents involving: (1) a posted high radiation area-(HRA), and ~(2) a:
posted very high-radiation area-(VHRA). Both incidents occurred during the inspectio (a) Incident 1: QA auditors found a gate t'o a permanently 1 posted VHRA unlocked. The gate to the area in l question was located approximately 15 feet above the floor of the Unit 2 boric acid evaporator. package ,
room. This area and five adjacent arans had initially l been fenced with a pipe / metal bar barrier. Each a cubicle had been provided with a lockable gate for 1
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work acces An inspector and the RP Manager visited the area o concern. The-area in question'was.not readily or safely accessible without use of a ladder. Surveys of
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the area showed general. area dosefrates' of less~ than 65 millirem per-hour (mres/hr) throughout:the are .
The inspector noted, in. addition,.that the area in question contained only resin transfer. lines'.and was -
normally; under constant RP coverage during such .
. transfers. Following any trans_fer the piping was flushed and radiation surveys were obtained .from the!
floor level with extendable radiation monitoring probes to verify the dose rates'on the exterior of the barrier to the space.-
As immediate corrective action,Lthe licensee installed
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a lock on the gate. In addition,.the licensee issued i an action request-(AR) for an.in-depth review of the~ :
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4 incident. The licensee's initial review indicated that the room may not have ever been locked since ,
construction of the barriers-in 1986. Personne access to the room without.RP. coverage, however,
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appeared unlikel (b)
Incident 2:- A licensee engineer entered a posted HR .
(specifically, .an area posted with the "high-visibility" warning sign) without an,-alarming-dosimeter and high-range-(0-1000 mrem) pocket ion.,
chamber (PIC) as required by the Radiation Work Permit (RWP) and RCP D-221. During a previous entry the engineer had possessed the proper monitoring #
equipment; however, for the entry in question h .
possessed only.his TLD and.'a low-range (0-200 mrem) . .
PI The engineer was observed by a.RP_ Technician (RPT) in the area and escorted out. Followup. radiation surves s indicated that_the engineer had not entered' areas-with
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c dose rates greater than 100 mrem /hr.during his stay in-the area-(several minutes).
The RPM-(with the inspector observing). met with the engineer's supervisor and discussed'the occurrence. A-Radiological Infraction Notice was issued and,the -
engineer's access authorization.to radiological areas was suspended until the RP Department could bei .
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satisfied that appropriate corrective action had been -
implemented and carried out to prevent. future infractions of this type' by the enginee ,
Based on a historical review of ARs the above incidents .
appeared to be isolated incidents. The licensee's initial- ;
actions appeared aggressive and adequate toidetermine both the~causes and~ effective corrective. actions. The inspector l had no further questions concerning the' incident (4). SG Nozzle Dam Installation The inspectors observed licensee mockup training for SG nozzle dam installation (on the hot and cold legs of each SG). The inspectors also observed crews training on.SGL manway removal using hydraulic stud detensioner Jumpers (workers entering the SG to install the dams):
received extensive _ classroom hands-on familiarization and performed qualification training wearing full protective' -
clothing and air-fed bubble hoods._ Mockup training times'
for installing a nozzle dam were 3 - 4' minutes. Two jumps were expected to be needed to fully. install and make ready a nozzle dam for inflatio ,
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The inspectors also observed workers .and RPTs preparing and performing the actual SG nozzle dam installation. With very few problems, the nozzle dams were installed satisfactoril The inspectors observed the work from the licensee's specially designed video monitoring and HP orchestration ~
facility on the Unit'l turbine. deck area. The following observations were made by the. inspectors:.
(a) With two nozzle dam crews working simultaneously on
.two separate SGs, the dose- rate indicator signal. for-the jumpers' remote 'dosineters (a. loud beep followed by the dose rate) caused confusion as to which signal was associated with a particular jumpe (b) The licensee's exposure control-program and the RPTs'
implementation of these controls from~the remote-facility were effective and highly' functional.-
The ALARA coordinator performed a debriefing of.the SG nozzle dam installation performance soon after completion of the work. Although the 12 person-rem goal for. the entire ]
job was exceeded (exposure totalled 13.0 person-rem), the ;
licensee felt that overall the job went.wel Several minor i items for improvement were identified during the 1 debriefing l l
With the exceptions noted, the licensee's. methods of controllin !
external exposure appeared highly effective in the aspects ]
observed. No violations of NRC requirements' were identifie c. Internal Exposure Control The inspectors examined the licensee's methods of controlling l internal exposure. Soecific-observations were made in relation to '
respiratory protection, general measures for airborne . .
radioactivity control, and airborne controls.for SG shot peenin (1) Resoiratory Protection The inspectors observed the use of respiratory protection-devices (full face respirators and air supplied hoods). - The inspectors noticed workers performing suitable qualitative testing (negative fit test) of their respirators prior to- J entering airborne radioactive areas. -Air-fed hoods were a tested following donning by personnel. . In all: case observed, respiratory protective equipment (RPE) was.being-used in accordance with the requirements of 10 CFR 20 Appendix ,
Qualification of RPE users was by quantitative person-to-mask testing using a corn-oil atmosphere in a 2-person test 1 chamber. The_ quantitative testing recommendations of NUREG ,
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6 l 0041 and NRC. Regulatory Guide 8.15 were satisfie Personnel requiring the use.of air-fed. hoods were specially mockup trained prior _to allowing us One inspector attended-licensee training for respiratory--
protection equipment use.. The following items'were noted:- l (a) The video on confined area entry requirements and safe 1 working practices for confined area entry activities was helpful and informative. The student handout fo the course was also helpful. for RPE usersi (b) During the training presentation, the instructor:
- Misquoted federal limits on allowed exposuretto airborne radioactivity,.and :
- Was unable-to_ provide answers t'o two questions /
concerning the basis for respiratory protection!
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requirement (c) The instructor also_-briefed the attendees'on: field-
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disassembly and inspection of respirator components prior to use. The inspector.noted that field i disassembly was not discussed'in the training handout.-
As presented, respirator field disass'embly consist'ed !
of removing the exhalation _ valve cover and lifting:the +
diaphragm to see its sealing side. . The instructo stated that wiping of the diaphragm seaP,r.g side surface was acceptable,for removal of minute' matter (hair'and soap residue). Also the' user. was told to -l
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remove the cartridge (s), if installed.. to_ inspect the
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gaskets on the respirator.- l The inspector noted that respirators were normally' l installe !
issued Further discussions with the technica trainin without cartridges or filters;l_
manager determined that this requirement.had.been .
instituted by the RP. Department Respiratory Protectio _
Engineer. The inspector expressed concern that-
. workers dressed in protective ~ clothing might-cause; more damage than good during the. field disassembling and wiping of the delicate exhalation valv (d) In review of. the instructor's, qualifications, .the -
inspector noted: .
'* The instructor had 3 years of experience as aI .
senior radiation protection technician-(RPT) and 3 months experience in RPE training.-
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- The instructor had received no pre /ious professional training on industry and federal l requirements concerning:. (1) acceptable respiratory protection programs,-(2) types,'use, ,
and limitations of RPE, or (3) user training requirement * The instructor provided training and qualification in the use of at-least 3 types of RPE, including SCBAs (sel.f contained breathing apparatus) and. emergency escape devices.(ELSA);
however...the instructor only possessed practical-experience in the 'use of one type of respitator ,
(full face air. purifying).
The inspector observed.that NUREG 0041, " Manual o ,
Respiratory Protection Against Airborne Radioacti.ve Materials," Chapter 8.1, " Qualifications of Training i
Pe ;onnel," recomends:-
l The instructor must have a thorough.. knowledge of the application and use of respiratory-protective' equipment and of the hazard associated with radioactive airborne- ..
contaminants. He [ sic) also must have had considerable experience in.the practical selection and use of respirators for protection :
against radioactive airborne contaminant The inspector expressed concern that the instructor's
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qualifications did not meet the recommendations of NUREG ~
0041. Overall the RPE training appeared to be acceptable r
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for the use of full-face air-purifying respirators. This-matter will be further examined in a future inspectic.. (50-275/92-26-01).
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(2) General Measures for Airborne Radioactivity Control-The licensee had installed portable filtration and ventilation units to reduce airborne radioactivity-l concentrations during work in various- plant. areas.. -The use -
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of ventilation systems was especially notable in residual l j
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l heat removal system modification' contamination control wor '
tent The inspectors observed that both working-zone high volume grab type airborne radioactivity samplers and long term -l general area low volume airborne radioactivity samplers were l
.placed throughout the facility., Alarming airborne-radioactivity monitors (ARMS) were observed strategically placed throughout both Containment and Auxiliary Building :
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Air sampling and RPE use during the reactor head removal and
.SG entry were observed. Several air sample assessments were examined and found to have been completed in accordance with licensee procedure (3) Airborne Controls for SG Shot Peenino The licensee informed the inspectors of several instances in which the unanticipated spread of contamination and/or airborne radioactivity had resulted from inspection and maintenance operations in the SG hot'and cold' leg (a) Description of Ooerations
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SG shot peening primarily involved robotic work in the SG hot leg. In addition, to maintain the optimum
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local atmosphere in- the SG bowl and tubes, dry air was blown in from the hot leg sid On the cold leg side, high efficiency particulate air (HEPA) ventilation was established to " overcome" the positive pressure induced by hot leg shot peening (i.e., to maintain a negative pressure in the steam generator bowl relative to the surrounding Containment atmosphere). In addition, simultaneous robotic eddy current inspection was being performed through the SG cold le Simultaneous eddy current (cold leg) and shot peening (hot leg) operations were performed on all four SGs at once. Airborne radioactivity monitors (ARMS) equipped with alarms were in place:
(1) on the 91' level near the SG 1-3 and 1-4 platform, (2) on the 91' level near the SG l-1 and 1-2 platform,
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(3) on the 115' level near Reactor. Coolant Pump-(RCP) 1-1, (4) on the 115' level near RCP l-4, and (5) on the 91' level outside the bioshield.-
All operators and RPTs working on or.near the-SG platforms wore respiratory protective equipment (air-fed bubble hoods).
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i (b) Description of Incidents-
) Incident 1: - On September 25, 1992, the cold leg
i manway door on.SG 1-l' was opened while' the SG was .
pressurized by a Copus' blower.1 This resulted in.the i
saread of contamination-(and hot particles) outside j tie posted hot particle zone. -No personne1~ ,
contamination or uptakes-resulted from this inciden !
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Incident 2: l0n September 26, 1992, the cold leg' 4 i
manway. door on SG 1-3 was opened for eddy curren maintenance. The dry air supply valve to the hot leg was either not fully closed or later. bumped open. . In '
,1 addition, shot. peening continued with the cold leg
manway door.open. This resulted in air: flow out of:
' the cold leg and caused a'high airborne condition--in Containmen Several workers' received uptakes from thisLincident '
i (the highest uptake was approximately 15 MPC-hours).
j Containment,was at a negative pressure relative'to the
outside atmosphere, and no release occurred to the~ i
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outside atmosphere.
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L Incident 3: On October'2,-1992, the cold leg manway a
i door on SG l-4 was_ opened for about.one hour.while
- shot peening continued. . This resulted in' air flow out-l of the cold leg and airborne alarms in the SG work- >
i area. .No worker contamination.or uptakes resulted
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from this-incident..
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i (c) Licensee Corrective Actions As a result of Incident 1, the licensee prepared-a-f writtenLi..druction emphasizing the need.for negative i
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SG pressure to be maintained relative.to the l
Containment-atmosphere. .The instruction gave. step-by-i step guidance on what to 'do if the cold leg 'manway; had-
! to be opened. LThe instruction'wasireviewed with l
applicable personnel, and posted:at the-work' stations. .
t The licensee's' Quality Evaluation (QE)-Q0010055 later
] concluded that the instruction'would have'been-L sufficient to prevent * Incidents 2 and 3 had it been
[ understood and followed;
i After Incident 2,. all SG-work was stopped and l Containment was evacuated. After holding.a critique, j
the licensee added a. checklist to the eddy current.
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procedure to control breaches of the cold leg manway.-
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! peening procedure to control continuation of' shot
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i peening if the cold. leg manway door remained open for
! more than 15 minutes. All applicable personnel were
} briefed prior to restarting work.
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QE 00010055 later concluded.that .the corrective i
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actions from Incident Ziwould have been sufficient to !
0 - prevent Incident 3 had.they:been understood an l followed.
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After Incident 3,.the HEPA suction was moved to the.
l hot leg, and the dry air input was. moved to the col ,
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leg. In addition, the' shot peening supervisor wa made the responsible individual for all breachin operations.- Checklists and procedures were appropriately. modified. and applicable personnel were -
re-traine (d) Licensee Assessment
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The licensee determined that the root cause of these'
events was the lack of establishing clear responsibility for. proper operation of the. HEPA'
ventilation system. .In addition,.the following contributing causes were.given in QE 0010055:~ ,
- Eddy current personnel h'ad not been~ properly:
trained on the ventilation system or the potential problems resulting from shot peenin '
- The original eddy current and shot _ paening procedures did not; address step-by-step '
operation of the HEPA ventilation' syste * Positive control of the dry air supply valve had' '
not been sufficiently establishe _
- -No low flow alarms or indicators had been made available~ to .the shot peening. and eddy current
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operators to indicate _ improper SG bowl ~
ventilatio j f
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At the October 9.- 1992, ' exit interview, the' licensee .
stated that these causes would be addressed' prior.to shot peening-in the upcoming 2RS outage.-
(e) .NRC Assessment The inspector concurred with the licensee's assessment; ,
as documented in QE Q0010055. The inspector noted, however, the following concerns:
- 10 CFR 19.12 requires licen'ees s to train person .
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working in a restricted area on the radiological-hazards present, including training.on the protective devices employe By shot peening in the hot leg' at the same tim .!
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that eddy current inspections were conducted in the cold leg, the licensee had induced.a: change in the cold leg radiological- conditions -(i.e, pressurization of the cold -leg with dry air flow)._ Eddy current operators had not received ,
training on this altered radiological condition prior to beginning eddy current inspections, no_r had they been properly trained on the' necessity of maintaining _HEPA ventilation.in. order _to control the airborne radioactivity hazar .
- The corrective actions associated with Incident I were' intended to heighten worker sensitivit to (1) the existing radiological conditions, an (2) the purposes of the HEPA ventilation. .The-corrective actions for Incident'2 were intended to further heighten worker sensitivity.to the same matters. These corrective actions,
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however, were not effective, as evidenced by the failure to follow the_ newly established shot peening controls in Incident * The' airborne monitoring controls established had not been optimally effective in preventing -
worker uptakes. During Incident 2, the ARM on the 91' level near Uie SG l-1 and 1-2 platform had'been found turned off. In addition, the. ARM '
on the 91' level near the SG 1-3'and 1-4:
platform (and nearest the release point of-airborne radioactivity) either had not alarmed-or had not resulted in timely, effective . -
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response. An alarm from the ARM on the 115'-
level near RCP 1-1 had resulted in alerting Containment workers and RPTs to the spread of -!
airborne radioactivit (f). Conclusion-Technical Specification 6.8.1 requires that written - .
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procedures shall- be ' established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 197 .
RG 1.33, Appendix A_ lists, in part, the following procedures:
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12' ; Procedures for Control of '
Radioactivity.(Forlimitin materials released to environment and limiting personnel exposure) ,
, Radiation Prote'ction Procedures j
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(3) Airborne Radioactivity
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Nonitoring
'J (4) Contamination Control
Licensee Procedure MRS-2.4.2-GEN 35 (Steam Generator Shot Peening: Procedure), Section g.7.13.5.2, established September 27, .1992 (followiing Incident ,
2), applied certain rules'in order to contro1~ airborne radioactivity and. contamination. . These rules required that, with ventilation interrupted to the steam generator cold leg for longer than 15 minutes, eitheri l
- Shot peening could be temporarily terminated, 'or With. ventilation switched from the cold -leg to
the hot leg, and dry air supply switched from
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the hot leg to the _ cold leg, shot peening could ;
continu The inspector concluded'that, on October 2, 1992, edd current and shot peening operators had failed to- '
implement the provisions for control of radioactivit as given in MRS-2.4.2-GEN 35, Section 9.7.13.5.2, in y'
that ventilation had been interrupted to the steam i generator cold leg for one hour, and shot peening had continued without switching of.the ventilation and dr ,
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air supply as required. The inspector concluded, further, that this constituted a violation of TS l'
6.8.1, as paraphrased above (50-275/92-26-02). :
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With the exception'of the discrepancies noted, the licensee's .
programs for controlling internal exposure appearedIn' adequate addition,- in the !
accomplishing the licensee's safety objective ;
overall control of occupational exposure'(both internal and external) associated with the shot peening.and eddy, current work . 4 was exemplary. The inspectors noted significant improvements and a external exposure reductions in the licensee's performance as compared to previous performances of.these evolutions at other !
licensees. One violation'of NRC requirements was identifie d. Control of RAM and Contamination. Surveys. and Monitorina ;
The inspector examined the radiological controls, work activities,,
and radiological surveys associated with the following Radiation
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Work Permits (RWPs): f e RWP 92-01088, Unit 1, IR5 " Perform Radiography in Containment for other than Normal ISI" .
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e RWP 92-01041, Unit 1,1RS " Primary.SG Work Including Remove, Install Manways, Diaphrages, Bowl Surveys, Diaphragm Cleaning, including Stud Hole cleaning & Inspection, and - .
Leak Monitoring Setup, and EPRI Surveys" e RWP 92-01045, Unit 1, 1R5 " Primary Steam Generator Shot Peening Work to I ulude All Supporting Activities" .,
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No discrepancies were identifie '
e. Maintainino Occupational Exposures ALA' RA The inspector observed and interviewed various workers during tours of the Unit 1 Containment and piping / electrical penetration '.
rooms. For the most part, all personnel.were; knowledgeable of-work area dose rates or their bounding values (less than-100-mrem /hr, less than 50 mrem /hr, location _of high contact dose rates,etc.). Workers were observed moving to low dose rate ' areas t to perform work or hold discussion ,
The inspectors focused on the licensee's preparations-for the-following 1R5 major work evolutions:
e Steam generator tube sheet shot peening -:
e Reactor vessel core barrel remova i The-inspectors examined the licensee's detailed ALARA evaluations of the above work which were used to develop training and the special radiation work permits for the jobs. Shot peening was -
performed. simultaneously with steam generator tube inspections (shot peening hot leg while cold leg eddy current inspections _were- 4 being performed). All four SGs were worked ' simultaneousl Licensee preparations had included performing an ALARA review per procedure RCP D-205, " Performing ALARA Reviews."~ In addition, >
project management and HP personnel had been.sent to observe --
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another utility perform the SG shot peening;- RPTs had.been given hands-on training (similar to that given to qualified; shot peen operators) so as to fully understand _the operation of. shot peening equipmen ,
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(1) ALARA-Related Trainino The licensee conducted detailed classroom and mockup training for the shot-peening job.(considered by the iicensee.to~be the outage job that posed the mosti significant potential for radiological problems).
The licensee's SG mockup 'used a full-size, completely ~
operational shot' peening apparatus. .This equipment was used to qualify vendor and licensee personnel:in shot peening operations. (See also discussion ender Section 2.b(4),.
above.)
(2) - Radiation Source and Field' Control ,
The SG shot peening' apparatus'(shot' tower, debris collectors, and filtering devices) had.been provided with integral; permanent shielding.: In addition, the licensee had-placed an large. amount of temporary shielding blankets i the form of a wall around each SG's shot peening' apparatu This' shielding was to reduce radiation shine'on the SG' work platform In order to further reduce.RPT exposure'during.SG_ work,' the licensee had constructed.and outfitted a video monitoring-and work orchestrating facility on the 140 elevation of the-Turbine Building. During previous outages, RPTs.had performed all monitoring activities (controlling high-dose area entries and calculating exposure stay-time @ from within the Reactor Containment. The licensee expected to significantly reduce RPT. exposure by using more remote monitoring' method The licensee had extensively used temporary l'ead shielding for reducing work area dose rates in areas of the RHR piping modification .
The licensee's ALARA programs and. practices, in the aspects observed, were effective in reducing. worker occupational; exposur No violations of NRC requirements were identifie . Facility Tours
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The inspectors performed independent beta / gamma and gamma radiation-exposure rate measurements of areas-inside and outside of' Units:1-1 2.-
Measurements were made using Geiger-Mueller_ type detectors (Xetex.Model 305B, NRC Serial Nos. 020206 and 020207) - and a Ludlum Model 3,,NRC Serial' No. 022879 (equipped with surface contamination frisker,' exposure-rate, and gamma scintillation type detectors). The instruments were due for calibration February 4, ~1993, January 9,1993, and November 27, 1992, respectivel .
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The inspectors noted that posting in all areas visited were in accordance with applicable NRC requirements, and conducive to alerting workers to the radiological status of the area i Independent radiation exposure rate surveys (general.' area and' contact readings) were conducted in the Unit 1 Reactor Containment and.the Units 2/3 Auxiliary Building. All_ readings agreed with current licensee surveys and posting. Surface contamination surveys (fixed beta / gamma) i of selected Unit I turbine components _were also conducted. No abnormal indications were observe During a tour of the Unit 1 Reactor Containment on October 9, 1992, the ,
inspector observed that.a radiological boundary, used to designate a hot '
particle. zone around an SG platform, was discontinuous at one potential point of entry. This matter was. brought to the attention of the RPT providing local coverage, and the problem was promptly correcte . Exit Meetina Mr. Chaney met with members of licensee management on September 22, 1992, to discuss the results of the first' week of inspection. On October 9, 1992, Mr. Coblentz met with members of licensee management to discuss the results of the second week of inspection. The scope and findings of the inspection were summarized. The licensee acknowledged ;
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the inspectors' observation ,
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