ML20003A738
| ML20003A738 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/15/1980 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20003A737 | List: |
| References | |
| NUDOCS 8102050822 | |
| Download: ML20003A738 (8) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.C). BOX 8699 PHILADELPHI A. PA.19101 SHIELCS L. D ALTROFF ELact cenco criom October 15, 1980 Re: Docket Nos. 50-277 50-278 Inspection Nos.: 50-277/80-05 50-278/80-05 50-277/80-11 50-278/80-11 50-277/80-26 50-278/80-19 Mr. Boyce M.
Crier, Director Office of Inspection and Enforcement Region I U.S.
Nuclear Regulatory Commission 631 Park Avenue Ki g of Prussia, PA 19406
Dear Mr. Grier:
Your letter of September 24, 1980, forwar.ded the results of three NRC inspections conducted on March 1-31, 1980, on April 25 - May 19, 1980, and on July 24-28, 1980.
Appendix A to your letter addresses eight items which did not appear to be in full compliance with Nuclear Regulatory Commission requirements.
Appendix B to your letter addresses one item of noncompliance which is categorized as an infraction, however, your letter also indicates that this iten has been corrected and no additional response is required.
Appendix A itema are restated below with our response.
A.
The following items of noncompliance were identified in Inspection No. 50-277/80-05:50-278/80-05, conducted on March 1-31, 198^.
1.
" Procedures", states in part:
" Written procedures...shall be established, implemented, and maintained that meet the requirements 81 G :: C E 0112.
Mr.,toycb H.
Grier Page 2 of... Regulatory Guide 1.33 (November, 1972).
...Each procedure...shall be reviewed by the PORC and approved by the Station Superintendent or his designated alternate...".
Regulatory Guide 1.33 (November, 1972),
Appendix A, Section C, references procedures for j
processing liquid radioactive waste.
Contraty se above, on March 7, 1980, the licensee
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conducted o,.. rations using the fuel pool cooling system demineralizer as an alternate path to process liquid radioactive vaste and no approved written procedures l
had been issued governing these operations.
i This is an infraction applicable to DPR-44 and DPR-56.
Response
Various operational problems with Radwaste Plant operation occurred during the first week of March, 1980 which greatly
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increased the liquid radwaste system inventory.
By March 7, 1980 the two surge tanks, which are not normally needed were filled to maximum capacity, and although inputs to the system had been minimized as much as possible, flow to the surge tanks continued.
The nor~ 1 liquid radwaste filter /demineralizer equipment was unava table.
The only practical alternative which remained was to c u r.p liquid radwaste through the fuel pool filter /
de..neralizer as provided for in the original system design to the refueling water storage tank.
This method to process liquid radwaste had been used successfully in February, 1980 after being reviewed by Operations Engineer and the Shift Superintendent and a draft procedure was prepared at that time.
This procedure was being reviewed and refined for subsequent Plant Operations Review Committee (PORC) approval when the problems with the Radwaste Plant developed.
The entire operation was again reviewed by the Operations Engineer and the Shift Superintendent before being used a second time.
i On April 7, 1980 procedure S 0.3.5.F "Using the Fuel Pool Filter /Demineralizers to Process Radwaste Into'the Refueling Water Storage Tank" was approved.
Plant Management has and will continue to make every effort to anticipate possible plant situations which may require procedures.
These procedures will be prepared and provided to appropriate personnel before they are required.
2.
Technical Specification 6.8.1 states:
" Written procedures and administrative. policies shall be established, implemented, and maintained...".
Procedure FH-5, "New Fuel Inspection, Channeling and Placement in the Fuel Pool", revision 17, dated January 11, 1980, states in part, " Fuel Inspectors...shall perform the fuel inspection according to the fuel
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Mr. Boyco,H. Grier Page 3 inspection plan Appendix B...shall initial-the steps of the check-off list corresponding to the part of the inspection performed by the fuel inspector...QC Inspector...shall sign the ' Fuel Bundle' Site Inspection j
Sheet' (Appendix B, Attachment B)...after all other items are completed...shall monitor the fuel-inspection-to ensure that it is' performed properly."
Contrary to the above, during the. period February 15 to February 26, 1980, Procedure FH-5 was not followed, in that:
i 13 Fuel Bundles which were to be channeled in used channels-did not contain verification that the capscrew hole would accept a 5/16-18.UNC-B.
j 1/18" capscrew to 1" depth (step 19B).
The Fuel-Bundles were LJM 012, LJM 014, LJM 026, LJM 039, LJM 076, LJM 087, LJM 179, LJM 185,LLJM 191, LJM i
221, LJM 326, LJM 079, LJM 184.
4 Fuel Bundles which were to be channeled in new fuel channels did not contain verification that a maximum 0.314" gap existed between the-fastener and channel for.100" thick-channels. machined to 4
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0.080" (step 20).
The fuel bundles ~ involved were LJM 058, _LJM 089, LJM 090,LLJM 110.
l This is an infraction applicable to DPR-44 and DPR-56.
Response
Special Procedure SP 348, " Reinspection of New Fuel. Bundles for-Unit 2 Reload 4" was written land performed to verify those-portions of the' fuel inspectionofor the-17 bundles listed in the Inspection Report which were-not documented 1as being complete during the initial fuel inspection.
The re-inspection _was satisfactorily coupleted March-12,'1980.
' Procedure.FH-5, "New Fuel Inspection, Channeling and Placement'in.the Fuel Pool"'and FH-5 Appendix B,
" Inspection Plan".were' revised April 30,n1980 to clarify fuel bundle inspection-requirements.
Personnel-performing and verifying the fuel inspection had' incorrectly interpreted which steps.of the Fuel Bundle Site Inspection Sheet should be performed for; fuel bundlesEwith^new:
channels and' fuel-bundles:with_used channels.
-They were made aware of th'eir error.
3.
Technical Specification 6.11, " Radiation ~ Protection Program" states in-part, " Procedures for~ personnel!
radiationfprotection shall be - preparedcconsistent with requirements of~10 CFR;Part 20 and shallche' approve'd, maintained,: and-adhered;to...".;
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Mr. Boyce H.
Grier Page 4 Health Physics Procedure HP0/CO-10a, " Conduct in Controlled Areas - Minimize Exposure", Revision 2, dated May 12, 1978, states in part, "Always wear provided personnel dosinetry." Additionally, the applicable RWP required dosimetry.
(No. 3-94-0057)
Contrary to the above, on March 21, 1980, at about 2:45 PM, one individual working in controlled area under Radiation Work Permit (RWP) No. 3-99-0057 in the turbine building 165 foot elevation was found not wearing his dosimetry.
This is an infraction applicable to DPR-44 and DPR-56.
Response
Upon notification by the inspector of this occurrence a Health Physics Supervisor initiated a Health Physics Investigation Report.
A discussion of the occurrence was held with the individual.
The individual stated that leaving his dosimetry outside the work area was.an inadvertent action and indicated that he would exercise greater care and properly wear his dosimetry in the future.
A copy of this report was forwarded to his Supervisor.
B.
The following items of noncompliance vere identified in Inspection No. 50-277/80-11:50-278/80-11, conducted on April-25 - May 19, 1980.
1.
Technical Specification 6.11, " Radiation Protection Program", requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
In addition, 10 CFR 20.103(c) states that when respiratory protective equipment is'used, the licensee.
may nake allowance for such use in estimating exposures-of individuals to such materials provided that such equipment is used as stipulated in Regulatory Guide 8.15.
Regulatory Guide 8.15, Section C.4.c, requires
" Written procedures to ensure...the testing of respiratory protective equipment for operability immediately prior to each use."
Procedure HP0/C09a, " Respiratory Training and Fitting",
requires that individuals who wear respirators shall perform a negative pressure test prior to each use.-
Contrary to the above, on April 24, 1980, during a tour of the access control to the torus, the inspector observed three individuals (as they suited up and
Mr. Boyce,H. Grier Page 5 donned respirators, as required by Radiation Work Permits), who failed to perform a negative pressure test, as required by Procedure HP0/C09a.
This is an infraction applicable to DPR-44.
Response
The three individuals were not identified by the inspector so that immediate individual counseling was not possible.
The requirement to perform a negative pressure test is covered in classroom instruction as well as in the equipment fitting phase of General Respiratory Training.
2.
10 CFR 50, Appendix B, Criterion VI states in part,
" Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto...these measures shall assure that documents...are distributed and used at locations where the activity i s performed." The licensee's NRC accepted Quality Assurance Plan, Volume III, Section 2, Paragraph 6.1 states in-part,
" documents, including changes...are distributed to and used at the location where the prescribed activity is performed.."
Contrary to the above, current revisions of HP0/C09,
" Respiratory Protection Program"; HP0/C09a,
" Respiratory Training and Fitting"; and HPO/C09b,
" Respiratory Protection Equipment and Selection and Use" were not in use during a tour of the respirator quality assurance and maintenance station on April 24, 1980.
This is an infraction applicable to DPR-44 and DPR-56.
Response
The latest revisions of the procedures which-control the Respiratory Protection Program (HP0/CO-9 series) have been placed at the respirator quality assurance and maintenance station.
This series of procedures had not previously_been controlled at this station.
The next revision to pro edure A-2, Procedure for Control of Procedures, will assure distribution of controlled copies of these procedures to this location.
3.
10 CFR 19.11(a) and (b) require that current copies of Part 19, Part 20, the-license conditions, the documents incorporated into the license, the license amendments and the operating procedures shall be posted, or that a notice describing these documents and where they may.be examined shall be posted.
10 CFR 19.11(c)' requires
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Mr. Boyca H.
Grier Pago 6 that a Form NRC-3, " Notice to Employees", shall be posted.
Contrary to the above, a check of the single controlled bulletin board during site entry on April 22, 1980, found 10 CFR 19 not current, in that a Form AEC-3 instead of Form NRC-3 was posted.
This is a deficiency applicable to DPR-44 and DPR-56.
Response
When Form NRC-3 is revised, copies of the latest available form are furnished to the site for posting.
The failure to replace the outdated form with the current form was an oversight and as stated in the inspection report was promptly remedied when brought to the attention of a licensee representative.
C.
The following items of noncompliance were identified in Inspection No. 50-277/80-26:50-278/80-19, conducted on July 24-28, 1980.
1.
Technical Specification 6.11 states, in part, that
" Procedures for personnel radiation protection shall be... adhered to for all operations involving personnel radiation exposure."
Paragraph 6.b of Health Physics Operations / Chemistry 11, " Establishing and Posting Operations Procedure Radiologically Controlled Areas", states, in part, that "A rad Tape indication line or a warning rope (or ribbon) is to be established to encompass the contaminated area and/or items which exceed 500 dpm/100 cm or 500 cpo/ft with a HP-210 or 260 probe...and posted with signs which read Caution (or Danger)
Contaminated Area."
Contrary to the above, an area exceeding the contamination levels stated in IIP 0/CO-11 Paragraph 6.b existed on the 135 foot elevation level of Reactor Building No. 2 on July 25, 1980, without the required posting sign.
This is a deficiency applicable to DPR-44.
Response
At the time this deficiency was identified, a major decontamination effort was underway et the referenced location.
An immediate interview with the crew leader responsible for health physics related activities in the' area did not identify _
the organization or individual responsible for. removal of_the barrier rope and signs which were in place during the morning
S Mr. Boyce.H. Grier Page 7 prior to the inspection.
It appears that a decontamination crew removed the barriers and signs, decontaminated the area and was awaiting an HP technician to survey and clear the area.
The crew leader was counseled and instructed to remain aware of activities in his area of responsibility and conduct them in accordance with approved procedures.
2.
Technical Specification 6.8.1 states, in part, that
" Written procedures and administrative policies shall be established, implemented and maintained..."
Physical Protection Procedure No. I " Normal Admittance Procedure", Revision 18, dated May 30, 1980 states, in
- part, "Section 2 Admittance The,aard shall ensure that the... dosimetry is being issued to the correct person."
Cantrary to the above, on July 28, 1980, an employee from the Bechtel-Corporation was visually observed by the NRC inspector to be wearing an Iberline Thermoluminescent Dosimeter (TLD) forwally assigned to a Peach Bottom Test Engineer.. Additionally, the Peach Bottom Test Engineer had worn the TLD assigned to the Bechtel employee.
This is a deficiency applicable to DPR-44.
Response
An investigation by Health Physics indicated that the exchange occurred in a change area when the individuals concerned exited the drywell.
Both individuals were counseled on their responsibility to check the dosimetric devices given them to assure that they are indeed their own.
The security force has been reinstructed in their duty to ensure that dosimetric devices are being issued to the correct person.
Additionally, following the occurrence an audit was conducted of the majority of badges which had been assigned (about 1200).
No other instances of exchanged dosimetry were discovered.
Your lettar also noted that each of the inspections addressed above identified noncompliances with radiation protection procedures.
You expressed concern with the effectiveness of our management controls in thisfarea.
Philadelphia Electric Company has been, and continues to be,. concerned with assuring that radiation protection procedures are adhered to by all personnel on'the Peach Bottom Atomic Power Station'(PBAPS). Site. 'A review of the-three non-sequential individual inspection reports submitted to Philadelphia Electric Company on September 26, 1980 indicates that four items of noncompliance with radiation-4 n
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Mr. Boyce H.
Crier Page 8 protection procedures were identified during the course of 227 inspector hours and three individual audits which spanned the time period of March 1, 1980 to July 28, 1980, approximately five months.
During this five month period, the number of personnel on site had increased significantly to support a major refueling outage.
A review of other inspection reports, consisting of about the same number of inspector hours, which addressed radiation protection. and which also spanned this time period did not identify any radiation protection procediare violations.
We believe that the number and frequency of radiation protection procedure violations does not indicate ineffectiveness of Philadelphia Electric Company management controls in this area.
As related in Philadelphia Electric Company's response to Inspection 50-277/80-01 and 50-278/80-01, which described a sequence of re-familiarization programs related to !!ealth Physics topics, the effort to increase awareness l i. this, and other areas is ongoing.
Presently a document, tentatively entitled " Site Rules and Regulations" is being developed.
This document addresses, in addition to many other topics, topics related to the non-compliances with radiation protection procedures cited in Appendix A of these combined inspections.
Currently, consideration is being given to the exact content of this document as well as the most effective means of conveying these
" Rules and Regulations." It is expected that all PBAPS workers will receive this document.
Very truly yours,
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