IR 05000155/1987012
| ML20236C705 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/21/1987 |
| From: | Greger L, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236C676 | List: |
| References | |
| 50-155-87-12, NUDOCS 8707300164 | |
| Download: ML20236C705 (16) | |
Text
- __ - - _ .. .
-
+
U.S NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-155/87012(DRSS) !
' Docket'No. 50-155 License No.~0PR-6 l
Licensee: Consumers. Power Company 212 West Michigan Avenue
. Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant- j Inspection At: Big Rock. Point Site, Charlevoix, Michigan
,
Ins'pection Conducted: -May.18 through June 29, 1987
'
Inspector: W. J. Slawins i 7 -2 /-6 7 -
Date
-
'
Approved By: L. R. Greger, Chief */ - z / - 6 7
. Facilities Radiation Protection Date Section l Inspection Summary -j Inspection May 18 through June 29, 1987 (Report No.- 50-155/87012(DRSS)) .
. Areas Inspected: Routine,. unannounced inspection of the radiation protection !
.-and portions.of the radwaste management programs, including: organization and management controls; training and qualifications; external and internal exposure controls and dosimetry; contamination control; ALARA; solid radwaste; and transportation. Also~ reviewed were past open items and allegations concerning the radiation protection progra Results: No violations or deviations were identitied, i
i i
8707300164 870723 l gDR ADOCK 05000155 PDR
.. - -
,.
73 7'
p DETAILS 1 1. .- Persons Cont' acted
,.
"
. R. Abel,, Production and Plant Performance Superintendent
- M. Acker, Senior Engineer /ISI Coordinator-u>
'
- R.- -
Alexander, Technical Engineer C. Barsy, Senior Chemistry / Health Physics Technician
- J. Beer, Chemistry / Health Physics Superintendent
?. **R. Burdette,'Senio'r Health Physicist' j
- T.'Elward, Plant Manage i
- G. Fox,:ALARA Coordinator
- R. Garrett, Chemistry / Health Physics Supervisor D. Johnson, Health Physics. Specialist'.
!: '*Lc Monshor,. Quality' Assurance Superintendent
- E. Raciborski, Planning and Scheduling Administrator o
- J.' White, Maintenance Supervisor, Field Maintenance _ Services West- I
- G. Withrow, Engineering and Maintenance Superintendent
.
.
.N.~ Choules, NRC Reactor Inspector q
!
T. Tella, NRC Reactor Inspector The! inspector also contacted other licensee personnel in the Operations-and Radiation Protection Department * Denotes those present at the exit meeting on May 22, 1987.
- Denotes those contacted by telephone during the-period June'4-18, 198 _
I General This inspection, which. began at approximately 2:15 p.m. on May 18, 1987, was conducted to review.the operational ~ radiation protection program,
.
solid radwaste, transportation, open items, and allegations concerning the radiation' protection program. The inspector toured radiologically controlled areas and conducted external radiation surveys of selected plant areas using an NRC survey instrument (PIC-6A); survey readings.were in general agreement with posted licensee data. Area postings and general housekeeping were adequat . Licensee Action on Previous Inspection Findings (0 pen) Open Item (155/86009-01): Review documentatica of corrective i actions for radiological incident report Due to the limited number o of incident reports generated since the previous inspection, conclusions regarding the effectiveness of radiological incident corrective actions i documentation / implementation will:be withheld pending further review .3 (Section'4). 1-(0 pen) Open Item (155/86009-02): Review Radiation Work Permit (RWP)
program changes. Recommendations for RWP program improvements have been made and approved. This matter will remain open pending implementation of the revised-RWP program (Section 10).
l
l l
I
.
-
.
l (Closed) Open-Item (155/86009-03): Review improvements to ALARA program implementation and documentation. Weaknesses in the ALARA program primarily relate to RWP program deficiencies; therefore, ALARA program-
-improvements will be reviewed in conjunction with the revised RWP progra . Organization and Management Controls 1 The inspector reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including changes in the organizational structure and staffing, effectiveness of procedures'and other management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesse Effective May 1, 1987, Mr. David Hoffman was replaced as Plant Manager by Mr. T. E. Elward; turnover of responsibilities is nearly complet The Chemistry and Health Physics Superintendent remains as the Radiation Protection Manager and reports 'directly to the Plant Manager. The j Chemistry / Radiation Protection Supervisor, General Engineer, ALARA 4 Coordinator, and Senior Health Physicist all report to the Chemistry l and Health Physics Superintendent. The Chemistry / Radiation Protection i Supervisor is responsible for the station's 12 Chemistry / Health Physics (C/HP) Technicians who perform both health physics and chemistry dutie The Senior Health Physicist's responsibilities include radwaste and environmental monitoring; the General Engineer handles special projects as assigned and provides technical support to the Chemistry / Health Physics Department. A Health Physics Specialist, reporting to the ALARA Coordinator, provides administrative support for the dosimetry progra There has been minimal turnover of the chemistry / radiation protection staff since mid-1985. Twelve C/HP technicians, the station's full -
'
complement, remain on staff and include six senior technicians, one technician II, and five technicians. The last remaining technician trainee was promoted to technician in late 1986. All technicians are considered by the licensee as qualified in radiation protection procedures (Section 5).
The inspector reviewed the licensee's Health Physics Department Functional Surveillance Program conducted pursuant to their Radiation Safety Pla ]
This program, previously described in Inspection Report No. 50-155/86009, 1 basically consists of informal surveillance of various health physics j programmatic areas conducted by members of the Chemistry / Radiation i Protection Department. This surveillance program, formally required by {
Section X of the Nuclear Operations Department Radiation Safety Plan, .)
has been deleted from this section of the plan, revised, and added to Section II. (Letter from B. D. Johnson to J. G. Keppler dated September 23, 1985). Surveillance are typically performed on a monthly
~ basis and have recently included reviews of station radiological posting, material control and the RWP progra Several programmatic weaknesses have been identified during these reviews; however, corrective action
3
_ - - _ - _
'
.
'.
recommendations are not in all cases' formally addressed or.their implementation adequately documente The desirability of improving l documentation and followup of corrective actions was discussed at the exit meetin According to the licensee, Administrative Procedure 5.15, " Investigation i of Radiological Incidents," dated July 22, 1986, was recently reviewed for j L possible revision of.the method of documenting corrective actions;.however, the original procedure was considered adequate and not revised. The >
inspector reviewed the six' Radiological Incident Investigation. Reports 5 generated from May 1986 to date. The reports were typically initiated
'for personnel contamination incidents and failure to follow RWP requirement Reports generated since late 1986 appear to show improved corrective action j documentation; nevertheless, conclusions regarding the adequacy of report !
'
documentation and of the overall investigation system will be withheld pending further implementation and review of the syste No violations or deviations were identified, i Training and Qualifications The inspector reviewed the training and qualifications aspects of the licensee's radiation protection and radwaste programs, including: 1 changes in responsibilities, policies, goals, programs, and methods; qualifications of newly hired or promoted radiation protection personnel; and. provision of appropriate radiation protection and radwaste training for station personne Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse .
Chemistry / Health Physics technician training consists of both farmal course work and on-the-job training. The licensee is seeking INP0 accreditation for the training program. Courses continue to be presented at the Midland Training Center and include a 12-week health physics fundamentals course and a three-week advanced chemistry / health physics course. Continuing training consists of various informal training sessions presented in-house every two to three weeks covering specialized
'
topic The licensee's on-the-job training program includes a qualification program for technician advancement upon completion of practical factor 6 tasks. Technician advancement to the four defined technician levels (technician trainee, technician, technician II, and senior technician)
depends on successful demonstration of the practical factors tasks to appropriate supervisory personnel. Technical specification 6.2. requires that a person qualified in radiation protection procedures be onsite while fuel is in the reactor. Based on the licensee's training and qualifications program, technicians above the trainee level usually meet this requirement. Administrative Procedure No.1.7.1, " Chemistry and Radiation Protection Technician On-The-Job Training Program,"
l outlines in Attachment 3 those practical factors tasks which must be successfully demonstrated before a technician can be considered l
l L - -- ----_ ------------ -------- _ ---
. _ _ - - _ _ _ _ - _ _ _ _ _ _ _ .
-
.
." qualified in radiation protection procedures" and capable of providing
~
back-shift coverage. .This procedure was recently revised.to include a more specific task breakdown, add other previously unrequired tasks, and better delineate the overall practical factors requirements. The licensee is transcribing previously completed practical factors task items for all technicians onto a newly revised . task items list. However, the licensee has no systematic method for transferring previously approved tasks onto the more specific revised task lis Also, documentation of task completions on the revised system is incomplete, lacking task approval
, signatures and dates. This matter was discussed at the exit meeting and will be reviewed further during future inspections (0 pen Item No. 155/87012-01).
Currently, all technicians are considered " qualified in radiation protection procedures" and eligible for shift rotation. .The station's ,
last remaining technician trainee was upgraded to technician in October 1986 and approved for' shift rotation. Back-shift coverage is usually provided by one technician working eight-hour shifts on weekdays and 12-hour shifts on weekends. Although meeting technical specification requirements for shift coverage, approximately 25% of the current technician staff do not meet ANSI N18.1-1971 experience requirement The licensee plans to continue this practice and allow technicians above the trainee level to be eligible-for shift rotation, provided minimum practical factors task requirements have been me No violations or deviations were identifie . External Exposure Control and Personal Dosimetry The inspector reviewed the licensee's external exposure control and personal dosimetry' programs, including: changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesse Exposure ~ records for plant and contractor personnel for 1986 and 1987 to date, were selectively reviewe A selective review of Forms NRC-4 or equivalent was made for those individuals whose whole body exposure ,
exceeded 1.25 rem in a calendar quarter; no problems were noted. No j exposures in excess of 10 CFR 20.101 or the licensee's quarterly administrative limits were noted. Total dose for 1986 was 9 s person-rem by pocket dosimeter and 76.1 by TLD. This is well below the station's annual average of about 300 person-rem and is primarily due to the lack of a refueling or other major outage during the yea No individual received greater than 3.5 rem to the whole body during 198 ;
Total dose for 1987 through April is about 193 person-rem by pocket
! dosimeter, the majority (95%) of this was accumulated during the recent refueling outage which ended in March. Maximum individual whole body l
,
5 i l
!
__________ A
'
.
l dose for 1987 thus far is less than 2.5 rem by pocket dosimete The licensee continues to review pocket chamber /TLD discrepancies exceeding 250 mrem and/or 25%. No problems were note No violations or deviations were identifie . Internal Exposure Control and Assessment l
l The inspector reviewed the licensee's internal exposure control and l assessment programs, including: changes in facilities, equipment, I personnel, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of' individual intakes meet regulatory requirements; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesses.
)
The licensee routinely performs whole body counts on radiation workers twice annually and whenever an intake is suspected. The inspector reviewed Radiation Protection Procedure No. RP-38, Revision 6, February 4, 1987,
" Policy for Whole Body Counting and Whole Body Count Evaluation" and reviewed the calculational method for determining MPC-hour uptake No problems were noted. The inspector reviewed whole body count results for September 1986 through March 1987. Ninety-two individuals were counted during the last four months of 1986 and 190 were counted in 1987 through April 11. No result exceeding the 40 MPC-hour control measure was noted; followup counts were performed on individuals who displayed initial elevated count No violations or deviations were identifie . Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated material The inspector reviewed results of routine radiological surveys performed during 1987 through April in accordance with Radiation Protection Procedure No. 29. The surveys consist of external surveys and smears of various radiologically controlled (RCA) and non-radiologically controlled areas performed on a daily, weekly, or monthly basis, depending on the locatio Monthly surveys of additional high traffic areas outside the RCA were recently included in the procedure as a result of contamination found in the lobby of the access control building (Inspection Report No. 50-155/86014(DRP)). Survey data indicated general area smear results of controlled areas are typically below the station's 400 dpm/100 cm2 decontamination action leve The highest smearable
. .
_ - _ _ _ _ _ _ _ _ - _
_ ___. __ ______-___
. >
l
!
!
contamination was consistently found at the reactor deck, a boundaried ]
area. Other contaminated areas greater than 400 dpm/100 cm2 that are l not readily decontaminated because of ALARA considerations are !
positively controlled by physical boundaries including locked door l A janitor is assigned area decontamination._ work two days per week; I technicians assist in decontamination tasks as time permits. The I janitor has received informal decontamination training from health !
physics supervision. Although the extent of contaminated areas is not !
tracked, the licensee estimates that 10-15% of the controlled area is 1 boundarie During the recently completed' refueling outage, the licensee retained three full time contract decontamination technicians; this was not done during past outages. The licensee is satisfied with their efforts and will consider a similarly augmented decontamination crew for future outage '
The inspector selectively reviewed personnel contamination reports for !
1986 and 1987 through April. The licensee reports all skin contaminations exceeding 100 cpm above background and tracks the data for ALARA purpose There were 33 personnel contamination incidents reported in 1986; over 50% occurred on the reactor deck. Sixty-nine incidents were reported for 1987 through April, nearly all occurring during the refueling and maintenance outage which ended March 1 Forty-two incidents occurred in January 1987 resulting primarily from fuel transfer operations and control rod drive replacements; however, nearly 50% of the January incidents were minor hand / foot contaminations less than 500 cpm. Whole body counts are required when skin contamination above the neck exceeds 1000 cpm or 50 cpm from a nasal smear. A skin dose determination is required when greater than 10,000. cpm are detected. According to the licensee, an inefficient fuel pool cleanup system leads to contamination control problems during refueling operations. To help rectify the problem, the licensee initiated operation of a supplemental underwater filtering 3 system in the fuel pool shortly after the refueling outage conclude The supplemental system will run continuously at 250 gpm with variable (1-25 micron) particulate filter If the new filtering-system proves effective, the licensee will consider decontamination of the fuel pool cooling system piping and heat exchanger The station recently modified their egress controls and reinforced their frisking policy in an attempt to eliminate incidents of contamination found outside the RCA. Currently, all RCA egress is through access control only, unless specifically authorized by radiation protectio Two previously used RCA exits are no longer authorized egress points. Also, the RCA in the shop area was extended to allow access to the stockroom window from the RCA. These changes became effective April 1, 1987. The licensee removed a frisker from the sphere's 585-foot elevation, leaving no frisker routinely available to workers inside the sphere. The only permanent friskers in the RCA are located immediately outside the personnel hatch !
and at access control. Admittedly, sphere area radiation background levels are elevated and reduce the effectiveness of detecting lower levels of j contamination; however, it appears desirable to reinstall a modified
'
!
,
ff ,
,
,c '
,.
shielded frisking booth at the 585-level to allow detection of gross i
' contamination after exiting highly contaminated rooms which exist in the area. Conventional hand-held friskers continue to be the sole method of ;
personnel contamination detection at access contro This method is not i state-of-the-art and is highly dependent upon individuals performing adequate. frisks and then reporting personnel contaminations which are '
identified. Instances of contamination detected outside the RCA i (presumably from shoe contamination) have been identified by the licensee. Additionally, Audit Report No. QT-87-02, conducted during-February 2-6, 1987, indicated that approximately 50% of workers observed over. the audit period were frisking improperly. It appears frisking methods, particularly at access control, are a programmatic weakness i requiring attention by the licensee, including procurement of whole body 1 friskers. These contamination control concerns were discussed at the exit meeting and will be reviewed during future inspections (0 pen Ite .l No. 155/87012-02). ;
,
On February 13, 1987, operators transferring water which had been processed ;
through a demineralized to the outdoor treated waste hold tank filled the tank to overflowing. Water apparently leaked from the manhole gasket and froze along the tank sides and on the concrete pad beneath. The licensee estimates that 10 to 25 gallons of liquid leaked from the gasket area with a total activity of about 7 to 17 uC Resultant contaminated soil was excavated and placed in onsite storage pending disposal as radwaste (Inspection Report No. 50-155/87009(DRSS)). Both maintenance activities associated with the leaking gasket and aspects of personnel errors associated with overflowing the tank are being pursued by the site's NRC Resident Inspecto The radiological aspects of'this incident are' subject to further review (0 pen Item No. 155/87012-03).
)
No violations or deviations were identifie . Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses, i
The formal ALARA program is administered by an ALARA Coordinator, no other personnel are assigned direct responsibilities under this program; however, chemistry / health physics technician. support is available. No formal ALARA training program currently exists; although an ALARA training program for the health physics and engineering staff is being developed by the licensee's Midland Training Center together with Palisades Statio The training program is anticipated to be developed in 1987 and should be available to Big Rock Point employee __ _ _ _ . _ ._
--_ __
'
.
-]
I For 1986, total plant exposure by pocket dosimeter and TLD was 94.6 and 76.1 person-rem, respectively; meeting the plant's goal of 100 person-re ]
This is considerably less than the station's 300 person-ren average over j the previous five years; however, unlike previous years, no refueling outage occurred. For 1987, the ALARA goal for total plant exposure i person-rem. Through April 1987, total plant exposure by pocket i
dosimeter is.193.7 person-rem; 183.6 person-rem was accumulated during l the 69-day outage which began January 2. For the 1985 refueling outage,- {
in which work'similar to the 1987 outage was performed, total exposure 1 was about 191 person-re Approximately 15 person-rem was accumulated i during the 1987 outage for jobs which were not performed in 198 Excluding the exposures attributed to jobs performed solely in 1987', I a minor (12%) dose savings was realized for the 1987 outag j
Audit Report No. QT-86-2, documenting results of an April 1986 audit by i the plant's QA department, identified one finding regarding the ALARA 1 program. The finding involved deficient implementation of administrative controls and documentation associated with ALARA work packages and included {
a
' underestimation of pre-job exposures and incomplete documentation of 1
, ALARA post-job reviews. A Deviation Report was initiated-to track resolution. .At management's request, a surveillance was performed of the station's ALARA and RWP. programs by a licensee QA auditor. The surveillance was conducted September 15-24, 1986, and identified several observations related to overall program inadequacies. Some of the '
observations noted in the surveillance report concerned worker failure
.to read and understand RWPs, lack of procedural direction for RWPs and i ALARA, and an overall attitude of indifference toward RWP and ALARA '
program The surveillance report also questioned whether sufficient staffing was devoted to RWP/ALARA program Similarly, a previous INP0 audit identified problems,with implementation of the ALARA program, J primarily relative to associated RWP program weaknesse '
During the inspector's cursory review of the formal ALARA program and discussions with licensee personnel, the inspector found that weaknesses in properly implementing and documenting the ALARA program apparently .
stem from inadequacies in the RWP program and apparent lack of sufficient i ALARA staffing during outages. The licensee recently concluded a review i of the RWP program and is currently planning extensive revisions to the !
program. The implementation of the revised RWP program and its effect j on the ALARA program will be reviewed during later inspections I (Sections 3 and 10).
<
"
No violations or deviations were identifie . Radiation Work Permit Program
!
The RWP program is the principal mechanism used to identify radiological j work conditions, specify radiation safety requirements, ensure required _l work briefings are conducted, and provide a means of exposure tracking.
f-l '
L 1
-
.
-
< oq i
I As discussed in Section 9, previous licensee'QA audits and surveillance identified a general weakness-in the RWP program. For example, the QA i surveillance conducted in September 1986 identified the.following: I ( ' Failure of workers to read and understand RWPs and sign associated i exposure entry logs
)
. *- 'No independent reviews of'RWPs j
!
- General RWPs exceeding their expiration date(s)'
- Errors in completing RWPs
- Attitude of indifference toward the RWP program In a followup infofmaT health physics surveillance conducted in February l 1987, many similar weaknesses were identified; however, certain aspects !
of the program showed some improvement.' The surveillance noted no
~
improvement-in worker attitudes toward the RWP program-and identified an overall insufficient attention to netail. The surveillance report !
outlined several recommendations to inp' rove the progra I
As a result of,these licensee identified wAaknesses, an RWP Task Force was established for the purpose of improvin'g the. RWP system; the task force consisted of individuals from each department that has significant involvement in RWP work. The task force has nearly completed their review and.an overhaul of the RWP program is planned. Plans call for more explicit and detailed RWPs and improved job preplanning. It also ;
appears that RWP program training is necessary. Implementation of the I revised program is planned to begin in June 1987. The RWP/ALARA program modifications were discussed at the exit meeting and will continue to be :
reviewed during subsequent inspection No violations or deviations were identifie . Solid Radwaste
'The. inspector reviewed the licensee's solid radioactive waste management prngram, including: adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the quality assurance program; adequacy of required records, reports, and notifications; and experience concerning identification and corrections of programmatic weaknesse Solid radwaste handling, compaction, and storage facilities are located in the radwaste building outside the protected area. The building is bounded by a lockable chainlink fence; keys are positively controlled by the Chemistry / Radiation Protection Department. High activity resins and filters are loaded into HICs and dewatered; HICs are stored in vaults in the radwaste building pending shipment. Dry active wastes (DAW) are either compacted in 55 gallon drums or placed in steel boxes. The licensee currently uses a conventional compactor yielding approximately 250 pounds
. L
"
10'
. _ - - _ _ _ - _ _ _ _ - _
-_ _ .
_ - . _ _ _ _ _ _ __ __ _-_
'
y of waste per-drum and anticipates increasing its compaction ability, using compaction disks, to about 280 pounds. Also, the licensee is considering the use of a vendor. supplied super compactor to further reduce volume QA Audit-No. QT-86-2, conducted in April 1986,. included a limited review of the station's radwaste shipping and packaging program. The audit identified two observations primarily concerning incomplete procedural 1 instr 0ctiorp for radwaste shipping. The audit observations appear to have been ' adequately addressed and correcte The station generated about 1400 cubic feet of radwaste in 1986 and about 1550 cubic feet in 1987 through April; the majority was comprised of non-compacted DAW. Approximately 900 cubic feet of non-compactible DAW was generated in March 1987 resulting exclusively from outage activitie The inspector toured radwaste handling and storage facilities and discussed radwaste handling with a licensee representative. No significant problems were note a No viohtions or deviations were identifie . Transportation of Radioactive Materials 1 The inspector reviewed the licensee's transportation of radioactive l'".
materials program, including: determination whether written implementing propwlures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT-regulations and the licensee's quality assurance prograr; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesse The inspector selectively reviewed portions of the solid radwaste shipment records for 1986 and 1987 to date. The information on the shipping papers appears to satisfy NRC, D0T, and burial site requirement j The station made three solid radwaste shipments in 1986 and four in 1987 '
through May 16 totaling about 1500 and 1600 cubic feet respectivel The majority of shipments were to the Barnwell, South Carolina sit Trending data shows a steady decline in the volume of radwaste shipped
'
annually since its peak of about 5000 cubic feet in 1981. The licensee indicated no transportation incidents or significant problems occurred in the last yea No violations or deviations were identifie i 13. gliegationFollowup
,
Discussed below are allegations concerning the radiation protection
,
program at Big Rock Point which were evaluated during this inspectio The evaluation consisted of record and procedure review and interviews J
,
with licensee personne ~. - _ _ _ . _
,, ; - ,
pg mv y ,
,
-
..
,
w Nh h' ,
[ L-a w w 94; '
)
, 1 . , n . ,
t
,
..
.a; The) Big Rock Point Resident Inspector's' office received information wo E .regarding. concerns withfplanning and.ALARA practices at the'stationL h.#r g"' .
during the 1987; refueling outage. The concerns were clarified <ina h
fy ',
telephone conversations with the' individual on June 17 and 29, 198 The allegation,and i_nspector's findings:are discussed belo t
% f
' '(AllegationNo.. kill-U-g-0057(Closed)) ,
,
~
w ' Allegation: PoorplanninhandALARApracticesresulted'inexcessive-
+ .and unnecessary radiation caposure to Field Maintenance' Services (FMS)-
workers: involved in'ISI? weld examinations in the steam drum are As :a~ result, sryeral crewmen reached their quarterly exposura ' limit 9: Jand'were'trtssskreed to other non-nuclear locations. Specifically,
.the concern was directed toward improper exposure distribution and lack of gianning associated-with scaffolding constructio ;
Discussion: The subject of' the' alleger's concern involved ISI
'vald preparation work performed in the steam drum area'during- .
y outage activities in lanuary 1987. Prior to performing actual weld !
preparation work, consisting of cleaning, brushing, and grinding, M scaffolding was constructed in thesarea. ' Scaffolding construction I
"
was initiated January '5,1987,' ahd was completed on+ or abou f l
January 9,1987. Scaffolding was erected by.the same. work group that performed the weld preparations (i.e.,'FMS crew), reportedly hl
- to' alleviate complaints of poorly constructed scaffolding which
.m ,
surfaced during the previoes' performance of this work during the q
" "'
station's 1985 outage *
- -
p
. k Athepre-jo ALARA review was completed for each of two.JSI jobs 'i steam drum area,~one for the lower and one.for the. upper steam 1 a
Ni" drum. room. The licensee performed a pre-job ALARA review, estimating _ i y' c!oses of approximately 7 rem for scaffolding erectior and approximately~ .l rem for weldgeparation ' activities. '(An.RWP contained incorrect l
%
'
.information cbn W ning'the estimated _ dose ~to complete the wor This'
n' N p" -
- did not result in'any fdcreased personal' doses, .but could have led to j aperceptionofincres[edpersonaldosessincetheRWPdoseinformatico j'
4i
.
was condderably:10wer than the ALARA pre-job estiste.) Scaffolding-
~
'
construction is relatively labor. intensive and require's workers to .,
w -
~~p hysically hoist 1p the l d ^ 50 feet from the s circ (pf9ces of scaffolding ulation pump'rcom floorusing to theropes, steam about drum s*
% area. Scaffolding' construction consumed about 18 person-hours, } l about six of'the 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> was expended hoisting-up the piece f Theilicensee did.imt dry-run' scaffolding constructGn or have
'
t
', , 4 hs of previous,1y constructed scaffolding or blueprints other training .or photograj#
aids: to streamline the process. -Use of such aids may hg '
_havel expedited the work and produced some dose. saving Although (3 there was no spe,cific training provided for scaffolding construction,
.the workers were reportedly reasonably experienced in such constru:: tion Q4N
'
e and rigging work.t The actual total exposure received for scaffolding
,
j M, work.was about 6 person-rem which was about 1 rem less than predicted.
c; N y '
According to the alleger 7 the scaffolding job took longer, therefore .,
worker radiation doses idercased, because incorrect scaffolding was j hoisted to,the Wrk floor before the error was discovered. Licensee
'
m['4g,m
_
,y ++ ,,
,
4 - % 12 i
b y1 Q-
/'
a j
- 4
-
___
wn =
'
+
q '
s t .
w
'
6 personnel interviewed. denied;this allegation, but did acknowledge W that the. job could have been completed more expeditiously had the
, <
workforce been better trained. While the' veracity of the allegations
was notiresolved,Lthe doseLsavings which could have been rchieved,.
'were:the allegation correct, appears to be.a' maximum of about 10%
of.the 6 person-rem expended on scaffolding erection. Inasmuch a the licensee. acknowledged the need for improvements-in future similar scaffolding erection,.no further NRC action. appears warrante '
The licensee'.has a mechanism in their'ALARA program for directl soliciting worker concerns and recommendations for joo improvements
'
. eccording to licensee' personnel, no.previously unconsidered-recommendations.to substantially reduce overall job' exposure were
@K made for this job. The. alleger claims that one of-the FMS workers.
W submitted an ALARA recommendation through his job supervisor
concerning the recent scaffolding work. The licensee's.ALARA coordinator' stated he~had not. received an ALARA recommendation from
, an FMS worker during the recent outage an'd'that ALARA recommendations should be submitted direct 19 to him rather thar, to the job surerviso .He.further stated that he would review the need to improve methods for soliciting ALARA' recommendations. This matter will be. reviewed
[ <
further during a future inspection (0 pen Item 155/012-05).
As'many as nine FMS workers may have been involved in the' scaffolding construction work and subsequent weld preparations during their> ;
,_ temporary assignment at Big Rock in January and February 198 .I
.The licensee's TLD analyses show no FMS worker received a whole body: exposure exceeding licensee quarterly' administrative limits; however,'several workers approached the limits and'were transferred l u to other.non-nuclear assignment To. improve. future similar tasks, the licensee plans to use photographs taken after the scaffolding was constructed as a' training aid and t : more closely track times and exposures' for all ISI work.- Construction ~
of. permanent scaffolding was considered, but will reportedly not be:
erecte Findina: The alleger's primary concern appeared to be that the ,
crew performing weld preparations also was required to erect the '
scaffolding, and in so doing,'they received additional radiation i exposure such that some of them had to be sent to non-nuclear jobs because they approached the' licensee's' quarterly dose ~1imit (2500' mrem). In the' June 17, 1987 telephone conversation, the alleger was informed that the licensee's failure to distribute the total radiation dose over a larger number of workers and therefore eliminate the' necessity.to transfer workers to non-nuclear jobs because they approached.the quarterly ~ dose limits, was not contrary to NRC regulations or guidanc ,
i
p L--___.-_____-__-_-__-_-_ _
- _
. _ _ _
-
.
The alleger's additional concerns of poor ALARA practices which_ .
resulted in excessive. exposures appears to be only partially correc ALARA planning was performed for_this work, and while the.. licensee has acknowledged that improved preparations for-future similar i- scaffolding work should be utilized, the pre-job dose estimates were reasonably accurate. While the ALARA practices could have been better, they did not violate regulatory requirements.
- ,An anonymous caller telephoned the NRC Region III office and expressed his_ concerns regarding activities at Big Rock Point. The alleger subsequently met with a Region III Physical Security Inspector, clarified his concerns, and made additional allegations including radiation protection program matters. The individual's allegations relating to the radiation protection program at Big Rock Point and the inspector's findings are discussed below or have been addressed in Section 13.a abov (Allegation No. RIII-87-A-0042(0 pen))
' Allegation: High radiation area door keys may be signed out by one person then given to others without an accurate record of who has used the keys. The person returning the key would, at times, be someone other than the person that signed out the key. Also, the alarm on the recirculation pump room door (high radiation area door) could be easily circumvented by tying off the contact switch, which he believed.to be a common practic Discussion: Technical Specification 6.12.2 requires that high radiation areas (> 1 R/hr) be provided with locked doors to prevent unauthorized entry, keys be maintained under the administrative control of the Shift Supervisor on duty and/or health physics supervision, and doors remain locked except during periods of access by personnel under an approved RWP. Administrative Procedure No. 5.8, "High Radiation Area Key and Access Control" states that the Shift Supervisor is responsible for high radiation area key custody and control. The procedure further states " keys are signed out in the Shift Supervisor's office and returned after us During ;
outages and in instances where high radiation areas are kept open i for several shifts or days, key responsibility may be transferred by the key recipient's notification of the Shift Supervisor." ;
A high radiation door key log is maintained in the Shift Supervisor's office and contains columns for recording key number, key type, ,
'
person signing out key, and date and person returning the ke The inspector selectively reviewed the logbook for 1987 and noted several instances where the individual returning the key was not specified, was someone other than the person who signed the key out, or a question mark was entered in the key return column. A Shift Supervisor (SS) indicated that keys may be transferred to another individual provided the SS is notified and approves the transfer; :
however, the log has no provision.for documenting transfer 1 responsibility. This is a weakness which should be corrected. In accordance with Administrative Procedure No. 2.1.4, " Plant status l
i 14 !
- - _ _
_ _ - - _ _ _ _ _ _ _ _
'
..+ i
- }
and' Equipment Control," Shift Supervisors stated they release keys and allow-transfer to individuals they personally know to be advanced radiatiorr workers,(i.e., radiation protection technicia'n's, certain-operators / engineers and supervisory personnel) or those that have
- arranged.for radiation protection coverage. A= list of plant. advanced ~
.
-radiation workers is:not available; however,-because'of the-
- relatively'small size.of the plant staff, the operators reportedly: i knowLall personnel qualified to be issued key '
During outages,.the plant'provides a list of qualified contract workers'to Shift Supervisor The recirculation. pump room is a locked high radiation area that has audible and visible local and control room alarms which actuate whe its' door (gate) is opened. The technical specifications.do not require alarms on high radiation area doors; the alarms'are used
! w to alert the control room of ontries into certain high radiation (> 1 R/hr) areas. The gate opens outward (towards'the individual'
entering) which causes an electrical contact arm to also swing outward
!
and activate the alarr. The individual opening / closing the gate is
.
responsible for notifying.the control room prior to entry.and after h
exiting. A phone .is maintained on the wall outside the room for such purposes. The local alarm actuat'es only while the gate is in the
'open position but continues to sound in the control room, regardless-of gate position, until acknowledged by the operator. During' periods when continual,or. frequent access to the room is required, the alarm!s'
contact arm is tied back and a gate watch controls entry; the.licens'ee reported this to.be a routine practice, especially during outage The' alarm cannot be' easily circumvented unless the entry gate is 1 opened; this was' confirmed during conversations with radiation-protection department management. After the' alarm is actuated, the
. alarm's contact arm can be tied off to prevent continuous alarming in'the area. Defeat of the alarm is acceptable when access to the room is controlled by an authorized gate watc ~ Finding: While the. allegations were substantiated, they~do not
. represent violations of regulatory requirements, and are generally acceptable practices. Improvements are desirable concerning the licensee's administrative controls over HRA keys. This matter was discussed at the exit meeting and will be reviewed further during
'
a future inspection (0 pen Item No. 155/87012-04).
Allegation: There was an insufficient supply of large-sized protective coveralls available at times during the 1987 refueling outage; contamination control can be' jeopardized when the small-sized coveralls pull loose at the taped wrists and/or ankle Discussion: The licensee acknowledged that protective clothing 7: shortages may have existed at limited times during the 1987 refueling outage; however, they stated that they were unaware of any personal contamination directly attributable to the wearing of under-sized coveralls. The licensee has plans to increase supplies of large-sized protective coveralls for the next refueling outag This matter will be reviewed further in a future inspection (0 pen Item 50-155/87012-06).
a =__-_____
-- -- -
-
.
Finding: While'the allegation was substantiated, the licensee had
' -
already identified the weakness and planned corrective measures for the next refueling outage. No regulatory requirements were violate No violations'or deviations were identifie . Exit Meeting The inspector met with those noted in Section 1 on May 22, 1987 to discuss the scope and findings of the inspection. The inspector also ;
discussed the'likely informational content of the inspection report with '
regard to documents or processes reviewed by the inspector during the inspection. The licensee identified no such documents / process as proprietary. In response to the inspector's comments, the licensee: Acknowledge the inspector's comments concerning the desirability of improving documentation and followup of corrective actions for the health physics functional surveillance program (Section 4), ' Acknowledged the need to devise a method for transferring a technicians previously approved practical factors tasks onto the revised task list and complete the documentation (Section 5). Agreed to consider reinstalling a frisker/ shielded frisking booth at the 585-foot elevation of the sphere and consider obtaining a whole body frisker at access control (Section 8). Acknowledged the need to improve high radiation area door key controls (Section 13).
,
-__