IR 05000155/1993012
| ML20057A084 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/31/1993 |
| From: | Mccormickbarge, Paul R, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057A083 | List: |
| References | |
| 50-155-93-12, NUDOCS 9309130021 | |
| Download: ML20057A084 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
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Report No. 50-155/93012(DRSS)
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Docket No. 50-155 License No. DPR-6.
Licensee:
Consumers Power Company
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212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Big Rock Point Nuclear Plant Inspection At:
Big Rock Point site, Charlevoix, Michigan Inspection Conducted:
August 9-13, 1993
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Inspectors:
N. Shah Wh7 Date
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Date b0 b Y-1 M
Approved By:
J. W. McCormick-Barger, Acting Chief 9/3/k3
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Radiological Controls Section 1 Date Inspection Summar_y Inspection on Auaust 9-13. 1993 (Report No. 50-155/93012(DRSS))
Areae Inspected:
Routine inspection of the radiation protection (RP) program (inspection procedure (IP) 83750) during an outage, including management control and organization, internal and external exposure, as low' as reasonably'
achievable (ALARA) program, 'and contaminated ' area control. Also reviewed were new 10 CFR Part 20 implementation (IP 83750), a Licensee Event Report (LER)
concerning the failure to post a high radiation area (IP 83750), and a Deviation Report (DR) concerning an unmonitored liquid release (IP 84750).
Results: Overall, the licensee's radiation protection program appeared good.
Planning and preparation for outage work addressed ALARA concerns and made good use of historical data (sections 5 and 6). Communication between work t
groups and maintenance job planning appeared to be improving'(section 5).
Transition to the new 10 CFR Part 20 also appeared to be going-well (section 6) and total plant exposure and contamination events were low. However, additional management oversight is warranted for control of work areas and radiological surveillance of contaminated areas (section 9).
7DR 309130021 930s33
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DETAILS
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Persons Contacted j
- P. M. Donnelly, Plant Manager
- G. C. Withrow, Safety and Licensing Director
- K. E. Pallagi, Radiation Protection Supervisor
- M. Bourassa, Senior Licensing Engineer-
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- T. A. Mosley, Senior Engineer (Chemistry and Health Physics)
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- B. Olmstead, Dosimetry Supervisor, RP Technician
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- T. Popa, Site ALARA Coordinator
- R. Burdette, Lead Health Physicist
- D. Turner, Manager Plant Maintenance
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E. A. Bogue, Manager Chemistry and Health Physics
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- Present at the August 13, 1993 exit meeting f
The inspector also interviewed other licensee and contractor personnel.
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Licensee Action on Previous Inspection Items (IP 83750)-
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(Closed) IFI 50-155/93008-01:
Licensee to. determine new minimum
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detectable activities (MDAs), upgrade software and provide training for i
the whole body counter (WBC). The inspectors reviewed the new MDAs.
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calculated by the licensee's WBC vendor; no. problems were identified.
The vendor is expected to install the new' software and-provide training
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to the licensee staff by December 1993.
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(Closed) LER 93006:
Failure to post a high radiation area (HRA).
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During a routine plant tour on July 15, 1993, the Health Physics Manager discovered that the high radiation area near the. steam drum conductivity
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cell was unposted. General area dose rates ranged between 10-300
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-millirem (0.1 - 3.0 milliSieverts (mSv)) per hour. A contract radiation protection technician (CRPT) had removed the posting about three days
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earlier to facilitate work in'the' area, but had forgotten to replace it.
Although the area was unposted during this period, the radiation work
permit (RWP) and local area status sheets identified the HRA, and local l
" hot spot" stickers were evident arourd the region of the elevated dose rates.
Immediate-corrective actions included reposting the area and discussing the event with the CRPT. Additional actions will include
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reemphasizing management expectations regarding area postings in weekly technician meetings and in high radiation area access (HRAA) training-
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(section 3). An inspector verified the posting was' replaced and that workers were aware of high radiation posting requirements.
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3.
Trainina and Oualifications (IP 83750)
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The inspectors reviewed the training and qualifications of CRPis and
.t station radiation protection technicians (RPTs). Also reviewed were the HRAA training program, and worker knowledge of new 10 CFR Part 20.
The licensee relied on vendors to verify CRPT resumes and to supply only-ANSI N18.1 qualified senior technicians. While the licensee may review these resumes against ANSI N18.1, their contents were usually not-
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these resumes against ANSI N18.1, their contents were usually not i
, verified.
For the outage, the licensee hired senior CRPTs and reviewed
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all resumes against ANSI N18.1. - Additionally, the quality assurance j
group planned to verify all CRPT resumes and determine the adequacy of i
the licensee provided training.
Prior to starting work, CRPTs received l
two days of new 10 CFR Part 20 and plant procedural training followed by
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a written test. Through selective personnel interviews, the inspectors
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verified that CRPTs were familiar with the new 10 CFR Part 20 and plant
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procedures.
j While all of the six station RPTs were ANSI N18.1 qualified seniors, none were certified under the National Registry of Radiation Protection i
Technologists (NRRPT). The licensee eacouraged RPTs to obtain NRRPT i
certification.
Currently, two RPTs were considering taking the NRRPT
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test.
Workers who routinely entered high radiation areas were provided HRAA
training, to allow them to perform dose rate coverage for themselves or j
other HRAA trained workers. HRAA trained workers were instructed in
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performing routine dose rate surveys and in plant procedures and policy l
governing high radiation areas.
Successful completion of the training i
required passing a written test and signatory approval by the Health
Physics Manager. The inspectors reviewed the HRAA training program and, i
through selective personnel interviews, verified that workers understood i
plant procedures.
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No violations or deviations were identified.
4.
External Exposure Control (IP 83750)
l The inspectors reviewed selected aspects of the licensee's external
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exposure control program including recent radiological performance,
personnel dosimetry assignment and processing, and RWPs.
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About 98 person-rem (0.98 person-SV) was accrued to date, significantly
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below the outage goal of 158 person-rem (1.58 person-Sv).
Decreased use i
of respirators (section 6) and improvements in ALARA planning (section l
5) were the major reasons for the decrease. Although the outage was i
extended due to emergent work on the turbine, the total dose was
expected to remain below the goal. As of July 1993, accrued dose for
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major outage activities included 10.0 rem (0.10 Sv) for Inservice Inspection (ISI), 6.2 rem (0.06 SV) for control rod drive (CRD) work,
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4.8 rem (0.05 Sv) for reactor head removal, and 7 rem (0.07 Sv) from miscellaneous valve work. About 26 rem (0.26 SV) was anticipated for i
the reactor head installation, refueling activities, and remaining valve i
work.
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The licensee used thermoluminscent dosimeters (TLDs) and self-reading
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desimeters (SRDs) to monitor workers for exposures.
While the SRDs and
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TLDs recorded beta and gamma exposure, a correlation factor was used to calculate neutron dose. The correlation factor was based on TLD
calibrations using a 2Cf neutron source and direct plant neutron field
measurements taken in 1979. Also reviewed, was the licensee's assignment of eye equivalent dose, which was based on a 1989 study j
correlating eye dose to the measured deep dose equivalent on a TLD. The-l
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inspectors reviewed selective personnel exposure reports for 1993; no i
problems were identified. The licensee was considering replacing SRDs with more accurate electronic dosimeters (EDs) in 1994.
These EDs would allow the licensee to set dose and dose rate alarms for workers.
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The inspectors confirmed that the licensee's TLD processor was certified.
l by the National Voluntary Laboratory Accreditation Program (NVLAP).
i Along with each shipment of TLDs, the licensee included about 10-12 j
" spiked" TLDs for quality verification purposes. A review of spiked TLD-l results for the last four quarters indicated an average conservative bias of 3% in the reported results.
- Selected radiation work permits (RWPs) were reviewed for appropriateness of the radiation protection requirements based on work scope, location,
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and radiological conditions. Although the RWPs were somewhat lengthy, plant workers were observed adhering to RWP requirements and demonstrated their understanding in interviews with the inspectors. The licensee was considering implementing a computerized RWP system to
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simplify communication of radiological conditions to the workers.
No violations or deviations were identified.
5.
Outaae ALARA Considerations (IP 83750)
The inspectors reviewed the implementation of the licensee's ALARA
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program during the outage and observcd work in progress.
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ALARA Preparation i
The permanent ALARA staff was comprised of one person; the ALARA
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coordinator. As part of a pilot program, a senior RPT was
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reassigned to assist the ALARA coordinator in maintenance job planning, and an experienced contractor was also-added for outage support.
Decontamination (decon) and housekeeping efforts (section 7) were aided by five_ temporary workers _who were given
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special training in decon techniques. Approximately fifteen CRPTs
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were also added (section 3) to assist RP job coverage. Overall RP support for the outage was good.-
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ALARA Plannina The inspectors attended several_ outage planning and briefing meetings to assess communication among work groups.
In addition to a morning staff meeting, three daily meetings occurred to coordinate outage activities. These meetings were supplemented by three and seven day schedule overviews distributed to plant management. These schedules were a new initiative and appeared to work well. Outage meetings were informative and attended by appropriate work groups, and interviews with workers' indicated that communication was good.
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The inspectors noted that lessons learned, historical job information, pre-job meetings, and ALARA briefings, were used for planning and implementation of engineering controls and were generally effective. Dose estimates for RWPs were based.on
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previous history files and were reasonably close. Although the'
station improved in integrating ALARA principles into the job
planning process, there was some minor difficulty in gathering information for the post-job review.
Some improvements were made during the outage, but the licensee indicated more effort was needed. While ALARA input to the work order / package review t
process was sufficient, supervisory tours of dose intensive jobs were not always made before completing the work package. The
inspectors also noted the lack of "in progress" job reviews
resulting in identified concerns typically being addressed after work was completed. The inspectors commented on the advantages of developing management action levels to ensure appropriate steps were taken before job completion. The licensee will evaluate these concerns and develop appropriate corrective actions.
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ALARA Imnlementation (Includino Work Observations)
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Good exposure reduction initiatives were used to reduce personal exposure.
For example, by hydrolazing the CRD poison line and using temporary shielding, area dose rates for CRD work were significantly reduced. The inspectors also noted good use of video cameras for remote coverage during reactor coolant pump i
(RCP) work.
Both RPTs and CRPTs covering jobs were knowledgeable
of the wor! mope and radiological conditions in the area. While
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worker's re.
slogical practices were generally good, the j
inspectors noted some workers loitering in radiation areas.
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was communicated to RP staff who promptly removed the workers from the radiological area.
- l Job planning significantly improved due to the additional staff added to the ALARA group (section Sa).
Good interaction was noted between the maintenance job planner and the RpT assigned to maintenance. Maintenance planning was also aided by the use of a maintenance planning guide to prepare work packages. The contract ALARA planner was in the process of upgrading the RWP program (section 4) by integrating and computerizing relevant information from job history files, health physics logs and lessons learned.
The contract planner planned to also develop ALARA recommendations to be used in the licensee's outage critique.
As noted in Section 6, the licensee began a program to reduce respirator use allowing work to be done more efficiently and thereby reduce overall dose. This initiative was used during
refueling floor activities with good results.
The inspectors noted that workers were generally favorable of the new approach.
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General radiation fields in the reactor building were relatively high owing to the source term. Although good ALARA practices
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(planning, shielding, etc) were generally used to control worker exposure, the inspectors were concerned over the licensee's control of hot spots. W511e hot spots were tracked, there were
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generally no recommended corrective actions, indicating a less l
than proactive approach.
The licensee recognized this and was planning to include the ALARA group in hot spot tracking.
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c Ove'rall, -it appeared that the staff was proactive, conscientious and
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experienced. The additional staffing _of the ALARA group produced significant improvements in maintenance job planning and in RWP development. Communication also improved among work groups, and good
exposure reduction 'nitiatives were noted. However, additional i
management oversig.t was needed to ensure.that work-areas were reviewed prior to compledng the work package and to develop corrective actions
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for hot spot reduction.
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No violations or deviations were identified l
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6.
Internal Exposure Control (IP 83750)
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The inspectors reviewed the licensee's implementation of the new 10 CFR
Part 20 regarding respirator use.
During this outage the licensee took steps to reduce the total effective
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dose equivalent (TEDE) by reducing respirator use.
Historical air t
sample data, and lapel and air sample data from the current outage were i
used to estimate internal exposures. The inspectors compared estimated derived air concentration hours (DAC-hrs) with actual air sample results
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for several workers; no problems were identified. The program appeared j
sufficient to estimate potential airborne concentrations and internal
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exposures, and included guidance on choice of instrumentation, sampling
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location, and working conditions. Actual DAC-hrs were tracked to verify
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the estimated committed' effective dose equivalent (CEDE), and based on j
air sample results, a CEDE of 50. millirem (0.5 mSv) was assigned to
'l individuals exposed to 20 DAC-hrs. The assignment of this dose was a-very conservative practice, which although allowed by regulations,
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appeared unwarranted since whole body count results generally did not:
identify an actual intake, and the DAC-hrs used to compute the dose were
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transfer. As a result, the TEDE could be conservatively skewed and could impact on ALARA decisions. The licensee will evaluate this-
practice after completing their first year under the new 10 CFR Part 20.'
l The inspectors will review this matter during a future inspection.
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No violations or deviations were identified i
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Control of Radioactive Materials and Contamination. Surveis and
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Monitorina (IP 83750)
The inspectors reviewed the licensee's contamination control program,
including portable instrumentation, laundry monitoring, decontamination
initiatives, and personnel contamination events (PCEs).
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Portable instrumentation examined during plant tours (section 9') were maintained in accordance with plant procedures and appeared.to be--
I properly used by workers. While these instruments were controlled by the RP group via an instrument logbook and an informal quarterly.
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inventory, an inspector noted that log entries were incraskte and that i
instruments assigned to workers were not tracked. The licensee was aware of these deficiencies, was~ developing a computer program to
replace the logbook, and was considering a formal quarterly inventory.
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These corrective actions will be reviewed in a future inspection (IFI
~ 50-155/93012-01).
The licensee used a contract vendor to supply and launder protective clothing (PCs). An inspector observed the collection and packaging of PCs by station radwaste handlers and noted no problems. Contamination monitoring setpoints used by the vendor for laundered PCs were verified by the licensee in 1991. Recently, the licensee also started selective-monitoring of incoming laundry to verify the vendor setpoints and establish background contamination levels. The inspectors compared the vendor"s setpoints against the licensee's criteria and reviewed the monitoring results; no problems were identified.
During the outage the reactor vessel was hydrolazed reducing incore dose rates from 10-70 rem /hr (100 - 700 mSv/hr) to 2-2.5 rem /hr (20-25 mSv/hr).
The CRD room and sump were also decontaminated, reducing area dose rates by 90% (from 500 millirem /hr (5 mSv/hr)) and 60% (from 900 millirem /hr (9 mSv/hr)), respectively. Because of the turbine work scope (section 4), the turbine components were sandblasted to remove fixed contamination. Additional contamination control initiatives
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included the use of tents and high efficiency air particulate (HEPA)
filters for turbine, CRD, and accumulator work.
The inspectors also noted continual mopping of floor areas by the temporary decon workers (section 5), regardless of actual contamination status.
During plant tours (section 10), the inspectors identified low level contamination (about 300 cpm above background) on sphere piping located about two feet above the floor, which was not identified on plant survey records. While the licensee performed routine area surveys, these surveys did not include elevated components or surfaces because these areas were considered outside " normal walkways" and required RP approval to enter.
However, the licensee had not clearly defined the " normal walkways" on survey maps or in the procedures. While discussions with worki 3 and a review of plant records indicated this practice was not detrimental to radiological performance, the inspectors informed the licensee that contamination surveys should include those areas readily accessible to the worker (such'as the above pipe surfaces). The-licensee agreed and planned to revise the contamination survey procedure
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and survey all a-
- sible areas to determine if other contaminated areas exist. This iten will be reviewed in a-future inspection (IFI 50-155/93012-02).
About 44 personnel contamination events (PCEs) were recorded to date,
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compared to an outage goal of 46. ' As expected, the majority of the PCEs (18) were attributed to the CRD and turbine maintenance activities j
(section 4).
The inspectors verified that PCEs were evaluated as required and that skin dose evaluations were performed correctly.' While reviewing PCEs, the inspectors noted a high incidence of shoe alarms 'on the whole body friskers (WBFs) for which no corresponding contamination w.v, identified using a hand held frisker. These nuisance alarms often.
resulted in workers waiting long periods of time at the access control point and, consequently, using poor frisking technique in order to exit the area.
A licensee evaluation concluded that the WBF alarm setpoints should be recalculated to better correspond with the hand held'frisker
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outage.
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I No violations or deviations were identified.
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Unmonitored Release via Feedwater Corrosion Product Monitor (IP 84750)
Between 5/30/93 and 6/11/93, chemistry technicians performing routine i
rounds on the feedwater corrosion product monitor noted abnormal sample
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flow and pressure indications. A subsequent investigation identified
minor leakage in the sample line cooler, and the cooler was removed from
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service for repair. The cooler consisted of tubes containing reactor feedwater traversing a reservoir of service water.
It was later determined that the feedwater was leaking into the surrounding service t
water, resulting in an unmonitored release.
i By reviewing sample logs and plant water usage, the licensee estimated
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Isotopic
measurements of the feedwater identified very low levels of noble gases l
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(about IE-6 microcuries (uCi) (3.7E-5 kiloBecquerels (kBq)) per
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milliliter). Total tritium released was estimated at 9.6E3 uCi (3.5E8 kBq), using concentrations observed in the condensate demineralizers.
An effluent monitor located in the discharge canal downstream of the
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service water discharge point, identified no abnormal activity during the release period.
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The licensee planned to include this release in the next semi-annual l
effluent report, and investigate the cause of the leakage.
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inspectors will review the licensee's investigation during routine
inspections.
No violations or deviations were identified.
9.
Plant Tours (IPs 83750)
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The inspectors toured work areas, observed work in progress, and took confirmatory radiological measurements.
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While overall housekeeping was adequate, there were several concerns indicating additional management attention was needed.
Because of the turbine work scope (section 4) and physical dimensions of the work
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space, contamination control was difficult, and the inspectors noted (
numerous instances of poor work practices, as described below. _
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Additionally, while reviewing previous work, the inspectors noted that about 300 millirem (3 mSv) was spent in the RCP room, removing tools and i
debris left over from previous activities. These findings were supported by similar observations made by station auditors.
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discussions with the inspectors, workers commented on the perceived lack i
of supervisory review over work areas. The licensee agreed that additional oversight was necessary and established two mar,agement J
committees to review housekeeping and facility controls.
AJditional corre.tive actions will occur after the outage critique.
The inspectors also identified several discrepancies in contaminated area control. On the refueling deck, the contaminated area posting inadequately defined the affected area. The: floor tape delineating the 8-C
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e inadequately defined the affected area.
The floor tape delineating the
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, contaminated area boundary was badly faded and difficult to read.
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I Additionally, there were several examples where different methods (tape, rope and stanchion) were used to designate contaminated area boundaries.
While this was allowable under station procedures, RP management-preferred using a rope and stanchion to delineate contaminated boundaries.
The ~ inspectors commented on the potential confusion to the workers when presented with.the different boundaries and on the need to better communicate management expectations. The licensee planned to correct the refueling deck posting discrepancy and revise the procedure to better reflect preferred posting practice.
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that roll up doors in both areas were open allowing air to flow across t
contaminated areas into clean areas. The inspectors also noted another egress point from the radiological controlled area (RCA) near the-machine shop which was not continually monitored by RP personnel. The licensee explained that the doors were open to alleviate turbine worker heat stress concerns and that a WBF located at the second egress point alarmed simultaneously at the main access control point. Although no contamination control problems were identified through direct observation or review of plant records, the inspectors commented at the exit meeting (section 10) that both situations were considered bad practices by the industry.
No violations or deviations were identified.
10.
Exit Interview The scope'and findings of the inspection were reviewed with licensee representatives (Section 1) at the conclusion of the inspection on August 13, 1993. No violations were identified,-and no documents were identified as proprietary by the licensee. The following matters were specifically discussed by the inspectors:
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Failure to post a high radiation area (section 4)
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ALARA improvements (section 5)
Plant housekeeping, tool control, contaminated area control, and contaminated area surveys (section 9)
Calculation of MDA for the WBC (section 2)
Unmonitored leakage from Feedwater Corrosion Product Monitor (section 8)
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