IR 05000247/1986017
| ML20212L305 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/05/1986 |
| From: | Bellamy R, Dragoun T, Amy Hull, Lequia D, Shanbaky M, Weadock A, Wigginton J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20212L298 | List: |
| References | |
| 50-247-86-17, NUDOCS 8608250282 | |
| Download: ML20212L305 (23) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 86-17 Docket No. 50-247 License No. DPR-26 Category C Licensee: Consolidated Edison Company of New York'
4 Irving Place New York, New York 10003
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Facility Name: Indian Point Nuclear Generating Station, Unit 2 ,
Inspection At: Buchanan, New York Inspection Conducted: June 16-20, 1986 Inspectors: M D /be, I d M. Shan'bakyTChief, Facilitie's Radiation ' da'te Protection Sectio eam Leader awl- n 5 -Gv 8/4l84 J. Wiggiptfi , Ser)for Reactor Health date Physic). , I&E
<~s r&okhafen A. H 11 c National &&
Laboratory eklu dat tw [
T' Drat 6Dg, iatio ' 1alist date Qam, D. LeQuia R iattd
_T p 1alist s/v/n date Y JP A. Weadoc fkadiation Specialist
& eH}M date Approved By: .
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R. R. BelIamy, Chiet, Emerg9apy Preparedness
[MydateC /9P6 and Radiological Protection Branch Inspection Summary: Inspection on~ June 16-20, 1986 (Report No. 50-247/86-17)
Areas Inspected: A special, announced Health Physics. Appraisal to evaluate the licensee's upgraded Radiological Controls Program developed in response to an NRC Order Modifying License dated September 27, 1984. Areas reviewed included ALARA, High Radiation Area Control, Management Oversight and Control, External Exposure Control, Internal Exposure Control, Personnel Training and Qualifications, Respiratory Protection, and Facilities and Equipmen "
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Results: No violations of NRC regulatory requirements, including the NRC Order Modifying License, were identified. The licensee's upgraded Radiation Protec-tion Program appears to be both effective and satisfactorily upgraded in all reviewed areas. Although weaknesses were noted, no programmatic problems were identified which would prevent closure of the NRC Order Modifying License.
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DETAILS 1.0 Persons Contacted 1.1 During the course of this appraisal the following licensee personnel were contacted or interviewe *J. Basile, General Manager, NP0
- M. Blatt, Manager, Regulatory Affairs
- Homyk, Manager, Radiological Engineering
- Lander, Manager, Radiological Health
- Lindgren, Manager, Emergency Planning /Public Affairs
- Marguglio, Manager, Nuclear Power QA
- M. Miele, General Manager, Environmental Health & Safety
- J. Parry, Radiation Protection Manager
- M. Selman, Vice-President, Nuclear Power
- T. Schmeiser, Manager, Radwaste
- Attended the exit interview on July 20, 1986 Additional licensee personnel were also contacted or interviewed during the course of this inspectio .0 Purpose On September 27, 1984, the NRC issued Enforcement Action #84-92, Order Modifying License, to Consolidated Edison for operating license DPR-2 This order was issued on the basis of a poor enforcement history and the identification of significant programmatic weaknesses in the licensee's Radiation Protection Program. Specific program areas requiring improve-ment were identified in the Order and included:
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High Radiation Area Control,
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the Radiation Work Permit (RWP) system,
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the Respiratory Protection Program,
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the Radiological Training Program,
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ALARA, and
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the Internal Audit Syste Licensee progress towards the development and implementation of an upgraded Radiation Protection Program has been followed and documented in various NRC inspection reports (Nos. 85-11, 85-27, 85-31, 86-04, and 86-08).
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The purpose of this special Health Physics Appraisal was to determine whether the licensee has successfully established and implemented an effective Radiation Protection Program. The findings of this Appraisal will be instrumental in determining whether NRC Enforcement Action
- 84-92, Order Modifying License, can be close Arcas reviewed during this Health Pnysics Appraisal included:
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Management Oversight Control,
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Organization and Staffing,
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Personnel Selection, Qualification and Training,
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External Exposure Control,
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Internal Exposure Control,
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Surveillance Program,
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ALARA Program,
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Facilities and Equipment, and
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Radioactive Material Contro .0 Organization and Staffing
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The radiation p.~otection (RP) organization required for the site is described in Technical Specification Figure 6.2-2. The five section managers report to the General Manager, Environmental Health and Safety (EH&S) who in turn reports to the Vice President, Nuclear Powe The licensee's organization is described in Station Administrative Order #300 " Radiation Protection Plan". This plan clearly defines the management structure and clearly assigns responsibility and authorit Interviews with the section managers indicates a good understanding of the individual responsibilities and the overall plan. The support received from upper level management is goo Since the NRC Order in 1984, the licensee has made changes to the RP organization. The Radiological Engineering section and manager have assumed increased responsibility for ALARA and the resolution of technical problem This increases the level of attention to these areas. The environmental monitoring function has been consolidated into the emergency planning section. A Radiological Health section was created with respon-sibility for support activities such as dosimetry and respiratory protec-tion. However, the Radiological Health Manager was recently reassigned on a temporary basis to act as interface between the licensee and NRC or INPO. Although the licensee has realigned the RP crganization in response to changes in program emphasis, the number of managerial personnel is above the level specified in the Technical Specification All management positions are filled by permanent licensee employees. A review of resumes and discussions with the staff indicates that each is competent, motivated and effectiv However, the inspector noted that the training and experience of the Rad Waste Manager, Manager-Emergency Planning, and Radiological Health Manager do not meet the requirements
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specified in the licensee's position guides. The General Manager (GM)
indicated that each was selected based on specific needs of the program areas and lack of technical training is compensated by participation in various off-site training programs. The inspector observed this approach has not negatively impacted the RP program performanc During this assessment the inspector experienced difficulty and delays in retrieving records. The weakness in recordkeeping is attributed to the fact that this responsibility is not specifically delegated in the Radia-tion Protection Plan. The licensee stated that the various recordkeeping ;
requirements will be identified and formally assigned to an appropriate manager. This matter will be reviewed in a future inspectio (247/86-17-01)
A program strength was noted in that the licensee publishes the annual management goals in " Book I - Nuclear Plant Goals & Objective Program."
For 1986 the RP department has 26 goals of which 6 were established at the corporate level. Progress towards achieving these goals is published quarterly in " Book II". At year end a discussion of missed goals is ,
provided in " Book III". The 1986 goal achievements for the RP department should improve the performance in several program area .0 Management Oversight Several systems with new initiative to enhance management oversight of the RP program are being implemented. The management oversight and controls were noticeable in the RP department and other plant organizations, in-cluding Maintenance and Operations. A new philcsophy, underlined by the fact that control of exposure is not limited to the RP department but is the responsibility of all site organizations and each individual within these organizations, was being promulgated and disseminated throughout the site organizations. Management support to radiological safety of workers was evident and management oversight and controls over the radiological safety program was continually improvin Initiatives to improve intradepartmental and interdepartmental communica-tions were underway. Daily plant planning briefings were attended by all department heads and key station personnel including RP staff. Weekly RP staff meetings were held to discuss radiological issues and disseminate l information relative to radiological controls and interfaces with other
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department Biweekly section head meetings were held to exchange information and co-ordinate operations, maintenance and radiological evaluations. Discussion at these interdepartmental meetings included significant radiological i operations and outage planning with emphasis on techniques to minimize personnel exposure. Radiological safety bulletins discussing radiological safety concerns and ALARA issues were published to station staff on a i
monthly basis. An extensive program to engage the station staff at all l levels into the ALARA process was being carried out through several forms of communications and incentive systems (see Section 9.0).
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As part of an effort to improve management oversight, and in accordance with the NRC Order of 1984, the Radiation Protection Oversight Committee (RPOC) was established. Review of the RP0C reports, discussions with licensee staff, and examination of implementation of RP0C recommendations indicated that the committee was effective and has significantly contri-buted to the RP program improvement. All of the RP0C actions which were required by the Order, including submission of monthly reports to the NRC Region I, have been completed. The last RP0C meeting was held in May 198 The Radiation Safety Subcommittee (RSSC), developed with a similar charter to that of the RP0C, will continue to be activ In accordance with the 1984 NRC Order, a Program Assessor function was established. The Program Assessor activities, at the time of this inspec-tion, were in transition due to the appointment of a new Program Assesso Although the new Prugram Assessor appears to be active and effective in identifying prograrr. weaknesses, the need for an item tracking system and a more aggressive pursuit of corrective actions was evident. The licensee stated that the items identified by the Program Assessor were followed-up and corrected in a timely manner; however, a copy of the item tracking system developed by the RP department will be regularly given to the Program Assesso In addition to the Program Assessor effort in following up on the effec-tiveness o'f program implementation, the licensee's procedures were up-gra.ded to provide for improvements in management oversight. Procedures No.' EHS-2.004, Revision I was approved for implementation by June 19, 198 This procedure establishes methods for routine surveillance of ongoing
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radiological operations. These surveillances will be conducted by dif-ferent EH&S Department supervisors. The procedures mandate plant tours, work performance evaluation as to the radiological safety aspects of on-going activities by Section N ds, and routine program review report The program review reports generated will be distributed to EH&S manage-ment and findings will be assigned to appropriate personnel to affect corrective action A Radiological Occurrence Report (ROR) system is being implemented to identify and correct radiological safety deficiencie Implementing Station Administrative Order No. 313 provided for methods available to all the station personnel to identify and report radiological events. This system was not used effectively in 1985; however, examination of system records indicated that the ROR system has been valuable in identifying and correcting radiological inadequacies in 1986.
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The inspector examined the licensee's corrective actions taken to prevent recurrence of radiological inadequacies identified by the previously discussed system, NRC inspections, Corporate QA audits and INP0 audit In most cases corrective actions were timely and adequate. However, the inspector discussed the apparent lack of effective corrective action to prevent recurrence. The licensee stated that these instances were isolated and not indicative of significant weakness, however, the need for improvements in this area were acknowledge :
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The overall program for management oversight and controls was effective in monitoring, controlling and improving performance of the radiation protection activitie .0 Personnel Selection, Qualification and Training The inspector examined the facility's personnel selection, qualification, and training program and overall found the program to be highly accept-able. The program was evaluated by review of controlling procedures, discussion with plant management and training personnel, review of lesson plans and training records, interview of two " watch qualified". senior Health Physics (HP) technicians, and comparison with selected industry good practice Based on the above activities, the following positive aspects and program strengths were noted. In general, the level of qualifications and profes-sional credentials of the RP management and training staff was impressiv The watch qualified Senior HP technicians interviewed appeared well quali-fied for their positions. The lesson plans reviewed were of high quality, and the instructors observed during classroom and practical factors train-ing conducted themselves as professionals. It was obvious to the inspec-tor that plant management supported radiation protection training, given the positive attitudes of all personnel involve Suggested areas for program improvements include:
Completion of a PWR systems training course is a qualification requirement for Con. Edison ANSI 18.1 HP technicians. Based on a review of the one-week course's lesson plan and discussions with responsible management and Senior HP technicians, the inspector noted that the existing course fails to focus on the radiological aspects (and hazards) of the plants' systems. As an example, the lesson plan for the nuclear incore detection system (h hour class duration)
failed to address the serious radiation hazards of the reactor cavity sump are Licensee management agreed to attempt course improvements to properly focus on this important aspect of HP technician qualifi-cation Records documenting the qualification status of " watch qualified" HP personnel (ANSI qualified personnel who stand backshift-coverage watches) were noted to be incomplete. The station Radiation Protec-tion Manager (RPM) stated that he will review and correct these administrative shortcoming Procedure No. EHS-Q-2.003, Rev. 2 establishes qualification and training requirements for plant and contractor personnel. Addendum 8.1 (Selection of Contractor Health Physics Personnel) establishes selection and qualification criteria for ANSI 18.1 technicians, and allows full credit (as experience) for U.S. nuclear Navy experience (on a one-for-one basis). Various different naval job classifica-
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tions are judged as equivalent--Engineering Lab Technician (ELT),
" Article 108" qualified personnel and Engineering Watch Supervisors (EWS). This practice has two negative aspects. Since 1971, industry consensus standard (ANSI 3.1) has moved away from allowing a full one-for-one allowance (recognizing that non power reactor experience is not equivalent to commercial experience); the current industry standard gives military experience only a 2 for 1 factor with a maximum limit up to 2 years. Given that an ELT spends up to 50% of his time on chemistry matters, (and 50% HP related areas), and a standard 4 years of responsible experience as a qualified watch stander, an ELT would be allowed approximately 1 year equivalent experience as a HP technician (using the 2:1 factor).
The second problem concerns equating ELT, " Article 108" and EWS qualifications. This practice is not justified since " Article 108" training is generally equivalent to radiation worker training (and only about 2-4 weeks duration). EWS qualifications and training provides insufficient breadth and depth in the radiological control areas to be considered meaningful HP experience related to commercial operation. In discussions with IP2 RP management about this general practice, the inspector was assured that no HP contractor with only Navy (standard 6 year ELT) experience acts as a ANSI-18.1 qualified
" responsible HD technician" (e.g., performs surveys, approves RWPs without supervision). The inspectors' chief concern focused on the potential for designating as fully ANSI qualified personnel with no commercial power plant experience. The licensee stated that they will re-examine this practic *
Station Administrative Order No. 312, " Radiation Protection Training and Qualifications," allows the General Manager, Environmental Health and Safety (GM, EH&S) to ". . . assign non qualified personnel to fill supervisory positions with the department, provided . . ."
(among other things), ". . . a plan is established to ensure quali-fication within 3 months." This flexibility is consistent with the guidance in the current industry standard " ANSI /ANS-3.1-1981."
Implementing procedure (EHS-Q-2.003 Rev. 2) allows this managerial flexibility, but omits the 3-month qualification limit. The GM, EH&S l stated that he will examine the inconsistency and take action to
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clarify this procedur The following items will be reviewed in a subsequent inspection:
a) addition and identification of radiological hazards to the PWR systems training course (247/86-17-02);
b) licensee review of procedure EHS-Q-2.003 to evaluate current practice of awarding full credit to HP technicians for previous L Naval experience; and the omission of 3-month qualification limit (247/86-17-03).
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6.0 External Exposure Control 6.1 Dosimetry Program f
, The licensee's external dosimetry program consists of two elements:
1) the day to day tracking of the cumulative exposure of personnel who enter the radiation control area which utilizes direct reading dosimeters and a computer " log-in" -_" log-out" system to assure that
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administrative limits are not exceeded, and 2) a primary personnel dosimetry system for the monitoring of exposure to photon, beta and
{ neutron radiation which utilizes multi-element CaSO 4 and Li247 8 0 RD
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' devices and an automated computer controller reader (Panasonic UD-802-AS TLD and Panasonic UD-710A Reader interfaced with a Hewlett Packard Model 1400 Computer). The TLD data are manually entered
- into'a Health Physics Computer System (HPCS) in which other personnel dosimetric data are entered, stored and processed for reporting and
. for quality control.
- The dosimetry program was reviewed and found adequate in a Special Inspection on November'12-15, 1985, (FRC Report No. 50-247/85-27), .
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with the exception of.some items related to technical issue In this assessment, particular attention.was.given to the open items in
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the Inspection Report.
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Since the 11/85 inspection, the Dosimetry Supervisor position became vacant and was subsequently filled by the then Senior Technicia The current Dosimetry Supervisor has the full time support of a Radiological Engineer.
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! Although the personnel dosimetry staff are admittedly on a " learning l curve", they displayed an adequate knowledge of the system. The Supervisor participates in the Panasonic Users Group meetings. He also has technical backup from a knowledgeable consultant. The licensee's dosimetry program attained NVLAP Accreditation on April 1, 1986. Refresher training for the Supervisor and the training of additional dosimetry personnel in the 3 week Panasonic school is planne The procedures, many of which have been revised since the November 1985 inspection, appear to be adequate. The responsible personnel are technically qualified. The administrative controls are compre-hensive. The equipment and facilities are suitable for the imple-mentation of an effective dosimetry progra At the present time the licensee is dependent on a manual backup (Panasonic 00-702) TLD reader. However, prompt service for the automatic reader is available from the vendor's regional office in r Northern New Jersey. The purchase of a second automatic reader, to
! provide an on-site backup and an independent capability for outage-related activities, is planned. The licensee is also developing a
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means for the direct interface between the Panasonic system and the HPCS Computer in order to improve the accuracy and the timeliness of the transfer of TLD dosimetry data into the HPCS files. The licensee also plans to participate in a "round-robin" exchange of calibration TLD's with other nuclear power plant licensee's in Region I who also. utilize the Panasonic System. An additional disc backup has been provided for the HPSC. Since the November 1985 inspection, additional space for the issuance of dosimeters has been provided in two trailers immediately adjacent to the former facilitie The following open items, identified in NRC Report No. 85-27, are considered closed or modified as indicated based on additional in-formation acquired during this inspection: /85-27-01: Licensee to provide additional training for the i dosimetry staff. Additional training has been made available through participation in the Users Group and additional tech-
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nical support has been provided as indicated above. The lic-ensee's understanding of the system by the responsible personnel was verified through interviews and is attested to by the NVLAP Certification. This item is considered closed.
' /85-27-02: Licensee to evaluate suitability of vendor-supplied algorithim for measuring and assigning beta dose. The licensee has made a study of the average energy of the beta
, . radiation in typical contaminated areas at IP-1 and IP- The inspector reviewed the licensee's study and noted additional data evaluation is required before a suitable method for calculating beta dose can be developed. This item will remain open pending additional licensee evaluation in this are . 247/85-27-03: Licensee to evaluate correction factor used in algorithim for neutron dosimetry to insure factor is represen-l tative of plant neutron spectra. The licensee supplied documen-tation on neutron spectra at its plant in the form of one of i the studies (PWR-3) described in NUREG-2524. Based on this j data, the licensee's current methodology for calculating neutron dose equivalent appears to be highly conservativ *
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1 /85-27-04: Licensee to verify the lower limit of detecta-
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bility for the dosimetry system. The licensee has independently
- verified that the lower limits of detectability supplied by the i vendor are conservative. This item can be considered closed, i /85-27-05
- Licensee to make temperature as well as pressure corrections to R-chamber readings during TLD calibrations. A i mercury barometer has been purchased and mounted in the cali-l l
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- bration facility.' The licensee. calibration procedure now calls
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for the employment of temperature adjusted pressure indication This item is considered close . 247/85-27-06: Area radiation monitor to be installed in I&C calibration facility to provide indication to individual enter-ing room if source is exposed. An area radiation monitor and warning light have been installed. This item is considered close . 247/85-27-07: ' Licensee to acquire R-chamber of appropriate-range to measure calibration exposure delivered to direct-read-ing dosimeters (DRDs). The licensee now calibrates DRDs at 50%
of scale (250 mR) and measures exposure directly with a R-cham-ber. This item is considered close , 247/85-27-08: Licensee to review all dosimetry procedures. The licensee's procedures for the issuance of personnel dosimetry (EHS-SQ-6.101), extremity dosimetry requirements (EHS-6.102),
multiple whole body dosimetry requirements (EHS-6.106), TLD Quality Control Testing Procedures (EHS-SQ-6.107), Process and Control of Thermolumiscent Dosimeters (EHS-6.108), Operation, Maintenance and Calibration of the Panasonic Model UD-710A (EHS-6.111), and Operation of the Shepherd Beam'Irradiator (EHS-6.115) have been revised since the 11/85 inspection. The inspector reviewed the above procedures and determined they were adequate for controlling the above activities. This item is considered close . 247/85-27 09: Review licensee's development of a computer program to track and assess the dose from-multiple whole body dosimetry. As indicated above, the procedure for the-issuance and evaluation of multiple dosimetry (MWB) has been revise The licensee found that the computer program which was developed ~!'
for the tracking and assessment of the doses from MWB in the HPCS was cumbersome, so it has been discarded. The software for i the Panasonic-HP-1000 has been upgraded so that information on
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the wearer of and the doses from multiple TLDs can readily be
- obtained from it. This item is considered close .2 High Radiation Area Control
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The licensee's program for the physical and administrative control l of personnel access to High Radiation Areas was evaluated by discus-i sion with cognizant radiation protection personnel, physical inspec-
! tion of facilities, and review of selected licensee procedures, j training records, and logbooks.
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Based on the above review, the licensee appears to be effectively controlling personnel access to High Radiation Areas (HRAs). Con-trolling procedure EHS-SQ-3.109 appears adequate to insure HRAs are locked and/or guarded as required. The inspector noted this proce-dure has been significantly streamlined since the last NRC review of this area. This procedure also describes the accountability system used to maintain administrative control over keys to Locked High Radiation Areas (LHRA). Four HRA keys are maintained at the Health Physics (HP) control point and are signed out to appropriately quali-fied HP technicians who then act as key custodians. These custodians are responsible for opening access doors and designating access guards for work parties that require access to a locked HR The appraiser reviewed various HRA area access control sheets and the HRA key logbook and determined the RP department is complying with the controlling procedure and maintaining strict accountability for locked HRA keys. The inspector also verified the Operations depart-ment is maintaining appropriate accountability for the HRA keys they control. A review of technician training records and an interview of acting key custodians indicated that HP technicians responsible for the locked HRA keys have received appropriate trainin Physical inspection of various HRA access points in the auxiliary buildings outside the Unit I and 2 containments verified that all accesses were secure; all HRA guards appeared knowledgeable of their responsibilities and duties upon questioning. The inspector did note two HRA accesses where an obsolete padlock, which could be opened by an uncontrolled key, was included as part of the locking device on the HRA door. The current HRA key / padlock, which was also on the door, could therefore be bypassed and the HRA door could be opened with the uncontrolled key. The licensee corrected these instances immediately upon identificatio The appraiser noted that overall physical security of the various HRAs is quite good. The licensee has recently completed the instal-lation of new self-locking doors at the majority of their HRA access points. The use of temporary gates featuring padlock type locks has been minimized throughout the statio Two areas for further improvement were identified during the review of the licensee's HRA contro . The licensee issues digital, alarming dosimeters (digi-doses)
to individuals entering HRAs. Digi-doses include a chirp feature which audibly alerts personnel to a change in area dose rate Individuals are provided a briefing sheet describing function and use of the digi-dose which.they are required to read and sign prior to their initial use of the instrument. The inspector reviewed the briefing sheet and found it to provide minimal instruction, concerning only the integrating dosimeter
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, function of the instrument,.to the worke No information is j' given concerning appropriate response to a change in area dose i a -
rate or the limitations of the instrument (for example,: unsuit-ability in a-high-noise environment).
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workers concerning the use of.the digi-dose. This will be reviewed during a subsequent inspection (247/86-17-04).
t Procedure'EHS-SQ-3.109 specifies that a= unique key, issued by a
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Radiation Protection Supervisor, is required for access to an
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_ Ultra Locked High Radiation Area (ULHRA). An ULHRA is defined'
as an area where dose rates exceed or have the potential fo exceeding 100 R/hr. The inspector discussed radiological con- trols over entry into the reactor cavity sump with the license The licensee indicated the reactor cavity sump is designated and ,
posted as a ULHRA and the above controls would apply. The
' inspector stated.that, due to generic overexposure and near overexposure problems in this area, additional controls over
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, worker entry should be considered. Typical additional controls l include a briefing of the work party by Operations and HP super-vision, tag-outs of the moveable incore detectors, use of two
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separate high-range instruments, appropriately calibrated, for entry, etc. The licensee indicated they would evaluate the need
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for either developing a specific procedure or adding additional
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controls to EHS-SQ-3.109. This area will be reviewed in a
{ subsequent inspection (247/86-17-05).
6.3 Radiation Work Permit System
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The licensee utilizes a Radiation Work Permit (RWP) system to assign
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radiological protection controls for work activities performed in l radiological areas. Initiation of the RWP begins with the submission i of an RWP request to the Radiation Protection group by the work group
- intending to perform the work. A generic problem with such requests
! is that they typically do not contain sufficient information concern-ing the scope of work to allow the assignment of appropriate radio-i logical controls. The inspector reviewed several RWP requests and noted they were generally descriptive and often contained detailed drawings of the location and component to be worked. The inspec- l tor also noted specific instances where the radiation protection group had returned the RWP request to the submitting party, along l with a request for additional information.
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pre-work surveys and setting radiological control requirements for the RWP based on conditions. Controlling procedure EHS-SQ-2.008,
" Radiation Work Permit", also requires that periodic surveys during work be performed to assess for changes in work condition.
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If required, a formal ALARA review is prepared by the radiological engineering department and is attached to the RWP. Activation of the RWP requires the signature of a radiation protection supervisor, the work supervisor, and an operations shift superviso The inspector reviewed various RWPs and associated surveys, sign-in sheets, ALARA reviews, and ALARA briefing sheets. Based on this review, the licensee appears to be implementing an effective P.WP progra In the majority of instances, radiological protective measures specified in the RWP were commensurate with actual radiological condition One instance was noted, however, in which the radiological controls specified in the RWP did not reflect work condition RWP #11407, issued June 2, 1986, specified controls to be used while removing insulation from a heat exchanger in the PAB building. This RWP did not require respiratory protection; the initial survey, performed on June 1, 1986, indicated contamination levels of 15,000 dpm/100 cm2 (the licensee's procedures require respirators to be used at contami-nation levels >100,000 dpm/100cm2 ). Subsequent surveys, however, performed on June 2, 8, and 15, 1986, indicated contamination levels in the work area up to 200,000 dpm/100cm 2 . These surveys were re-viewed by radiation protection supervisors but no change was made to the RWP to reflect the new conditions. The disparity between radio-logical conditions and RWP requirements was noted in the field by the HP technician, prior to the performance of work on June 10, 198 The technician issued respirators to the work party and noted in the area logbook that the RWP should be terminate Despite this note in the log (which is also reviewed by radiation protection supervision)
no change or termination of the RWP occurred until June 20, 1986, after identification and prompting by the NRC inspector.
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The inspector also noted that each RWP package includes a tremendous volume of material requiring review. Numerous administrative and clerical errors were evident upon review of the packages, including:
surveys not reviewed by radiation protection supervision as required, ALARA briefing sheets not included as required, instrument serial numbers not included on surveys, et The inspector stated that the present RWP system may be unnecessarily cumbersome in implementation and the responsiveness of the system to changes in conditions or new input may be suffering as a result. The licensee committed to upgrade the RWP procedure to 1) enhance super-visory oversight and responsiveness, and 2) streamline the paperwork l proces This area will be reviewed during a subsequent instiction (247/86-17-06).
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7.0 Internal Exposure Control 7.1 Respiratory Protection Program The licensee's Respiratory Protection Program (RPP) was evaluated by review of applicable procedures, inspection of facilities, discussion with supervisory and support personnel, and comparison with criteria included in applicable regulations and industry standards. Overall, the licensee's program was found to be highly acceptabl Based on the above review, the following positive aspects and program strengths were noted. The implementing procedural controls were well written and in general, technically sound. The newly appointed Respiratory Protection Supervisor (RPS) is actively involved in program oversight and management and is scheduled for a one-week professional training course this year. The RPS meets or exceeds the qualifications recommendations of NUREG-0041. The RPP supporting technicians are experienced and technically competen Areas suggested for program improvements include:
Consideration for increasing the current acceptable fit factor (100) to a higher value. Industry experts generally agree that a good fitting respirator will provide a significantly higher fit factor. The inspector also stated that a larger supply of multi-sized respirators and different vendor-makes are generally provided at other facilities to provide a wider selection for better accommodating facial differences (and thus providing for better, overall fitting).
Improve management controls / oversight over vendor-supplied breathing air when portable air compressors are used for sup-plying breathing air tc, support in plant use of air-supplied respirators (e.g., hoods for steam generator jumping). No procedural controls exist to ensure adequate licensee oversight over contractor personnel operating the compressors (e.g., ven-dor procedures to ensure continued quality Grade D air supply).
Both these areas for program improvement were discussed in detail with cognizant plant management, and in general, good technical agreement was reached. Licensee management stated that they will consider implementing these program improvement *
Qualitative fit-testing is used only as a backup fit method when the quantitative fit booth is unavailable. However, the pro-cedural guidance for both qualitative methods (banana oil and irritant smoke) should be improved and better testing protocols incorporated. By using existing consensus-standard protocols, these backup fit methods can be substantially upgraded (e.g.,
give better sensitivity to leaks).
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One area of significant weakness was identified during this apprais-
, al. The inspector reviewed licensee respiratory protection cap-ability and controls for performing routine and emergency response entries to Immediately Dangerous to Life and Health (IDLH) area While the location, hazards, and nature of potential IDLH areas was understood / recognized, programmatic controls for required maintenance and routine inspections of emergency-use Self-Contained Breathing Apparatus (SCBA) were inadequate. Management personnel responsible for SCBA inspection and maintenance were not fully knowledgeable of existing regulatory requirements and guidance, or good industry practice. After a review of the sole periodic test (PT) procedure for SCBA, and an inspection of a typical emergency kit, the NRC inspector discovered that only the air cylinder pressure and cylinder hydrostatic test date were included in the monthly PT. The inspector questioned the technical validity of both acceptance criteria (5 year hydro. frequency and 1800 psi cylinder pressure), and informed the IP2 personnel that numerous other manufacturer's required and recom-mended preventive maintenance and periodic testing (e.g., regulator /
diaphragm function check) should be routinely performed. After *
discussion of the above with senior licensee management, the licensee committed to transfer management oversight responsibility to the Respiratory Protection Supervisor, (effective week of inspection) and to upgrade the existing SCBA maintenance / inspection program. This should include NUREG-0041 " requirements" (shall-items listed in Chapters 9 and 10) in concert with the applicable SCBA vendor /manu-facturer's instructions. Before the NRC appraisal team had lef t site, licensee efforts were underway to correct identified
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deficiencies in this are Items identified in this area that will be reviewed during a sub-sequent inspection include:
a) licensee evaluation of current acceptable fit factor (247/
86-17-07),
b) licensee development of procedural controls over vendor-supplied air compressor operation (247/86-17-08),
c) upgrade of qualitative fit-testing methods (247/86-17-09),
d) efforts to upgrade SCBA inspection and maintenance program (247/86-17-10).
7.2 Bioassay Program The primary bioassay system used by the licensee to evaluate internal exposure is the Nuclear Date (ND) 6700 Counting System. This system incorparates a chair arrangement, with three separate detectors for (1) thyroid; (2) upper torso; and (3) lower torso monitorin Each detector is connected to a 512-channel multichannel analyzer.
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Additionally, an Intrinsic Germanium (IG) whole-body counting (WBC)
chair is available for use. This WBC system uses two IG detectors for monitoring of the upper and lower torso, and a lh x 2 inch sodium iodide detector for thyroid monitoring. However, the inspector noted that the resolution on the IG detectors, at 2.5 Full-Width-Half-Max (FWHM), does not meet the vendor's specification of 1.8-2.0 FWH The licensee continues to investigate the reason for the noted poor resolution of the detector. The detector was not being used. The IG detectors are connected to multichannel analyzers (MCA) of 4056 channel capacity, with the thyroid monitor having an MCA with 512 channel Routine whole-body counts are performed for 3 minutes using the sodium iodide chair and for 5 minutes using the IG chai Action levels have been established for each of the sixteen nuclides contained in the computer library. This library can be expanded if the need arises.
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Procedures detailing the operation of the whole body counting systems exist and are adequate. Overnight background checks are performed as well as daily counts to check for coatamination of the chair itsel Source checks, using a bar with three Europium-152 sources, are l performed every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> during use and results are plotted on charts to identify trends. However, the inspector noted that this source has no serial number and is not well controlled. In addition, the Europium-152 sources are mounted on a flimsy metal bar which is !
easily bent. This can cause a change in counting geometry. The l licensee stated that examination of the physical configuration of the source was routinely performed prior to use. Calibration of the whole-body counting system is performed at six month intervals, using a representative spectrum of NBS traceable sources in a phanto Calibration as performed is adequat The frequency for routine personnel whole-body counting is set at once each yea Non-routine bioassays are performed as necessar Requirements for these are identified in Environmental Health and Safety procedure 6.200, Rev. 2. The licensee provides each plant and contractor employee an opportunity for a whole-body count upon term-ination. In addition, procedural and program provisions have been made for the handling, processing and use of indirect bioassay methods, including urinalysis, fecal analysis, and nasal swab Routine whole-body count results are reviewed, then maintained in each individual's respective exposure history file. Special whole-body count results are reviewed, and then maintained by the Internal Dosimetry Superviso Data from these special whole-body counts are forwarded to the Radiological Engineering group for evaluation and internal dose assessment. The record keeping system, with respect to internal exposure control, is adequat Air sampling for airborne concentrations of radioactive materials was being performed. Air sample results, occupancy times, and respira-tory device protection factors are used to determine and assign MPC-Hours. An "MPC Tracking Card" has been developed to facilitate collection of data concerning type (s) of respirator used and hours worn. MPC-Hours are assigned when an individual exceeds twenty five
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percent of MPC. However, review of twenty-two (22) " Airborne Acti-vity Survey Logs," selected.at random, were found to have over forty-three examples of administrative errors including: missing signatures, missing MPC factors, purpose for air sampling, and multiple instances of write-overs or cross-out In addition, the inspector _noted that 15 of the 22 samples (68%) had not been analyzed until 6 or more hours after collection. The licensee appears to have weak administrative controls for the processing and handling of air sampling record During this appraisal the licensee provided the inspector with new information concerning an apparent violation in the area of air sampling that was discussed in NRC Inspection Report 247/86-08 and it's accompanying Notice of. Violation. Information provided during this appraisal indicated the licensee had taken a high volume air sample at the start of reactor cavity decontamination and was there-fore performing suitable and timely measurements of concentrations o ,
airborne activity. This violation will be withdrawn (Closed:
247/86-08-03).
The inspector observed that the Nuclear Environmental Monitoring -
(NEM) Technician charged with operating the whole-body counting equipment was familiar with expected and non-routine counting results and did provide an adequate review of whole-body counting result The Internal Dosimetry Supervisor was knowledgeable of basic whole-
, body counting system theory and operatio Based on the above findings, this portion of the licensee's radio-logical controls program appears to be acceptable, but the following items should be considered for improvement of the bioassay program, Designing and building a separate facility for whole-body count-ing. The current area does not provide sufficient space or adequate environmentally controlled conditions for efficient use of the whole-body counting syste This space has insufficient air conditioning capacity for cool-ing of computer components. This lack of adequate cooling, combined with radio frequency interference, voltage transients and high background counts from concrete building materials, produces high whole-body count results (Type 1 errors). The Internal Dosimetry Supervisor should complete the Nuclear Data 6700 " MIDAS Hardware and Operating System Course" to enhance his training and qualification . .
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8.0 Surveillance Program 8.1 Procedures and Basis The licensee has a comprehensive surveillance program for the evalua-tion of potential in plant exposure as described in Station Adminis-trative Order (SAO) and Implementing Procedures. It includes an extensive schedule of routine surveys of the levels of radiation and contamination within the radiologically-controlled areas. Their type and frequency (daily to monthly) are commensurate with the extent of the anticipated hazards in specific locations, so as to promptly identify changes in radiological conditions. The program also includes monthly and quarterly radiation contamination surveys in uncontrolled areas. Non-routine surveys are also conducted as necessary to support operations and maintenance and for the releases of equipment to unrestricted area The schedules are developed, assignments of personnel for the surveys made, and their performance is monitored by the Unit-1 and j Unit-2 Radiation Protection Supervisors. The results are depicted
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on standarized diagrams of the specific locations that have been surveye Surveys are reviewed by the Supervisors and copies are utilized for the updating of Work Permits which are posted at the surveyed location The results of complete quarterly surveys of both Unit-1 and Unit-2 are distributed to the Environmental Health and Safety (EH&S) Manage-ment and to Engineering Groups for their review. A computer gene-rated list of open items is utilized to assure that they are com-pleted on schedule.
8.2 Instrumentation Guidance on selection of the types, numbers, maintenance, calibration and purposes of instruments are set forth in a SAO. The number of instruments actually available was found to generally exceed the licensee's recommended minimum instrument inventory set forth in this SA0. Detailed information on the specific instruments utilized by the licensee, including the ranges and limitations, are set forth in l procedure From interviews with supervisory personnel it was established that the numbers and types of instruments available are sufficient for both routine and outage activitie Although the SA0 on the calibration and control of operational equip-ment specifies that EH&S shall calibrate instruments that are used by their group, most of the calibrations are in fact performed by the I&C group. If anything, instruments are calibrated more frequently than semi-annually, as called for in procedures.
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Although the calibration facility is adequate for its intended pur-pose, the safety of the free-air method utilized is highly dependent on administrative control, which could be relaxed by the provision of a shielded calibrator. The inspector was informed by the I&C Super-visor that a purchase requisition for one has been initiated, both to improve safety and because the current source is inadequate for the full-scale (approaching 1,000 R/hr) calibration of high-range instru-ment A recent internal audit by the licensee's staff indicated that it was difficult from the currently available information to determine the repair history of instruments. The I&C Supervisor indicated that software is under development, so that this information will be more readily availabl .0 ALARA The licensee's ALARA program was reviewed against the criteria provided in Regulatory Guide 8.8 and 8.10 and 10 CFR 20.1. The elements of the licensee's program are described in the following documents:
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Con Edison Corporate Policy Statement " Maintaining Occupational Radiation Exposure ALARA at Indian Point Station" issued May 15, 1986
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Station Administrative Order (SAO) #300, " Radiation Protection Plan"
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SA0 #303 "ALARA Program"
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SA0 #305 " REM Reduction Committee"
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Environmental Health & Safety Procedures: S-2.203, Q-2.008, S-8.001, S-8.005, SQ-8.006, SQ-8.007, SQ-8.101, SQ-8.103, SQ-8.104, S-8.201, and Q-8.30 The licensee's ALARA program is fully functional although some of the procedures were only recently issued. A significant improvement in ALARA performance has occurred since 1984. The 1986 exposure goal remains as high as 1200 man-rem including the Spring Outage. However, in comparison with previous outrage years, a declining trend in the collective projected dose was note The previous outage year, 1984, resulted in 2,644 man-Rem total exposure. There are separate exposure goals established for each section at the station. Beginning in 1985, the performance relative to these goals is included in the overall salary appraisal for section level managers and above. This technique has proven effective at other sta-tions. The licensee's long range plans are to reduce average annual exposure into the 400 man-rem range by 199 Interviews with maintenance department and operations department personnel indicate that tt,e licensee has succeeded in achieving active involvement in the ALARA program from these group Several methods are used to i
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increase worker awareness including posters, lapel buttons, meetings and an ALARA suggestion program that awards the vice president's reserved parking place for one month to the winner. An ALARA Design Engineering Course was presented to 87 personnel in October 1984 and an Operational ALARA Course to 69 personnel in November 1985. Worker training is pro-vided on a full size steam generator channel head and portions of a reactor coolant pump mock-up permanently located on the turbine dec The licensee has initiated other efforts to reduce personnel exposure The pH of the primary coolant was adjusted to reduce crud buildup. As a result hot spot dose rates in the primary system were reduced an average of 20% for the 1986 Refueling Outage. This technique was adopted from a highly successful chemistry control program used on European nuclear plants. In addition, the square footage of contaminated area in the work zones was significantly reduced to minimize protective clothing and in-crease worker efficienc Followup programs are in place to prevent these areas from being re-contaminate Although the licensee has initiated a commendable ALARA program the in-spector noted that two characteristics of the reactor systems inside containment result in personnel exposures significantly higher than average for a PWR. Major primary system components, such as reactor coolant pumps, and the steam generators are not individually shielded. A worker in the Vapor Containment (VC) and inside the biological shield can receive exposure from all of these hot spots regardless of the job lo-cation. In addition, the dose rates measured at the hot spots and the ambient level in the loop area are significantly higher than other PWR plants. The licensee is aware that these problems must be resolved to produce major gains in exposure reduction. The licensee advised that chemical decontamination of the primary system is under review. The progress of these efforts will be reviewed in a future inspectio . Facilities and Equipment The licensee's facilities and equipment are adequate for carrying out an effective radiation protection program. In the area immediately behind the access control point are office space and rest rooms available for health physics (HP) personnel performing administrative tasks. Adjacent to the offices are the Radiation Work Permit (RWP) issue room and male locker room, which have been expanded to approximately double their original siz This allows for more efficient clothing changeout and RWP issue. Senior H.P. supervisors, engineers and support clerks are located in additional offices in the plant administration building directly off the main turbine floor. Training facilities include full scale mock-ups of a reactor coolant pump seal and a steam generator channel hea The access control and TLD issue area is sufficiently large and equipped with an automated controlled area entry system. The automatic log-in
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system is keyed to the TLD badge number which is automatically read and data inputted directly to the HP Department Computer. During this
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i check-in procedure each individual is provided information concerning his remaining quarterly and annual exposure. This check point also serves as a respirator and HP equipment issue area, and is equipped with an Eberline Model 1000 calibrator for response checking of dose rate instrument A locker room and restroom which had been located within the controlled zone has been eliminated. However, expansion of the locker room outside the control point, with its adjacent restroom, appears to be adequate if somewhat inconvenient. A new " Maintenance Outage Building" has been constructed to provide more locker space for personnel during outage One small stainless steel washing facility was available for low level decontamination of workers' hand A well equipped counting room for H.P. survey work is located just off the controlled area access point to the Primary Auxiliary Building (PAB). Counting equipment includes two (2) gas flow proportional counters for air sample counting; two (2) NaI(TL) crystals with single channel analyze'rs for measurement of iodine in charcoal cartridges; an Eberline SAC-4 for alpha counting of smears and air samples; and a BAIRD automatic sample counter / changer for smear counting. The licensee is in the process of installing a Germanium-Lithium (GeLi) detector with a multichannel analyzer, dedicated for HP use. Plans are also being made to obtain another automatic sample counter / changer to expedite sample processin There appears to be limited availability of high volume air samolers. The inspector and a HP Supervisor toured the control zone for approximately thirty (30) minutes before finally locating one. Questioning of several HP Technicians revealed that personnel were not sure where additional high volume air samplers could be located. The licensee stated that they were aware of this problem and have initiated a purchase order for ten (10) additional samplers in 1986, with another ten expected to be pur-chased next year. Additional consideration is being given to centralizing a location for this equipment to help ensure its availability for use. An adequate supply of low volume air samplers was on hand to support the licensee's air sampling program. Medical treatment and first aid rooms for handling contaminated, injured personnel are located on the floor above the access control point. This facility consists of two rooms con-nected by a door and a shower stall which opens into both rooms. Person-nel can be decontaminated in one room, shower if necessary, and then enter the other room. Decontamination equipment, medical response kits and a dedicated frisking instrument were available. The entire floor of one of these rooms is covered with stainless steel to aid in the control of contamination and to facilitate decontamination effort Consumable health physic supplies we e observed to be on hand in adequate numbers throughout the controlled zone. A large supply of reusable pro-tective coveralls, gloves and shoecovers were available for ready-use by personnel entering contaminated areas. Protective clothing is processed for shipping to a vendor for laundering, then returned to the plant. This clothing is then surveyed for contamination prior to use.
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The Chemistry Department analyzes radioactive liquid samples and performs isotopic identification of smears and air samples for the Health Physics Department. The inspector toured the chemistry counting facility and observed that a liquid scintillation counter and two multichannel analy-zers with Germanium-Lithium (GeLi) detectors are available for use. The laboratory and office spaces for radiochemical analysis are adequat .0 Radioactive Material Control The licensee has well developed procedures for the control of radioactive material as it enters, is within and as it leaves the plant. They call for a semiannual status report which identifies the location of all radioactive materials within the radiation controlled areas and in the uncontrolled areas of the plan In a first-hand tour of the plant, the housekeeping was found to be excellent. All of the reviewed source locations were appropriately posted. The decontamination activities which could release airborne rad-iation materials were contained within filtered enclosures. Color coded plastic bags are utilized for the segregation of clean items, contami-nated, trash and items for evaluatic.1 and decontamination; these bags are
. readily available throughout the controlled are The licensee has established four contamination zones (#1 <1,000 dpm/100 cm2 , #2 >1,000 dpm/100 cm2, #3 >25,000 dpm/100 cm2 and #4 >100,000 dpm/100 cm2 ). The areas above 1,000 dpm/100 cm2 have been reduced by 50% since January 198 The licensee has recently initiated a Contamination Radiation Pragram for the reduction of sources of potential radioactive contamination within Units 1 and 2. It contains defined milestones for the identification, j repair and the removal of unneeded items, such as the unutilized evapora-
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The inspectors met with licensee personnel denoted in section 2.2 at the I conclusion of this appraisal on June 20, 1986. The scope and findings of the appraisal were discussed at that time.
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