IR 05000247/1986033

Radiation Protection Insp Rept 50-247/86-33 on 861215-19.No Violations Noted.Major Areas Inspected:Alara,Internal Exposure Control & External Exposure Control

ML20210B276
Person / Time
Site:	Indian Point
Issue date:	01/27/1987
From:	Lequia D, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210B241	List: IR 05000247/1986033 ML20210B235
References
50-247-86-33, NUDOCS 8702090116
Download: ML20210B276 (13)

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9 , U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N Docket N i License No. D R P-Lt'. Priority --

Category C Licensee: Consolidated Edison Company of New York 4 Irving Place t

New York, New York 10003 kacilityName: Indian Point Nuclear Generating Station, Unit 2 Inspection At: Buchanan, New York

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Inspection Conducted: December 15-19, 1986

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Inspectors: dtu / - 77 ' 8 ~1

. LeQuie g lfadjttio ~ ialist date W

T. Weadoi:k,(Sadiathn'Speciali st /

1 U ~L I- 21 -d *1 date

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Approved by: E_ ~

%xMI /[-z,7 /

M.Shanbaky, Chief,FacilifffsRadiation dat'e Protection Section Inspection Summary: A routine, unannounced radiation protection inspection was performed to review the status of previously identified item In

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addition, the following program areas were inspected: ALARA, Internal s Exposure Control, and External Exposure Contro Results: No violations were observed. However, some weaknesses in the licensee's survey documentation practices and procedural controls for radioactive material were identified (Section 7.0).

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DETAILS 1.0 During the course of this inspection, the following personnel were contacted or interviewed:

1.1 Licensee Personnel:

• Selman, Vice-President, Nuclear

• Miele, General Manager, E.H. & *J. Parry, Radiation Protection Manager

• A. Homyk, Radiological Engineering Manager

• T. Giorgio, Training Manager J. Higgins, Chemistry Manager

• J. Cullen, Radiological Assessor

• M. Shannon, Senior Radiation Protection Supervisor

• R. Vogle, Training Administrator

• D. Maffei, Senior Radwaste Supervisor

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• E. Poplees, Chemistry Supervisor P. Madigan, Internal Dosimetry Supervisor J. Connolly, Nuclear Supervisor N. Hartmann, QA Lead Auditor

• B. Raskovic, Engineer-Licensing E. Imbimbo, Senior Radiation Protection Instructor i D. Miller, Radiation Protection Instructor

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J. Goebel, Test Engineer

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A. Pittman, Engineer Additional licensee or contractor personnel were also contacted or interviewed during the course of this inspectio * Denotes attendance at the Exit Meeting held on December 19, 198 .0 The purpose of this routine radiation protection safety inspection was to review licensee progress on open items from previous inspections. A total of sixteen (16) open items were reviewed, evaluated and closed (see Section 3.0 for details). In addition, the following areas were inspected:

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Licensee Corrective Actions;

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Program Changes;

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ALARA;

External Exposure Controls;

Internal Exposure Controls.

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3 3.0 Status of Previously Indentified Items 3.1 (Closed) Inspector Follow Item (247/86-04-03): Licensee to evaluate operating parameters of the whole body counting system and set appro-priate control limits. Inspector review of whole body counting (WBC)

system records, and discussions with cognizant personnel, verified that the licensee has evaluated system efficiency, centroid, reso-lution and background count rates. Appropriate acceptance criteria for each parameter have been established. In addition, quality control (QC) charts, which are reviewed by technicians and management personnel, have been developed to track and trend these operating parameter Inspector review of the QC charts for the period Aug-ust-December 1986, verified that these charts are being maintaine _

3.2 (Closed) Inspector Follow Item (247/86-04-01): Licensee to station Control Point Monitors (CPM) at accesses to Locked High Radiation Areas (LHRA); CPMs to have no ancillary duties to prohibit them from controlling the acces Inspector review of procedure EHS-SQ-3.109,

" Control of High Radiation and Locked High Radiation Areas," Rev. 4 dated October 6, 1986, verified that personnel assigned to control access to a LHRA, when doors are unlocked to facilitate access, staging or removing of equipment from the area "...shall have no other tasks assigned ... that will prevent continuous observation of the LHRA entrance." In addition, during the previous Health Physics Appraisal (Inspection Number 86-17, conducted June 16-20, 1986), the inspector observed LHRA CPMs stationed outside accesses to these areas. Subsequent questioning of these personnel revealed that they were "... knowledgeable of their responsibilities and duties...."

3.3 (Closed) Inspector Follow Item (247/86-04-05): Licensee to increase Health Physics (HP) technician coverage in support of current outage work. Inspector review of documents provided by the licensee verified that HP technician staffing levels were increased from twenty-nine (29) available tecnnicians on January 25, 1986, to sixty-one (61) technicians by February 1, 1986. The additional personnel were brought on-site to strengthen radiation protection over-sight as the momentum of the outage increased. The licensee's promptness in obtaining additional personnel demonstrates responsiveness to NRC initiatives and a commitment to radiological safet .4 (Closed) Inspector Follow Item (247/86-17-07): Licensee to evaluate current fit test acceptance factor of 100. The licensee has re-evaluated the acceptance criteria for acceptable respirator fit testing, and a new minimum fit factor of 500 has been establishe Inspector review of procedure EHS-10.202, " Daily Calibration Main-tenance and Use of the Air-Technique Fit Test Systc=", Rev. 1, verified that the 500 acceptance factor has been incorporated into the applicable procedur .

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3.5 (Closed) Inspector Follow Item (247/86-17-09): Licensee to upgrade their qualitative fit test methods. Inspector review of procedure EHS-10.203 " Qualitative Fit Test Using Isoamyl Acetate or Irritant Smoke," Rev. O, verified that the licensee has developed and proceduralized, upgraded methodology for qualitative fit testin .6 (Closed) Inspector Follow Item (247/86-17-10): Licensee to upgrade the Self-Contained-Breathing-Apparatus (SCBA) inspection and main-tenance program. The licensee has upgraded the SCBA inspection and maintenance program. Responsibility for maintenance of these units has been transferred from the Maintenance Department to the Health Physics Department. Three procedures: EHS-10.302 " Inventory and Control of SCBA Units and Spare Tanks," Rev. 0; EHS-10.303 "Calibra-tion and Repair of Self Contained Breathing Apparatus (SCBA)," Re O, and EHS-10.107 " Calibration of Regulator Gauges Used In Breathing Air Systems," Rev.1; have been written or modified to provide con-trol of these activities. Training of the SCBA repair technicians has been conducted by a vendor. The technicians have been certified for all levels of maintenance and repair on SCBAs. Maintenance cards have been developed to track location and repair status for each uni Based on inspector review of this area, this item is close .7 (Closed) Inspector Follow Item (247/86-04-04): Environmental Health and Safety (EH&S) Department to improve QA audit response and corrective action implementatio Inspector review of responses to Audit Number 85-03-E, verified that all findings have now been closed. The inspector held a discussion with the QA Lead Auditor, who indicated that EH&S response and implementation of corrective actions has "significantly improved." In addition, inspector review of EH&S responses to identified items in Audit Number 86-03-F, found that responses and corrective action implementation were being handled in a timely manne .8 (Closed) Inspector Follow Item (247/86-17-01): Licensee to formally identify and assign responsibility for maintenance of radiological records. The inspector reviewed the following revised licensee procedures:

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EHS-SQ-2.001. Revision 2, "EH&S Records and Reports,"

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SA0 300 Rev. 3, " Radiation Protection Plan."

The inspector noted each of the above procedures now contains a statement which indicates that responsibility for the EH&S records management system will be assigned to a specific individual. The inspector also reviewed a licensee memo designating that individ-ual. This item is considered closed.

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3.9 (Closed) Inspector r'ollow Item (247/86-09-04): Licensee to implement corrective actions to control vacuums. NRC Inspection Report No. 247/86-09 discussed a personnel contamination event which resulted from three workers performing an operation check on a vacuum with no HEPA filter attached. The inspector reviewed licensee corrective actions for the above event during the current inspection. These included:

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briefing of radwaste workers concerning pre-operational checks of vacuums,

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provided a specific training course, developed by a vendor, on vacuum operation and use,

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presented several discussions of the vacuum operation and use procedure during the routine Friday afternoon Radwaste group meeting In addition to the above actions, the licensee has modified the system used to issue radiological vacuums. Previously, individuals would check out a vacuum on their own at the vacuum storage are Currently, all vacuums ready for use are now maintained in a locked storage area. Vacuums are checked out by a single individual who insures each vacuum is in proper operating condition prior to issu The licensee's corrective actions in this area appear both widespread and effective. This item is considered close .10 (Closed) Inspector Follow Item (247/86-17-02): Licensee to upgrade the Pressurized Water Reactor (PWR) Systems training course to focus on radiological hazards associated with specific plant system Since the previous inspection in this area (Report No. 86-17) the licensee has added a training module on high exposure rate operations to the one week PWR systems class. The licensee has also included additional reference material on the Reactor Vessel, Reactor Coolant, Chemistry and Volume Control, and Radiation Monitoring Systems in a

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handout package which is provided to each student. The inspector reviewed Lesson Plan #RP 301.09, "High Exposure Rate Operations," and noted it provided a valuable review of several high exposure jobs, including: Vapor Containment entry, resin transfer, post-accident

! sampling, S/G entry, and incore detector area entry. The inspector reviewed class attendance sheets and verified all Con-Ed house HP technicians had been cycled through the revised one-week systems course by August 31, 1986. The above item can be considered closed based on these efforts by the license The inspector noted, however, that licensee actions to improve the course content were superficial. Review of the lesson plan for the systems portion of the course indicated no specific radiological information had been added to the purpose and objective sheets for

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each specific PWR syste Instead, the four voluminous system de-scriptions listed above were provided to augment the systems infor-mation provided in the course. The inspector cursorily reviewed the four systems descriptions and noted they primarily provided opera-tional information only. Additionally, the high-exposure rate operations module, originally designed to be a two-day separate course, was added to the already existing one-week systems cours Although this upgraded the radiological content of the course, no additional time was added to the length of the course. Consequently, seven days worth of material was condensed into five days of class time, thereby academically undermining both course The inspector reviewed the above conclusions with the licensee. The licensee. indicated additional efforts would be made to upgrade the PWR Systems course. These efforts will receive continuing review in subsequent radiological inspection .11 (Closed) Inspector Follow Item (247/86-02-08): Calibration of radioiodine monitors not being adequately performed. During the original NRC review in this area (Inspection 247/80-02) it was noted that the calibration procedures for plant process monitors RI-1, RI-2, RI-3, and RI-4 did not require an electronic calibration to be performed. During the current inspection, the inspector reviewed draft procedure PC-EM18, Rev. O, " Radio-Iodine Monitors." This draft was noted to require an adequate electronic calibration of the monitors; however, the following deficiencies were noted:

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PC-EM18 did not include a functional check of the isola. tion of the Waste Gas Release Valve due to a high alarm at RI-1,

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radiological calibration of the monitors was less than adequate, in that acceptance criteria on monitor response was not included in the procedur The licensee revised the draft copy of PC-EM18 to resolve the above deficiencies during the week of the inspection. Procedure PC-EM18 was approved on December 23, 1986. This item can be considered close .12 (Closed) Inspector Follow Item (247/86-17-04): Upgrade training provided to workers concerning the use of digital chirping dosimeters (Digidoses). The inspector deterrained through discussion with 11-censee training personnel that an instruction sheet outlining the use of the Digidose is no longer presented to individuals at the Con-trolled Area Access Point. Instructions concerning the use of the Digidose are currently provided during initial radiation worker training. The inspector reviewed approved Lesson Plan No. RW 100.03, Rev. 3, " Initial Training," and noted it incorporated the following items concerning the use of the Digidose which were not originally mentioned on the worker instruction sheet:

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worker response to a sudden increase in chirp rate,

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limitations on use of the Digidose in a high-noise environmen This item can be considered close .13 (Closed) Inspector Follow Item (247/86-17-05): Licensee to evaluate whether additional procedural controls should be developed to cover personnel entry to the reactor cavity sump. The licensee has developed an approved Procedure No. EHS-3.110, Rev. O, " Control of Locked Ultra High Radiation Areas" which defines the requirements for the control of Locked Ultra High Radiation Areas (LUHRAs). Both the Reactor Cavity area and the Spent Resin Storage Tank Room are specifically mentioned as areas which shall normally be designated as LUHRA The inspector reviewed procedure EHS-3.110 and compared it with the procedure EHS-SQ-3.109, " Control of High Radiation and Locked High Radiation Areas." Procedure EHS-3.110 requires additional controls over LUHRA key administration and approval requirements for entr This item can be considered close .14 (Closed) Inspector Follow Item (247/85-05-03): Failure to have a procedure to implement the dose calculation methods of the ODC The licensee developed procedure IPC-S-050, " Radioactive Gaseous and Liquid Release Calculations" in response to the above violatio Procedure IPC-S-050 was reviewed during NRC Inspection 85-19, at which time it was noted that several typographic errors and erroneous Table references existed in the body of the procedure which might lead to errors in dose calculatio The inspector reviewed a draft form of Revision 6 of Procedure IPC-S-050 during the current inspection and noted that the typographic errors and erroneous references identified earlier had been correcte Revision 6 was approved by the licensee on December 22, 1986. This item can be considered closed.

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3.15 (Closed) Noncompliance Item (247/86-08-01): Failure to post High Radiation Area originating from the Vapor Containment (VC) Sump.

l The inspector determined through discussion with Radiation Protection Management that HP technicians were familiarized with events concerning the failure to post the sump. The licensee has also revised procedure EHS-SQ-3.901, " Vapor Containment Entry and Egress," to insure the 46' containment sump receives appropriate review as a potential site for installing temporary shielding when the VC is opened for outage activitie The inspector also noted during tours of licensee facilities that all High Radiation Areas were appropriately poste This item is considered close . . - . _ _

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3.16 (Closed) Noncompliance Item (247/86-08-02): Multiple examples of failure to follow procedures. The inspector determined through discussion with Radiation Protection Management that EH&S personnel were briefed concerning the multiple radiological procedural viola-tions described in NRC Inspection Report No. 247/86-08. The in-spector also toured licensee radiological work areas and noted that all personnel observed were complying with station RWP and protective clothing procedures. This item is considered close .17 (0 pen) Inspector Follow Item (247/86-17-08): Licensee to develop procedural oversight over compressor operation for vendor supplied

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breathing air. Inspector review of licensee corrective actions for this item found corrective actions to be superficial in nature. The

' licensee's procedural revision did not expand upon the original requirement for management oversight of vendor supplied air as identified in NRC Inspection Number 86-17. This item will remain open pending substantial licensee review and improvement of this action item.

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4.0 Licensee Corrective Actions During the inspection it was noted that the licensee has developed a

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" packaging" concept to effectively track and resolve open items in a timely fashio Under this concept the open item, it's status, and supporting documentation are compiled into a folder or binder, thus making tracking and closecut of the item easy and convenient.

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This system was recently employed to track the findings associated with NRC Inspection Number 86-17. Radiation Protection management has taken the initiative to expand the ten (10) NRC Followup Items from this report

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these items to ensure timely resolution of the ten NRC concerns. This new method of handling open items should prevent the lack of timely response such as that associated with item 80-02-08, which was closed in

this report (see Section 3.0).

l One area needing improvement, concerning documentation and correlation between open items and their corrective action, was identified by the inspector. Specifically, licensee records and documentation to support close out of an open item were found to be weak. In some cases there was not a direct, or even indirect, correlation between the open item and the data presented as evidence of satisfactory resolution of the findin The inspector discussed this issue with station management, who indicated they were aware of the problem and were taking steps to strengthen doc-umentation in this are Overall, licensee performance in their corrective actions to NRC and licensee identified findings appears inconsistent. Two examples (see paragraphs 3.10 and 3.17), indicate superficial, " quick-fix" response to I --

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identified problems. On the other hand, licensee corrective actions in the area of SCBA maintenance and radiological vacuum cleaner control (see paragraphs 3.6 and 3.9) indicate well thought-out and comprehensive action. In the future, licensee attention should be directed to insure the effective resolution of identified concern .0 Program Changes The licensee has made the following changes to the radiation protection program:

A new solid-state detector system has been purchased and placed in service to upgrade isotopic counting capabilitie A low background alpha and beta automatic sample counter has been purchased. The licensee is presently developing operating and calibration procedures for the uni A second Thermoluminescent Dosimetry (TLD) Reader has been purchased to backup the primary reader and to expedite normal TLD processing operation All portable survey instruments are now under the control of, and calibrated by, the Environmental Health & Safety (EH&S) Departmen Instrument & Control (I&C) technicians will continue to work for the EH&S Department until six (6) EH&S technicians complete approximately two-hundred (200) hours of classroom training (on going) and three to six months of on-the-job practical training. Current plans call for the I&C technicians to return to the I&C Group by, or before, the end of 198 *

The Radiological Assessor has returned to duty following an extended absence. The Acting Radiological Assessor returned to the Radio-logical Engineering Grou .0 ALARA The licensee's ALARA program was evaluated against criteria contained in

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10 CFR 20.1 " Purpose";

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Regulatory Guide 8.8, "Information Relevant tc Ensuring The Occupa-i tional Radiation Exposures at Nuclear Power Stations Will Be As Low l As Is Reasonably Achievable" (ALARA);

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Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupa-tional Radiation Exposures As Low As Is Reasonably Achievable".

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Licensee performance relative to these criteria was evaluated by the following:

Discussions with cognizant personnel Tours of the radiologically controlled area

Review of Radiation Work Permits and ALARA Reviews Review of radiation survey documents Review of proposed ALARA Modifications / Projects list Review of "Non-Outage Monthly Exposure" graphs

Review of " Indian Point 2 Personnel Exposure" graphs for 1974 through 198 The licensee continues to make good progress in ALARA. The 1986 exposure goal of 1250 man-rem is expected to be met, with present station exposure at approximately 1246 man-rem. This amount of man-rem expenditure for a refueling year, while not settina a standard of excellence for the nuclear industry in the ALARA area, is a considerable achievement at Indian Point Unit 2, considering the more than 2500 man-rem expended in years 1981 and 1984. In addition, the licensee has managed to reduce reduce non-outage monthly exposure by more than fifty percent (50%) since 198 In an effort to reduce exposure rates at the station, the licensee has planned and budgeted for steam generator channel head chemical decon-tamination during the next refueling outage. Chemical decontamination of the Regenerative Heat Exchanger is also being considered. Furthermore, the licensee is funding a study evaluating the feasibility and costs associated wit! a complete decontamination cf the primary system, including the fuel elements. These evolutions, when completed, should be instrumental in reducing the source term at the facility, with far reaching short and long-term benefits to the ALARA progra Preliminary 1987 exposure goals have been estimated at 900 man-rem (800 outage and 100 non-outage). This station goal was developed following input from all station section heads, who set individual departmental goals. By actively involving each of the station work groups there ap-pears to be improved commitment to the overall station ALARA goal. The 1987 goal will become " official" when accepted by the Vice President-Nuclea Innovative techniques, using fiber optic scopes and steam generator (S/G)

mock-ups, have been used by station Radiological Engineers to demonstrate that additional sludge lancing of the S/G secondary side was unneces-sary. This resulted in reduced personnel exposure and more rapid

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completion of outage activities. The licensee is also evaluating the use of robotics for scabbling of large areas of contaminated concrete flooring. A study to evaluate the durability of a variety of floor coatings was also in progress during the week of this inspectio Within the scope of this review, no violations were identifie .0 External Exposure Control The licensee's program for external radiation exposure control was reviewed against criteria contained in the following:

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10 CFR 20.201, " Surveys";

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10 CFR 20.203, " Caution signs, labels, signals and controls";

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10 CFR 20.401, " Records of surveys, radiation monitoring, and disposal";

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Technical Specification 6.12, "High Radiation Area";

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Licensee procedures:

EHS-3.011, " Radiation And Contamination Survey Techniques";

EHS-3.001, " Radiological Posting Requirements";

EHS-SQ-3.109, " Control of High Radiation And Locked High Radiation Areas"; and EHS-3.110, " Control of Locked Ultra High Radiation Areas".

The licensee has established an effective program for the control of external exposure. During tours of the Radiologically Controlled Area (RCA), all Locked High Radiation Areas (LHRA) checked were found to be properly secured. Appropriate barrier ropes and postings had been established to warn personnel of existing radiological hazards. Review of twenty (20) Radiation Work Permits (RWP), verified that radiological controls consistent with work area radiological conditions had been establishe During a tour of the RCA, the inspector noted that several containers of radioactive trash were not labelled " Caution, Radioactive Materials."

However, inspector surveys of these containers verified that Appendix C quantities of radioactive materials had not been exceede Li esee management was notified, and took immediate action to label the containers as a precautionary measure. The inspector questioned technicians concerning when and how to label and control containers of radioactive material. A wide variety of responses was received, with very little consistenc Subsequent review of EHS-3,001, " Radiological

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Posting Requirements" found the section relative to radioative material labelling to be inconsistent with 10 CFR 20.201 (f)(1) requirements. In fact, each of the six (6) revisions of the procedure were found to mis-quote regulatory requirements. This indicates a weakness in the licensee's technical review capabilities. Consequently, this procedure did not provide effective guidance to HP technicians in the plant. In addition, the inspector discussed technician training with Radiation Protection Instructors, who indicated that this topic is not covered in any lesson pla The inspector discussed these program weaknesses with licensee management, who took immediate action to correct the procedural erro In addition, they committed to improving lesson plans in this area or to develop a station policy or guidance to ensure effective control of radioactive material. This area will be evaluated in a future inspectio Inspector review of surveys found most surveys to be accurately and legibly completed. However, some weaknesses were noted in survey docu-mentation. Specifically, survey documentation technique between tech-nicians was inconsistent and some High Radiation Area (HRA) boundaries were not being depicted on survey maps. Thir raised questions concerning whether or nor HRA controls had been established. However, discussions with licensee personnel confirmed that appropriate controls had been established. To investigate this problem further, the inspector reviewed

. procedure EHS-3.011, " Radiation and Contamination Survey Techniques," and training Lesson Plans for this subject. Both of these documents were found to be weak, with very little guidance to the technician concerning standard survey conventio In addition, neither document provided an

" example" of what management considered 's a minimally acceptable survey, or of expected documentation techniques. These weaknesses contributed to the inconsistency between technicians when documenting survey The inspector discussed these weaknesses with licensee management, who committed to improving standardization of sur"ey documentation. This area will be re-evaluated during a future inspectio Within the scope of this inspection, no violations were observe .0 Internal Exposure Controls The licensee's program for the control of internal exposure was reviewed against criteria contained in the following:

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10 CFR 20.103, " Exposure of individuals to concentrations of radio-active materials in air in restricted areas";

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NIOSH certified Equipment List; and

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NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials."

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13 l Evaluation of licensee performance in this area was based on the following:

Discussions with cognizant personnel; Tour of the Self-Contained-Breathing-Apparatus (SCBA) maintenance facility; Inspection of personnel training certificates and equipment record files;

Inspection of SCBA devices; and Review of spare parts inventory and repair manual availabilit During NRC Inspection Number 86-17, significant problems with the licensee's maintenance and control of Self-Contained-Breathing-Apparatus (SCBA) were detected. At that time, SCBAs were being maintained by the Maintenance Department. Following Inspection 86-17, responsibility for SCBA maintenance and control has been transferred to the Environmental Health and Safety Department (EH&S). l Inspector review of SCBA maintenance and control during this inspection found the area to be substantially improved. It was readily apparent that the licensee has taken the initiative to develop a first-rate program for these respiratory protection device Vendor personnel have been on-site to conduct classes to train and certify technicians for all levels of SCBA service ano repair. Each SCBA has been identified with a unique number, and a tracking system established to ensure timely completion of all required maintenance item Inspector tour of the SCBA maintenance facility found it to be adequately staffed with training and certified technicians. A ready supply of repair parts and service manuals was observed to be on-han It was noted, however, that the space available in the repair facility was very limite The inspector also toured the Whole Body Counting (WBC) facility and noted that the licensee has taken action to correct previously identified detector resolution problems with the Intrinsic-Germanium WBC chair. The crystals with poor resolution have been returned to the vendor for troubleshooting and repai Routine WBC continues using the Sodium-Iodide WBC chai Within the scope of this inspection, no violations were observe .0 Exit Interview The inspector met with licensee management denoted in Section 1.0 on December 19, 1986, at the conclusion of the inspection. The scope and findings of the inspection were discussed at that time.